1. Data controller
The data controller is Eurosia Systems OÜ, registered in Estonia, registry no. 16523847.
Data Protection Officer: info@eurosiapay.com.
2. What data we collect
- Identity data: name, date of birth, nationality, government ID, selfie/liveness for KYC.
- Contact data: email, phone, residential address.
- Transactional data: deposits, withdrawals, payments, merchant details, blockchain transaction hashes.
- Device & usage data: IP address, device identifiers, operating system, in-app activity for fraud and security.
- Communications: support tickets, chat logs, recorded calls (where permitted).
3. Why we process it
- To create and operate your EurosiaPay account.
- To comply with AML/CFT, KYC, MiCA, Travel Rule and tax laws.
- To detect and prevent fraud, money-laundering and abuse.
- To provide customer support and product communications.
- To improve the service and statistical reporting (aggregated).
4. Legal bases (GDPR Art. 6)
- Performance of a contract — to deliver the EurosiaPay service.
- Legal obligation — financial supervision, AML, tax.
- Legitimate interests — fraud prevention, security, and improvement, balanced against your rights.
- Consent — for optional marketing or non-essential cookies.
5. Sharing
We share data only with: (a) our regulated banking, EMI, custody, Travel Rule and KYC partners; (b) auditors, regulators and law enforcement when legally required; (c) cloud and analytics providers bound by data-processing agreements.
International transfers are protected by EU Standard Contractual Clauses or equivalent safeguards.
6. Retention
Account and transactional records are retained for at least 5 years after account closure, in line with EU AML obligations. Marketing data is deleted within 12 months of last interaction or upon withdrawal of consent.
7. Your rights
- Access, rectification, erasure (subject to legal retention).
- Restriction and objection to processing.
- Data portability for data you provided.
- Withdraw consent at any time for consent-based processing.
- Lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your local supervisory authority.
8. Security
We use end-to-end TLS, encryption at rest, MPC custody, hardware security modules, and continuous monitoring. Access is restricted on a need-to-know basis and subject to audit logs.
9. Contact
Privacy queries: info@eurosiapay.com.
If you have questions about this document, contact info@eurosiapay.com or write to Eurosia Systems OÜ, Tornimäe tn 7, 10145 Tallinn, Estonia.