Introduction

Stable Payments Inc. ("Autospend", "we", "our", or "us") is committed to protecting your privacy. This Privacy & Data Policy explains how we collect, use, disclose, store, and safeguard your information when you use our website, platform, and services, including our use of cookies and tracking technologies.

By using Autospend's services, you agree to the collection and use of information in accordance with this Policy. If you do not agree with our policies and practices, please do not use our services.

Information We Collect

Personal Information

We collect personal information that you provide directly to us, including:

• Identity Information: Full name, date of birth, nationality, government-issued ID
• Contact Information: Email address, phone number, physical address
• Business Information: Company name, business registration number, tax ID
• Financial Information: Bank account details, payment card information
• Verification Documents: Proof of identity, proof of address, business licenses

Transaction Information

• Payment transaction details and history
• Wallet addresses and blockchain transaction data
• Transaction amounts, currencies, and timestamps
• Merchant and beneficiary information

Technical Information

We automatically collect certain information when you use our services:

• Device Information: IP address, device type, operating system, browser type
• Usage Data: Pages visited, features used, time spent on platform
• Cookies and Tracking: Information collected through cookies and similar technologies
• Location Data: General geographic location based on IP address

Cookies and Tracking Technologies

What Are Cookies

Cookies are small text files that are placed on your device when you visit our website. They help us provide you with a better experience by remembering your preferences and understanding how you use our services.

Types of Cookies We Use

Essential Cookies

These cookies are necessary for the website to function properly. They enable core functionality such as security, network management, and accessibility.

Performance Cookies

These cookies collect information about how visitors use our website, such as which pages are visited most often. This data helps us improve the performance of our website.

Functional Cookies

These cookies allow our website to remember choices you make (such as your username, language, or region) and provide enhanced, more personalized features.

Targeting/Advertising Cookies

These cookies are used to deliver advertisements that are relevant to you and your interests. They also help us measure the effectiveness of advertising campaigns.

Third-Party Cookies

We may also use third-party cookies from trusted partners to help us analyze website traffic, provide social media features, and deliver targeted advertising.

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

• View what cookies are stored on your device
• Delete cookies individually or all at once
• Block third-party cookies
• Block cookies from specific websites
• Block all cookies from being set

Please note that if you choose to block or delete cookies, some features of our website may not function properly.

How We Use Your Information

Service Provision

• Process and facilitate payment transactions
• Manage your account and provide customer support
• Send transaction confirmations and account notifications
• Provide access to platform features and services

Compliance and Security

• Verify your identity (KYC/KYCB requirements)
• Comply with AML/CFT regulations and legal obligations
• Detect, prevent, and investigate fraud and illegal activities
• Monitor transactions for suspicious activity
• Respond to legal requests and enforce our terms

Business Operations

• Improve and optimize our platform and services
• Conduct data analysis and research
• Develop new features and products
• Send marketing communications (with your consent)

Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), we process your personal data based on:

• Contract Performance: Processing necessary to provide our services
• Legal Obligation: Compliance with KYC/AML/CFT and other legal requirements
• Legitimate Interests: Fraud prevention, security, and business operations
• Consent: Marketing communications and optional features

How We Share Your Information

Service Providers

We share information with third-party service providers who perform services on our behalf:

• Payment processors and financial institutions
• Identity verification and KYC/AML service providers
• Cloud hosting and data storage providers
• Customer support and communication platforms
• Analytics and monitoring services

Business Partners

• Merchants and beneficiaries involved in your transactions
• Banking partners for currency conversion and settlement
• Blockchain networks for transaction processing

Legal and Regulatory Authorities

We may disclose your information to:

• Law enforcement agencies and government officials
• Regulatory bodies (FinCEN, OFAC, etc.)
• Courts and legal proceedings
• Comply with subpoenas, court orders, or legal processes

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

We do not sell your personal data to third parties for marketing purposes.

Data Retention

We retain your information for as long as necessary to:

• Provide our services to you
• Comply with legal and regulatory requirements (minimum 5 years for financial records)
• Resolve disputes and enforce our agreements
• Prevent fraud and maintain security

After the retention period, we will securely delete or anonymize your information.

Data Security

We implement robust security measures to protect your information:

• Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Multi-factor authentication and access controls
• Regular security audits and penetration testing
• Employee training on data protection
• Incident response and breach notification procedures

However, no method of transmission over the internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

Your Privacy Rights

General Rights

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal requirements)
• Objection: Object to certain processing activities
• Restriction: Request restriction of processing
• Portability: Request transfer of your data to another service

GDPR Rights (EEA Users)

If you are in the EEA, you have additional rights under GDPR, including the right to lodge a complaint with a supervisory authority.

CCPA Rights (California Users)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to know if personal information is sold or disclosed
• Right to opt-out of the sale of personal information
• Right to deletion
• Right to non-discrimination

Exercising Your Rights

To exercise any of these rights, please contact us at: [email protected]

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. We ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Other legally approved transfer mechanisms

Third-Party Links

Our platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

Changes to This Policy

We may update this Privacy & Data Policy from time to time to reflect changes in our practices, technology, legislation, or legal requirements. We will notify you of material changes by:

• Posting the updated policy on our website
• Sending an email notification to your registered email address
• Displaying a prominent notice on our platform

Your continued use of our services after the effective date constitutes acceptance of the updated Policy.

Contact Us

If you have questions, concerns, or requests regarding this Privacy & Data Policy or our privacy practices, please contact us:

Stable Payments Inc.
Email: [email protected]
General Inquiries: [email protected]

Data Protection Officer:
Email: [email protected]

Last Updated: October 27, 2025