1. Valuing Customers’ trust and understanding the importance of ensuring the confidentiality of Customers’ Personal Data, as well as that of the Informational Materials posted by Customers on the Website in the course of fulfilling the provisions of the Terms and Conditions, the Administrator puts into effect this Policy to define the order for performing operations involving the Parties’ Confidential Information when using the Website and the System’s Services.

2. Every Customer should be familiar with the terms of this Policy before starting to use the System's Services.

The following words and phrases shall be used in the meanings as specified below:
2.1. Cookie is a piece of Data that does not contain any Personal Data, which is created by the Website and stored on the Customer’s computer as one file or multiple files. If the Customer chooses to block a Cookie file, the Customer may experience difficulty or find it impossible to use the Website.
2.2. Informational Materials (Data) are any text, graphic, audio, video, and mixed-type materials of informational nature.
2.3. Confidential Information is any information that is not Public Data, which is considered confidential under the Parties’ agreement or in accordance with the applicable laws.
2.4. Confidentiality is accessibility of information solely to its owner, as well as any parties to which such information can and/or must be provided under law and/or under agreement with this party.
2.5. Public Data is any data (including Personal Data) to which the owner of such data provides access to an unlimited number of parties (including by means of publishing data on any website without restricting access to such data) or to which, in accordance with this Appendix and/or the effective laws, confidentiality requirements do not apply.
2.6. Personal Data is any information related, directly or indirectly, to a specific or identifiable individual person (the subject of personal data).
2.7. Receiving Party is the Party receiving Confidential Information.
2.8. Compromise of Confidential Information is one of the Parties’ actions or inaction resulting in the Confidential Information becoming known or available to third parties without the permission of the owner of such confidential information. The format of the information compromise (orally, in writing, via any technical devices, etc.) is immaterial.
2.9. Disclosing Party is a Member, in relation to the Confidential Information disclosed by the Administrator; and, it is the Administrator, in relation to the Confidential Information disclosed by a Member.
2.10. Disclosure of Confidential Information is transfer to any third party of any Confidential Information in compliance with the requirements of this Appendix, including leaking, stealing, losing, distorting, corrupting, destroying, modifying, copying, or blocking Confidential Information resulting from failure to comply or improper compliance with the terms of this Appendix by the Receiving Party.
2.11. The terms that are not defined in this section shall be used further in the text in the meanings as specified (in the order of priority) in bilateral agreements signed by the Parties and in the current version of the Terms and Conditions approved by the Administrator and all Appendixes thereto.

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3. Collection of information

3.1. OkPay can gather and process the following information about the Customer:
3.1.1. Customer’s full first name and last name, address, email address, phone number, date of birth, bank or payment card details, as well as the documents confirming the Customer’s identity and residence address, to be provided on our request;
3.1.2. Information related to the Transactions performed by the Customer through the System with the use of the Wallet and to the execution of the Customer’s Orders;
3.2. For the purpose of fulfilling mandatory legal obligations related to anti-fraud and anti-money laundering requirements, OkPay have a right to request some information related to the Customer About big operations suspected of not representing a purchase or commercial operation, at any other time when OkPay may deem it necessary to prevent fraud and minimize financial risks.
3.3. During the Customer’s Registration in the System and when the Customer is creating a Wallet, the Customer has to provide their Authorization Data, as well as other details (mandatory or optional). After the Customer has created and used their Wallet, OkPay is able to identify the Customer every time this Customer uses the System and visits the Website.
3.4. OkPay may install cookies to Customers’ computers (unless the Customer purposely restricts this option in their browser), as well as receive, store, process, and use the information created through cookies.
3.5. When the Customer visits the Website, OkPay automatically stores, processes, and uses the Customer’s data that is not their Personal Data, for example: Customer’s IP address, Customer’s location identifiable with their IP address, Customer’s computer’s technical parameters, presence or absence of specific software on the Customer’s computer, such software’s settings, cookies, as well as statistics on the Customer’s activities.
3.6. Besides visiting the Website, the Customer also provides information to OkPay when using the System (if possible) via applications for mobile devices, social media applications, payment terminals, etc., contacting and submitting requests by phone, mail, email, or via other means of communication; OkPay also receives information about the Customer from other sources when verifying the information previously provided by the Customer.

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4. Use Of information

OkPay use the available information related to Customers for the following purposes:
4.1. rendering services related to Customers’ Wallets and providing services requested by Customers.
4.2. executing Customers’ Orders related to Money Transfers and receiving Payments, as well as making Transactions using the Services;
4.3. notifying Customers of changes in the Services, the System, the Terms and Conditions, the Software, etc.
4.4. fulfilling the requirements of the applicable laws and regulations, in particular, those related to anti-money laundering laws and KYC (Know Your Customer) procedures.
4.5. Check the customer's identity and adress
4.6. carrying out verification procedures to prevent fraud and money laundering.
4.7. providing services to Customers, including responding to Customers’ questions, requests, comments, and Complaints.
4.8. increasing the security of the Services.
4.9. providing the Website’s content (including its interactive features) in a way that is most efficient for Customers and their computers.
4.10. providing to Customers products and services requested, or products and services that OkPay believes may interest Customers.
4.11. providing assistance in the development, provision, and improvement of the System’s Services, as well as providing the Website’s content and informing Customers.
4.12. carrying out OkPay internal procedures and processes, such as audits, analytical data processing, quality assessment as to the Services provided, etc.