Privacy Policy

2.1 Information You Provide

• Contact information (email address, phone number)
• Identity verification documents (when required by law)
• Transaction preferences and settings
• Customer support communications
• Feedback and survey responses

2.2 KYC and Identity Verification Information

To comply with regulatory requirements and ensure platform security, we collect the following information through our Know Your Customer (KYC) process:

• Passport information obtained through in-app passport scanning
• Full name, date of birth, and nationality as shown on your passport
• Passport number and expiration date
• Biometric data from passport scanning (processed by our KYC partner)
• Selfie photographs for identity verification
• Additional identity documents as required by local regulations

Important: Your passport and KYC data is securely processed and stored by our trusted third-party KYC partner, not on Coming Pay's systems. This ensures the highest level of security and compliance with international data protection standards.

2.3 Automatically Collected Information

• Device information (device type, operating system, unique device identifiers)
• Usage data (app interactions, features used, time spent)
• Location data (with your permission, for merchant discovery)
• Network information (IP address, connection type)
• App performance and crash data

2.4 Blockchain and Transaction Data

• Wallet addresses (public keys only)
• Transaction amounts and timestamps
• Digital asset types and balances
• Transaction history and status
• Exchange rate data at time of transaction

2.5 Third-Party Information

• Information from payment processors and partners
• Merchant transaction confirmations
• Exchange rate data from financial data providers
• Compliance and verification data from third-party services
• KYC verification results from our trusted KYC partner

3.1 Service Provision

• Process QR payments and currency conversions
• Provide real-time exchange rates and fee calculations
• Facilitate transactions with merchant partners
• Maintain transaction history and records

3.2 Security and Compliance

• Verify user identity and prevent fraud
• Comply with anti-money laundering (AML) regulations
• Monitor for suspicious activities
• Ensure platform security and integrity

3.3 Service Improvement

• Analyze usage patterns to improve user experience
• Develop new features and services
• Optimize app performance and reliability
• Conduct research and analytics

3.4 Communication

• Send transaction confirmations and updates
• Provide customer support
• Send important service announcements
• Respond to inquiries and feedback

4.1 KYC Partner

We share identity verification information with our trusted KYC partner for the purpose of verifying your identity and ensuring compliance with regulatory requirements. Your passport and KYC data is securely stored on our KYC partner's platform, which maintains industry-leading security standards and compliance protocols.

4.2 Service Providers

We share information with trusted third-party service providers who assist us in operating our platform, including payment processors, compliance services, and technology providers.

4.3 Merchant Partners

We share necessary transaction information with merchants to complete payments and provide transaction confirmations.

4.4 Legal Requirements and Compliance

Coming Pay may be required to disclose your information to legal authorities and regulatory bodies to comply with applicable laws and regulations, including:

• Anti-Money Laundering (AML) laws and regulations
• Anti-Fraud laws and investigations
• Counter-terrorism financing regulations
• Court orders, subpoenas, or other legal processes
• Regulatory requirements from financial authorities
• Law enforcement investigations related to financial crimes
• Tax reporting obligations

Such disclosures will be made only to the extent required by law and in accordance with applicable legal procedures. We will make reasonable efforts to notify users of such requests unless prohibited by law, court order, or when disclosure is necessary to prevent harm.

4.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction.

5.1 Coming Pay Security Measures

Coming Pay is committed to protecting your information and implements comprehensive security measures:

• End-to-end encryption for sensitive data transmission
• Secure storage with industry-standard encryption
• Regular security audits and penetration testing
• Multi-factor authentication for account access
• Limited access controls for employee data handling
• Secure development practices and code reviews

5.2 KYC Partner Security

Your passport and identity verification data is processed and stored by our trusted KYC partner, which maintains industry-leading security standards including:

• Bank-level encryption and security protocols
• SOC 2 Type II compliance and regular security audits
• ISO 27001 information security management certification
• Secure data centers with physical and digital access controls
• Regular compliance assessments and third-party security reviews

This separation ensures that your most sensitive identity information is protected by specialized security infrastructure designed specifically for handling sensitive personal data.

5.3 Data Protection Commitment

Coming Pay is committed to protecting your personal information and will never sell, rent, or share your data for commercial purposes. We only share information as described in this Privacy Policy or as required by law for compliance with regulatory obligations.

7.1 Access and Portability

Request access to your personal information and receive a copy in a portable format.

7.2 Correction and Updates

Request correction of inaccurate or incomplete personal information.

7.3 Deletion

Request deletion of your personal information, subject to legal and regulatory requirements.

7.4 Consent Withdrawal

Withdraw consent for data processing where consent is the legal basis.

7.5 Objection and Restriction

Object to or request restriction of certain data processing activities.