Privacy Policy

Euroxen Pay is a commercial and technology brand used in connection with a network of independent entities, technology companies, financial service providers, payment providers and other service partners operating across different jurisdictions. The network may involve entities and service providers located or operating across Europe, the Americas and other international markets.

References to “Euroxen Pay”, “Euroxen”, “we”, “us” or “our” on the Website are used for commercial presentation and convenience. They should not necessarily be interpreted as meaning that a single legal entity controls or provides every service presented under the Euroxen Pay brand.

For Website-related processing described in this Privacy Policy, the Website Operator is responsible for the processing unless otherwise indicated.

Where an enquiry progresses into onboarding or a commercial relationship, additional Euroxen Pay entities or service providers may become involved and may act as independent controllers, joint controllers, processors or service providers depending on the particular arrangement. The relevant contractual and privacy documentation may provide further information in such cases.

This Privacy Policy applies primarily when you:

• visit euroxenpay.com
• submit a contact form
• request information about Euroxen Pay
• request a meeting
• communicate with us regarding potential services
• provide business contact information
• interact with Website functionality
• otherwise communicate with the Website Operator in connection with the Website

The Website is intended primarily for business and professional users.

This Privacy Policy does not necessarily govern all processing carried out after a business enters into a separate agreement with an entity within the Euroxen Pay network. Additional terms may apply to merchant accounts, payment processing, onboarding, transaction processing, dashboards, APIs or other services.

Depending on how you interact with the Website, we may collect the following categories of personal data.

You should provide only information reasonably necessary for your enquiry.

Unless specifically requested through an authorised onboarding process, you should not submit sensitive documents or confidential financial information through a general Website contact form. General Website forms are intended primarily for initial business enquiries.

If additional documentation is required for onboarding, KYB, compliance or contractual purposes, appropriate submission channels or instructions may be provided separately.

We may process personal data for purposes including:

Where the EU General Data Protection Regulation (“GDPR”), UK GDPR or another law requiring a legal basis applies, personal data may be processed on one or more of the following bases.

The Website is directed toward business and professional users.

Where you provide business contact information, we may use that information to respond to your enquiry and conduct relevant business communications. We may also retain appropriate records of communications for business administration, security, compliance and legal purposes.

Marketing communications will be handled in accordance with applicable electronic communications and direct marketing requirements. Where legally required, recipients will be provided with an appropriate method to opt out of marketing communications.

An important part of the Euroxen Pay model is that different entities and providers may be involved depending on the requested service and customer circumstances. Information submitted through the Website may therefore be shared with relevant entities or service providers within the network where reasonably necessary to evaluate or progress an enquiry.

This may occur based on factors such as:

• customer jurisdiction
• requested service
• industry
• currencies
• payment methods
• settlement requirements
• technical requirements
• transaction profile
• regulatory considerations
• risk assessment
• provider availability

Information will not necessarily be shared with every participant in the Euroxen Pay network. It should be shared only where there is a relevant business, operational, contractual, legal, technical or compliance reason for doing so.

We may disclose personal data to third parties that support the Website or potential business relationship. Depending on the circumstances, recipients may include:

• hosting providers
• cloud infrastructure providers
• IT providers
• cybersecurity providers
• communication providers
• CRM providers
• analytics providers
• professional advisers
• identity verification providers
• KYB/KYC providers
• compliance providers
• payment service providers
• payment processors
• banks and financial institutions
• card acquiring providers
• digital asset service providers
• liquidity providers
• technology partners
• other providers necessary for the requested service

A particular provider will receive information only where relevant to its role and subject to applicable legal and contractual requirements.

Submitting an enquiry through the Website does not itself constitute formal onboarding.

Where a prospective customer wishes to proceed, additional information may subsequently be requested for purposes including:

• business verification
• beneficial ownership verification
• director verification
• identity verification
• sanctions screening
• AML checks
• fraud prevention
• risk assessment
• source of funds or source of wealth assessment where applicable
• regulatory compliance
• contractual onboarding

Such processing may be performed by the relevant Euroxen Pay entity, a third-party provider, or both. Where appropriate, additional privacy information will be provided as part of that process.

Certain third-party providers may process personal data as independent data controllers rather than solely on our instructions. For example, depending on the service arrangement, this may apply to certain:

• banks
• regulated payment providers
• financial institutions
• acquiring institutions
• identity verification providers
• digital asset providers
• other independently regulated service providers

Such providers may be legally required to conduct their own verification, monitoring, recordkeeping or compliance activities. Their processing may be subject to their own privacy notices and legal obligations.

Euroxen Pay operates through an international network.

As a result, personal data may be processed or accessed in countries other than the country in which it was originally collected. Relevant entities and service providers may be located in Costa Rica, Europe, the Americas and other jurisdictions.

Where personal data subject to GDPR, UK GDPR or similar transfer restrictions is transferred internationally, appropriate safeguards will be used where required by applicable law. Depending on the circumstances, such safeguards may include:

• adequacy decisions
• standard contractual clauses
• recognised contractual safeguards
• legally permitted transfer mechanisms
• another lawful basis for the transfer

The specific transfer mechanism may depend on the entities and service providers involved.

Personal data will be retained only for as long as reasonably necessary for the purpose for which it was collected or where retention is required for legal, regulatory, security or legitimate business purposes. Retention periods may vary depending on the nature of the information. For example:

General enquiries

may be retained for a reasonable period to respond to the enquiry and maintain appropriate business records.

Commercial discussions

may be retained while a potential business relationship remains active and for an appropriate period thereafter.

Security records

may be retained where necessary to investigate incidents or protect Website infrastructure.

Contractual and compliance records

may be subject to longer retention requirements where a business relationship is established.

Where a separate customer relationship is established, the applicable agreement or privacy notice may provide additional information concerning retention.

We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, unlawful disclosure, alteration, destruction and misuse. Security measures may include, where appropriate:

• access controls
• authentication controls
• encryption
• secure communications
• infrastructure monitoring
• logging
• vulnerability management
• backups
• security reviews
• restrictions on internal access

No Internet-based system can be guaranteed to be completely secure. Accordingly, while reasonable safeguards are maintained, absolute security cannot be guaranteed.

Depending on your jurisdiction and applicable law, you may have rights concerning your personal data. These may include the right to:

• request access to personal data
• request correction of inaccurate information
• request deletion of personal data
• request restriction of processing
• object to certain processing
• withdraw consent
• request data portability where applicable
• lodge a complaint with an applicable data protection authority

These rights are not absolute and may be subject to legal exceptions, regulatory obligations and verification requirements.

Where the GDPR or UK GDPR applies to the processing of your personal data, you may exercise the applicable rights granted under those laws.

Where processing is based on legitimate interests, you may have the right to object to such processing based on circumstances relating to your particular situation. Where personal data is processed for direct marketing purposes, you may have the right to object to such processing at any time.

Requests can be submitted to contact@euroxen.com. We may need to verify your identity before processing a request.

If you believe your personal data has been processed improperly, you may contact us first at contact@euroxen.com.

Depending on your location and applicable law, you may also have the right to submit a complaint to the competent data protection or supervisory authority.

Nothing in this Privacy Policy is intended to restrict statutory rights available under applicable data protection law.

The Website may use cookies and similar technologies.

Some cookies may be necessary for security and Website functionality, while optional technologies may be used for analytics, functionality or marketing purposes. Where required by applicable law, optional cookies will be activated only after the necessary consent has been obtained.

Further information is available in our Cookie Policy.

The general Website and contact process is not intended to make decisions producing legal or similarly significant effects solely through automated processing.

Where automated systems are subsequently used as part of onboarding, fraud prevention, compliance, transaction monitoring or service delivery, additional information may be provided where required by applicable law.

The Website may contain links to external websites and third-party services.

The Website Operator is not responsible for the privacy practices of independently operated third-party websites. Visitors should review the privacy information provided by the relevant third party before providing personal information.

The Website and the services presented through Euroxen Pay are intended for businesses and professional users. They are not directed toward children.

We do not knowingly seek to collect personal data from children through the Website for the purpose of providing Euroxen Pay business services.

Personal data may be transferred where reasonably necessary in connection with a merger, acquisition, restructuring, financing, sale of assets, corporate reorganisation or similar transaction involving the Website Operator or relevant business operations.

Any such processing will remain subject to applicable data protection requirements.

We may disclose information where reasonably necessary to:

• comply with applicable law
• comply with a court order or legally binding request
• respond to competent authorities
• investigate suspected fraud or unlawful activity
• enforce legal rights
• establish, exercise or defend legal claims
• protect our systems and infrastructure
• protect the rights and legitimate interests of Euroxen Pay, its network participants, providers, customers or others

Requests from authorities will be assessed in accordance with applicable legal requirements.

We may update this Privacy Policy from time to time to reflect changes to:

• the Website
• our organisational structure
• the Euroxen Pay network
• service providers
• data processing activities
• technologies
• applicable legal requirements

The current version will be published on the Website with the applicable “Last Updated” date. Material changes may be communicated through additional means where required by applicable law.

This Privacy Policy primarily concerns the Website and initial business communications.

If a business proceeds with Euroxen Pay services, the relevant contracting entity or service provider will be identified during the onboarding and contracting process. Additional privacy notices, data processing agreements or contractual provisions may apply. Those documents may contain more specific information regarding:

• the relevant data controller
• processors
• payment data
• transaction data
• KYB/KYC information
• compliance processing
• fraud monitoring
• retention periods
• international transfers
• statutory or regulatory obligations

Where a service-specific privacy notice applies to a particular processing activity, that notice should be read together with this Website Privacy Policy.

For questions regarding this Privacy Policy or the processing of personal data in connection with the Website, please contact: