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Privacy Policy

Sürüm: 0.9 (draft) · Son güncelleme: 2026-09-11

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1. Who is responsible

AtaForge Inc. (operating as Baynoy) is the controller for personal data processed to provide the Services, unless the Data Processing Addendum makes us a processor for a platform customer. Contact: privacy@baynoy.com.

2. What we collect

We collect only what running a regulated payment product requires:

  • Account data — name, business role, email, phone, language.
  • Verification data — company registry information, documents, directors and owners, identity checks and their results.
  • Transaction data — payments, payouts, balances, cards, crypto movements, and the counterparty details they contain.
  • Device and usage data — IP address, device identifiers, security signals, and product usage events.
  • Support data — messages you send us and records of how we resolved them.

3. Why we process it

Each purpose has a legal basis:

  • Providing the Services and executing your instructions (contract).
  • Verification, sanctions screening, fraud and financial-crime prevention (legal obligation and legitimate interest).
  • Security of accounts and infrastructure (legitimate interest).
  • Accounting, tax and record-keeping (legal obligation).
  • Product communications about your account (contract); optional news only with consent.

4. Who we share it with

We share personal data only where providing the Services requires it: the regulated banking, card-issuing, acquiring, custody and verification institutions we work with; technical service providers under contract; and authorities where law compels us. The institutions relevant to your account are named in the Card & Account Disclosures.

We never sell personal data. Our analytics are Plausible, which we host ourselves, and Google Analytics, which runs with Google Signals and ad personalisation switched off — so what it measures is visits, not an advertising profile.

5. International transfers

Where data leaves the region it was collected in, we use recognised safeguards such as adequacy decisions or standard contractual clauses.

6. How long we keep it

Verification and transaction records are kept as long as financial-services law requires (typically five to ten years after the relationship ends, depending on country). Everything else is kept only while needed for its purpose, then deleted or anonymised.

Where an address resolves to is worked out on our own servers using a local copy of the DB-IP City Lite database (© db-ip.com, CC BY 4.0) — no address is ever sent to a third-party lookup service. IP addresses, the city they resolve to, and the raw browser identification string attached to an administrative or sign-in event are deleted 90 days after the event. The record of the event itself — who acted, on what, when, from which country, on what class of device, and whether it was allowed — is kept, because it is the audit evidence financial-services law requires and it does not identify a person on its own.

7. Your rights

Depending on your jurisdiction you can request access, correction, deletion, restriction, portability, and object to certain processing; where processing rests on consent you can withdraw it. Some records cannot be deleted while retention law applies — we tell you when that is the case. Write to privacy@baynoy.com; you may also complain to your data-protection authority.

8. Security

Data is encrypted in transit and at rest, access is role-based and logged, card numbers never touch our servers in the clear, and administrative actions land in an immutable audit log. The Security page describes our practices; the Responsible Disclosure policy explains how to report a vulnerability.

9. Cookies

See the Cookie Policy — the short version: essential cookies, plus analytics that run only if you consent. One of them, Google Analytics, is a third party: consenting means visit data goes to Google.

10. Changes

We will post changes here with a new date and, for material changes, notify account holders.