Privacy Policy — Payceler Limited

1. Key Definitions

• Business Customer: An organization using Payceler’s Services (e.g., remittance partner, merchant, corporate client).
• Authorized User: An individual authorized to use the Services on behalf of a Business Customer.
• End User: An individual whose transaction or payment is facilitated through a Business Customer using Payceler.
• Personal Information: Information that identifies or can reasonably be linked to an individual.

2. Our Role: Controller vs Processor

Because our Services are primarily B2B/B2B2C, Payceler may act as either a data controller or data processor depending on the context.

• Controller: When we determine how and why personal data is processed for our own business purposes.
• Processor: When we process data on behalf of a Business Customer according to their instructions.

If you are an End User interacting with a Business Customer using Payceler infrastructure, that Business Customer may provide additional privacy notices.

3. Personal Information We Collect

Information You Provide

• Contact details (name, email, phone number, address)
• Business and account information
• Onboarding and verification details (KYC / KYB)
• Communications with Payceler support or sales

Automatically Collected Data

• IP address and device identifiers
• Browser and operating system information
• Usage data and interaction analytics
• Cookies and similar technologies

Transaction & Financial Data

• Transaction references, amounts, and currencies
• Sender and recipient identifiers
• Payout or collection method information
• Transaction timestamps and status

4. How We Use Personal Information

• Operate and maintain Payceler Services
• Enable collections, FX conversion, and payouts
• Authenticate users and manage permissions
• Provide customer support
• Conduct compliance checks and fraud prevention
• Improve platform performance and reliability
• Send B2B marketing communications where permitted

5. Legal Basis for Processing

• Contractual necessity to provide services
• Compliance with legal obligations
• Legitimate business interests
• Consent where required by law

6. Sharing Personal Information

• Service providers supporting platform operations
• Banks and payment ecosystem partners
• Business Customers using Payceler infrastructure
• Regulators or legal authorities where required
• Corporate transaction participants (e.g., mergers)

7. Cookies & Analytics

We use cookies and similar technologies to ensure proper platform functionality, improve user experience, and analyze usage patterns.

• Essential cookies for site functionality
• Analytics tools such as Google Analytics
• Preference cookies to remember user settings

8. International Data Transfers

Because Payceler operates globally, personal information may be transferred to and processed in jurisdictions outside your country. Where required, we implement safeguards to protect your data during international transfers.

9. Data Retention

We retain personal information only as long as necessary to provide our Services, comply with legal obligations, resolve disputes, prevent fraud, and enforce agreements.

10. Security

Payceler implements technical and organizational safeguards to protect personal information from unauthorized access, disclosure, or loss.

11. Your Rights

Depending on applicable law, you may have rights to:

• Access your personal data
• Correct inaccurate data
• Request deletion
• Restrict or object to processing
• Request data portability
• Opt out of marketing communications

12. Children’s Privacy

Payceler Services are not directed at children, and we do not knowingly collect personal information from children.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Updated versions will be posted on our website with the revised “Last Updated” date.