Introduction

Last updated: June 3rd, 2025

This Privacy Notice ("Notice") explains how Radom Pay Limited (UK) and Radom Pay Spółka z ograniczoną odpowiedzialnością (Poland), collectively referred to as "Radom", "we", "our", or "us", collect, use, retain, and protect your personal data. It applies to all users of our Services, including Merchants, End Customers, Representatives, and Visitors.

1. Who We Are

Radom is a financial technology group offering crypto payments, exchange infrastructure, fiatconnectivity, and related tools. Radom Pay SP z o.o. is a MiCA-compliant VASP licensed inPoland. Radom Pay Limited is based in the United Kingdom and is the parent company.

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2. Data We Collect

2.1 End Customers (during checkout)

• Full name
• Date of birth
• Jurisdiction/country of residence
• Email address
• Wallet address
• Purchase details (amount, currency, timestamp)
• In certain flows: identity documents, proof of address, bank account details

2.2 End Customers (at sign-up)

• Full name
• Address
• Date of birth
• Email address
• Identity document
• Proof of address
• Tax Identification Number

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2.3 Business Representatives (during checkout)

• Full name of representative
• Representative's date of birth
• Registered name and country of the business

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2.4 Business Accounts (at sign-up)

• Ownership structure documentation
• Incorporation documents
• Registration numbers
• Tax Identification Number
• Proof of address
• Registration and operating addresses
• Business description, purpose, and source of funds

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2.5 Site Visitors

• IP address
• Location
• Data provided via forms or contact requests
• Analytics data (e.g., cookies, browser metadata)

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3. How We Use Your Data

Purpose

• To process transactions and provide services
• To meet regulatory requirements (e.g., AML/KYC/MiCA)
• To perform fraud prevention, monitoring, compliance checks
• To send marketing materials
• To improve site experience via analytics

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Lawful Basis

• Contractual necessity
• Legal obligation
• Legitimate interest
• Consent (where applicable)
• Legitimate interest / Consent

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4. Subprocessors and Data Sharing

We use third-party providers for key operational and compliance functions. These include:

• Cloud Hosting: AWS
• KYC Providers: Persona, Sumsub
• Banking Partners: Lead Bank, Revolut, Modulr, Banking Circle
• Blockchain Analytics: Elliptic, Chainalysis, Crystal Blockchain

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We do not sell your data. We only share it with:

• Trusted subprocessors as listed above
• Law enforcement or regulators, if legally required
  
• Business Users when you engage in a transaction with them

A complete list of subprocessors is available on request.

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5. International Data Transfers

We operate primarily in the UK and Poland. Where we transfer data outside the EEA/UK, werely on:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions (where applicable)

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6. Data Retention

• Personal and transactional data: retained for 5 years, or longer if required by law (e.g.,FATF/MiCA).
• Cookie and analytics data: retained for 12 to 24 months, depending on browser and settings.

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7. Your Rights

You have the right to:

• Access a copy of your data
• Rectify inaccurate or incomplete data
• Request deletion (where applicable)
• Object or restrict processing
• Data portability (to another provider)
• Withdraw consent at any time

To exercise your rights, email: contact@radom.com

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8. Security Measures

We implement industry-standard technical and organizational measures, including encryption and role-based access control. However, electronic transmission is not completely secure and we cannot guarantee absolute security.

9. Updates

This Notice may be updated from time to time. Any updates will be posted to our website or communicated via email or within our services. Continued use of our services constitutes your acknowledgment of the updated notice.

10. Contact

Radom Pay Limited71–75 Shelton Street, Covent Garden London, WC2H 9JQ, United Kingdom

Email: contact@radom.com

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