Privacy policy

Privacy Policy – Effective November 1, 2024

Thank you for using our virtual currency wallet service. Protecting your privacy is very important to us. Please read the following privacy policy carefully to understand how we collect, use and protect your personal information.
This policy explains what you can expect from HoyaPay and what personal information HoyaPay needs you to provide. Please read it carefully, as this policy is legally binding when you use HoyaPay services.
If you have any questions about how HoyaPay protects or uses your data, please contact: [email protected]

1. Information We Collect About You
Personal data or personal information refers to any information relating to an identified or identifiable individual. This does not include anonymized data, which cannot be linked back to an individual's identity. We may collect and process the following personal data about you:

1.1 Information You Provide to Us
When you register for our services, you may provide us with your personal information, such as your name and email address. This includes information you provide when you: Continue using our services; Participate in discussion boards or other social media functions on our website or app; Enter competitions, promotions, or surveys; Report problems with our services. Other information you may provide for purposes of security, identification, and verification includes your address, phone number, financial information (such as credit card, debit card, or bank account details), payment reason, location, social security/insurance number, ID number, personal description, photo, tax reference number, proof of address, proof of residency, passport, and/or identification card. Failure to provide this information may affect our ability to provide services to you.

1. Information We Collect About You
When you use our services, we may collect:
•Details of transactions, including the geolocation from which the transaction was initiated;

•Technical information such as your IP address, login details, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform, and any remote-access apps installed on your mobile device (if applicable);

•Usage data including full URLs (with date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (scrolling, clicks, mouse hovers), and the phone numbers used to contact our customer service.

1.3 Sensitive Information
As part of the identity verification process, we collect, use, and store biometric data:
We may extract facial scan information from photos and videos and compare it with your ID document photo and your selfie to verify your identity and perform anti-fraud checks. If required by privacy laws in your jurisdiction, we will request your explicit consent to collect, use, and store your biometric data. If you do not consent, we will provide alternative verification methods, which may take longer. Both methods require the same documents and photos. We will not disclose, distribute, sell, rent, trade, or otherwise process your biometric data for profit. Biometric data will be retained only for as long as necessary to complete the identity verification process and in any event no longer than 1 year after collection, unless a longer period is required by law or legal proceedings.

2. How We Protect Your Personal Information
2.1 We take your data security very seriously:
Transmitting information over the internet is not completely secure. While we do our best to protect your personal data, we cannot guarantee its security during transmission. Any transmission is at your own risk. Once we receive your information, we use strict procedures and security features to ensure its safety, including:
•Use of strong asymmetric encryption for communication between your device and our websites/apps;

•Regular updates and patching of our servers;

•A responsible disclosure and bug bounty program to identify security issues;

•A dedicated security team that monitors for anomalies and malicious activity;

•Static encryption of data at rest.

2.2 Access to your personal information is restricted:
Only employees with a business need to know and third-party service providers who process data on our behalf have access to your data. All employees and service providers are required to adhere to this policy and implement appropriate security measures.
2.3 We continuously educate and train our staff on the importance of confidentiality and privacy.
We maintain physical, technical, and organizational safeguards to comply with applicable laws and regulations, ensuring your personal information is protected from unauthorized access.

3. How We Use Your Information
3.1 We may use your personal data for the following purposes:
•To fulfill the virtual currency wallet services under our agreement with you;

•To provide information, products, and services you request;

•To process your data based on your consent (where required);

•To comply with legal obligations, such as responding to government requests or court orders;

•To prevent and investigate crimes, including fraud and financial crimes;

•For credit protection;

•To notify you of service updates or administrative changes;

•For internal operations including audits, data analysis, research, and troubleshooting;

•To assist third parties in recovering mistakenly or fraudulently sent funds.

4. Disclosure of Your Personal Data
4.1 We may share your personal data with the following third parties:
•Affiliates, business partners, suppliers, and subcontractors;

•Advertisers and advertising networks;

•Data analytics and search engine providers;

•Potential buyers or merging parties in the event of a business sale or merger; 

•Beneficiaries of your payments (with limited information disclosed);

•To comply with legal obligations, court orders, or to protect the rights of our company and stakeholders;

•To prevent or investigate fraudulent or illegal activity;

•In response to lawful subpoenas, legal orders, or law enforcement requests;

•With your consent, to share your details during service use.

5. Changes to the Privacy Policy
To keep up with changing laws, best practices, and changes in how we process personal information, we may revise this policy at any time by posting an updated version on this website. Please check back regularly to stay informed of any updates.

6. Contact
For any questions, comments, or requests regarding this policy, please contact us at: [email protected]