Privacy Policy

KoronaPay Europe Limited
Last updated 26 May 2025

This privacy policy describes how we process personal data when you use our mobile application or email us to specified contact emails.

Who we are

KoronaPay Europe Limited (“KoronaPay”, “we”) is an Electronic Money Institution (EMI) licensed and regulated by the Central Bank of Cyprus, the License No. 115.1.3.30.

Address: 359, 28th October str, World Trade Center, 5th floor, Limassol, 3107, Cyprus.
Email: privacy@koronapay.eu.

How we use your personal data

KoronaPay processes your personal data when you:

• Email us to specified contact emails.

We do not collect, process, or store any personal data through our application or in the course of providing our services described herein. No user information is recorded, transmitted, or shared with third parties.

Who we work with

We may use third-party data processors to obtain some services and software. Such providers grant an adequate, sufficient safeguarding service when it comes to processing your data, since we carefully screen service providers by including specific demands in the event that their services involve the need to process personal data.

We have necessary contracts with third-party providers. This means we are aware of operations they perform with your personal data on our behalf and instruct them how to keep your personal data secure and how long to store it.

Namely, we use services of the following third-party companies:

• Third-party cloud and hosting providers which host KoronaPay’s systems or provide IT infrastructure in Europe. KoronaPay has taken measures to ensure that providers protect our users' data from inappropriate use and restricts access to it by its personnel and subcontractors.
• We use electronic communication services and services of telecom providers to receive and process your requests, and communicate with you via email.

Detailed description of data processing activities

Process information requests or feedback

Purpose and legal basis for processing
Our purpose is to process requests and feedback when you email us to specified contact emails.

In general, we may receive the following types of requests:

• Information requests, such as those related to personal data processing. Our purpose of processing will be to fulfill your request. To help you with a support issue, we may need to ask you to provide your contact data, identification details, and additional information about the case.
• Feedback. It is important for us to receive your feedback to make our service better. Sending the feedback is voluntary for all users. Processing users’ feedback constitutes our legitimate interest to resolve an issue you have trouble with, identify deficiencies in our services as they occur, to assess views of existing users on using money transfer services, and receive ideas for improvements.

The legal basis:

• Compliance with legal obligation for processing of account misuse requests or other requests we are required to process by law (Article 6(1)(c) of the GDPR);
• Legitimate interests to answer requests or feedback; to keep data necessary to exercise and defend our legal claims in case a dispute arises (Article 6(1)(f) of the GDPR).

Personal data we process
The information we need may vary depending on the nature of your request. Generally, we process the following categories of data:

• Contact data (email);
• Content of request or feedback;
• Other details related to the case.

Why we need your data
We need to process personal data to answer you for your request.

How long we store your data
We process data from the information request until the issue is resolved or we have fulfilled your request. We then store data for up to 3 years to be able to exercise and defend our rights in case a dispute arises.

Third parties involved in processing
Telecom providers and electronic communication services through which we communicate with you.

Your data protection rights

Under the GDPR you have several rights as a data subject. Please contact via privacy@koronapay.eu if you want to exercise any of them. Note that we may request some additional information from you to verify your identity before we fulfill your request.

• Access, correct or erase - You have the right to access, correct, or erase your personal data and the right to restrict their processing, as well as the right to data portability.
• Withdraw consent - If we process your data based on your consent, you have the right to withdraw your consent at any time.
• Complaint - Pursuant to Art. 77 GDPR, you, as a data subject, have the right to file a complaint with a supervisory authority of the EU Member State in which your permanent place of residence, place of work, or in which there was an alleged violation of your information privacy.

In case some questions about the protection of your personal data remain, you can contact us via privacy@koronapay.eu.

How we protect your data

We secure your personal data on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal data in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your personal data, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Policy Amendment

From time to time, we may change this policy and adopt its new version. In the event of significant changes in data processing terms, such as those concerning the nature or means of processing, we will notify you about changes before they become effective.

Contact details

You can address all your questions concerning our privacy practices to privacy@koronapay.eu.