Last update 5/2/2024

All references to “us”, “we” or “our” apply to Cabbagino Payments LTD, a company registered 319 W Hastings Street, #400, Vancouver, BC, Canada.
For all the issues related to data protection please contact us at: [email protected]

The types of Personal Information we may collect include:


• Contact details (email, telephone number or messenger ID)
• Details of your identity document
• Residence address
• Financial information
• Employment details
• Geolocation details
• History of your logs and activity on the Website
• IP address, browser, and operating system information, device fingerprint.


The majority of the information we gather is provided directly by you. Additionally, we may obtain certain information from publicly available sources, such as sanction lists, or from our contractors. We utilize screening lists supplied by data vendors, identity verification procedures, anti-fraud measures, and transaction monitoring services.



It's important to understand that if you decline to provide the information required to fulfill our KYC/AML requirements, which we communicate to you upon applying for any of our services that necessitate identity verification and ongoing activity monitoring, we will be unable to offer our services to you. Please be aware that there may be instances where we need further details and documentation for KYC and AML/CTF purposes.



Furthermore, please note that the processing of your Personal Data may involve automated decision-making, including profiling. We may employ automated decision-making and profiling for purposes such as onboarding, account maintenance, and fraud prevention.

We handle our clients’ data for the subsequent objectives:


• to provide our services to you, as an individual, or a corporate client you represent;
• to contact you or respond to your inquiries;
• to fulfill our legal obligations, such as KYC/AML requirements;
• to offer assistance in criminal investigations and regulatory proceedings;
• to safeguard your assets from unauthorized access;
• to prevent fraud and scam activities;
• to provide you with information regarding our products, news, and updates;
• to resolve disputes and safeguard your interests or the interests of other users.



The lawful bases we rely on for processing this information are:



Your consent. You can withdraw your consent at any time by reaching us at [email protected];


We have a contractual obligation;


We are legally obliged to adhere to AML/CTF requirements under the relevant laws and regulations, as well as maintain records for tax purposes;


We have a legitimate interest in providing essential updates about our services, proactively and retroactively preventing fraudulent activity, and contacting employees of our clients and business partners.

We might disclose this information to:

• 
our affiliates, agents, and representatives;
• our contractors who supply software for identity verification and anti-fraud purposes;
• our contractors who provide us with information sourced from publicly accessible channels, such as sanction lists;
• our financial service providers through whom we manage fiat currency transactions to and from our services;
• our law enforcement or regulatory agencies as necessitated or permitted by law.

We may transfer your Personal Information under the following circumstances:


• if the country to which we transfer your Personal Information provides an adequate level of personal data protection;
• if we implement appropriate measures to ensure the protection of your rights as a data subject;
• if any exceptions for specific situations apply (such as if the transfer is necessary for the establishment, exercise, or defense of legal claims, or for important reasons of public interest).

We will ensure that any information required for specific purposes is not retained longer than necessary. Your personal data will be retained solely to fulfill our legal obligations, resolve disputes, and protect both your and our legitimate interests.



We will retain your Personal Information for a maximum of seven (7) years following the termination of our legal relationship.



You always have the option to request the removal of your personal data. However, please note that in certain circumstances, we are obligated to retain your information to ensure legal compliance.

According to data protection law, you have the following rights:


• Your right to access – You can request copies of your personal information from us;
• Your right to rectification – You can ask us to correct any inaccurate information or complete incomplete information;
• Your right to erasure – You can request the deletion of your personal information;
• Your right to restriction of processing – You can ask us to limit the processing of your information;
• Your right to object to processing – You can object to the processing of your personal data;
• Your right to data portability – You can request that we transfer the information you provided to another organization or to you.

You are not obligated to pay any fee to exercise your rights. We have one month to respond to your request. If you wish to make a request, please contact us at [email protected]



Please be aware that in certain situations, we may not be able to fulfill your request due to our legal obligations or overriding legitimate interests. In such cases, we will explain the reasons why your request cannot be fulfilled and how you can file a complaint.


We have implemented security measures to comply with acknowledged international security standards. Additionally, our platform also uses SSL or TLS to ensure the security and confidentiality of transmitted requests.

We reserve the right to make changes to the current Policy at any time. Notification of such changes will be provided on our Website or through Email Newsletters.