POLICY ON THE PROCESSING OF
PERSONAL DATA AND USE OF COOKIES
Last Updated: 01/02/2026
This Policy on the processing
of personal data and the use of cookies (hereinafter, the "Policy") located at
the www.payfio.com (hereinafter, Website) establishes the procedure for
collecting, storing, processing, and transferring the personal data of Website
users Payfio Gateway Limited, addressed at 80 Birmingham Street, Unit C6,
Etobicoke, Ontario, M8V3W6, Canada (hereinafter, the "Operator" or "we"). It
also discloses information about the measures taken by the Operator to ensure
the security of personal data, aimed at protecting the rights and freedoms of
users, including the right to privacy, personal, family, and business secrets.
1. Accepting Policy
1.1. If you agree with the
provisions of this Policy, you can accept them by placing a checkmark or its
equivalent next to the field "I agree to the terms of the Policy on the
processing of personal data and the use of cookies" when visiting the
Website.
1.2. If at any time you disagree with any provision of this
Policy, you must immediately cease using the Website.
2. Collected personal data
2.1. To provide access to the
Website, we request information about you. This data can be divided into the
following categories:
Communication
Data: Email address, Telegram account, other contact information you
use to contact us.
AutomaticallyCollected Data: IP
address, browser type and version, browser plug-in types and versions, operating
system and Website, usage data (URLs of transitions to, through, and from the
site, including date and time; products viewed or searched for; page response
time; download errors; time spent on specific pages; movement data; methods used
to navigate from page to page; other data collected using cookies and similar
technologies).
2.2. We are constantly
developing the Website, adding new features and capabilities. In connection with
this, the table of collected Personal data indicated above may be changed. To
access new features, we may ask you to provide additional information about
yourself. In this case, we will inform you about such changes and request your
consent to the collection and processing of additional personal data.
3. Purposes of collection and
processing of personal data
3.1. We collect your personal
data for the following purposes:
Communication
Data: Purpose: Providing feedback; communication on
administrative issues.
Registration Data: Purpose:
Providing access to a limited amount of functionality.
Automatically
Collected Data: Purpose: Ensuring the normal
functioning of Products; monitoring the use of Services; improving the
efficiency of the Website; ensuring ease of use and simplicity of the Website;
identifying errors and weaknesses and developing the Website.
3.2. We undertake to use your
Personal data EXCLUSIVELY for the purposes indicated above. Exceptions are cases
where the collection and use of data are required for other purposes compatible
with the original purpose, or when it is necessary in accordance with applicable
laws, court decisions, or orders of executive authorities.
4. Procedure for collecting
personal data
Communication
Data: Procedure for collection: We gain access to
this data when you contact us for any reason before account registration, to get
feedback, or for any other purpose (e.g., by email/Telegram).
Registration
Data: Procedure for collection: You provide
this data when you fill out and submit the relevant forms for account
registration.
Automatically Collected Data: Procedure
for collection: We collect this data in the process of your
interaction with the Website using cookies, server logs, and other similar
technologies.
5. Data retention Period
5.1. We store your personal
data only for the time necessary to achieve the purposes of its collection and
processing, or within the timeframes established by applicable legislation.
Depending on the category of personal data, the following storage periods apply:
Communication
Data: Storage Period: We gain access to this data
when you contact us for any reason before account registration, to get feedback,
or for any other purpose (e.g., by email/Telegram).
Registration
Data: Storage Period: You provide this data
when you fill out and submit the relevant forms for account
registration.
Automatically Collected Data: Storage
Period: We collect this data in the process of your interaction
with the Website using cookies, server logs, and other similar technologies.
5.2. Please note that we may
store your Personal data for a longer period if necessary to comply
with the requirements of applicable laws and regulations. Some Personal
data may be retained even after your account is closed for the purposes of
fraud prevention, the ability to prosecute individuals involved in fraudulent
activities, and compliance with our legal obligations.
6. Legal Basis for processing
personal data
6.1. Processing of personal
data is carried out in accordance with the Regulation of the European Parliament
and of the Council of the European Union on the protection of natural persons
with regard to the processing of personal data and on the free movement of such
data (the General Data Protection Regulation or GDPR) and our local regulations.
6.2.
Where the legislation of your country of residence establishes stricter
standards for the processing of Personal Data, we undertake to comply with such
standards when processing your data.
6.3. The legal grounds for
processing Personal data include:
(a) Consent: Processing of personal
data may be carried out with your prior explicit consent, given voluntarily,
knowingly, and unambiguously. You have the right to withdraw your consent at any
time by notifying us, which will lead to the termination of processing of your
personal data if it was based solely on this ground.
(b) Performance of a
contract: We process your personal data within the framework of fulfilling our
obligations under the contract to which you are a party, or to take the
necessary steps prior to entering into a contract. Processing may include the
identification of the user and the provision of access to services.
(c)
Legitimate interests: We may process your personal data to protect our
legitimate interests or the interests of third parties, provided that such
interests do not violate your rights, freedoms, and legitimate interests.
Legitimate interests may include ensuring the security of the Website,
preventing fraud, and improving the quality of services.
(d) Compliance
with the law: We are obliged to process Personal data in cases where this is
necessary to fulfill obligations established by the legislation and regulations
of Canada. This may include meeting the requirements of legislation in the field
of providing services related to virtual assets, taxation, accounting, financial
control, or consumer protection, as well as obligations to provide data to
government bodies in cases provided for by law.
7. Transfer of Your Personal
data to Third Parties
7.1. We transfer your
personal data to third parties only to the extent necessary to achieve the
processing purposes specified in this Policy and in accordance with the
applicable legislation of the Canada.
7.2. Transfer is carried out only
in the following cases:
(a) With your prior explicit consent; (b) Within
the framework of fulfilling the contract to which you are a party; (c) To
fulfill our legal obligations; (d) To protect our legitimate interests or the
interests of third parties.
7.3. Transfer of your personal data may be
carried out to the following categories of persons: (a) Business partners,
suppliers, and subcontractors: We may involve external service providers, such
as agents, contractors, payment providers, notification services, and other
companies that help us provide Services and ensure the operation of the Website.
(b) Legal and government authorities: Your Personal data may be transferred to
competent state bodies, including judicial and law enforcement agencies. (c)
Legal successors: In the event of reorganization, merger, sale, or other
transfer of our business, your Personal data may be transferred to a legal
successor, provided that confidentiality is maintained and the data is used in
accordance with this Policy.
7.4. We guarantee that we will not sell,
exchange, or transfer your Personal data to third parties without your explicit
consent.
8. Cross-Border transfer of
personal data
8.1. To ensure the ability to
provide services and operate the Website, we may use the services of foreign
data processing service providers where permitted by the law applicable to the
processing of your personal data. In addition, certain jurisdictions establish
requirements for storing personal data on servers located within the territory
of the state of the subject of personal data.
8.2. In the event of the
transfer of your personal data outside the Canada, we ensure compliance with all
requirements of applicable legislation, including: (a) Ensuring an adequate
level of data protection in the recipient country; (b) Concluding agreements
with data recipients containing provisions on data protection; (c) Obtaining
your consent if required by law.
8.3. To ensure the security of your
personal data during cross-border transfer, we take the following measures: (a)
Fixing the standards for handling personal data in the contract. We conclude
contracts with third parties to whom we transfer your personal data, which
stipulate the requirements for interacting with personal data of users , which
are designed to ensure a sufficient level of protection of personal data. (b)
Analysis of the level of data protection. We assess the level of data protection
in the countries where the data may be transferred and take additional
protective measures if necessary. (c) Use of encryption technologies. We use
security measures such as encryption to ensure the confidentiality and security
of your data during its transmission through international channels.
9. Measures to protect
personal data
9.1. To ensure the security
of your data, we use modern encryption technologies and other security methods.
The main technical measures include: (a) HTTPS and secure encoding: We
protect data using HTTPS and secure encoding, which helps prevent data leakage
during its transmission over the network. (b) Regular security checks: We
regularly conduct penetration testing and vulnerability assessments of our
security system to minimize security risks.
9.2. We also take the
following organizational measures to protect your personal data: (a) Access
restriction: Only a limited circle of authorized employees has access to your
Personal Data, and this access is strictly controlled. All employees are obliged
to maintain confidentiality and not to transfer information to third parties
without legal grounds. (b) Security policies and procedures: We have implemented
strict internal security policies and procedures to ensure the proper protection
of data and its processing in accordance with applicable laws and regulations.
10. Rights of users as
subjects of personal data
10.1. Your main rights as a
subject of personal data include: 1. Correction of the personal data. If you
consider your personal data as incomplete or inaccurate, you can request the
correction thereof; 2. Erasure of personal data. You have the right to ask
us to delete your personal data except in cases when it is restricted by
respective regulations; 3. Restriction of the processing of the personal
data. You have the right to suspend the processing of your personal data of any
of its part; 4. Objection of the processing of personal data. You have the
right to object to the processing of your personal data which may be used, for
example for direct marketing purposes; 5. Transfer of personal data. You
have the right to request to transfer your personal data to a new service
provider or to another party; 6. Other rights granted to you by
GDPR.
10.2. Please note that none of the above rights are absolute,
meaning they must generally be balanced against our own legal obligations and
legitimate interests. If a decision is made to reject your request, we will
inform you of this along with the reasons for our decision.
10.3. To
exercise any of the rights listed, please contact us using the contact details
specified in this Policy.
10.4. If you believe that your rights to the
protection of Personal data have been violated, you have the right to file a
complaint with the competent authority.
11. COOKIES
11.1. Cookies are small text
files that are stored on your device when you visit the Website. This text file
stores certain information, for example, language selection. When you revisit
the site, this cookie file is sent to the site, which recognizes your browser
and can display the corresponding language version of the text on the
site.
11.2. The Operator uses cookies and similar technologies to improve
the functionality of the Website, analyze user experience, monitor the use of
the Website's functionalities, and provide personalized content and advertising.
11.3.
Upon your first visit to the Website, we request your consent to place cookies
on your device.
11.4. You can instruct your browser to refuse certain
cookies, require your browser to obtain your consent before a new cookie is
placed in your browser, or completely block cookies by selecting the appropriate
settings in your browser's privacy settings. To prevent cookies from being
received on your mobile device's browser, you need to refer to its user manual.
For information on how to refuse cookies set by our providers, follow the links
indicated in the table above.
12. Changes to the Policy
12.1. The Operator hereby
reserves the right, at its own discretion and at any time, to make changes to
this Policy by publishing its amended version on the Website. The new version of
the Policy will include the date of the last update on its first page.
12.2.
The user undertakes, at their own risk, to constantly check for changes to the
Policy and perform the following actions: (i) remember/note the date of the last
update indicated in the Policy (e.g., save a copy of the Policy, etc.) upon
initial registration of their account and at any time after changes are made,
(ii) regularly visit the relevant page of the Website and study the document in
case the update date changes.
12.3. If you disagree with any changes to
the Policy, you must immediately cease using the Website and Services.
13. Our Contact Information
13.1. If anything remains
unclear in the text of this Policy, we will be happy to clarify its provisions.
You can also use the contact details indicated in this section for any reason
provided for in this Policy. 13.2. For questions related to this Policy,
please contact us by email at [email protected].