1. Introduction
This Privacy Policy explains how PayCow collects, uses, and protects Merchant and Customer information across our custodial payment infrastructure.
2. Legal Definitions & Entity Roles
To ensure total regulatory and operational clarity regarding data processing responsibilities, the following legal definitions apply:
- PayCow ("Company", "We", "Us", "Our"): Refers to PayCow Distributed Ledger Technologies LLC, a legal corporate entity incorporated and registered under the laws of Georgia (Tbilisi, Georgia). PayCow operates as an enterprise custodial payment infrastructure provider operating secure on-chain ERC20 smart contract deposit wallets, transaction confirmation monitoring, automated fee sweepings, and merchant balance settlements. PayCow acts as a Data Controller for Merchant registration data and a Data Processor on behalf of Merchants regarding Customer payment telemetry.
- Merchant ("Operator", "Business", "You"): Any registered enterprise, digital platform, online store, or commercial operator using PayCow payment infrastructure to accept cryptocurrency payments from Customers.
- Customer ("Payer", "End-User"): An individual or entity executing cryptocurrency payments to a Merchant via PayCow-generated dynamic deposit wallet addresses on the blockchain.
- Affiliate Partner ("Affiliate", "Referrer"): An individual or corporate entity enrolled in the PayCow Affiliate Program referring Merchants to the platform.
- Custodial Deposit Wallet: A temporary, blockchain-native ERC20 wallet generated by PayCow for a specific checkout session to receive Customer funds prior to 12-block confirmation and automated settlement.
3. Information We Collect
Depending on your entity classification and interaction with our platform, we collect the following categories of data:
- Merchant Profile Data: Full corporate name, operator identity, business registration, contact email address, country of residence, and API credentials.
- Merchant KYC & Verification Data: Government-issued identification documents, corporate registration records, and biometric verification data.
- Customer Transaction Data: Public blockchain transaction hashes, sending wallet addresses, deposit wallet addresses, token contract addresses, and timestamp logs.
- Technical & System Telemetry: IP addresses, browser user-agents, device fingerprints, and API request logs for security and fraud prevention.
4. Purpose & Legal Basis of Data Processing
We process Merchant and Customer data under strict legal grounds to:
- Perform Identity Verification (KYC) and Anti-Money Laundering (AML) risk scoring.
- Execute custodial payment processing, block confirmation tracking, and treasury settlements.
- Detect and prevent double-spending attacks, smart contract exploits, and fraudulent activity.
- Comply with applicable legal, regulatory, and audit obligations.
5. Data Sharing & Disclosures
We do not sell Merchant or Customer data. We share data strictly when necessary with:
- Automated identity verification and compliance providers.
- Financial audit partners and legal authorities when legally mandated.
- Infrastructure service providers operating our secure cloud hosting and database systems.
6. Data Retention Standards
Merchant identity records and transaction ledgers are retained for mandatory legal retention periods required by financial regulations. Temporary checkout telemetry is purged according to standard data minimization schedules.
7. Data Security Architecture
We implement enterprise-grade encryption, isolated private key management, database access controls, and strict rate-limiting to protect Merchant and Customer data from unauthorized access or breach.
8. Data Subject Rights
Merchants and users may request access, correction, or export of their account information by contacting our data protection officer via the Support Hub.
9. Policy Amendments
PayCow reserves the right to amend this Privacy Policy at any time. Continued use of our infrastructure constitutes acceptance of updated privacy terms.