Privacy Policy

1. SCOPE AND DATA CONTROLLER

1.1 Scope

The Services are offered to corporate Merchants, not to individual consumers. This Policy applies to the personal data of individuals connected with a Merchant or a prospective Merchant, such as its directors, beneficial owners, and Authorised Representatives, and personal data of other website visitors (each an "Individual").

1.2 Data Controller

Kaskade Pay is the data controller responsible for personal data processed in connection with the Services, save where we act as a data processor on behalf of a Merchant in respect of that Merchant’s own customers, in which case the Merchant is the data controller for that data and Kaskade Pay processes it under the Merchant’s instructions and applicable service terms.

1.3 Contact Details

Enquiries regarding this Policy or our data processing practices may be directed to legal@kaskade.com or to our registered office set out above.

2. PERSONAL DATA WE COLLECT

We may collect the following categories of personal data:

• Identity data: name, date of birth, nationality, government issued identification documents, and photographs used for identity verification.
• Contact data: email address, telephone number, and postal address.
• Corporate and beneficial ownership data: company registration details, beneficial ownership information, and details of directors and authorised representatives, for KYB purposes.
• Financial and transaction data: wallet addresses, transaction history, source of funds documentation, and Fee payment records.
• Technical data: IP address, device identifiers, browser type, operating system, and log data.
• Usage data: information about how the Site and the Services are accessed and used.
• Communications data: records of correspondence with support, legal, or compliance teams.

3. HOW WE COLLECT PERSONAL DATA

We collect personal data directly from Individuals, for example when registering an Account or completing KYC or KYB verification; automatically, through cookies and similar technologies as described in our Cookie Policy; and from third parties, including identity verification providers, blockchain analytics providers, sanctions screening providers, and, where applicable, publicly available sources and corporate registries.

4. PURPOSES AND LEGAL BASES FOR PROCESSING

We process personal data only where we have an appropriate legal basis to do so. We process personal data for the following purposes and on the following legal bases:

• To provide and administer the Services and Accounts (performance of a contract).
• To carry out KYC, KYB, enhanced due diligence, sanctions screening, and transaction monitoring (compliance with a legal obligation, and, where relevant, our legitimate interests in preventing financial crime).
• To detect and prevent fraud and to maintain the security of the Site and the Services (legitimate interests, and compliance with a legal obligation).
• To communicate with Individuals about the Services, including service notices and changes to our policies (performance of a contract and legitimate interests).
• To comply with applicable law, respond to regulators and law enforcement, and enforce our Terms of Service (compliance with a legal obligation and legitimate interests).
• With consent, to send marketing communications and to use non-essential cookies as described in our Cookie Policy (consent).

5. KYC, KYB AND AML PROCESSING

Verification of identity and source of funds is mandatory for use of the Services, as described in Clause 9 of our Terms of Service. Personal data collected for this purpose may be checked against sanctions lists, politically exposed persons databases, and blockchain analytics tools, and may be retained for the periods required by applicable anti-money laundering law even after an Account is closed.

6. SHARING AND DISCLOSURE OF PERSONAL DATA

We may share personal data with:

• Regulators, law enforcement, and courts, where legally required or permitted.
• Identity verification, KYC, KYB, and sanctions screening vendors engaged to perform compliance checks on our behalf.
• Blockchain analytics providers, to screen wallet addresses and monitor transactions.
• Banking partners and liquidity providers, where necessary to facilitate the Services.
• Professional advisers, including lawyers, auditors, and insurers, where necessary for their services to us.
• A successor entity in connection with a merger, reorganisation, or sale of assets, subject to Clause 30 of our Terms of Service.

We do not sell personal data to third parties for their own independent marketing purposes.

7. INTERNATIONAL TRANSFERS

Kaskade Pay is based in the Republic of Panama and works with service providers located in other jurisdictions. Where personal data is transferred outside the jurisdiction in which it was collected, we will take appropriate contractual, technical, and organisational measures to protect that data, and will comply with any specific transfer requirement imposed by a data protection law that applies to the transfer in question.

8. DATA RETENTION

We retain personal data for as long as necessary to provide the Services, to comply with legal, regulatory, and anti-money laundering obligations (which commonly require retention for a minimum period after the end of a business relationship), and to establish, exercise, or defend legal claims. Retention periods vary by category of data and applicable law and are available on request.

9. DATA SECURITY

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorised access, loss, misuse, or alteration, consistent with the security measures described in Clause 16 of our Terms of Service. No system of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. RIGHTS OF INDIVIDUALS

10.1 Rights under Panama Law

Under Panama’s Law 81 of 2019 on Personal Data Protection, Individuals have the right to: access their personal data; request rectification of data that is incorrect, incomplete, or outdated; request cancellation of their data; oppose specific processing activities and withdraw consent at any time, without affecting the lawfulness of processing before withdrawal; and request portability of their data in a structured, commonly used format.

10.2 Rights under Other Applicable Law

Where a data protection law other than Panama’s Law 81 of 2019 applies to the processing of an Individual’s personal data, that Individual may also have rights under that law, and we will honour those rights to the extent they apply to us.

10.3 Exercising Rights

Requests to exercise these rights may be sent to legal@kaskade.com. We may need to verify the identity of the person making the request, and certain rights may be limited where retention or processing is required by applicable anti-money laundering or other law.

10.4 Right to Complain

If we do not respond to a request within the time required by law, or if an Individual otherwise considers that their personal data has been processed unlawfully, they may lodge a complaint or appeal with Panama’s National Authority for Transparency and Access to Information (ANTAI), acting through its Directorate for the Protection of Personal Data, or with any other data protection authority that has jurisdiction over the complaint, without prejudice to any other administrative or judicial remedy.

11. COOKIES

Details of the cookies and similar technologies used on the Site, and how to manage them, are set out in our Cookie Policy.

12. CHILDREN

The Services are a business to business offering for corporate Merchants and are not directed at, offered to, or available for use by, individual consumers or children. We do not knowingly collect personal data from children in connection with the Services.

13. AUTOMATED DECISION MAKING

We may use automated tools, including blockchain analytics and risk scoring systems, to support fraud prevention, transaction monitoring, and sanctions screening. Automated outputs that could produce a legal or similarly significant effect on an Individual, such as an Account suspension, are subject to human review before a final decision is taken.

14. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be notified in accordance with Clause 1.3 of our Terms of Service, and the effective date at the top of this Policy will be updated accordingly.