Privacy Policy


Last updated: 29 November 2023

Adpay ("Adpay", "Service", "we" or "us") is committed to protecting the privacy of our customers and we take our data protection responsibilities very seriously.

This Privacy Policy explains how personal data is collected, processed, used, and disclosed when you use the Adpay Service When registering, logging in, making payments, contacting support, filling out forms, or submitting data, personal data will be collected, used, and stored as described in the Privacy Policy.


1.1. To use the Service, the User is obliged to accept the terms of this Policy. The Participant shall not be entitled to use the Service in case of disagreement with the terms of this Policy.

1.2. Personal data is data that identifies or relates to an identifiable person. This includes information that you provide to us, information that is collected about you automatically, and information that we receive from third parties.


2.1 This Policy determines the procedure for obtaining, storing, processing, using, and disclosing Personal, Public, and other data provided by the User when using the Service.

2.2. The processing of the User's personal data is carried out in accordance with the requirements of the Law of Ukraine "On Personal Data Protection".

2.3 By using any part of the Service, the User grants us the right to receive, store, process, use, and disclose the User's Personal Data under the terms of this Policy.

2.4. This Policy does not regulate, and we are not responsible for, the procedure for obtaining, storing, processing, using, and disclosing the User's Personal Data by third-party enterprises, organizations, and services that are not owned or controlled by us, and individuals who are not our employees, even if the User has accessed the websites, software, goods or services of these persons through the Service.

2.5. The purpose of obtaining, storing, processing, and using the User's Personal and other data is to protect the interests of the User and the Service, as well as to provide the User with the Service, identify the User, and contact the User.


3.1. When using the Service, the User shall indicate the name, surname, e-mail address, username in the Telegram messenger, and other data that he/she provides voluntarily. This data is considered the User's Personal Data.

3.2. We have the right to store the User's Personal and other data to the extent and for the periods necessary to fulfill the purpose specified in this Policy, or for the periods established by the current legislation of Ukraine, international law, or the legislation of the country of residence or stay of the User, or until the User deletes this data.

3.3. The information specified in clause 3.1. is stored in cloud storage.

3.4. We do not request additional documents or information from the User, except in the case of compliance with the requirements of anti-money laundering and terrorist financing legislation, at the request of the merchant, when required by law. In this case, we request the following information from the User:

- information on the origin of funds;

- information about the shipping service;

- information about the purpose of the payment;

- screenshots of the output from the sending service interface;

- Full names of the parties to the transaction;

- any other information about the transaction and its participants that we or the User believe may be useful.

In this case, the User is obliged to provide us with this information. The Service does not store this information but receives it solely for the purpose of transferring merchandise.

3.5. To the extent permitted by applicable law, we may collect certain types of information automatically, for example, whenever you interact with us or use the services. This information helps us to resolve customer support issues, improve the performance of our sites and services, maintain and/or enhance the user experience, and protect your account from fraud by detecting unauthorized access.

3.6. We may collect information from your device, including your Internet Service Provider (IP) address, location, login information, browser type and settings, time zone, operating system, type of device you are using, unique device identifier, screen size, mobile network information, mobile operating system and type of mobile browser you are using, and the date, time and duration of your visit.

3.7. We may receive information from payment systems, payment service providers, card systems, card program managers, public authorities, and law enforcement agencies, as well as from publicly available sources.


4.1 We undertake not to provide Personal Data to third parties for commercial purposes without the consent of the User to whom this data belongs. The transfer of Personal Data to third parties is allowed in the following cases:

- After obtaining the consent of the User to whom this information belongs;

- If it is necessary to transfer Personal Data in order to fulfill the User's request;

- At the reasonable request of enterprises, institutions, and organizations entitled to receive such data;

- In the event that, in our opinion, the User violates the terms of this Policy and/or other contracts and agreements between us and the User.

4.2. The User agrees, and we have the right to distribute personal data to third parties who fulfill their obligations to provide services on the Service, as well as merchandise in accordance with clause 3.4. of this Policy. Owners, managers of personal data, and third parties are obliged to ensure the protection of this data from accidental loss or destruction, as well as from unlawful processing.

4.3. The User agrees that the confidentiality of the data transmitted via the Internet is not guaranteed and in the event that access to this data is obtained by third parties outside the area of technical means of communication under our control, we shall not be liable for any damage caused by such access.

4.4. The User has the right to request, change, or delete his/her Personal Data that is in our access unless otherwise provided by law.


5.1. The user, as a subject of personal data, has the rights provided for by the Law of Ukraine "On Personal Data Protection", namely:

1) to know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or to give a corresponding order to obtain this information to persons authorized by him/her, except in cases established by law;

2) to receive information on the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;

3) access to their personal data;

4) to receive a response on whether his/her personal data is processed no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, and to receive the content of such personal data;

5) to submit a reasoned request to the personal data controller with an objection to the processing of their personal data;

6) to submit a reasoned request to change or destroy their personal data by any owner and manager of personal data if such data is processed illegally or is unreliable;

7) to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide, or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honor, dignity, and business reputation of an individual;

8) file complaints against the processing of their personal data with the Commissioner or the court;

9) apply legal remedies in case of violation of the legislation on personal data protection;

10) to make reservations regarding the restriction of the right to process their personal data when giving consent;

11) withdraw consent to the processing of personal data;

12) know the mechanism of automatic processing of personal data;

13) to be protected against an automated decision that has legal consequences for him/her.


6.1. We use generally accepted standards of technological and operational protection of information and personal data against loss, misuse, alteration, or destruction. However, despite our best efforts, we cannot guarantee absolute protection against any threats arising outside of our control.

6.2. We ensure the application of all relevant confidentiality obligations, as well as technical and organizational security measures to prevent unauthorized or unlawful disclosure or processing of such information and data, their accidental loss, destruction, or damage.

6.3. Dissemination of personal data without the consent of the personal data subject or his/her authorized person is allowed in cases determined by law and only (if necessary) in the interests of national security, economic welfare, and human rights.

6.4. The User's personal data is not encrypted, encryption is applied only to the password on the Service platform.


7.1. The Service has the right to make changes to the Privacy Policy. All changes made to the Policy will be available in the form of a new version of the Policy. All changes to the Policy shall take effect from the moment they are published on the Service. By using the Service, the User confirms acceptance of the new terms of the Policy in the version in force at the time of the User's use of the Service.


8.1. The Data Protection Officer can be contacted by e-mail at [email protected]