MikePayPrivacy PolicyDownload

PRIVACY POLICY

Last updated: May 25, 2026

This Privacy Policy (“Privacy Policy”) regulates the collection, use, and disclosure of Personal Data and other information when You use Application, Website or access Our Services (collectively, “Services”). It also governs the relationship between You and MIKEPAY INC. (a company registered in Republic of Panama, company code 155764322), together with any of its current or future affiliated entities that may be involved in the provision, operation, or support of the Services (collectively, “We”, “Us”, or the “Company”) as further set out in Our Terms of Use, in relation to the processing of Your Personal Data.

Our Services are provided through affiliated operating entities that are part of the group of companies, each acting within the scope of its respective role. The entities specified in this Privacy Policy and as noted in the Terms of Use are responsible for the collection, storage and processing of Your Personal Data to operate, maintain, and improve the Services, fulfill regulatory and security obligations, and ensure a seamless user experience. Personal Data is shared between such entities where necessary for the purposes described in this Privacy Policy, including identity verification, compliance, and service provision, in accordance with applicable laws.

You acknowledge and agree that Your Personal Data may be processed in jurisdictions outside of your country of residence, including jurisdictions that may have data protection laws differing from, or less stringent than, those applicable in the jurisdiction You reside in. By accessing or using the Application, You understand and accept that Your Personal Data may be transferred to, stored in, and processed in such jurisdictions, subject to the safeguards and safety measures implemented by Us.

We respect and value the privacy of everyone who visits our Website or uses our Services, and We process personal data in a transparent and secure manner and only collect and use information where necessary to provide the Services, maintain platform integrity, prevent fraud and misuse, and fulfill our operational and compliance responsibilities.

The Privacy Policy is a part of the Terms of Use. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use. If You do not agree with this Privacy Policy, You are not allowed to use Application.

Upon use of the Application, You certify that You consent to the Privacy Policy and also accept the Terms of Use. By providing us with Your personal information, You also consent for us to collect, hold, process, use and disclose your Personal Data in accordance with this Privacy Policy.

Definitions

  1. Personal Data means data about a living individual who can be identified from that data.
  2. Processing means any action or set of actions performed on Personal Data, whether automated or manual, including collection, recording, organization, storage, use, disclosure, modification, or deletion.;
  3. Third Party means any natural or legal person, authority, agency, or organization outside MIKEPAY INC. and its affiliated entities that may collect, store, or use Personal Data in connection with providing, operating, or supporting the Services.;

Legal grounds for the processing of Your Personal Data

  1. We collect and process Personal Data for various purposes, including providing and improving our Services, communicating with You, and ensuring security and compliance with applicable laws. The processing of Your data is based on one or more of the following legal grounds:
    1. Consent: when You have explicitly agreed to specific uses of Your Personal Data;
    2. Performance of a contract: when processing is necessary to provide the Services You request. This contract is formed between You and Us when You access the Application and accept the Terms of Use, along with any other notices or policies presented to You, as they may be updated from time to time;
    3. Legitimate interests: when processing is necessary to protect the integrity of the Services, prevent fraud, comply with global Anti-Money Laundering (AML) and other regulatory requirements, or maintain overall security.

Purposes of collecting Personal Data

We process Personal Data for the following purposes:

  1. Maintaining and providing You with the Application / Website / our Services;
  2. Providing, maintaining, delivering or improving our Website, the Application provided through our software;
  3. Making more of such Services available to You where possible and appropriate;
  4. Fulfilling our legal or regulatory requirements, compliance with our policies and obligations, including, but not limited to, disclosures and responses in response to any requests from law enforcement authorities and/or regulators in accordance with any applicable law, rule, regulation, judicial or governmental order.
  5. Protecting Our Services and users by pursuing Our legitimate interests, including for preventing fraud, detecting and mitigating unauthorized or harmful activity, reducing the risk of misuse of the Services for criminal purposes, and complying with global Anti-Money Laundering (AML) and related regulatory standards, as well as Our internal policies and procedures.
  6. Providing You with the information or Services that You have requested. Communicating with you about your account and our Services, including informing you of our products and Services;
  7. Carrying out any actions for which we have received Your consent, carrying out any other purpose or reason for which the information was collected.

Personal Data Type

Time and manner of receipt

Purpose and/or activity

Lawful basis for processing

Telephone number

During registration procedure/ log in procedure/ verification procedure

To register You as a new customer/

To protect Your Account with 2FA

Consent/
Performance of a contract

Email

During registration procedure/ log in procedure/ verification procedure

During using Application / Website / our Services

To register You as a new customer/

To protect Your Account with 2FA/

To provide targeted marketing communications

Consent/
Performance of a contract

Documents for natural persons, if You decide to provide them to us:

  1. government-issued ID (passport, or driver's license, or national identity card, or passport number, or driver's license details, tax ID number);
  2. proof of address;
  3. photos and videos.

During verification process

To fulfill KYC requirements, for the verification purposes of the individual

Consent/ Legitimate interests

Device and website usage data:

  1. the information that Your browser sends whenever You use Application/ Website;
  2. information about Your use of the Application/ Website including the type of browser and the version You are using;
  3. information about the device You are using, including hardware model, operating system and version, as well as unique device identifiers and others;
  4. IP address that You use to access the Website;
  5. the website address from which You linked to our Website, and the address of the website to which You navigate from our Website/ the source from which You go to download the Application, if possible;
  6. the public data You have imported into Application;
  7. public addresses of the systems of the blockchains;
  8. unique User hash;
  9. other non-personified traffic data.

During using Application / Website our / Services

To ensure the security of User's accounts and fulfill requirements of AML Policy. We also use these types of data to protect Users against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.

Consent/
Performance of a contract

Account activity:

1. trade activity;

2. transaction history;

3. orders terms;

4. orders created;

5. account status and notifications;

6. default currency, default language, time zone.

During using Application / Website / our Services

To ensure the security of User's accounts and fulfill requirements of AML Policy

Legitimate interests /
Performance of a contract

Cookies

During using Application / Website

To improve the quality of Services.
You can easily remove any cookies that have been created in the cookie folder on Your browser settings.

You can instruct Your browser to refuse all cookies or to indicate where a cookie is being sent.

Consent/ Performance of a contract

The information You voluntarily provide to us when You contact the Support.

During using Application and in the process of providing You with support

To contact You in response to Your inquiries, comments and suggestions and make our Services better.

We will retain this information for as long as necessary to provide You with technical support.

Consent/ Performance of a contract

Disclosure of Personal Data

  1. As a general principle, we collect and process Personal Data in order to facilitate or improve our Services or offers, as well as for other purposes outlined in this Privacy Policy.
  2. We protect Personal Data with appropriate physical, technological and organizational safeguards and security measures. The access to Personal Data is restricted and certain access rights are set.
  3. We do not sell Your Personal Data to any Third Parties. All personal information collected is used solely for the purposes outlined in this Privacy Policy and to fulfill Our obligations in accordance with applicable laws and regulatory standards.
  4. We may disclose Personal Data to Third Parties only to the extent expressly permitted by applicable law and this Privacy Policy.
  5. We engage qualified providers (Third Parties) on a contractual basis to ensure the security and lawfulness of the collection and processing of Personal Data
  6. The processing of Your Personal Data and its transfer to Third Parties is carried out in accordance with this Privacy Policy and applicable laws, and may be based on Your consent and other legal grounds as set out in this Privacy Policy.. That said, You consent to the transfer of such data to Third Parties as set forth in agreements with Third Party service providers. If You do not provide such consent, You are not allowed to use the Application.
  7. We may share Your Personal Data with the following Third Parties:
    1. external services or authorities when such disclosure is necessary to comply with applicable laws, regulations, or standards relevant to our Services;
    2. other service providers, including foreign entities, to enable the provision and improvement of Services to You..
  8. When we disclose Your Personal Data to a Third Party, we take all reasonable steps to ensure that those Third Parties are bound by confidentiality and privacy obligations with respect to the protection of Your Personal Data. Personal Data is shared only in accordance with applicable laws and standards, and strictly for the purposes described in this Privacy Policy. We employ necessary measures to ensure that Your data is handled securely and responsibly at all times.
  9. In the event of a merger, acquisition, corporate restructuring, or sale of assets, Your Personal Data may be transferred to an affiliated entity within our group of entities or a third party, where necessary to continue the provision of Services. Any such transfer will be subject to appropriate measures to ensure the continued protection of Your Personal Data.
  10. Your information, whether public or private, will not be exchanged, transferred, or given to any other company for any reason whatsoever, without Your consent, other than for the purpose of delivering the requested Services and improving our Services.

Storage / Retention / Deletion of Your Personal Data

  1. We retain the information of You only as long as it is necessary, in accordance with the purpose of collecting the data and as required by law. When Personal Data and other information is no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form.
  2. You may request deletion of Your Personal Data, subject to any legal, regulatory, or operational requirements that may require Us to retain certain information. . You can revoke consent and/or request deletion of Your Personal Data at any time by contacting us via the email address set out in Section 10 of this Privacy Policy
  3. We reserve the right to store/process Personal Data in accordance with the specific purpose of their storage/processing without limitation of storage and processing time in cases stipulated by law.
  4. Withdrawal of consent and/or deletion of Your Personal Data disables the use of the Application by You.
  5. We will erase Your Personal Data without undue delay where one of the following grounds applies:
    1. the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
    2. You withdraw consent on which the processing is based and where there is no other legal ground for the processing;
    3. You object to the processing and there are no overriding legitimate grounds for the processing;
    4. the Personal Data has been unlawfully processed;

We may retain Your Personal Data when necessary to comply with applicable laws, regulations, or operational standards relevant to our Services.

Security of Personal Data

  1. Data security is of great importance to us, and to protect Your Personal Data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Websites and mobile application. Steps we take to secure and protect Your data include:
    1. use of cryptographic encryption ;
    2. implementing access control;
    3. implementing measures to ensure the ongoing confidentiality, integrity, availability and resilience of our Services;
    4. implementing measures to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident.
  2. If You suspect that Your Personal Data or User Account has been compromised, especially account and/or password information, please lock Your User Account and immediately contact us via the email address set out in Section 10 of this Privacy Policy

Your Data rights

We are committed to the protection and responsible management of Your Personal Data. This section outlines the rights You have to access, correct, manage, or delete your data.

  1. You have the right to:
    1. get confirmation as to whether or not we process Your Personal Data and, where we do, to access the Personal Data. We will supply to You a copy of Your Personal Data;
    2. modify and correct Your Personal Data at any time in which You are therefore responsible for the accuracy of Your Personal Data;
    3. request to restrict the processing of Your Personal Data and/or to delete it in case obligation to retain the data is not set out by the applicable law;
    4. object to processing of Your Personal Data and/or to withdraw consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.;
    5. request erasure of Your Personal Data.
  2. You can exercise Your rights by contacting us via the email address set out in Section 10 of this Privacy Policy

Children's Privacy

  1. We do not address anyone under the age of 18 ("Children").
  2. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your Children have provided us with Personal Data, please contact us via the email address set out in Section 10 of this Privacy Policy.
  3. If We become aware that we have collected Personal Data from children without verification of parental consent, We take steps to remove that information.

Amendments

  1. We may change, update, delete or add to this Privacy Policy at any time.
  2. Any such changes will be effective upon the posting on a Website or mobile application. The effective date which is at the top of the Privacy Policy informs You about the latest version of the Privacy Policy.
  3. Your continued use of the Application and/or Website constitutes Your acceptance of such changes and Your consent to the processing of Personal Data according to the latest version. If You do not agree with any such changes, please do not accept and do not continue to use the Application and/or Website.

Questions and Complaints

  1. Any questions about this Policy, the collection, use, and disclosure of Personal Data or access to Your Personal Data which is required by law to be disclosed should be directed to [email protected].
  2. In the event that You wish to make a complaint about how we process your Personal Data, please contact us first at [email protected] and we will endeavor to deal with Your request as soon as possible.