Privacy Policy

1. Data Controller

The data controller responsible for your personal data is:

If you have questions or requests regarding this Privacy Policy, please contact us at the email above.

2. Who This Policy Applies To

This Privacy Policy applies to individuals who:

• visit or browse our Website ("Users", "Browsers"), and
• are at least 18 years old.

We do not knowingly collect personal data from individuals under the age of 18.

This Privacy Policy applies to natural persons only.

3. What Personal Data We Collect

The personal data we collect depends on how you interact with our Website.

3.1. Data collected automatically (from all Browsers)

• Technical Data: IP address and associated country, browser type, device type, operating system, time zone, language settings.
• Usage Data: pages viewed, links clicked, time spent, interactions (scrolling, clicks), referral sources.
• Cookies and similar technologies: as described in our Cookies Policy.
• Communications Data: any information you send us via forms or email.
• Preferences: cookie consents, marketing consents, language settings.

3.2. Data provided voluntarily by Users

If you contact us or request information:

• Contact Data: name, email address, company name, role, country.
• Inquiry Data: information you provide in forms or messages (e.g., details about your business or interest in crypto payment concierge services).
• Marketing Data: your preferences for receiving communications from us.

3.3. Aggregated Data

We may create aggregated or anonymised data for analytics. This data does not identify you and is not considered personal data.

We do NOT collect:

• KYB/KYC documents
• passport/ID numbers
• financial data
• crypto wallet information
• sensitive data (racial origin, health, religion, etc.)

4. How We Collect Personal Data

We collect personal data through:

• your interactions with our Website
• contact forms or email inquiries
• cookies and analytics tools
• communication you choose to send us

5. Why We Process Your Personal Data (Legal Bases)

We process personal data only when allowed by GDPR. Below are the purposes and legal bases:

5.1. Performance of Services (Legitimate Interest or Pre-contractual Need)

To:

• respond to your inquiries
• provide information about our services
• help determine whether your business may be a fit for a Licensed Partner
• maintain communication regarding your request

If you do not provide necessary personal data, we may not be able to respond properly.

5.2. Legitimate Interests

We process your data for our legitimate interests, including to:

• maintain, secure and improve our Website
• analyze usage patterns and Website performance
• customize Website interactions and communications
• prevent fraud, misuse, or security threats
• protect our legal rights
• develop new services and business opportunities
• perform internal analytics

We ensure that your rights and freedoms do not override these interests.

5.3. Compliance with Legal Obligations

We may process your data to:

• respond to lawful requests from authorities
• comply with regulatory or legal obligations
• manage disputes, investigations or litigation

5.4. Consent

We process personal data based on your consent for:

• marketing emails
• non-essential cookies

You may withdraw your consent any time.

6. Important Clarification: We Do Not Perform KYB/KYC

If you choose to engage with a Licensed Partner, any KYB/KYC required will be handled directly by that Licensed Partner under their own privacy policy.

7. Sharing Your Personal Data

We do not sell personal data.

We may share your personal data with:

7.1. Service Providers

(e.g., hosting providers, CRM tools, analytics providers, email systems) All are bound by GDPR-compliant contracts.

7.2. Licensed Partners (Only If You Request an Introduction)

If you explicitly request to be introduced to an EU-licensed crypto-asset service provider, we may share:

• your name
• email
• company name
• a brief description of your inquiry

7.3. Professional advisers

(e.g., lawyers, auditors) Only when necessary to protect our rights.

7.4. Public authorities

If legally required to comply with investigations or legal processes.

7.5. Corporate events

In the case of a sale, merger or business transfer, provided that privacy rights continue to be protected.

7.6. Aggregated data

Non-identifiable analytics may be shared freely.

8. International Transfers

If personal data is transferred outside the EEA, we will ensure appropriate safeguards such as:

• EU adequacy decisions
• Standard Contractual Clauses (SCCs)
• other GDPR-compliant mechanisms

9. Security of Personal Data

We take appropriate technical and organizational measures to protect your data, including:

• access controls
• encryption
• secure servers
• firewalls
• limited access on a need-to-know basis

No system is fully secure, but we take reasonable precautions to safeguard your information.

10. Marketing Communications

We may send marketing communications about PortierPay's services if:

• you consent, or
• it is permitted based on legitimate interest (e.g., existing inquiries)

You can opt out at any time by contacting: sergio@portierpay.com

You may still receive non-marketing messages (e.g., responses to your inquiries).

11. Data Retention

We retain your personal data only for as long as necessary for the purposes it was collected, including:

• responding to your inquiries
• fulfilling legal obligations
• resolving disputes
• protecting our rights

Once no longer needed, data will be deleted or anonymised. You may request deletion as described in Section 12.

12. Your GDPR Rights

You have the following rights:

• Right of access -- request a copy of your personal data
• Right to rectification -- correct inaccurate or incomplete data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to object to legitimate-interest processing or marketing
• Right to data portability (for data processed based on consent or contract)
• Right to withdraw consent at any time

To exercise your rights, contact us at: sergio@portierpay.com

We may need to verify your identity before processing a request.

13. Cookies

We use cookies and similar technologies. Details are provided in our Cookies Policy.

You may manage cookies through your browser or our cookie controls.

14. Complaints

If you believe we have mishandled your personal data, please contact us first at:

sergio@portierpay.com

You also have the right to lodge a complaint with the Spanish data protection authority (AEPD):

Agencia Espanola de Proteccion de Datos
https://www.aepd.es

Or with your local EU/EEA supervisory authority.

15. Third-Party Links

Our Website may contain links to third-party websites or services. We do not control these third parties and are not responsible for their privacy policies or practices.

We encourage you to review their privacy policies.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be available on this page with an updated "Effective date".

We encourage you to review this Policy periodically.

17. Contact

If you have questions about this Privacy Policy, your personal data, or your rights, please contact:

sergio@portierpay.com
Attn: Data Protection

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