Privacy Policy
1. About this Policy
[CONFIRM: operating entity and company number], trading as ARMPG ("ARMPG", "we", "us"), respects your privacy. This Policy explains how we collect, use, share, and protect personal information when you visit armpg.com, register for an ARMPG account, or use our crypto payment gateway.
We handle personal information in accordance with the privacy law that applies to us [CONFIRM: governing privacy regime]. Where you are in the EEA, the UK, or another jurisdiction with its own privacy law, we also comply with that law and you may have additional rights (see Section 8).
2. Who We Are
- Legal entity: [CONFIRM: registered company name and number]
- Registered office: [CONFIRM: address]
- Industry: Crypto payment infrastructure
- Contact: privacy@armpg.com
3. Information We Collect
We collect personal information in three ways:
- On the marketing website: your email if you subscribe to the newsletter, and your name, email, and message if you use the contact form (we also record IP address and browser User-Agent to prevent spam and abuse).
- When you register for an account: full name, date of birth, address, contact details, government ID, and a selfie or document images for identity verification (KYC), where we are required to collect them [CONFIRM: applicable AML/CTF regime].
- When you use the Services: transaction details, account activity, device and login data, communications with our support team, and cookies (see Section 9).
- Blockchain data: the wallet addresses we issue to you, the addresses funds are sent from and to, and the transactions between them.
We may also receive information from identity-verification providers, sanctions and PEP screening providers, banking partners, and government agencies where required by law.
4. How We Use Your Information
- To provide, operate, and improve the Services.
- To verify your identity and meet our AML/CTF, sanctions, and tax obligations.
- To process payments, FX conversions, and reconcile transactions with our banking partners.
- To detect and prevent fraud, scams, and abuse of our platform.
- To send transactional alerts, security notices, and (where you have opted in) marketing.
- To comply with legal obligations and respond to lawful requests from authorities.
We do not sell your personal information and we do not disclose it to third parties for their own marketing.
5. Sharing with Service Providers and Authorities
We share limited information with parties who help us deliver the Services:
- Cloud hosting and database providers.
- Identity verification, sanctions and PEP screening, and fraud-prevention vendors.
- Banking partners, payment processors, and blockchain infrastructure providers needed to settle your transactions.
- Blockchain analytics providers, to screen addresses for sanctions and illicit-finance risk.
- Email, SMS, and customer-support tooling.
- Analytics (Google Analytics 4 with IP anonymisation, only when you opt in).
- Regulators and law-enforcement agencies where required by law [CONFIRM: which authorities].
All service providers are bound by confidentiality and data-protection obligations.
6. International Data Transfers
To deliver the Services we transfer personal information to, and process it in, countries other than your own [CONFIRM: list of processing locations]. Where we send personal information overseas we use standard contractual clauses or equivalent safeguards required by applicable law.
6a. Information Published on a Blockchain
Cryptocurrency transactions are recorded on public blockchains. This means the wallet addresses involved, the amounts, and the timing of every transaction are public, permanent, and outside our control. We cannot edit, delete, or anonymise information once it is written to a blockchain, and your right to erasure (Section 8) cannot extend to it.
Blockchain records do not carry your name, but an address can sometimes be linked back to an individual by combining it with other information. Consider this before reusing an address or publishing one alongside your identity.
7. Data Retention
- KYC records, transaction records, and AML/CTF reports: at least 7 years [CONFIRM: retention period required in your jurisdiction].
- Account profile and communications: for the life of the account and 7 years after closure.
- Newsletter subscriptions: until you unsubscribe.
- Marketing-website contact form (including IP and User-Agent): up to 24 months.
- Server logs and analytics: typically up to 14 months.
When we no longer need personal information and are not legally required to keep it, we securely delete or de-identify it.
8. Your Rights
You can request access to the personal information we hold about you, and ask us to correct it if it is inaccurate. If you are in the EEA, the UK, or another jurisdiction with its own privacy law, you may also have rights to delete, restrict, or object to processing, and to data portability. Some rights are limited where we are required by law (for example AML/CTF) to keep records.
To exercise a right, email privacy@armpg.com. We will respond within 30 days.
9. Cookies
We use a small number of cookies and similar technologies. Strictly necessary storage (such as your theme preference and cookie choices) is always set. Analytics and marketing cookies are only set when you opt in. You can change your choices at any time on the Cookie Preferences page.
10. Security and Data Breach Notification
We use industry-standard measures to protect personal information, including TLS encryption in transit, encryption at rest, multi-factor authentication, role-based access controls, and regular security reviews. No system is ever 100% secure. If you suspect your account has been compromised, please email security@armpg.com immediately.
In the event of an eligible data breach we will notify affected individuals and the relevant supervisory authority within the time required by law [CONFIRM: breach-notification regime and authority].
11. Children
Our Services are not directed at, and we do not knowingly accept customers under, the age of 18. If you believe a minor has provided us with personal information, please email privacy@armpg.com.
12. Changes to this Policy
We may update this Policy from time to time. The "Last updated" date at the top will reflect any changes, and where the change is significant we will give you additional notice (for example by email or in-app banner).
13. Contact, Privacy Officer & Complaints
We have a Privacy Officer responsible for this Policy. To contact them or lodge a complaint:
- Email: privacy@armpg.com
- General support: support@armpg.com
- Phone: [CONFIRM: contact number]
- Postal: Privacy Officer, ARMPG, [CONFIRM: address]
We will acknowledge complaints within 7 days and aim to resolve them within 30 days. If you are not satisfied with our response on a privacy matter, you may escalate to the data-protection authority in your jurisdiction [CONFIRM: supervisory authority].