Privacy Notice

Last Updated: 1 July 2026

This Privacy Notice includes important information about your personal data and we encourage you to read it carefully.

This Privacy Notice ("Notice") explains how RADOM PAY LLC, referred to as "Radom", "we", "our", or "us", collects, uses, retains, and protects 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, and related tools. RADOM PAY LLC is organized under the laws of the Cook Islands and operates as the sole data controller for the Services. Radom Pay LLC is registered as a reporting institution with the Cook Islands Financial Intelligence Unit (FIU).

2. Data We Collect

2.1 End Customers (during checkout)

• Full name
• Billing Address
• Jurisdiction/country of residence
• Email address
• Wallet address
• Purchase details (amount, currency, timestamp)
• In certain flows: identity documents, date of birth, 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

2.3 Business Representatives (during checkout)

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

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

2.5 Site Visitors

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

3. How We Use Your Data

PurposeLawful BasisTo process transactions and provide servicesContractual necessityTo meet international regulatory requirements (e.g., AML/KYC)Legal obligationTo perform fraud prevention, monitoring, compliance checksLegitimate interestTo send marketing materials (only with explicit consent)ConsentTo improve site experience via analyticsLegitimate interest (essential) / Consent (non-essential)

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, ClearBank, Banking Circle
• Blockchain Analytics: Elliptic, Chainalysis, Crystal Intelligence

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

• Trusted subprocessors as listed above
• Law enforcement or regulators, if legally required. Specifically, personal data may be disclosed to the Cook Islands Financial Intelligence Unit (FIU) as required by Cook Islands Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) laws.
• Business Users when you engage in a transaction with them

Note: A complete list of subprocessors is available on request.

5. Data Processing Jurisdiction

Radom operates exclusively from the Cook Islands. By utilizing our Services, you acknowledge and agree that your personal data will be transferred to, stored, and processed within the Cook Islands, subject exclusively to the laws and jurisdiction of the Cook Islands.

6. Data Retention

• Personal and transactional data: retained for at least 5 years, or longer if required by applicable global financial and anti-money laundering regulations (e.g., FATF compliance).
• Cookie and analytics data: retained for 12 to 24 months, depending on browser settings and consent preferences.

7. Your Rights

Under our standard privacy practices, you have the right to:

• Access a copy of your data
• Rectify inaccurate or incomplete data
• Request deletion (where applicable and not superseded by statutory financial retention limits)
• Object or restrict processing
• Data portability (to another provider)
• Withdraw consent at any time

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

8. Security Measures

We implement industry-standard technical and organizational measures, including encryption and role-based access controls. While we apply both preventative and detective controls, please note that electronic transmission of data can never be guaranteed to be 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected individuals and the relevant regulatory authorities as soon as reasonably practicable.

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 LLCGlobal House, Avarua, Rarotonga, Cook Islands
Email: contact@radom.com

© 2026 RADOM PAY LLC. All rights reserved. RADOM PAY LLC is registered in the Cook Islands (Company No. LLC16897/2026) with its registered office at Global House, Avarua, Rarotonga, Cook Islands. RADOM PAY LLC owns all intellectual property relating to the Radom platform, provides software development services, and acts as the sole operator of the platform services.

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