Privacy Policy

This Privacy Policy explains how personal data is collected, used, stored, shared, and protected when you access this website and use the services available through it.

The services covered by this Privacy Policy include consultancy on crypto payment processing, client onboarding, compliance advisory, operational support, and related corporate functions. The company does not itself carry out payment or crypto processing and does not handle client or third-party funds.

By accessing or using the website and services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, you must discontinue use of the website and services.

1. Definitions

Personal Data means any information relating to an identified or identifiable natural person.
Processing means any operation performed on personal data, including collection, storage, use, disclosure, transfer, restriction, or deletion.
User means any person who visits the website, submits information, or engages the services.
Services means consultancy on crypto payment processing, advisory on transaction routing and monitoring frameworks, client onboarding, verification, customer support, and related operational services.
Service Provider means any third party engaged to provide infrastructure, identity verification, payment support, compliance tools, analytics, hosting, or other operational assistance.
Applicable Law means any laws, regulations, regulatory requirements, or binding rules applicable to privacy, payments, financial crime prevention, sanctions, and data security.

2. Principles of Data Processing

Personal data is processed in a lawful, fair, and proportionate manner and only where there is a valid legal basis to do so.

Personal data is:

collected for specific and legitimate purposes
limited to what is necessary for those purposes
kept accurate and updated where required
retained only for as long as necessary or legally required
protected through appropriate technical and organisational safeguards

The services are not intended for persons under 18 years of age. If it becomes known that personal data relating to a minor has been collected, it may be deleted unless retention is required by law.

3. Categories of Data Processed

Depending on the nature of the services used, the following categories of personal data may be processed:

identity information, such as full name, date of birth, nationality, and tax residency
verification documents, such as passport or ID details, proof of address, selfies, biometric data, and source-of-funds documentation
contact information, such as email address, phone number, messaging details, and residential address
access and authentication data relating to systems or tools shared in the course of an engagement
transaction and payment data shared by clients in the course of an advisory engagement, including wallet information, blockchain transaction details, payment references, amounts, counterparties, and settlement records
financial and background information, including payment methods, bank details where applicable, business information, and compliance-related disclosures
compliance screening data, such as sanctions checks, politically exposed person checks, adverse media results, and fraud indicators
communication records, including support messages, emails, chats, call notes, and complaint records
technical and device data, such as IP address, browser type, operating system, device identifiers, and usage logs
cookie, analytics, and website usage data
other information voluntarily submitted through forms, support requests, or communications

4. Legal Bases for Processing

Personal data may be processed on one or more of the following legal grounds:

Contractual necessity — where processing is required to provide consultancy services, establish or manage an engagement, or respond to user requests.
Legal obligation — where processing is necessary to comply with KYC, AML, sanctions, fraud prevention, reporting, recordkeeping, or other applicable legal requirements.
Legitimate interests — where processing is reasonably necessary for security, service improvement, fraud detection, business operations, analytics, or dispute management, provided such interests are not overridden by user rights.
Consent — where consent is required by law, including for certain cookies, analytics tools, or marketing communications.

5. Purposes of Processing

Personal data may be processed for the following purposes:

onboarding clients and managing engagements
performing identity verification and KYC / AML checks on prospective clients
providing consultancy on crypto payment processing
advising on transaction monitoring, fraud detection, and security controls
providing customer support and managing service requests
communicating service-related notices and operational updates
maintaining records for audit, legal, regulatory, and compliance purposes
improving website functionality, system reliability, and service performance
handling disputes, complaints, or misuse investigations
enforcing legal rights, policies, and contractual terms
complying with sanctions, prohibited jurisdiction restrictions, and financial crime prevention requirements
sending marketing communications where permitted by law or where consent has been obtained

6. Sharing of Personal Data

Personal data may be disclosed to third parties where necessary for the operation of the services or compliance with applicable law.

Recipients may include:

identity verification and KYC / AML screening providers
blockchain analytics and compliance tooling providers
hosting, cloud, infrastructure, and security providers
customer support and communications platforms
analytics and fraud prevention providers
professional advisers, auditors, insurers, and legal counsel
regulators, supervisory authorities, law enforcement, tax authorities, or courts where required or permitted by law
parties involved in a merger, acquisition, restructuring, or sale of business assets, subject to appropriate safeguards

Personal data is not sold.

Where third parties process personal data on behalf of the company, they are required to act only on authorised instructions and to implement appropriate confidentiality and security measures.

7. Cookies and Tracking Technologies

The website may use cookies and similar technologies to support security, improve functionality, analyse usage, and, where permitted, deliver relevant content or measure performance.

Further information about cookies and available controls should be provided in the separate Cookie Policy.

8. Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected, including to meet legal, regulatory, tax, accounting, fraud prevention, dispute resolution, and operational requirements.

Retention periods may vary depending on the type of data and the reason for processing. Data may be retained for longer where required by law, where necessary to establish or defend legal claims, or where needed for compliance and security purposes.

When retention is no longer necessary, personal data is securely deleted, anonymised, or irreversibly de-identified where appropriate.

9. Data Security

Appropriate technical and organisational measures are implemented to protect personal data against unauthorised access, disclosure, alteration, destruction, or loss.

These measures may include:

encryption in transit and, where appropriate, at rest
access controls and role-based permissions
authentication and access protection measures
logging, monitoring, and incident response procedures
vendor due diligence and contractual security requirements
backup, disaster recovery, and business continuity measures

No system can be guaranteed to be completely secure, but reasonable steps are taken to reduce risks and respond to incidents appropriately.

10. International Transfers

Personal data may be transferred to, stored in, or accessed from countries outside the user’s country of residence where this is necessary for service delivery, infrastructure, compliance, fraud prevention, support, or operational continuity.

Where cross-border transfers occur, reasonable safeguards are applied to protect personal data in accordance with applicable law.

11. User Rights

Subject to applicable law, users may have the right to:

request access to personal data
request correction of inaccurate or incomplete data
request deletion of data where lawful and applicable
request restriction of processing in certain cases
object to certain processing activities
withdraw consent where processing is based on consent
submit a complaint to a competent authority

These rights may be limited where data must be retained for legal, regulatory, fraud prevention, security, or dispute-related reasons.

12. Automated Processing

Automated tools may be used for client screening, sanctions checks, risk scoring, or service optimisation. Automated monitoring of end-user transactions is performed by clients within their own systems, not by the company.

Where required by law, appropriate safeguards and human review procedures are applied.

13. Third-Party Websites and Services

The website or services may contain links to third-party websites, tools, or integrations.

Those third parties operate independently and are responsible for their own privacy practices. Users should review their privacy policies before providing any personal data.

14. Changes to this Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes in the services, legal requirements, or operational practices.

The latest version will be made available on the website. Continued use of the services after an update may constitute acceptance of the revised Privacy Policy, where permitted by law.

15. Contact and Complaints

The data controller is Eteri Digital Management Ltd, a company registered in Georgia. Registered address: Georgia, Tbilisi, Saburtalo district, Bakhtrioni street, N 22, apartment N75.

If you have questions, requests, or complaints relating to this Privacy Policy or the processing of personal data, you may contact the company at legal@eterix.ge, through the website, or via any official support channel made available to users.