VRPay
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Privacy policy

Last updated: [DATE]

This policy will explain what personal data VRPay collects, why, who it is shared with, and what rights you have over it.

[DRAFT STRUCTURE — NOT A POLICY] This page is scaffolding: the headings below are the sections a policy of this kind needs, and each one describes what belongs in it. None of it is legal text and none of it has been reviewed by a lawyer. It must be replaced with drafted, jurisdiction-specific wording before VRPay is offered to the public.

  1. 01Who we are

    Name the legal entity acting as data controller, its registered address, company number, and the contact details of the data protection officer or privacy contact.

  2. 02What data we collect

    List each category: identity and verification documents collected for KYC, contact details, financial and transaction data, device and log data, and anything gathered from third-party verification providers.

  3. 03How we use your data and our legal basis

    Map each purpose to a lawful basis under GDPR Article 6 — contract performance for operating accounts, legal obligation for anti-money-laundering checks and record keeping, legitimate interests for fraud prevention, consent for marketing.

  4. 04Who we share it with

    Name the categories of recipient: licensed partner institutions holding the funds, card issuers and processors, identity verification providers, cloud hosting, and regulators or law enforcement where legally required.

  5. 05International transfers

    State which transfers leave the UK/EEA, and the safeguard relied on for each — adequacy decision, standard contractual clauses, or another Article 46 mechanism.

  6. 06How long we keep it

    Give retention periods per category. Anti-money-laundering records typically carry a statutory minimum retention period that outlives account closure — state it explicitly.

  7. 07Your rights

    Access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. Explain how to exercise each, the response deadline, and that no fee applies in ordinary cases.

  8. 08Complaints and contact

    Give the privacy contact address and name the supervisory authority a complaint can be raised with in each market VRPay operates in.