Raipay Privacy Policy
RaiPay LLC recognizes that people who use RaiPay Wallet value their privacy. This privacy policy
(“Policy”) describes how RaiPay LLC (“Company”, “we”, “our”, or “us”) collects, uses, shares, and
stores personal information of users of our website, raipay.co, and our mobile
application, (collectively the “Site”). This Policy applies to the Site, applications, products and
services (collectively, “Services”) on or in which it is posted, linked, or referenced.
By using the Services, you accept the terms of this Policy and our terms of service which can be found
on our website, and consent to our collection, use, disclosure, and retention of your information as
described in this Policy. If you have not done so already, please also review our terms of use. The terms
of use contain provisions that limit our liability to you and require you to resolve any dispute with us
on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE
WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN DO NOT USE
ANY OF THE SERVICES.
Please note that this Policy does not apply to information collected through third-party websites or
services that you may access through the Services or that you submit to us through email, text message
or other electronic message or offline.
If you are visiting this site from the European Union (EU), see our Notice to EU Data Subjects below
for our legal bases for processing and transfer of your data.
WHAT WE COLLECT
We get information about you in a range of ways.
Information You Give Us. Information we collect from you includes:
Network information regarding transactions;
Contact information, such as your email address;
Feedback and correspondence, such as information you provide in your responses to surveys,
when you participate in market research activities, report a problem with Service, receive
customer support or otherwise correspond with us;
Usage information, such as information about how you use the Service and interact with us; and
Marketing information, such your preferences for receiving marketing communications and
details about how you engage with them.
Information We Get From Others. We may get information about you from other third party sources
and we may add this to information we get from your use of the Services. Such information may
include:
KYC information: Some app features may require users to have completed a Know Your
Customer (KYC) and/or Anti-money laundering (AML) verification process. RaiPay does not
provide KYC/AML services. Raipay, it may list entities that offer RaiPay compatible
KYC/AML services for the users convenience. Your agreement to work with a third-party to
undergo the KYC/AML process or to request completed KYC/AML data to be transferred over
the RaiPay Wallet is your own. If you agree to connect the third party’s KYC/AML data, RaiPay
may store KYC information on our servers and/or loally on the device.
Social Media Widgets: Our Site may include social media features, such as the Facebook
“like” button and widgets, such as the “share this” button. These features may collect your
personal information and track your use of the Site. These social media features are either
hosted by a third party or hosted directly on our Site. Your interactions with these features are
governed by the privacy policy of the company providing such functionality.
Information Automatically Collected. We may automatically record certain information about how
you use our Site (we refer to this information as “Log Data“). Log Data may include information such
as a users Internet Protocol (IP) address, device and browser type, operating system, the pages or
features of our Site to which a user browsed and the time spent on those pages or features, the
frequency with which the Site is used by a user, search terms, the links on our Site that a user clicked
on or used, and other statistics. We use this information to administer the Service and we analyze (and
may engage third parties to analyze) this information to improve and enhance the Service by expanding
its features and functionality and tailoring it to our users’ needs and preferences.
We may use cookies, local storage, or similar technologies to analyze trends, administer the website,
track users’ movements around the website, and to gather demographic information about our user base
as a whole. Users can control the use of cookies and local storage at the individual browser level. For
more information, please see the sections entitled “Cookies Policy and “Local Storage Policy”” below.
We also use Google Analytics to help us offer you an optimized user experience. You can find more
information about Google Analytics’ use of your personal data here:
https://policies.google.com/privacy?hl=en
Information we will never collect. We will never ask you to share your private keys or wallet seed.
Never trust anyone or any site that asks you to enter your private keys or wallet seed.
USE OF PERSONAL INFORMATION
To provide our service
We will use your personal information in the following ways:
To enable you to access and use the Services
To provide and deliver products and services that you may request.
To send information, including confirmations, technical notices, updates, security alerts, and
support and administrative messages.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable
laws, lawful requests and legal process, such as to respond to subpoenas or requests from government
authorities.
To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news
about products and services offered by us and our selected partners.
To optimize our platform
In order to optimize your user experience, we may use your personal information to operate, maintain,
and improve our Services. We may also use your information to respond to your comments and
questions regarding the Services, and to provide you and other users with general customer service.
With your consent
We may use or share your personal information with your consent, such as when you instruct us to take
a specific action with respect to your personal information, or you opt into third party marketing
communications.
For compliance, fraud prevention, and safety
We may use your personal information to protect, investigate, and deter against fraudulent,
unauthorized, or illegal activity.
SHARING OF PERSONAL INFORMATION
We do not share or sell the personal information that you provide us with other organizations without
your consent, except as described in this Privacy Policy. We disclose personal information to third
parties under the following circumstances:
Affiliates. We may disclose your personal information to our subsidiaries and corporate
affiliates for purposes consistent with this Privacy Policy.
Business Transfers. We may share personal information when we do a business deal, or
negotiate a business deal, involving the sale or transfer of all or a part of our business or assets.
These deals can include any merger, financing, acquisition, or bankruptcy transaction or
proceeding.
Compliance with Laws and Law Enforcement; Protection and Safety. We may share
personal information for legal, protection, and safety purposes.
We may share information to comply with laws.
We may share information to respond to lawful requests and legal processes.
We may share information to protect the rights and property of the Company, our agents,
customers, and others. This includes enforcing our agreements, policies, and terms of use.
We may share information in an emergency. This includes protecting the safety of our
employees and agents, our customers, or any person.
Professional Advisors and Service Providers. We may share information with those who need
it to do work for us. These recipients may include third party companies and individuals to
administer and provide the Service on our behalf (such as customer support, hosting, email
delivery and database management services), as well as lawyers, bankers, auditors, and insurers.
Other. You may permit us to share your personal information with other companies or entities
of your choosing. Those uses will be subject to the privacy policies of the recipient entity or
entities.
We may also share aggregated and/or anonymized data with others for their own uses.
INTERNATIONAL TRANSFER
The Company has offices outside of the EU and has affiliates and service providers in the United States
and in other countries. Your personal information may be transferred to or from the United States or
other locations outside of your state, province, country or other governmental jurisdiction where
privacy laws may not be as protective as those in your jurisdiction.
EU users should read the important information provided below about transfer of personal information
outside of the European Economic Area (EEA).
HOW INFORMATION IS SECURED
We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined
in this privacy policy. In addition, we retain personal information to comply with applicable law where
required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce
our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for
personal information, we consider the amount, nature, and sensitivity of the personal information, the
potential risk of harm from unauthorized use or disclosure of your personal information, the purposes
for which we process your personal information and whether we can achieve those purposes through
other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be
associated with you) in which case we may use this information indefinitely without further notice to
you.
We employ industry standard security measures designed to protect the security of all information
submitted through the Services. However, the security of information transmitted through the internet
can never be guaranteed. We are not responsible for any interception or interruption of any
communications through the internet or for changes to or losses of data. Users of the Services are
responsible for maintaining the security of any password, biometrics, user ID or other form of
authentication involved in obtaining access to password protected or secure areas of any of our digital
services. In order to protect you and your data, we may suspend your use of any of the Services,
without notice, pending an investigation, if any breach of security is suspected.
INFORMATION CHOICES AND CHANGES
Accessing, Updating, Correcting, and Deleting your Information
You may access information that you have voluntarily provided through your account on the Services,
and to review, correct, or delete it by sending a request to privacy@raipay.co. You can request to
change contact choices, opt-out of our sharing with others, and update your personal information and
preferences.
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial
browsers, and in some instances blocked in the future by selecting certain settings. For more
information, please see the section entitled “Cookies Policy” below.
Google Analytics
You may exercise choices regarding the use of cookies from Google Analytics by going to
https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-
on.
CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you
may contact us at: privacy@raipay.co
CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy at any time. We
encourage you to periodically review this page for the latest information on our privacy practices. If we
make any changes, we will change the Last Updated date above.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or
upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all
cases, your continued use of the the Site or Services after the posting of any modified Privacy Policy
indicates your acceptance of the terms of the modified Privacy Policy.
ELIGIBILITY
If you are under the age of majority in your jurisdiction of residence, you may use the Services only
with the consent of or under the supervision of your parent or legal guardian. Consistent with the
requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have
received any information directly from a child under age 13 without first receiving his or her parent's
verified consent, we will use that information only to respond directly to that child (or his or her parent
or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete
that information.
NOTICE TO CALIFORNIA RESIDENTS
Under California Civil Code Section 1789.3, California users are entitled to the following consumer
rights notice: California residents may reach the Complaint Assistance Unit of the Division of
Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market
Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
NOTICE TO EU DATA SUBJECTS
Personal Information
With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent
to
“personal data” as defined in the European Union General Data Protection Regulation (GDPR).
Sensitive Data
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also
referred to as special categories of personal data), including identification of your race or ethnicity on
government-issued identification documents.
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal
bases of our processing of your personal information, which are described in the table below. If you
have questions about the legal bases under which we process your personal information, contact us at
privacy@raipay.co
Processing Purpose Legal Basis:
To communicate with you, to optimize our platform, for compliance, fraud prevention, and safety, and
to provide our service.
These processing activities constitute our legitimate interests. We make sure we consider and balance
any potential impacts on you (both positive and negative) and your rights before we process your
personal information for our legitimate interests. We do not use your personal information for activities
where our interests are overridden by any adverse impact on you (unless we have your consent or are
otherwise required or permitted to by law).
Where our use of your personal information is based upon your consent, you have the right to withdraw
it anytime in the manner indicated in the Service or by contacting us at privacy@raipay.co
Use for New Purposes
We may use your personal information for reasons not described in this Privacy Policy, where we are
permitted by law to do so and where the reason is compatible with the purpose for which we collected
it. If we need to use your personal information for an unrelated purpose, we will notify you and explain
the applicable legal basis for that use. If we have relied upon your consent for a particular use of your
personal information, we will seek your consent for any unrelated purpose.
Your Rights
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take
the following actions in relation to your personal information that we hold:
Opt-out. Stop sending you direct marketing communications which you have previously
consented to receive. We may continue to send you Service-related and other non-marketing
communications.
Access. Provide you with information about our processing of your personal information and
give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information.
Transfer. Transfer a machine-readable copy of your personal information to you or a third party
of your choice.
Restrict. Restrict the processing of your personal information.
Object. Object to our reliance on our legitimate interests as the basis of our processing of your
personal information that impacts your rights.
You can submit these requests by email to privacy@raipay.co. We may request specific information
from you to help us confirm your identity and process your request. Applicable law may require or
permit us to decline your request. If we decline your request, we will tell you why, subject to legal
restrictions. If you would like to submit a complaint about our use of your personal information or
response to your requests regarding your personal information, you may contact us at
privacy@raipay.co or submit a complaint to the data protection regulator in your jurisdiction. You can
find your data protection regulator here.
Cross-Border Data Transfer
Please be aware that your personal data will be transferred to, processed, and stored in the United
States. Data protection laws in the U.S. may be different from those in your country of residence. You
consent to the transfer of your information, including personal information, to the U.S. as set forth in
this Privacy Policy by visiting our site or using our service.
Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by
the European Commission to provide an adequate level of personal information protection, the transfer
will be based on a data transfer mechanism recognized by the European Commission as providing
adequate protection for personal information.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal information out of the EEA.
COOKIES POLICY
We understand that your privacy is important to you and are committed to being transparent about the
technologies we use. In the spirit of transparency, this policy provides detailed information about how
and when we use cookies on our Site.
Do we use Cookies?
Yes. We and our marketing partners, affiliates, and analytics or service providers use cookies, web
beacons, or pixels and other technologies to ensure everyone who uses the Site has the best possible
experience.
What is a Cookie?
A cookie (“Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies
contain information that can later be read by a web server in the domain that issued the cookie to you.
Some of the cookies will only be used if you use certain features or select certain preferences, and
some cookies will always be used. You can find out more about each cookie by viewing our current
cookie list below. We update this list periodically, so there may be additional cookies that are not yet
listed. Web beacons, tags and scripts may be used in the Site or in emails to help us to deliver cookies,
count visits, understand usage and campaign effectiveness and determine whether an email has been
opened and acted upon. We may receive reports based on the use of these technologies by our
service/analytics providers on an individual and aggregated basis.
Why do we use Cookies?
We generally use Cookies for the following purposes:
To recognize new or past customers.
To store your password if you are registered on our Site.
To improve our Site and to better understand your visits on our platforms and Site.
To integrate with third party social media websites.
To serve you with interest-based or targeted advertising.
To observe your behaviors and browsing activities over time across multiple websites or other
platforms.
To better understand the interests of our customers and our website visitors.
Some Cookies are necessary for certain uses of the Site, and without such Cookies, we would not be
able to provide many services that you need to properly use the Site. These Cookies, for example, allow
us to operate our Site so you may access it as you have requested and let us recognize that you have
created an account and have logged into that account to access Site content. They also include Cookies
that enable us to remember your previous actions within the same browsing session and secure our
Sites.
We also use functional Cookies and Cookies from third parties for analysis and marketing
purposes. Functional Cookies enable certain parts of the site to work properly and your user
preferences to remain known. Analysis Cookies, among other things, collect information on how
visitors use our Site, the content and products that users view most frequently, and the effectiveness of
our third party advertising. Advertising Cookies assist in delivering ads to relevant audiences and
having our ads appear at the top of search results. Cookies are either “session” Cookies which are
deleted when you end your browser session, or “persistent,” which remain until their deletion by you
(discussed below) or the party who served the cookie. Full details on all of the Cookies used on the
Site are available at our Cookie Disclosure table below.
How to disable Cookies.
You can generally activate or later deactivate the use of cookies through a functionality built into your
web browser. To learn more about how to control cookie settings through your browser:
Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox;
Click here to learn more about “Incognito” and managing cookie settings in Chrome;
Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer; or
Click here to learn more about “Private Browsing” and managing cookie settings in Safari.
If you want to learn more about cookies, or how to control, disable or delete them, please visit
http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising
networks, including Google, permit users to opt out of or customize preferences associated with your
internet browsing. To learn more about this feature from Google, click here.
To control flash cookies, which we may use on our Site from time to time, you can go to this link
because Flash cookies cannot be controlled through your browser settings. Please note that if you
decline the use of Cookies, some functions of the website may be unavailable and we will not be able
to present personally tailored content and advertisements to you.
We may link the information collected by Cookies with other information we collect from you pursuant
to this Privacy Policy and use the combined information as set forth herein. Similarly, the third parties
who serve cookies on our Site may link your name or email address to other information they collect,
which may include past purchases made offline or online, or your online usage information. If you are
located in the European Economic Area, you have certain rights that are described above under the
header “Notice to EU Data Subjects”, including the right to inspect and correct or delete the data that
we have about you.
LOCAL STORAGE POLICY
Local Storage, including Javascript-enabled localStorage, is a typical way for a website to store a small
file of letters and numbers in your browser. We use Local Storage to assign you a unique user ID for
purposes of communication with you. Local Storage are deleted when the website that stored them
deletes them. You can also delete Local Storage from your browser at any time you like by visiting
your web browser settings.
How to Clear Local Storage from Your Browser:
In Firefox, localStorage is cleared when the following conditions are met: (a) user clears recent
history, (b) cookies are selected to be cleared, and (c) time range is “Everything.”
In Chrome, localStorage is cleared when the following conditions are met: (a) clear browsing
data, (b) "cookies and other site data" is selected, and (c) timeframe is “from beginning of
time.” In Chrome, it is also now possible to delete localStorage for one specific site.
In IE, to clear localStorage: (a) click on Tools--Internet Options, (b) General tab, (c) delete
browsing history on exit, (d) ensure “Cookies and website data” (or “temporary internet files
and website files”) is selected, and (e) consider unchecking "Preserve Favorites website data" at
the top.
In Safari, (a) Click Safari, (b) Preferences, (c) Select the Privacy tab, (d) Click Remove all
website data and (e) Click Remove Now