Privacy Policy
NFTIPAY
PRIVACY POLICY
Last updated: 01/28/2025
NFTipay Brazil Ltda. (“Liberpay”, “we”, “us”, or “our”) is committed to respecting your privacy. This Privacy Policy explains our practices regarding the collection, use, and disclosure of information that you (“User,” “Users” “you” or “your”) may provide to us through your use of the mobile-enabled website hosted on the domain https://nftipay.com (the “Website”) and its sub-domains. The platform we make available through the Website (the “Technology”), and any related services, applications, APIs and social media pages (the Website and Technology, together with any related services, applications, APIs, social media pages, and any other products or services made available by Liberpay that link to this Privacy Policy, are collectively referred to as our “Services”).
This Privacy Policy is incorporated into, and is part of, our Terms of Service available at NFTIPAY.COM/TERMSOFSERVICE, which governs your access to and your use of the Services. If you have entered into a separate agreement with us, that separate agreement shall control, and only those terms within this Privacy Policy that do not conflict with such separate agreement shall apply. This Privacy Policy does not cover third party products and services. If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer, Steven Albrechtsen, at PRIVACY@NFTIPAY.COM.
By accessing, registering for, or using the Services, you agree to be bound by this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Services. The current version of this Privacy Policy will apply each time you use the Services.
Information We Collect and How We Use it
We collect different types of information from Users of our Services, such as: “Personal Information,” which is information that you provide that can be used to identify you (such as your name or your email address).
INFORMATION YOU PROVIDE TO US
We collect Personal Information and other information that you voluntarily provide to us when you use our Services. Exemples include:
- Identity information, such as first and last name, photo ID, and selfie;
- Contact information, such as postal address, email address and telephone number;
- Feedback and correspondence, such as information you share when you participate in market research activities, request and receive customer support or otherwise correspond with us;
- Transactional Data, such as the details of a purchase you make through the Services;
- Marketing information, such as your preferences for receiving marketing communications;
- Technical information, such as credentials, your wallet address, application programming interface (“API”) keys and network information regarding Transactions.
ACCOUNTS & IDENTITY VERIFICATION
When creating an account with us, Liberpay, or third party service providers acting on Liberpay’s behalf, may collect certain Personal Information about you in order to verify your identity and eligibility to use the Services and to send you log-in codes and other registration information for the Services. The data requested depends on the type of account you are requesting:
- For a Buyer Account, you must provide your name, email address, and date of birth;
- For a Seller Account of an unincorporated business/sole proprietorship, you must provide your name, email address, physical address, date of birth, and social security or taxpayer identification number;
- For a Seller Account on behalf of a business or any other type of business legal entity, you must provide your name, email address, taxpayer identification number and corporate information not considered personal data (such as a business name, business address, business taxpayer identification number and proof of business existence).
In addition to the required identifying information above, all Users utilizing the Services for Transactions involving digital currencies will need to provide a valid government ID and face ID capture to our third party authentication partner in connection with Liberpay’s identity verification procedures. In certain jurisdictions, it may be necessary to collect other information or documents from you to confirm identity as determined by Liberpay and its service providers, which will be carried out by us to the extent permitted by applicable laws.
TRANSACTIONAL DATA
Users of our Services will engage in transactions with each other using the Technology (“Transactions”). Liberpay will collect data related to these Transactions (“Transactional Data”) and associate it with Personal Information about Users engaged in the Transaction in order to provide the Services and facilitate Transactions and Minting Services (if applicable) in accordance with the Terms of Service. Due to the nature of blockchain applications, your wallet address and the amount of funds exchanged in connection with a Transaction involving digital currency will remain publicly available on the applicable blockchain.
FIAT Bridge and Bridge Apps
Users may link their account with any third party payment processor application integrated with our Services (each, a “Bridge App”) in order to facilitate payments and invoicing for Transactions using fiat currencies (the “FIAT Bridge”). The FIAT Bridge permits Seller Accounts to accept any type of fiat currency payment from Buyer Accounts. When using the FIAT Bridge, your credit or debit card information is never shared with us, and at no point in any transaction do we have access to that information. You should consult the privacy policies of the Bridge Apps to learn more about how each processes credit and debit card transactions for fiat currencies.
PAYMENT INFORMATION
Any Fees and network gas charges owed to Liberpay are paid by Users through Bridge Apps or from a digital wallet connected to the Payment Gateway to a digital wallet maintained by Liberpay. Please note that Liberpay does not collect your credit or debit card information at any time and we ask Users not to share this information with us when using the Services.
YOUR COMMUNICATION WITH US
We collect information when you communicate with us. The specific types of information we collect will depend on the forum in which you communicate with us. For example, if you send us an email, we will collect your email address and the content of your email.
MARKETING
If you subscribe to our mailing list, we or a third party vendor will collect the information you submit and you are signing up to receive marketing and other communications from us.
If you do not want to receive such type of communication, you are able to express your intention of opting out by following the instructions included in each communication.
SOCIAL MEDIA
If you interact with us on social media, we may collect your social media profile information, your communications with us, and your communications and posts on our social media pages.
INFORMATION WE AUTOMATICALLY COLLECT
When you use our Services, we automatically receive and collect information from your device. This information includes the following:
- Information about your device, such as the operating system, hardware, system version, Internet Protocol (IP) address, device ID, and device language.
- Your country and general location, time zone, and language used.
- The specific actions that you take when you use our Services, including but not limited to the pages and screens that you view or visit, search terms that you enter, and how you interact with our Services.
- The time, frequency, connection type, and duration of your use of our Services.
- Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
- Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
- Pages you visited before or after navigating to our Services.
We also store information that we collect through cookies, log files, clear gifs, and/or third party sources and analytics to create a “profile” of your preferences. We may tie your Personal Information to information in the profile or other sources of data we have about you, in order to improve the content and features of the Services for you. We do not share your profile with other third parties other than service providers we use to support our business and provide Services to you.
COOKIES AND ANALYTICS
Like most websites, our Services may use “cookies.” Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to help us identify you when you come to our Services.
Our Services collect cookies and may use cookies for reasons including, but not limited to:
- Analyze our web traffic using an analytics package.
- Identify if you are signed into the Services.
- Test content on the Services.
- Store information about your preferences.
- Recognize when you return to the Services.
Overall, cookies help us provide you with better Services by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This setting may prevent you from taking full advantage of the Services.
We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our website. Google Analytics does not create individual profiles for visitors and only collects aggregate data.
To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en.
To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners/. You have the option to opt out of Google’s use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page at http://www.google.com/policies.
We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Website, Technology or social media and whether or not certain content was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Privacy Policy.
Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser.
HOW WE USE YOUR INFORMATION
In general, we collect information and Personal Information from you so that we can provide our Services, operate our business, communicate with you, and provide information that you request from us. This includes but is not limited to the following:
- Provide, operate, improve, maintain, modify, and protect our Services.
- Create your account, complete any identity verification procedures, and allow you to use our Services and any Bridge Apps integrated with the Services.
- Provide you with technical and other support.
- Fulfill your order and deliver your products.
- Assist you with product selection and suggest products to you.
- Send you updates, marketing communications, and other information about Liberpay, our Services, and our products, events, promotions, and our websites.
- Send you notices and alerts.
- Conduct research, analytics, and monitor and analyze trends and usage, including marketing campaign performance.
- Product improvement and development.
- Contact you and respond to your inquiries and requests, and when needed verify your status and identity in connection with our exchanges.
- Detect, prevent, or otherwise address fraud, security or technical issues.
- Enhance or improve user experience, our business, our products, and our websites, including the safety and security thereof.
- Personalize our Services for you.
- As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
- Enforce contracts and our Terms of Service, including investigation of potential violations thereof.
- Protect against harm to the rights, property or safety of Liberpay, our users, or the public as required or permitted by law.
How we share your information
We do not rent or sell your Personal Information.
Like most companies, we share information, including Personal Information, in certain circumstances with third parties through operation of our Services and our business. Below we explain when that happens.
TRANSACTIONS
In order to complete and memorialize Transactions utilizing our Technology, Liberpay delivers a non-fungible token (“NFT”) to each User involved in a Transaction providing access to certain Transactional Data and Personal Data applicable to the Transaction, including but not limited to:
- Buyer contact information (such as your name, address, and email, and phone number);
- Seller contact information;
- Products/services exchanged; and
- Publicly available blockchain data (as described in the ”Transactional Data & Digital Wallets” section above).
Only the original parties to the Transaction will be provided the NFT in order to access the Transactional Data described above. By utilizing Minting Services in connection with a Transaction, Users consent to Liberpay sharing their Personal Information and applicable Transactional Data with each party to the Transaction as reasonably necessary to complete and memorialize the Transaction.
SERVICE PROVIDERS
We may transfer Personal Information to third parties for the purpose of providing the Services or operating our business. For example, we may transfer your Personal Information to third-party vendors and service providers to verify your identity in connection with creating your account, to assist with providing and improving the Services, to operate the FIAT Bridge, and to communicate with you about current or future offerings.
REQUIRED TRANSFERS
We may also transfer your Personal Information to third parties without prior notice to you under the following circumstances: (i) to our affiliates and subsidiaries, (ii) to governmental authorities in response to governmental requests, (iii) to comply with a legal requirement, law, subpoena, judicial proceeding, court order, or legal process, (iv) to investigate a possible crime, such as fraud or identity theft, (v) in connection with the sale, purchase, merger, asset sale, financing, reorganization, liquidation or dissolution of Liberpay or an affiliate, including the evaluation thereof, (vi) when we believe it is necessary to protect the rights, property, or safety of Liberpay or other persons, or (vii) as otherwise required or permitted by law, including any contractual obligations of Liberpay.
AS DIRECTED BY YOU AND WITH YOUR CONSENT
Except as otherwise provided in this Privacy Policy, we share Personal Information with companies, organizations or individuals outside of Liberpay only at your direction or when we have your consent to do so.
THIRD PARTY WEBSITES
Our Services may contain hyperlinks to websites operated by third parties, which may include social media features, such as social media buttons or links. We provide such hyperlinks for your reference and convenience only. We do not control such websites and are not responsible for their content or the privacy or other practices of such websites. It is up to you to read and fully understand their privacy policies. Our inclusion of hyperlinks to such websites does not imply any endorsement of the material on such websites or any association with their operators. If you are submitting information to any such third party through our Services, you should review and understand that party’s applicable policies, including their privacy policies, before providing your information to the third party.
Children’s privacy
Our Services are not intended for use by individuals under 13 years of age (or the legal age of majority where you reside if that jurisdiction has an older age of majority) and we do not knowingly collect Personal Information from children under the age of 13 in the US (or the relevant age threshold in other jurisdictions) in connection with the Services.
Privacy Choices and Access to Information
Users of the Platform may access and delete information through account settings.
Depending on your jurisdiction, you may be entitled to exercise some rights in relation to your Personal Information.
If you are a Brazilian user, you have the following rights, which can be exercised by emailing us at PRIVACY@NFTIPAY.COM:
- Obtain confirmation that we process your Personal Information. In response to this request, we will inform you whether we process your Personal Information or not.
- Access your Personal Information. If you are interested, you can receive a report in which we present the Personal Information related to you and processed by us.
- Correct Personal Information that is incomplete, inaccurate or out of date. If you understand that your Personal Information is incorrect, you can request correction, indicating what needs to be changed and why. We may ask for proof to make the required update.
- Request anonymization, blocking or deletion of unnecessary, excessive or processed Personal Information that does not comply with the provisions of the Brazilian law. If you understand that we are processing your Personal Information in an unnecessary, excessive or non-compliant manner with the Brazilian law, you can request that the Personal Information be anonymized, blocked or deleted.
- Request the portability of your Personal Information to another service or product provider, subject to our commercial and industrial secrets, after regulation by the relevant authority. You are the owner of your own Personal Information. Therefore, you may request that this Personal Information be transferred to another service or product provider, in accordance with regulations, as long as commercial and industrial secrets are respected.
- Obtain information about who we share your Personal Information with. You can request that we provide information on which entities we share your Personal Information with.
- Obtain information about the possibility of not providing your consent and the respective consequences. When consent is used as a legal basis for the processing of Personal Information, you have the right to be informed about the possibility of not providing consent and the consequences of refusal.
- Revoke your consent to the processing of your Personal Information. If your Personal Information is processed based on consent, you may revoke this consent. As a result, any processing of your Personal Information that is being carried out based on consent will be ceased.
- Oppose processing that violates the law. If you understand that we are processing your Personal Information in a manner contrary to the law, you can object to this processing. The request will be analyzed very carefully and, if we agree, the processing of your Personal Information that does not comply with the law will be ceased.
- Request the review of decisions made solely based on automated processing of your Personal Information. It is possible that decisions will be made based on the automated processing of your Personal Information. If this occurs, you can request a review of these decisions.
INTERNATIONAL TRANSFER
Our Services are hosted in various countries, including the United States. If you use our Services from the United Kingdom, European Union or other regions of the world with laws governing data collection and use that may differ from United States and other countries’ law, then please note that by sending an email or other communication containing Personal Information or by providing Personal Information through our Services, you are voluntarily transferring your Personal Information outside of those regions to the United States and other countries.
How Do We Protect Your Information
We take the security of your Personal Information very seriously. We use reasonable administrative, physical, and technical safeguards to secure the Personal Information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Information.
Changes to our Privacy Policy
We reserve the right to amend this policy at any time without any prior notice to you. Each time you use our Services the current version of this Privacy Policy will apply. When you use our Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version.
Questions
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
By e-mail: PRIVACY@NFTIPAY.COM
By mail: 3 Howard Munroe Pl., Lexington MA 02420
Notice to Residents of the European Economic Area, Switzerland and the United Kingdom
Residents of the EEA, Switzerland and the United Kingdom have additional privacy rights. Information on these rights is provided in our supplemental European Economic Area, Switzerland and United Kingdom Resident Privacy Notice below.
This European Economic Area (“EEA”), Switzerland and United Kingdom (“UK”) Resident Privacy Notice supplements the information contained in our Privacy Policy and applies to residents of the EEA, the UK and Switzerland. It contains additional information required by the EU General Data Protection Regulation (“GDPR”) and the UK and Swiss equivalents. These provisions, which should be read together with the statements in the main Privacy Policy, explain our practices with regard to data privacy in the EEA, UK and Switzerland.
Name of data controller and contact details | NFTipay Inc. 3 Howard Munroe Pl. Lexington, MA 02420 United States Phone: |
Purposes of the processing | The purposes of the processing are described in the section of the main Privacy Policy entitled Information We Collect and How We Use It. |
Lawful basis for the processing | Our legal basis for processing personal data is described in the main Privacy Policy and will depend on the personal data concerned and the specific context in which we collect it. Generally, we process personal data on the basis that the processing is necessary for purposes of our legitimate interest in conducting our business in a manner typical in the US technology industry, having taken into account any risks to your fundamental rights and freedoms (including your right to privacy). We also may process personal data on other bases permitted by the GDPR, the UK Data Protection Act 2018 and other applicable laws, such as to fulfill a contract with you, or when the processing is necessary for us to comply with our legal obligations. |
The legitimate interests of the controller or third party, where applicable | Our specific legitimate interests, such as responding to your requests, comments and questions, providing you with support and improving the Services, providing you with the Services, completing your transactions, verifying your status and identity, are described in the section of the main Privacy Policy entitled Information We Collect and How We Use It. |
The categories of personal data concerned | The categories of personal data that we process are described in the section of the main Privacy Policy entitled Information We Collect and How We Use It. |
The recipients or categories of recipients of the personal data | The potential recipients of the personal data that we collect via the Services are described in the section of the main Privacy Policy entitled How We Share your Information. |
Information regarding the transfers of personal data outside of the EEA, Switzerland and the UK | NFTipay Inc. is headquartered in the USA and the Services are hosted in the USA. The laws of the USA have not been deemed by the European Commission, the United Kingdom or Switzerland to provide an adequate level of protection to personal data. When you provide your personal data to us via the Services or contact us by email, you are providing your personal data directly to the USA. Before you provide your personal data to us via the Services, we request your explicit consent to the transfer of your personal data to the USA. When you email us, the fact that you have chosen to email us knowing that we are located in the USA will be understood to constitute your explicit consent to the transfer of the personal data in your email (including your email address) to the USA. Regardless of the differences in US and European privacy laws, we safeguard your personal data as described in our main Privacy Policy and this section. If we transfer your personal data to a third party, we require the third party to commit contractually to process your personal data only in ways that are consistent with our main Privacy Policy and this supplemental notice. |
The period for which the personal data will be stored, or the criteria for determining the retention period | How long we retain personal data varies according to the type of data in question, the purpose for which it is used, and applicable data retention and record-keeping requirements. We delete personal data within a reasonable period after we no longer need to use it for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request that we delete your personal data before the end of its retention period. We may archive personal data (which means storing it in inactive files) for a certain period prior to its final deletion, as part of our ordinary business continuity procedures. |
Your rights to access, correct, restrict or delete your personal data and object to processing | You have the right to request access to your personal data, to have your personal data corrected, restricted or deleted, the right to data portability, and to object to our processing of your personal data. Your rights may be subject to various limitations under the GDPR. If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us by emailing us at PRIVACY@NFTIPAY.COM |
The right to lodge a complaint with a supervisory authority | You have the right to file a complaint concerning our processing of your personal data with your national (or in some countries, regional) data protection authority. The EU Commission has a list here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm See www.ico.org.uk for information about contacting the UK Information Commissioner’s Office. See www.edoeb.admin.ch/edoeb/en/home.html for information about contacting the Swiss Federal Data Protection and Information Commissioner. |
Controlling Cookies
You can learn about how you can adjust your browser’s settings to limit or disable non-essential cookies and other tracking technologies by visiting the COOKIES AND ANALYTICS section above. Strictly necessary cookies cannot be disabled.
516476165v.2