This Privacy Policy (the “Policy”) sets out how Banxis Limited a company incorporated and existing under the laws of the Republic of Cyprus with registration number HE 451283 (“Banxis” or “ we” or “us” or “our” or “Company”) processes data, whether on individuals (including personal data in respect of individuals who are clients, intermediaries or other third parties that the Company interacts with, or any individual who is connected to those parties) or otherwise. Where the data held are on individuals, this document also sets out the rights of those individuals in respect of that personal data.

“You” in this Privacy Policy may refer to a Visitor and/or User of our website and/or Dashboard (the “Visitor” or “User” or “Client”), who intends to use or already uses, directly or indirectly, our products or services including inter alia any shareholders, beneficial owners, principals, directors, staff members, merchants and customers of merchants accessing our website available at www.banxis.com (the “Website”).

This Policy has been prepared in accordance with the provisions of the EU General Data Protection Regulation (“GDPR”). Any questions relating to this Policy or requests in respect of personal data should be directed to our Data Protection Officer (DPO) at dpo@banxis.com.

Banxis Limited is a registered E-money Distributor ( the “EMD”) with the Central Bank of Cyprus (the “CBC”) and its authorized to distribute and redeem Electronic Money on behalf of SURESWIPE EMI PLC an Electronic Money Institution (“EMI”) under the licence 115.1.3 26/2018.

We collect the following information:

1. Information and documentation that You provide by filling in the necessary fields on our Website and/or Dashboard and/or via an Application form available at our Website. Such information may include but is not limited to Your name, surname, e-mail address, telephone number, website, and other information which You provide;

2. Information and documentation that You as a Visitor and/or User and or/Client provide to us in order to conclude an agreement. Such information may include, but is not limited to, Your name, date of birth, home, work or other physical address, country, telephone number, e-mail address, company name, company number, current position, passport or ID data, utility bill and/or proof of address, corporate documents of the company, payment account number, business bank statement, information regarding the beneficial ownership in other companies;

3. A record of correspondence / communication and/or the telephone call in the event You contact us. Such record may include Your name, surname, e-mail address, telephone number, name of Your company and other personal data You may disclose to us during such communication;

4. Where You as a Visitor and/or User and/or Client have been granted access to the Dashboard – details of Your visits, including, but not limited to, location data, weblogs, other communication data and the resources that are accessed by You;

5. Where You as a User and/or Client use the Dashboard in order to utilize the offered Services – Your personal data, including, but not limited to, name, surname, e-mail address, telephone number, details of Your payment instrument, including, but not limited to information relating to the services, including the location and time of the transaction;

6. Information about You as a Client or as a merchant, which we receive from other sources, including, but not limited to, our business partners, service providers and subcontractors. Such information may include the data provided by the card organisations, payment service providers, credit reference agencies and other third parties, as well as publicly available information.

Banxis is obliged to disclose your personal data to Sureswipe E.M.I. PLC which is an Electronic Money Institution (EMI) licensed by the Central Bank of Cyprus (authorization number 115.1.3.26). Banxis is registered as E-Money Distributors of Sureswipe E.M.I. PLC , authorized Electronic Money Distributors (the “EMD”) of Sureswipe E.M.I. PLC, the electronic money institution (the “EMI”). Banxis and Sureswipe E.M.I. PLC will process your personal data as independent controllers. By accepting this Privacy Policy, you are implicitly accepting the Sureswipe’s Privacy Policy. You can find more information with respect to the processing of your personal data by Sureswipe E.M.I. PLC in Sureswipe’s Privacy Policy at the following link:

https://revsto.com/wp-content/uploads/Revsto-Privacy-Statement-2023.pdf

We work with third-party service providers to help us operate, provide, improve, customize, and support our Services. Information might be shared with third-party service providers, affiliates, and partners in order to provide our services to you and meet your needs, which are delivered in a manner that is useful and relevant to you.

We do not sell or otherwise disclose your personal data to third parties, except as described above and in this Policy.

All third parties with which we share personal data are required to protect such information in accordance with all relevant legislation and in a manner similar to the way we protect your personal data. We will not share personal data with third parties which we consider that they will not provide you the required level of protection.

Where we need to comply with our legal obligations under laws and regulations or under the terms of a contract and you fail to provide any requested personal data, Banxis may not be able to accept you as a Client or continue our business relationship and will inform you in this regard.

We may also collect non-personal information about You, which does not identify You as a specific individual. Such non-personal information that we may collect includes:

1. Browser and device data, for instance, IP address, operating system and browser type. This is statistical data about the Website users’ browsing actions and patterns and does not identify any individual;
2. Cookie data, such as time spent on the Website, pages visited, language preferences, and other anonymous traffic data;
3. Company data, such as a company’s name, product and service offerings, jurisdiction.

1. How long we keep your information will depend on the purpose for which we use it and so may vary. We will only retain your information for as long as is necessary for the purposes set out in this Privacy Policy and as is necessary to comply with our legal obligations. We do not keep more information than we need for the particular purpose.
2. Where we have provided you with a product or service, we will keep an archived record of your personal data for a period of up to 6 years after termination and/or termination of your account (unless a longer period is prescribed by law) for the purposes of responding to legal disputes and legal or regulatory enquiries or investigations only, but will not use this data for any other purpose.
3. If you ask us to stop sending direct marketing communications to you, we will keep the minimum amount of information necessary (such as your name and email address) to ensure that we are able to adhere to your request. We also routinely seek to minimise the amount of personal data we hold where any marketing contact is deemed inactive. We deem a contact to be inactive if we have not been able to identify any engagement (e.g. through opening an email or visiting our website) for a period of 12 months or if an email is not delivered due to a hard bounce. In such circumstances we will anonymise all relevant data for aggregation purposes, with the exception of an email address.

1. We use Your personal data in order to provide our services/products to You, in the capacity of a Client and/or User of our Website and/or Dashboard, and to respectively conclude contracts and carry out our contractual obligations. In this regard, we rely on a contract entered into by You and Banxis as the valid ground for the processing of Your personal data.
2. We use Your personal data to enable You, in the capacity of a Client, to make use of our services/products which we provide to the Merchant. In this regard, we rely on the legitimate interests pursued by us.
3. We are also required by law to constantly carry out various activities for the prevention of fraud, money laundering and terrorism financing, as well as for compliance with other legal obligations. In this regard, we rely on the necessity to comply with legal obligations as the valid ground for the processing of Your personal data.
4. In addition, we process personal data in order to carry out various marketing activities and in this regard, we rely on Your consent as the valid ground for the processing of Your personal data.
5. Examples of how we may use Your personal data include:
   1. to verify Your identity for legal and/or compliance purposes;
   2. in order to start the onboarding process, including the review and approval of the Compliance team based on the internal policies of Banxis;
   3. to provide You with information, products or services requested from us;
   4. to provide You with information, which we feel may interest You, provided that You have consented to be contacted for such purposes;
   5. to notify You about changes to our products or services;
   6. to process transactions/payments;
   7. to ensure that content from the Website is presented in the most effective manner and to keep our Website safe and secure;
   8. to allow You to use interactive features of our Website;
   9. to administer our Website;
   10. to conduct monitoring against any possible fraud, money laundering, terrorism financing or crime risks;
   11. to respond to Your inquiries and provide customer support;
   12. to conduct market research and carry out marketing activities.

1. You have the right to decide whether we can process your personal data for general marketing purposes. We will ask for your consent in advance if we intend to use your personal data for marketing purposes or if we intend to disclose your personal data to any third party for such purposes. You can withdraw a consent given for the use of your personal data for marketing purposes at any time.
2. Besides, we may use your personal data for direct marketing purposes (e.g. to inform you about our products or services similar to those you have purchased from us) based on our legitimate interests. You can ask us to stop using your personal data for direct marketing purposes at any time.
3. You are also able at any time to withdraw any consent to receive marketing communications that you have given to us. You can do this by contacting us at marketing@banxis.com or by writing to us at: Banxis Ltd, 58 Agios Athanasios Avenue, El Greco Building, 2nd Floor, Office 202, 4102, Limassol, Cyprus
   Please provide us with your full name, address and other contact details to enable us to find your records. Sometimes we may also need to contact you further to ask you for additional information so that we can comply with your request.

When we process your personal data under this Policy, you have the right to require us to:

1. provide you with further details on the use we make of your information;
2. provide you with a copy of your personal data that we hold;
3. update any inaccuracies in the personal data we hold;
4. delete any personal data that we no longer have a lawful ground to use;
5. where processing is based on consent, withdraw your consent so that we stop that particular processing;
6. object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
7. restrict how we use your information whilst a complaint is being investigated;.
8. not be subject to profiling or decisions based on automated decisions that could result in adverse effects; and
9. transfer your personal data to a legitimate party of your choice, if possible, in a readily usable format.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

To effectively run Our Service, We must partner with third parties and, therefore, We may exchange Your data with:

1. Payment account providers ("Partners");
2. Third parties and service You choose to Use in connection with the services;
3. Our trusted data aggregation Partners;
4. Potentially, other third parties, if we have to do so to fulfil our legal obligations.

The security of your personal information is important to Us. We take legal, technical and organizational measures that it considers necessary in order to maintain the confidentiality and security of your personal information, with due regard to the applicable obligations and exceptions under the legislation in force.

Banxis regularly reviews its policies regarding the collection, storage and processing of your personal information, including physical security measures, to prevent alteration, loss, query, use or fraudulent or unauthorized access of your personal information.

Banxis has put in place procedures to deal with personal information breach and will notify you and any applicable regulator or authority of a breach where we are legally required to do so.

Please refer to our cookie policy which is available at our Website. We will not share Your cookies with third parties, without Your authorization.

We may change or update this Privacy Policy. Any changes we may make to this Privacy Policy in the future will be posted on the Website and any such changes will be effective starting from the date when we post the revised Privacy Policy.

We may provide You with notifications regarding the changes in the Privacy Policy by posting them on our Website.

Questions, comments and requests regarding this Privacy Policy should be addressed to support@banxis.com. Alternatively, you can write to us at: BANXIS LTD, 58 Agios Athanasios Avenue, El Greco Building, 2nd Floor, Office 202, 4102, Limassol, Cyprus.