Privacy Policy

This Privacy Policy includes important information about your personal data and we encourage you to read it carefully.
Last updated: August 11th 2023

Introduction

This Privacy Policy (“Policy”) describes the “Personal Data” that we collect about you, how we use it, your rights and choices, and how you can contact us about our privacy practices.“

Radom”, “we”, “our”, “us” means the entity, Radom Pay Limited, responsible for the collection and use of Personal Data under this Privacy Policy.

“Personal Data” means any information that relates to an identified or identifiable individual, and can include information that you provide to us and that we collect about you, such as when you engage with our Services (e.g. IP address, device information).

“Services” means the products that Radom indicates are covered by this Policy. “Business Services” are Services provided by Radom to merchants (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business activities.

Depending on the context, “you” means End Customer, Representative or Visitor:

  • When you transact with a Business User (e.g. when an End Customer purchases a product from a merchant who uses Radom Checkout for payments) but are not doing business directly with Radom, we refer to you as an “End Customer.”
  • When you administer an account signed into Radom’s Business Services or are employed on behalf of a merchant, we refer to you as a “Representative.”
  • When you visit the www.radom.network website without signing in or you communicate with Radom, we refer to you as a “Visitor.” (e.g. you contact Radom asking for more information because you are considering being a user of our products).

1. Personal Data We Collect and Use

We may collect information to personalise, improve, protect, and continue to operate the Services. We may request, collect and/or display some of your Personal Data.

Our collection and use of Personal Data depends on whether you are acting as an End Customer, Representative or Business User and our different services. 

For example, if you are a Business User, you may provide Personal Data for us to collect and enhance services such as company name and imagery used on Checkout for End Customers, but if you are an End Customer purchasing goods and services from a Business User utilising Radom's Services for payments, the type of Personal Data collected from yourself may vary. 

“Order Data” as used in this Privacy Policy includes End Customer Personal Data, and may include the following: your name, email address, billing address, shipping address, ERC-20 wallet address, merchant, purchase amount, purchase currency/token, date of purchase.

1.1 End Customers

Radom offers Business Services to our Business Users (e.g. crypto payment processing through online checkout, or processing wallet withdrawals for those Business Users). We may process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions (e.g. when we process a payment for a Business User because you bought a product from them). 

Business Users are responsible for making sure that their End Customers’ privacy rights are respected, including ensuring appropriate disclosures about data collection and use that happens in connection with their products and services. If you are an End Customer, please refer to the privacy policy or notice of the Business User you choose to do business with for information regarding their privacy practices, choices and controls. 

Radom only collects Personal Data from End Customers during payment on behalf of Business Users. 

a. Personal Data that we collect about End Customers 
  • Order Data. As an End Customer, when you make payments to a Business User using our crypto payment processing services, we will receive Order Data. The exact information we receive will vary depending on what data the Business User requests from you.
b. How we use End Customer data 
  • Business Users. We use your Order Data to provide our Business Users with your Personal Data on our application/dashboard. We do not provide Order Data to anyone else besides Business Users and Representatives they have authorised to use the application on their Business’ behalf. 
  • Anonymised Information. We may collect data in an anonymised and non-discriminate way in order to understand better the usage of our Services. For example, we may collect data around IP-addresses to better understand our Services. 
  • Advertising by Business Users. If you have made a purchase, we share Personal Data with that Business User in connection with our provision of Services and that Business User may use your Personal Data to market and advertise their own products or services, subject to the terms of their privacy policy. Please review your merchant’s privacy policy to learn more, including your rights to stop their use of your Personal Data for marketing purposes. 
  • We do not use, sell or share End Customer Personal Data for our marketing or advertising, or for marketing and advertising by third parties who are not the Business User with which you have transacted or attempted to transact.

1.2 Representatives

To provide Business Services, we may collect, and use Personal Data from Representatives of Business Users (e.g. merchants). 

a. Personal Data that we collect about Representatives 
  • Business Information. If you sign up and/or log in to the application, you may enter Personal Data such as your business name, logo and contact email address. 
  • Invitation Information. If you are the administrator of a Business User, i.e. you are the administrator of the Organisational account, we may collect information about colleagues you invite to use the application in the event you add them as users. Information about your colleagues will include their name and email address or wallet address. 
b. How we use Representative data 

We use Personal Data of Representatives to provide Business Services to the associated Business Users.

  • Invitation Notifications. We use Personal Data of Representatives to provide the Services you (or the Business User you are associated with) have requested. 

    In cases where Representatives acting as administrators invite other Representatives to the application, we will require the invitee’s email address to notify them of their access, role and permissions. 
  • Service Notifications. We may use your contact information to send you important information about our Services and communicate with you via email, through the application, Telegram, Slack or another text message (“Message”) application (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Message or receive a push notification. We use this information to improve our Services, including our customer service. 

    You may unsubscribe from some of these messages by emailing us at contact@radom.network, although we reserve the right to contact you when we believe it is required. 
  • Payment Notifications. Representatives who have the necessary permissions and have opted-in to receive email notifications will receive notifications of Order events, including new payments, subscriptions, and cancellations etc.

1.3 Site Visitors

We collect Personal Data of Visitors (who are not End Customers or Representatives).

a. Personal Data that we collect about Visitors 

When you visit our Website, we will receive Personal Data either from you providing it to us or through analytics information. 

  • Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Twitter), we will collect the information included in the form (e.g. your contact information and other information about your question related to our Services). We may also associate a location with your visit. 
b. How we use Visitor Personal Data 
    • Engagement. When Visitors fill in forms or engage with surveys, we will use the information to contact and engage in conversations to answer your questions and submissions.
    • Analytics. We may use third-party cookies, such as Google Analytics, for website traffic tracking and user targeting, which helps us to analyse how you use Radom’s website. You can opt out by setting your browser to refuse some or all third-party cookies or be notified when a website tries to set a cookie in your browser. If you choose to disable cookies in your browser, you can still use the Radom site, but availability to use some of the features may be affected.
      Click here for more information on how to opt out from Google Analytics tracking.

    2. Other Information We Collect and Use

    We may collect technical and usage information, such as the IP address used to connect your computer to the Internet, the number and frequency of visitors to the application and users of the Services. We may use this data in aggregate form, that is, as a statistical measure, or in other anonymous forms, but not in a manner that would identify you personally. This type of data enables us, and third parties authorised by us, to figure out how often individuals use parts of the Services. 

    Aggregate Information 

    We collect statistical information about how merchants use the Services (“Aggregate Information”). Some of this information is derived from Personal Data. This statistical information is not Personal Data and cannot be tied back to you, your Account, your web browser. 

    Use of Your Personal Data 

    The following is how we use your Personal Data: 

    • To fulfill our obligations under your contract with us and provide you with the information and services you have requested. 
    • To adhere to any legal and/or regulatory obligations that may apply.
    • To keep you up to date on changes to our Services. 
    • As part of our ongoing efforts to ensure the safety and security of our Services.
    • To administer our Services and for internal operations, such as troubleshooting, data analysis, testing, research, statistical, and survey purposes; to improve our Services and ensure that they are presented most effectively. 
    • To enable you to take part in interactive aspects of our Services if you so desire.
    • To notify you about other similar items and services that we provide.

    3. International Data Transfer

    Our Services are operated primarily in the United Kingdom, and the recipients of the data disclosures described in this Privacy Policy are in the United Kingdom and elsewhere in the world. We will comply with legal requirements and will take all steps reasonably necessary to ensure that your data is treated securely for cross-border data protection.

    4. Personal Data Retention

    We keep your information no longer than necessary for the processing. The length of time for which we retain information depends on the purposes we collected and use and/or as required to comply with applicable laws.

    5. Your Data Protection Rights

    You can decline to submit information through the Services, in which case we may not be able to provide certain services to you. You have the right to access the information we have on you, subject to relevant laws. You can exercise your right of access in line with the applicable data protection legislation. You can ask us to delete your data when it’s no longer necessary or subject to a legal obligation to which Radom is subject. By emailing us at contact@radom.network, you may ask us not to contact you for marketing reasons. 

    EEA and UK: Residents of the European Economic Area (“EEA”), and the United Kingdom can contact us as described below to exercise their rights within the scope of the General Data Protection Regulation (GDPR). 

    California Privacy Rights: California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the types of Personal Data disclosed to those parties. If you are a California resident and would like to request this information, please mail your request by email to contact@radom.network.

    6. Updates to Privacy Policy

    We may update this privacy policy from time to time to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. We will endeavour to provide you with reasonable notice of such changes. We may do so via prominent notice in the Service or to your email address of record, and where required by law, we will obtain your consent or allow you to opt-out of such changes.

    7. Contact Us

    For more information about our privacy practices, if you have any questions, or if you would like to make a complaint, please contact us by email at contact@radom.network