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Privacy Policy

Effective date: 06 October 2025

This Privacy Policy explains what personal data Aigen LLC (hereinafter "ItisPay", "we") collects, uses and discloses when providing digital financial services through our website itispay.com, API, SDK and related applications (the "Applications"). We are committed to respecting and protecting the privacy of visitors and customers ("you").

Our services include payment infrastructure as well as access to virtual wallets and a virtual IBAN provided by Striga Technology OÜ. In this partnership we act as a data processor for Striga for the portion necessary to verify clients and comply with regulatory requirements, and as an independent data controller for other information we collect ourselves.

I. What data we collect

1. Data you provide to us

  • Basic data: first name, last name, date of birth, citizenship, country of residence, phone number, email address.
  • Identification data: identity document number (passport, ID card), tax number, residential address.
  • Financial data: account numbers, payment instrument details, source of funds.
  • Account data: username, security settings, preferences.
  • Transaction data: amount, currency (fiat or crypto), time and date of the operation, wallet addresses.
  • Preferences: language, notification format and other settings.
  • Other information: content of support requests, files and documents uploaded during verification or interaction.

2. Data collected automatically

  • Technical data: device type, operating system, IP address, browser data, geolocation information (if permitted).
  • Usage data: log files, API/SDK usage metrics, interaction with our website and Applications.
  • Cookies and similar technologies: see our Cookie Policy.

3. Data obtained from third parties

  • Compliance checks: information from identity verification services, AML/KYC/KYB providers (including Striga), sanctions and public registers.
  • Public blockchain data: wallet addresses, transaction hashes, amounts.

II. How we use your data

We use personal data to:

  • Provide services: create and manage accounts, issue invoices, receive and send payments, provide access to wallets and vIBANs, and other platform features.
  • Identity verification: transmit data to Striga or other KYC providers to comply with anti‑money laundering and counter‑terrorism financing requirements.
  • Process transactions: create, process and confirm cryptocurrency and fiat payments.
  • Customer support: respond to inquiries, resolve issues, send notifications about updates.
  • Legal compliance: comply with legal and regulatory requirements.
  • Security: detect and prevent fraud, hacking and other unlawful activities.
  • Analytics and service improvement: analyse platform usage to improve functionality.

III. How we share your data

We may transfer your data to the following categories of recipients:

  • Striga Technology OÜ: to provide virtual wallet services, digital asset exchange and issuance of vIBANs in accordance with its regulatory licence and terms. Striga acts as an independent data controller and applies its own privacy policy.
  • ItisPay group partners: to fulfil contractual obligations, provide user support and comply with legal requirements.
  • Service providers: hosting providers, payment processors, identity verification providers, electronic signature providers and analytics providers. We enter into agreements with them to ensure the protection of your data.
  • Regulatory and law enforcement authorities: when required to comply with the law, court orders or government requests.
  • Business partners: when you have authorised integration with their services (e.g. payment gateways).
  • Corporate transactions: in the case of a merger, acquisition, reorganisation or asset sale, your data may be transferred to the successor.

We do not sell your personal data.

IV. Data retention

We retain personal data as long as necessary to:

  • provide services and fulfil contractual obligations;
  • comply with legal requirements (e.g. retention periods for KYC/AML data);
  • resolve disputes and protect our rights.

After the purpose has been achieved, data is deleted or anonymised.

V. Children’s data

Our services are not intended for persons under 18 years of age. We do not knowingly collect data about minors. If we learn that such information has been collected, we will promptly delete it.

VI. International transfers

Your data may be stored and processed in countries where our servers or service providers are located, including the European Economic Area and other jurisdictions. We use legal mechanisms (e.g. standard contractual clauses) to ensure adequate data protection during cross‑border transfers.

VII. Your rights

Depending on your jurisdiction, you may have the right to:

  • receive a copy of your personal data;
  • correct inaccuracies;
  • request deletion of your data;
  • restrict or object to certain processing operations;
  • withdraw consent to processing where it is based on consent;
  • lodge complaints with a data protection supervisory authority.

To exercise your rights, contact us at [email protected]. We will respond to requests within a reasonable time as required by law.

VIII. Security measures

We have implemented security measures, including:

  • encryption of data in transit and at rest;
  • tiered access controls and user authentication;
  • regular security audits;
  • secure management of cryptocurrency wallet keys.

IX. Changes to the Policy

We may periodically update this Privacy Policy. Updates will be published on itispay.com with a new effective date. Material changes will be communicated to you in advance.

X. Contact details

Data controller:

Aigen LLC

ul. Domaniewska 17/19/133

02‑672 Warsaw, Poland

For privacy‑related inquiries: [email protected]

General inquiries: [email protected]

Website: https://itispay.com