Scope and consent

This Privacy Notice (“Notice”) describes the ways FASTPAY (Leo Global UAB), (“Fastpay”, “we”, “us”, “our”) collects, stores, uses and protects information. Fastpay services include merchant processing services, websites, mobile applications, products, and any other features, technologies or functionalities, including customer support (“Services”) offered by us. This Notice applies to www.fastpay.world and all other Fastpay sites on which it appears (the “Sites”).

Our privacy practices may vary among the countries or territories in which we operate to reflect local practices and legal requirements.

We may process information from the following types of users:

1. Visitors of our Sites;

2. Merchants who sign up for our Services (“Merchants” means any business that uses our Services to process payments, including non-profits that use our Services to accept donations and “Aggregators” that use our Services as a payment services platform for their own Merchants);

3. Shoppers of Merchants (“Shoppers” means individuals who indirectly interface with Fastpay when paying a Merchant’s invoice that is forwarded by Fastpay to a Merchant during checkout, when requesting a refund from a Merchant, when creating a Fastpay account, or when making a donation to a non-profit); Fastpay card holders who have signed up for a Fastpay debit card;

4. Fastpay wallet holders who have downloaded and installed the Fastpay app on their mobile device/website; and

5. Payees (e.g., employees, contractors, vendors or exchange customers) who request a payment (“Payout”) via cryptocurrency from a Merchant and create a Fastpay account.

What kind of information do we collect?

We collect different kinds of information when users interact with us. The information we collect depends on the type of user. We collect information you choose to provide to us when interacting with our Services. We may also collect information automatically from your devices. The following sections provide you with some more information.

1. Visitors of Our Sites

2. Merchants (including businesses such as nonprofits and Aggregators)

3. Shoppers of Merchants

4. Cardholders

5. Fastpay Wallet Holders

6. Payees of Merchant

7. Additional Collection

How we use cookies

We may collect information about your activities on our sites via first and third-party cookies, clear GIFs or web beacons, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as cookies.

We may allow third parties to use cookies on our sites. The information collected by cookies may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by cookies may be used on this site or on other websites or services, including those that may not be operated by us. Other parties may collect personally identifiable information about an individual consumer’s online activities over time and across different websites when a consumer uses our websites or online services. For more information about our use of cookies, please see our Cookie Policy.

Why we collect personal information

We use the information we collect to operate our business, provide our Services, for other purposes as permitted or required by law, and to provide you with a smooth, efficient, and customized experience. Specifically, we may use your information to:

• Provide our Services (including customer support);

• Process transactions and send notices about your transactions;

• Resolve disputes, collect fees, and troubleshoot problems;

• Communicate with you about our Services and business and to inform you of matters that are important for your account and/or use of the Sites. We also use your personal data to respond to any questions, comments or requests you filed with us and the handling of any complaints;

• Comply with applicable laws and regulations;

• Establish, exercise and defend legal claims;

• Monitor and report compliance issues;

• Customize, measure, and improve our business, the Services, and the content and layout of our website and applications (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services, websites and apps; ensuring the security of our networks and information systems; performing accounting, auditing, invoicing, reconciliation and collection activities; and improving and maintaining the quality of our customer services);

• Preform data analysis;

• Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences, and measure the effectiveness of it. To approach you via email for marketing purposes, we request your consent, unless it is not required by law. You always have the option to unsubscribe from our mailings, e.g., via the unsubscribe link in our newsletter;

• Perform risk management, including comparing information for accuracy and verify it with third parties and protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities; and

• Enforce our contractual terms.

How we protect and store personal information

We take the security of our information seriously. We use administrative, technical, and physical security designed to safeguard personal information in our possession, and we maintain internal policies and procedures to address our data security. We have been audited and received a SOC 2 report addressing the security, confidentiality, and availability of our Services. However, we cannot guarantee the security of the information that we collect and store. We will notify relevant authorities and users in the event of a data breach, if required under applicable law.

We retain data as required or permitted by law. For example, as a regulated financial institution, we may retain identification for 5 years or more after an account has been closed or become dormant.

How we share data with third parties

We may disclose the information we gather with our affiliates and third parties. For example, we may share information with:

• Other Fastpay entities, including to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;

• Service providers who help with our business operations and to deliver our Services, such as cloud service providers providing cloud infrastructure; providers of ID verification solutions and other due diligence solutions; providers of customer service solutions; providers of website analytics; and providers of marketing automation platforms;

• Law enforcement, government officials, regulatory agencies, our banks, and other third parties pursuant to a subpoena, court order or other legal process or requirement if applicable to Fastpay; or when we believe, in our sole discretion, that the disclosure of information is necessary to report suspected illegal or fraudulent activity or to investigate violations of our Terms of Use; and

• We may also share certain Shopper information with our Merchants, for example, in cases of suspected fraud or in connection with an ongoing investigation.

Please note that these third parties may be in other countries where the laws on processing information may be less stringent than in your country.

Your choices

You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. You may control how your browser accepts cookies. For more information, please consult your browser’s help documentation.

As of the last updated date of this Notice, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.