Legal Terms

Effective date: [EFFECTIVE DATE]

This Privacy Policy describes how [LEGAL ENTITY NAME], operating the CityPay platform (“CityPay”, “we”, “us”, or “our”), collects, uses, stores, shares, and protects personal information when you access our website, mobile applications, digital-asset services, customer-support channels, or related products.

By using CityPay, you acknowledge that your personal information may be processed as described in this Policy. If you do not agree with these practices, you should discontinue use of the relevant services.

This Policy applies to individuals who:

• Visit the CityPay website;
• Create or maintain a CityPay account;
• Use wallet, exchange, transfer, payment, or related functionality;
• Submit a partnership or support request;
• Communicate with us through email, telephone, chat, or social media;
• Represent a merchant, partner, supplier, or corporate customer.

This Policy does not govern third-party websites or services that may be linked from CityPay. Those services operate under their own privacy policies.

Depending on the services you use, we may collect the following categories of information:

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• Full name;
• Date and place of birth;
• Citizenship and country of residence;
• Passport, national identity card, or other identification document;
• Photograph or facial-verification information;
• Taxpayer or personal identification number, where required.

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• Email address;
• Telephone number;
• Residential or business address;
• Username, account identifier, and authentication settings;
• Customer-support correspondence.

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• Wallet addresses;
• Transaction identifiers and histories;
• Payment method information;
• Currency and digital-asset balances;
• Information concerning the source or destination of funds;
• Merchant, beneficiary, or counterparty information.

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• IP address;
• Browser and device type;
• Operating system;
• Language and time-zone settings;
• Session identifiers;
• Access dates, times, and activity logs;
• Diagnostic, security, and performance information.

We may process personal information to:

1. Create, verify, and administer user accounts;
2. Provide wallet, transfer, payment, exchange, and support services;
3. Verify identity and conduct customer due-diligence checks;
4. Detect, investigate, and prevent fraud, abuse, unauthorized access, and suspicious activity;
5. Comply with applicable legal, regulatory, accounting, and reporting obligations;
6. Process customer and partner requests;
7. Protect the security and integrity of CityPay systems;
8. Improve functionality, accessibility, performance, and user experience;
9. Communicate important service, security, and policy updates;
10. Send marketing communications where permitted and where the user has not opted out.

We will not use personal information for materially incompatible purposes without providing appropriate notice or obtaining consent where required.

We may share information with:

• Identity-verification and compliance providers;
• Banks, payment providers, merchants, and transaction counterparties;
• Cloud hosting, analytics, cybersecurity, and communications providers;
• Professional advisers, auditors, insurers, and legal representatives;
• Government agencies, courts, regulators, or law-enforcement bodies when legally required;
• A successor entity in connection with a merger, restructuring, acquisition, or transfer of business assets.

Service providers may process information only for the agreed purpose and subject to appropriate confidentiality and security requirements.

We do not sell personal information in exchange for monetary payment.

We retain personal information only for as long as reasonably necessary to provide services, resolve disputes, maintain security, enforce agreements, and satisfy applicable legal or regulatory requirements.

Retention periods may vary according to:

• The type and sensitivity of the information;
• The duration of the customer relationship;
• Transaction-record requirements;
• Legal claims or investigations;
• Fraud-prevention and security needs.

We use administrative, organizational, and technical safeguards designed to protect information against unauthorized access, alteration, loss, disclosure, or destruction. No internet-based system can be guaranteed to be completely secure.

Subject to applicable law, you may be entitled to:

• Request access to personal information held about you;
• Request correction of inaccurate or incomplete information;
• Request deletion where continued retention is not legally required;
• Withdraw consent where processing is based on consent;
• Object to or restrict certain processing;
• Opt out of non-essential marketing communications;
• Request information about how your data is used or shared;
• Submit a complaint to an appropriate authority.

Some requests may be restricted where retaining or processing information is necessary for security, contractual, legal, or regulatory purposes.

CityPay and its service providers may process information in countries other than your country of residence. Where required, we use appropriate contractual, organizational, or legal safeguards for cross-border processing.

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CityPay services are not intended for individuals below the minimum legal age required to use the relevant financial or digital-asset service. We do not knowingly provide accounts to children.

We may update this Policy to reflect changes in our services, technology, or legal obligations. The latest version will be published with an updated effective date.

For privacy questions or requests, contact:

[LEGAL ENTITY NAME]
Address: [REGISTERED ADDRESS] Email: [PRIVACY EMAIL] Telephone: [CONTACT NUMBER]