Privacy Policy

Effective Date: February 25, 2026

1. Introduction

Welcome to SiraPay ("we," "our," or "us"). SiraPay provides private virtual card services for secure and flexible online payments worldwide. This Privacy Policy describes how we handle your personal information when you use our mobile application, website (www.sirapays.com), and related services (collectively, the "Services").

By using SiraPay, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

2. Information We Collect

2.1 Information You Provide to Us

We collect information that you voluntarily provide when using our Services, including:

• Account Registration Information: Name, email address, phone number, date of birth, and other identification information required for account creation and verification.
• Financial Information: Payment card details, bank account information, cryptocurrency wallet addresses, and transaction history necessary to provide our virtual card services.
• Identity Verification Information: Government-issued ID, proof of address, and other documents required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
• Communication Data: Information you provide when you contact our customer support, participate in surveys, or communicate with us through any channel.

2.2 Information Collected Automatically

When you use our Services, we automatically collect certain information, including:

• Device Information: Device type, operating system, unique device identifiers, mobile network information, and device settings.
• Usage Information: Features you use, actions you take, time and duration of your activities, and other usage statistics.
• Location Information: Approximate location based on IP address and, with your permission, precise location data from your device.
• Log Data: IP address, browser type, access times, pages viewed, and the page you visited before navigating to our Services.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information and improve our Services.

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Identity verification services and fraud prevention providers
• Payment processors and financial institutions
• Marketing and analytics partners
• Public databases and credit bureaus (where permitted by law)

3. How We Use Your Information

We use the information we collect for the following purposes:

• Provide and Maintain Services: Create and manage your account, process transactions, issue virtual cards, and deliver the core functionality of SiraPay.
• Verification and Security: Verify your identity, prevent fraud, detect and prevent security incidents, and comply with legal obligations including KYC and AML requirements.
• Customer Support: Respond to your inquiries, provide technical support, and resolve issues you may encounter.
• Improve Our Services: Analyze usage patterns, conduct research and development, and enhance the user experience.
• Communications: Send you service-related notifications, updates, security alerts, and administrative messages.
• Marketing: With your consent, send you promotional materials, special offers, and news about our Services (you can opt out at any time).
• Legal Compliance: Comply with applicable laws, regulations, legal processes, and enforceable governmental requests.
• Business Operations: Manage our business operations, including internal audits, data analysis, and business planning.

4. How We Share Your Information

We respect your privacy and do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Payment processors and card network providers
• Identity verification and KYC/AML compliance services
• Cloud hosting and data storage providers
• Customer support and communication platforms
• Analytics and marketing service providers

4.2 Financial Institutions and Partners

We share information with banks, payment networks, and other financial institutions necessary to provide virtual card services and process your transactions.

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to:

• Legal processes (such as subpoenas or court orders)
• Government or regulatory authorities
• Law enforcement requests
• Protection of our rights, privacy, safety, or property

4.4 Business Transfers

If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction.

4.5 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

5. Data Security

We implement robust security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security practices include:

• Encryption of sensitive data in transit and at rest
• Secure socket layer (SSL) technology for data transmission
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Employee training on data security and privacy
• Monitoring and logging of system activities

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services and fulfill the purposes described in this Privacy Policy
• Comply with legal, regulatory, tax, and accounting obligations
• Resolve disputes and enforce our agreements
• Maintain security and prevent fraud

When your information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.

7. Your Rights and Choices

Depending on your location and applicable laws, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information, subject to legal retention requirements.
• Portability: Request a copy of your information in a structured, machine-readable format.
• Objection: Object to the processing of your information for certain purposes.
• Restriction: Request restriction of processing under certain circumstances.
• Withdraw Consent: Withdraw your consent for processing where we rely on consent as the legal basis.
• Opt-Out of Marketing: Unsubscribe from promotional communications at any time.

To exercise these rights, please contact us using the information provided in the Contact Us section below.

8. International Data Transfers

SiraPay operates globally and may transfer your personal information to countries other than the one in which you reside. These countries may have different data protection laws than your home country. When we transfer your information internationally, we implement appropriate safeguards to protect your information in accordance with this Privacy Policy and applicable laws.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected information from a child without parental consent, we will take steps to delete that information.

10. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before providing any personal information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy in our app and on our website
• Updating the "Effective Date" at the top of this policy
• Sending you an email or in-app notification (for significant changes)

Your continued use of our Services after any changes indicates your acceptance of the updated Privacy Policy.

12. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies to enhance your experience and collect information about how you use our Services. You can control cookies through your browser settings, but disabling cookies may limit your ability to use certain features of our Services.

13. Your California Privacy Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your information, and the right to opt-out of the sale of your information (note: we do not sell personal information). To exercise these rights, please contact us.

14. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR), including the rights described in Section 7 above. Our legal basis for processing your information includes:

• Contract Performance: Processing necessary to provide our Services
• Legal Obligations: Processing required to comply with legal requirements
• Legitimate Interests: Processing necessary for our legitimate business interests
• Consent: Processing based on your explicit consent

15. Contact Us

16. Dispute Resolution

If you have a concern about our privacy practices, please contact us first. We will investigate and attempt to resolve complaints and disputes in accordance with this Privacy Policy. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority.