Introduction

Last updated: June 3rd, 2025

This Privacy Notice ("Notice") explains how Radom Pay Limited (UK) and Radom Pay Spółka z ograniczoną odpowiedzialnością (Poland), collectively referred to as "Radom", "we", "our", or "us", collect, use, retain, and protect your personal data. It applies to all users of our Services, including Merchants, End Customers, Representatives, and Visitors.

1. Who We Are

Radom is a financial technology group offering crypto payments, exchange infrastructure, fiatconnectivity, and related tools. Radom Pay SP z o.o. is a MiCA-compliant VASP licensed inPoland. Radom Pay Limited is based in the United Kingdom and is the parent company.

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2. Data We Collect

2.1 End Customers (during checkout)

Full name
Date of birth
Jurisdiction/country of residence
Email address
Wallet address
Purchase details (amount, currency, timestamp)
In certain flows: identity documents, proof of address, bank account details

2.2 End Customers (at sign-up)

Full name
Address
Date of birth
Email address
Identity document
Proof of address
Tax Identification Number

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2.3 Business Representatives (during checkout)

Full name of representative
Representative's date of birth
Registered name and country of the business

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2.4 Business Accounts (at sign-up)

Ownership structure documentation
Incorporation documents
Registration numbers
Tax Identification Number
Proof of address
Registration and operating addresses
Business description, purpose, and source of funds

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2.5 Site Visitors

IP address
Location
Data provided via forms or contact requests
Analytics data (e.g., cookies, browser metadata)

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3. How We Use Your Data

Purpose

To process transactions and provide services
To meet regulatory requirements (e.g., AML/KYC/MiCA)
To perform fraud prevention, monitoring, compliance checks
To send marketing materials
To improve site experience via analytics

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Lawful Basis

Contractual necessity
Legal obligation
Legitimate interest
Consent (where applicable)
Legitimate interest / Consent

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4. Subprocessors and Data Sharing

We use third-party providers for key operational and compliance functions. These include:

Cloud Hosting: AWS
KYC Providers: Persona, Sumsub
Banking Partners: Lead Bank, Revolut, Modulr, Banking Circle
Blockchain Analytics: Elliptic, Chainalysis, Crystal Blockchain

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We do not sell your data. We only share it with:

Trusted subprocessors as listed above
Law enforcement or regulators, if legally required
Business Users when you engage in a transaction with them

A complete list of subprocessors is available on request.

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5. International Data Transfers

We operate primarily in the UK and Poland. Where we transfer data outside the EEA/UK, werely on:

Standard Contractual Clauses (SCCs)
Adequacy decisions (where applicable)

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6. Data Retention

Personal and transactional data: retained for 5 years, or longer if required by law (e.g.,FATF/MiCA).
Cookie and analytics data: retained for 12 to 24 months, depending on browser and settings.

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7. Your Rights

You have the right to:

Access a copy of your data
Rectify inaccurate or incomplete data
Request deletion (where applicable)
Object or restrict processing
Data portability (to another provider)
Withdraw consent at any time

To exercise your rights, email: contact@radom.com

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8. Security Measures

We implement industry-standard technical and organizational measures, including encryption and role-based access control. However, electronic transmission is not completely secure and we cannot guarantee absolute security.

9. Updates

This Notice may be updated from time to time. Any updates will be posted to our website or communicated via email or within our services. Continued use of our services constitutes your acknowledgment of the updated notice.

10. Contact

Radom Pay Limited71–75 Shelton Street, Covent Garden London, WC2H 9JQ, United Kingdom

Email: contact@radom.com

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Privacy Policy