Privacy Policy

Last modified: 05/11/2025

This privacy policy describes how we will collect, use, share and otherwise process your personal data in connection with your use of our website Web3Payments (the Website), when you access, use, or download our web based software development tools and downloadable software (collectively, the “Software”) and access any of our services that are accessible through the Website (the Services). The primary purpose for which we collect information is to provide you with our Services so that by use of our Software, you can create applications and tokens.

The Website is not intended for those under 18 and we do not knowingly collect data relating to children.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

KG Token Holdings Ltd is trading as Web3Payments (Web3Payments) (we, us or our in this Policy).

Contact details

Our full details are: KG Token Holdings Ltd

E-mail: data@web3paymentsolutions.io

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on the date at the beginning of it. It may change and, if it does, those changes will be posted on the Website. You may be required to read and acknowledge the changes to continue your use of the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links and sites

Our Website will contain links to and from the websites of third parties.

Please note that these websites (and any services accessible through them) are controlled by those third parties and are not covered by this privacy notice. You should review their own privacy notices to understand how they use your personal data before you submit any personal data to these websites or use these services.

The data we collect about you

• Contact Data: e-mail address and telephone number.
• Cookies Data: the information collected through the cookies and similar technologies listed in our Cookies Policy (set out in this Policy).
• Device Data: the type of device you use (Device), a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), network information, your mobile operating system, screen type and resolution, the type of web browser you use, the time zone setting.
• Direct Marketing Data: information which we collect and store as a result of you being added to our mailing databases.
• Identity Data: name, surname, gender, country of residence, date of birth.
• Location: details of your use of our Services including, but not limited to, traffic data, statistics of content uploaded, downloaded and viewed. We may make use of location data sent from Devices. You can turn off this functionality at any time by turning off the location services settings for the mobile application on the Device.
• Personalisation Data: data about your preferences while using the Website.
• Technical Data: protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and other technology on the devices you use to access the Services. We will collect your cryptocurrency wallet address. We will never ask you to share your private keys or wallet seed. You should not share these details with anyone purporting to be or act on behalf of us.
• Profile information such as your social media username.
• Job applicants: When you submit a job application, we will collect your personal information. The categories of information we may collect include your full name, email address, phone number, resume, current and previous work history, and other information about you personally and your employment history.

We do not intentionally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

How is your personal data collected?

• Registration. We collect your Identity Data and Contact Data when you register with us.
• Communications. When you communicate with us via email, chat or provide feedback, we collect your Contact Data.
• Information you generate when using our Services. Each time you access and use our Services we collect Device, Cookies and Personalisation Data. Please see our cookie notice for further details.
• Information we collect through monitoring the use of our Website and Services. Each time you access and use our Services we collect information about that access and use, being Cookies, Device and Personalisation Data.
• Direct Marketing. We collect and record Direct Marketing Data when we add you to our marketing database, you request to change your direct marketing preferences, or you interact with our direct marketing communications.
• Cookies. We use cookies (small files placed on your device) and other tracking technologies on the Website and in our direct marketing emails to improve your experience and our development of our Services. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
• Third-party plugins. Our Services may include plugins from other companies, including social media companies. These plugins may collect Personalisation Data, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.
• Third-party online tracking. We also may partner with certain third parties to collect, analyse, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels and mobile advertising IDs through the Website. This information may be used for a variety of purposes, including Website analytics.

How we use your personal data

We will only use your personal data when we have a lawful basis to do so. Our lawful basis for each purpose for which we use your personal data is specified below. Most commonly we will use your personal data in the following circumstances:

• Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by sending us a message at data@web3paymentsolutions.io or using our cookie banner (see Your legal rights below).
• Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.
• Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation.

1.1 Delivery and improvement of our Services

(The original document presents the following in a three-column table: Purpose or activity / Type of personal data / Lawful basis for processing.)

Purpose or activity	Type of personal data	Lawful basis for processing
To register you as a user of our Services	Identity Contact Device	Performance of a contract
To take steps towards providing you with Services at your request, sending you service communications	Identity Contact Device	Performance of a contract
Enforce our terms and conditions, including to collect money owed to us	Identity	Legitimate interests (to recover debts due to us)

1.2 Account management and profiling

Purpose or activity	Type of personal data	Lawful basis for processing
Combining the information we collect about you into a single customer account profile	Contact Direct marketing	Legitimate Interests (to publicise and grow our business)

1.3 Direct marketing

Purpose or activity	Type of personal data	Lawful basis for processing
To send you direct marketing communications via email, text and/or push notification	Contact Device Direct Marketing	Consent (unless soft opt-in applies, then Legitimate Interests)

1.4 Troubleshooting, improvement and security

Purpose or activity	Type of personal data	Lawful basis for processing
To administer, monitor and improve our business, Services including troubleshooting, data analysis and system testing	Identity Contact Device	Legitimate interests (running our business, IT, network and Website security, preventing misuse)
Applying security measures to our processing of your personal data	All personal data under this privacy notice	Legal obligation (Article 32 of UK/EU GDPR)
Otherwise monitoring use of the Website and deploying appropriate security measures	Contact Device	Legitimate interests (running our business, IT and network security)

1.5 Rights and obligations

Purpose or activity	Type of personal data	Lawful basis for processing
To comply with our other legal obligations, including compliance with tax legislation, judicial, law enforcement and government authorities’ requests	All personal data under this privacy notice	Legal obligations

1.6 Cookies and personalisation

Purpose or activity	Type of personal data	Lawful basis for processing
To deploy and process personal data collected via Cookies that are strictly necessary, as set out in the cookies policy	Cookies	Legitimate interests (delivering and securing our Services)
To deploy and process personal data collected via Cookies that are not strictly necessary, as set out in the cookies policy	Cookies	Consent
To deliver (personalised) advertisements to you	Personalisation	Consent

1.7 Other communications

Purpose or activity	Type of personal data	Lawful basis for processing
To notify you of changes to the Website Services and our terms and conditions for ongoing contracts	Contact	Performance of a contract / Legitimate interests
To notify you of updates to this privacy notice	Contact	Legal obligation (Articles 13/14 UK/EU GDPR)
To respond to your requests to exercise your rights under this notice	As relevant to your request	Legal obligation (Chapter 3 UK/EU GDPR)
To ask you to complete a survey and process your response	Contact	Legitimate interests (product analysis and development) / Consent if previously opted out
To otherwise respond to your enquiries, fulfil your requests and to contact you where necessary	As relevant to your enquiry or request	Legitimate interests (service our users and prospective users)

1.8 Personal data sharing

Purpose or activity	Type of personal data	Lawful basis for processing
Share personal data with our third-party providers, and business partners for purposes not otherwise set out above (see Disclosures of your personal data)	Contact	Legitimate interests (as relevant to the recipient and purpose)

1.9 Business contacts

Purpose or activity	Type of personal data	Lawful basis for processing
Process personal data relating to staff members of our business contacts, including suppliers, customers and prospects	Contact	Legitimate interests (servicing and receiving products or services in our B2B business)

1.10 Job Applications

Purpose or activity	Type of personal data	Lawful basis for processing
Process personal data relating to job applicants	Contact Identity	Consent / Legitimate Interests

Automated decision making and profiling

We do not make decisions based solely on automated processing or profiling that produce legal effects concerning you (or have similarly significant effects).

Disclosures of your personal data

• Internal third parties. Other companies who provide IT and system administration services and undertake leadership reporting.
• External third parties.
  • Service providers who provide IT and system administration services, hosting services for our Website, delivery and logistics services, payment processing, fraud and identity verification providers, customer service support, email delivery and administration, and data storage and analysis.
  • Marketing agencies and other collaborators with whom we have partnerships.
  • Our professional advisors including lawyers, auditors, insurers, and consultants who provide legal, accounting, insurance and other advisory services.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Tax authorities, regulators, law enforcement, public authorities or other third parties based in any jurisdiction where necessary to exercise our rights or comply with a legal obligation.

International transfers

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or where we rely on another established transfer mechanism.

Data retention

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

Once we no longer have a legal right to hold your personal data, we will delete or, in some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

• Access. Request access to and/or a copy of the personal data we process about you (commonly known as a data subject access request). This enables you to check that we are lawfully processing it.
• Correction. Request correction of any incomplete or inaccurate data we hold about you. (We may need to verify the accuracy of the new data you provide to us.)
• Deletion. Request us to delete or remove personal data where there is no good reason for us continuing to process it. You also can ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we have processed your information unlawfully or where we need to erase your personal data to comply with law. (In some cases, we may need to continue to retain some of your personal data where required by law. If these apply, we will notify you at the time of our response.)
• Objection. Object to us processing your personal data where (a) we are relying on legitimate interests as the lawful basis and you feel the processing impacts on your fundamental rights and freedoms, or (b) the processing is for direct marketing purposes. In some cases, we may refuse your objection if we can demonstrate that we have compelling legitimate grounds to continue processing your information which override your rights and freedoms.
• Restriction. Request that we restrict or suspend our processing of your personal data:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful, but you do not want us to erase it;
  • where we no longer require it, but you need us to hold onto it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Data portability. Request we transfer certain of your personal data to you or your chosen third party in a structured, commonly used, machine-readable format. This right only applies to information processed by automated means that we process on the lawful bases of consent or performance of a contract.
• Withdraw consent. Withdraw your consent at any time where we are relying on consent to process your personal data. Please know that this does not affect the lawfulness of any processing carried out before you withdraw your consent, and after withdrawal, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Complain to the data protection regulator. If you are unhappy with how we process your personal data, we ask that you contact us first using the details below so that we have the chance to put it right. However, you also have the right to make a complaint at any time to your regulator.

You can exercise any of these rights at any time by contacting us at: data@web3paymentsolutions.io