DATA PROTECTION POLICY

Introduction

At DB Technology Innovations Ltd (CPayant), we recognize the importance of protecting the personal data entrusted to us by our users. This Data Protection Policy, approved by our Board of Directors, outlines our commitment to responsible data collection, use, and disclosure in accordance with all applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR).

Personal Data We Collect and Use

We collect and use personal data to deliver our cross-border payment app experience and fulfill our contractual obligations. This data includes, but is not limited to:

• Account information: Name, email address, phone number, date of birth, identification documents.
• Financial information: Payment details, transaction history.
• App Usage data: IP address, device type, operating system, browsing history, location data (with consent).
• Third-Party Data: Information from social media platforms or payment processors (with consent).

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Transparency and Legal Basis

We believe in transparency and obtaining your informed consent whenever possible. However, in some cases, we may process your data based on the following legal grounds:

• Contractual Necessity: To provide the app services and fulfill our agreements with you.
• Legal Obligations: To comply with anti-money laundering and other regulatory requirements.
• Legitimate Interests: To improve our services, prevent fraud, and market our offerings, ensuring your interests are not overridden.

Data Retention and Security

We retain your data only for as long as necessary for the stated purposes, adhering to strict legal requirements. We implement robust security measures to protect your information against unauthorized access, disclosure, alteration, or destruction.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

We will only process the data for minors under 18 based on their parent's or guardian's consent as a legal basis for processing their information and Your country may require consent from a parent. We may require Your parent's consent before We collect and use that information.

Data Sharing and Your Rights

We may share your data with trusted third-party service providers who assist us in operating the app and delivering services. We disclose data only as required by law or with your explicit consent.

You have the right to:

• Access and rectify your personal data.
• Request erasure or restriction of processing.
• Object to processing and data portability.
• Lodge complaints with supervisory authorities.

We encourage you to exercise these rights and have established clear procedures to facilitate them.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last Updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Commitment and Continuous Improvement

Our Board of Directors regularly reviews and updates this policy to ensure it aligns with evolving data protection regulations and best practices. We are committed to protecting your privacy and fostering trust through responsible data handling.

Contact Us

For any inquiries or concerns regarding this policy, please contact our Data Protection Officer at contact@cpayant.com.

If you have any questions about this Privacy Policy, You can contact us:

• By email: contact@cpayant.com
• By visiting this page on our website: https://cpayant.com/contact-us/
• By mail: 86-90 Paul Street, London EC2A 4NE, United Kingdom