This Policy explains how LLC «WIZARDPAY», hereinafter referred to as WIZARDPAY, processes personal and other data in connection with the Website, communications with users, and the research, development and testing of digital products and technology solutions.

1. About Us

Where WIZARDPAY determines the purposes and means of processing personal data, such processing is carried out in accordance with applicable Ukrainian law.

In specific customer scenarios, the roles, rights and obligations of the parties in relation to data may be determined by a separate agreement, depending on the nature of the relevant processing.

For questions regarding personal data processing, please contact us at info@wizardpay.com.ua.

2. Data We May Process

Depending on how you interact with WIZARDPAY, we may process:
- name and contact details;
- company or business information;
- information voluntarily provided through the Website or during product testing;
- technical information, including IP address, device information, access logs and technical events;
- data and documents provided for the operation or testing of a relevant technology solution;
- where applicable, financial data, including account information, transactions, statements and documents.

We seek to process only data that is necessary for the relevant defined purpose.

3. Sources of Data

Data may be obtained:
- directly from the user;
- from a business representative or authorized person;
- automatically through the use of the Website or products;
- through technology and integration mechanisms configured or authorized by the user for a particular scenario;
- from other sources where permitted by law or a separate agreement.

4. Cookies

At the current stage, the Website uses only strictly necessary cookies required for its correct operation and security.

We do not use third-party analytics, advertising or tracking tools.

If this changes, we will update this Policy and obtain consent where required by law.

5. How We Use Data

WIZARDPAY may process data for:
- research, development and testing of products;
- providing and operating available technology features;
- technical support and communication with users;
- information and cybersecurity;
- analyzing and improving technology solutions;
- complying with legal obligations;
- protecting the rights and legitimate interests of WIZARDPAY.

We do not sell personal data or use it for purposes incompatible with the purpose for which it was collected.

6. Legal Grounds

Personal data is processed on the legal grounds provided by Ukrainian law, depending on the specific purpose and nature of the processing.

Where applicable, the legal basis may include consent, performance of a contract, compliance with a legal obligation, or another legal basis provided by law.

Where consent is required for a particular operation, WIZARDPAY obtains such consent in a form that allows the fact of consent to be confirmed. Consent may be withdrawn at any time; withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

7. Customer and Third-Party Data

In future customer products, a user or customer may provide WIZARDPAY with data relating to its employees, contractors, counterparties or other individuals.

In such cases, the relevant customer is responsible for having an appropriate legal basis for providing such data to WIZARDPAY, unless otherwise required by law or agreed separately.

The roles of the parties, scope and procedures for data processing, retention periods and other details may be established in a separate agreement with the relevant customer.

8. Sharing of Data

WIZARDPAY may engage technology and infrastructure providers necessary to operate the Website and products.

Access to data by such providers is limited to what is necessary for the relevant function or service.

Some providers may be located outside Ukraine. In such cases WIZARDPAY takes measures to ensure an appropriate level of data protection in accordance with Ukrainian law.

In the event of a reorganization, merger, or sale of shares or assets of WIZARDPAY, data may be transferred to the successor on processing terms no less protective than those set out in this Policy.

Data may also be disclosed where required by Ukrainian law or where necessary to protect the rights and security of WIZARDPAY, its users or other persons.

9. Data Security

WIZARDPAY applies appropriate technical and organizational measures to protect data against unauthorized access, loss, destruction, alteration or other unlawful processing.

Depending on the relevant system, these measures may include access controls, least-privilege principles, secure data transmission, encryption, logging, backups, monitoring and incident response procedures.

In the event of an incident creating a significant risk to individuals' rights, WIZARDPAY notifies the affected individuals and, where required by law, the competent authorities without undue delay.

10. Data Retention

We retain data only for as long as necessary for the relevant processing purpose, contractual or legal obligations, security, or the protection of legitimate interests.

For data collected through the Website we apply the following guideline periods: contact form enquiries — up to 24 months from the last communication; technical access logs — up to 12 months.

Specific retention periods for customer products may be established in a separate agreement with the relevant customer.

11. Data Subject Rights

Individuals have the rights provided by Ukrainian law, including the right to receive information about the processing of their personal data, access their data, request correction of inaccurate data, withdraw consent given, and, where provided by law, request cessation or restriction of processing or deletion of their data.

To exercise your rights or obtain information about the processing of your data, please contact WIZARDPAY at info@wizardpay.com.ua.

Individuals may also have the right to contact the Ukrainian Parliament Commissioner for Human Rights or a court in accordance with applicable law.

12. Data of Minors

The Website and WIZARDPAY products are intended for business users and are not directed at persons under 18 years of age. We do not knowingly collect data of such persons.

If such data has reached us, please notify info@wizardpay.com.ua and we will delete it.

13. Open Banking and Regulated Services

Open Banking and financial infrastructure are among the areas researched and developed by WIZARDPAY.

At the current stage, WIZARDPAY researches, develops and tests relevant technology scenarios.

WIZARDPAY does not receive, hold or control users' funds.

Services that require specific authorization under Ukrainian law, including AISP/PISP services, may be provided only after the relevant authorization has been obtained and within the applicable regulatory framework.

14. Updates to this Policy

This Policy may be updated to reflect changes in our products, technology, applicable law or data processing practices.

The current version will be published on this page. The effective date of the current version is stated at the top of this document.

Where a change is material and relates to the purpose or legal basis of processing for which an individual previously gave consent, WIZARDPAY will notify the individual concerned and, where required by law, obtain updated consent before the change takes effect. For other updates, publication of the new version on this page is sufficient.

15. Company Information

LLC «WIZARDPAY»
Company Registration Number (EDRPOU): 46180969
Email: info@wizardpay.com.ua
Website: wizardpay.com.ua