Privacy Policy

We want to thank you for choosing and using the Application. The Application provides you with a variety of payment services to help you make payments, transfers and other transactions quickly and conveniently. In particular, the Application allows you to open a payment card, recharge a payment card, make payments and transfers and perform other transactions with a payment card under the terms and conditions set forth by the payment card issuer. In the process of using the Application, You are entrusting Us with Your User Data specified in the Policy. Given the confidential nature of your User Data, We take measures, in accordance with Applicable Law, to ensure its security and confidentiality. We collect and process your User Data in accordance with Applicable Law.


Please read this Policy carefully before using the Application, as it defines which User Data We Collect and Process, how We Collect and Process Your User Data, why We Collect and Process Your User Data and other matters relevant to You. By installing and using the Application, you agree to this Policy.


1. What kind of User Data We Collect and Process


User Data


We, through the Application, collect and process a variety of User Data as part of your registration, identification and verification on the Application, and as part of your use of the Application. These data include your surname, first name, patronymic, personal identification number, birth data (date and place of birth), citizenship, nationality, residency, gender, identification document data, facial photographs and video footage of your identity document, legal and residential address, contact data, your means of identification (logins, passwords, codes), payment card data (including in token form), data obtained during payment and other service provision, data on


Personal and Confidential User Data


Some of the above User Data is Personal and Sensitive User Data, which is collected and processed under the specific conditions set forth in the Policy.


We, through the Application, Collect and Process the following Personal and Sensitive User Data, including for purposes that may not meet users' reasonable expectations of the Application:


1) User Identification, financial, payment and credential data (your last name, first name, middle name, individual identification number, birth data (date of birth and place of birth), citizenship, nationality, residency, gender, identity document data, photos of the person and a video of the person, your identity document, legal address and address of residence, contact information, your identification means (logins, passwords, codes), payment card data (including in form t
2) your phone book and contacts stored in your mobile device to ensure that your phone number is auto-filled in the "Share" menu when you issue a new card;
3) your mobile device's camera data and file data stored on your mobile device to ensure that a photo is attached as a user image in the "Profile" menu;
4) confidential device information (model and other identification data of your mobile device, your cellular subscriber number) to enable you to use the Application, improve the performance of the Application and ensure the security of the use of the Application. The Collection and Processing of Personal and Sensitive User Data is limited and carried out in accordance with the Applicable Law and the rules in force with Us. It is collected and processed only for the purposes set forth in the Applicable Law and Policy.


2. How We Collect and Process User Data


We collect the User Data in the process of using the Application (your registration identification and verification in the Application as well as in the process of using the Application). In the process of using the Application, You, on Your own or in response to Our requests (by entering information, attaching files), transmit Us the User Data. In some cases, the App itself reads and transmits to Us the User Data relating to sensitive device information.


We process the User Data on our own without the involvement of third parties.


During the Collection and Processing, We use licensed software and certified equipment to ensure the protection of the User Data.


The Collection and Processing of Personal and Sensitive User Data is permitted only for the purposes of:


1) the use of the Application;
2) that do not violate the expectations of users and as provided in the Policy and other contracts entered into with the user.
We do not transfer User Data to third parties. Exceptions are as follows:
1) the transfer is required by Applicable Law (e.g., at the request of government and regulatory agencies, officials and regulators) or authorized by You;
2) the transfer is made to providers providing services to Us (e.g., Our affiliates and other fiduciaries for processing related to the purposes set forth in the Policy);
3) there is a merger or sale transaction involving Us.


The Application and other software and hardware tools used by Us have safeguards in place to ensure the security of User Data. We collect and analyze information in connection with the Application and such other software and hardware that enables Us to identify, assess and correct security problems and to prevent similar problems from occurring. In addition, We take measures to protect You against the illegal Collection and Processing of User Data. Specifically, we take the following measures:


1) We use encryption during the Processing of User Data;
2) improving the methods of Collection and Processing of User Data;
3) Distribute the levels of access to User Data among Our employees and Our service providers;
4) Require all of Our employees to comply with the security and confidentiality of User Data.


3. Why We Collect and Process User Data


Through the Collection and Processing of User Data, We can:


1) provide you with access to the payment services you need;
2) maintain and improve the payment services We provide;
3) Create new payment services;
4) ensure the security of Our services and users;
5) fulfill the obligations imposed on Us under Applicable Law.


User Data allows You to access the necessary payment services


Under Applicable law, We are obliged to obtain a set of User Data from you before granting you access to payment services. By obtaining these User Data we are able to provide you with access to our payment services.


User Data enables Us to maintain and improve the payment services that We provide.


We use User Data to maintain the stability of the Application and to communicate with You. For example, We may use User Data to notify you of scheduled maintenance that affects your ability to access payment services. We may also use User Data to contact you in the event of unauthorized transactions with your payment cards.


Also, User Data helps us understand your needs and facilitate your use of Our Application.


User Data allows us to create new payment services


We are able to create new payment services with the User Data we receive.


User Data helps us ensure the security of Our services and users


The User Data We collect and Process is important to ensure the security of Our services and users. Through User Data, We can determine whether a payment card transaction is authorized, identify and block threats to prevent unauthorized transactions that could harm You and the public interest.


User Data enables Us to fulfill obligations imposed on Us under Applicable Law


The User Data We collect and Process is important in order to comply with obligations imposed on Us by decisions of government bodies, regulatory authorities, officials and commissioners.


4. Other provisions


If You have any questions relating to User Data and the Policy, You may contact Us at Our legal address, via Our website and the App.


We may make changes to the Policy at Our discretion. If We do so, We will post the amended Policy on Our resources. We encourage You to periodically check for the most current version of the Policy.


5. Terms and Definitions


You, Your means the person whose User Data We Collect and Process in accordance with the Policy.


User Data means information provided by the user as well as information obtained during the user's use of the Application, including information about the device.


Personal and Sensitive User Data means Personally Identifiable Information, financial, payment and account data, phone book, contacts, call and SMS data, health data, Health and Sports platform data, device location data and list of other applications on the device, microphone and camera data, and other confidential information about the device or its use.


We, Us, Our means SilkSoftGroup LLP, business ID number 180940028838 and S1LK PAY Ltd, business ID number 191040900066, collecting and processing User Data.


Policy means this privacy policy.


App means the "S1LKPAY" cell phone application posted for download and installation on Google Play.


Applicable Law means the law applicable to Us in connection with the Collection and Processing of User Data.


Collection means the act of obtaining User Data.


Processing means activities aimed at accumulating, storing, modifying, supplementing, using, distributing, depersonalizing, blocking, destroying, organizing, searching, adapting, deleting, customizing, combining and performing other activities with User Data.


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