PRIVACY POLICY
This Privacy Notice for Pay Airo Inc('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
• Visit our website at https://payairo.com, or any website of ours that links to this Privacy Notice.
• Use Pay Airo. PayAiro is a forward-thinking payment infrastructure company designed to bridge the gap between traditional finance and the digital economy. With a focus on empowering businesses and individuals, PayAiro delivers a seamless, secure, and scalable ecosystem for managing transactions across fiat and cryptocurrency. At the core of our platform is the PayAiro Token, enabling instant, multi-currency payments and conversions. Our infrastructure integrates robust APis, real-time exchange services, and compliance with U.S. regulatory standards, making it the go-to solution for e-commerce, retail, and financial institutions. PayAiro's mission is to simplify the complexities of payments, offering merchants and users an intuitive experience while fostering financial inclusion. By combining cutting-edge technology with a commitment to innovation, PayAiro is shaping the future of payments-one transaction at a time.
• Engage with us in other related ways, including any sales, marketing, or events.
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at grievances@payairo.com .
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do we collect information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
In what situations do we share personal information with third parties? We may share information in specific situations such as to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. and with specific third parties mentioned in this policy.
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
TABLE OF CONTENTS
For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below. These definitions are intended to provide clarity and consistency in interpreting the rights and obligations under this Privacy Policy:
government-issued identifiers (such as Social Security Number or Employer Identification Number), account login credentials, geolocation data, biometric data, and internet or device identifiers such as IP address.
use, disclosure, analysis, modification, transfer, or deletion.
Personal information you disclose to us
We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
• Names
• phone numbers
• email addresses
• usemames
• passwords
• debit/credit card numbers
• Wallet Addresses
• Tax identification numbers (SSN or EIN)
• Retirement Account details
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
• financial data
• biometric data
• credit worthiness data
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Some information such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical infonnation. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: payairo.com/cookies.
• Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports. (sometimes called 'crash dumps'), and hardware settings).
• Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data: We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.
However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Our use of information received from Google APis will adhere to Google API Services User Data Policy, including the Limited Use requirements.
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
• To facilitate account creation and authentication and otherwise manage user accounts: We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user: We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users: We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To fulfil and manage your orders: We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications: We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback: We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To deliver targeted advertising to you: We may process your information to develop and display personalised content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: payairo.com/cookies.
• To protect our Services: We may process your information as part of our efforts to Keep our Services safe and secure, including fraud monitoring and prevention.
• To evaluate and improve our Services, products, marketing, and your experience: We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To identify usage trends: We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns: We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To comply with our legal obligations: We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
• To comply with KYC/AML regulations: We may process your information to comply with our KYC/AML regulations (e.g. BSA/FinCEN), assess investment eligibility and support automated decision making (with manual opt-out rights)
We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Custodians: We may share your information with custodians and identity/payment providers
Third-Party Service Providers
To deliver our Services, we partner with trusted third-party service providers who assist us in processing payments, verifying identities, safeguarding assets, and providing infrastructure support. We only share the minimum necessary information with such providers and require them to handle your data in accordance with this Privacy Policy and applicable laws.
The main service providers we currently use include:
We do not allow our service providers to use your personal information for their own marketing or unrelated purposes. They are contractually obligated to use the information we share only to provide services to us and to implement reasonable security measures to protect your data.
Information about our third party service providers can be found at Disclosure.
We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.
The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or
applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.
We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: payairo.com/cookies.
Yes. As part of our Services, we may provide products, features, or tools powered by artificial intelligence ("AI"), machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to improve user experience, enable automation, and support secure and efficient payment operations.
• We may use AI to assist with identity verification, fraud detection, transaction monitoring, customer support, and personalization of our Services.
• AI may also be used for analytics, automation, and blockchain-related applications in line with our business model.
Our AI Products may rely on third-party providers, including OpenAI and other AI vendors, to process user inputs and generate outputs. This means that information you submit through AI-powered features (such as text, voice, or image inputs) may be shared with these providers. These providers are contractually obligated to use such information only for the purpose of enabling AI functionality and in accordance with applicable data protection requirements.
We do not use AI to build personal profiles of users unless you have provided explicit consent. However, user inputs and outputs submitted to AI Products may be temporarily stored by us and/or our AI Service Providers to:
• Improve service performance,
• Ensure security and compliance, and
• Detect abuse or misuse.
W here possible, inputs are either anonymized or pseudonymized before further processing.
Use of AI Products is optional, and you will be asked to provide explicit consent before engaging with features that use AI. If you do not wish your data to be processed by AI technologies, you may opt out by:
• Adjusting your account settings; or
• Contact us at
Opting out of AI Products may restrict certain features or enhancements.
You must not use AI Products to input sensitive or confidential information unless explicitly required for a Service (e.g., identity verification). By using AI Products, you acknowledge that your information may be processed by third-party AI providers under the safeguards described in this Privacy Policy.
Our Al Products
Our Al Products are designed for the following functions:
• Al automation
• Al applications
• Blockchain
How We Process Your Data Using Al
All personal information processed using our Al Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.
We retain Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The retention period depends on the type of data, the purpose for which it is collected, and applicable legal or regulatory requirements.
When the retention period expires, we will securely delete or anonymize the data so that it can no longer reasonably identify you. If deletion is not immediately possible (e.g., because of technical or legal constraints), we will isolate and securely store the data until deletion is feasible.
We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, So we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you - for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:
• Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services. For further information, please see our Cookie Notice: payairo.com/cookies.
If you have questions or comments about your privacy rights, you may email us at grievances@payairo.com .
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, lowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have the following categories of personal information that we collect:
|
S.NO |
CATEGORY |
EXAMPLES |
|
A. |
Identifier's |
Contact details- such as real name, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name. |
|
B. |
Personal Information as defined in the California Customer Records Statue |
Name, contact information, education, employment, employment history and financial information |
|
C. |
Protected Classification characteristics under state or federal law |
Gender, age, date of birth, race and ethnicity, national origin, marital status and other demographic data |
|
D. |
Commercial Information |
Transaction information, purchase history, financial details and payment information |
|
E. |
Biometric Information |
Fingerprints and Voiceprints |
|
F. |
Internet or other similar network activity |
Browsing history, search history, online behaviour, interest data and interactions with our and other websites, applications, systems and advertisements |
|
G. |
Geolocation Data |
Device Location |
|
H. |
Audio, electronic sensory or similar information |
Images and audio, video or call recordings created in connection with our business activities |
|
I |
Professional or employment-related information |
Business contact details in order to provide you our Services at a business |
|
|
|
level or job title, work history and professional qualifications. |
|
J. |
Education Information |
Students records and directory information |
|
K. |
Inferences drawn from collected personal information |
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, For example, an individual's preferences and characteristics. |
|
L. |
Sensitive Personal Information |
Account Login Information, biometric data, citizenship or immigration status, contents of email or text messages, debit or credit card numbers, financial information including account access details, precise geolocation and state id card numbers |
We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
• Category H - As long as the user has an account with us
• Category L - As long as the user has an account with us
How We Use and Share Personal Information
Your personal information may be used in profiling and automated processes that could produce legal or similarly significant effects for you.
Will your information be shared with anyone else?
We may disclose your personal infonnation with our service providers pursuant to a written contract between us and each service provider.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.
We have not and would not disclose, sell, or share any personal information to third parties for a business or commercial purpose in the past. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
• Right to know whether or not we are processing your personal data.
• Right to access your personal data.
• Right to correct inaccuracies in your personal data.
• Right to request the deletion of your personal data.
• Right to obtain a copy of the personal data you previously shared with us.
• Right to non-discrimination for exercising your rights.
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under relevant state privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling').
Depending upon the state where you live, you may also have the following rights:
• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota's privacy law).
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law).
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota's and Oregon's privacy law).
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota's privacy law).
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law).
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law)
Opting out may restrict certainfeatures or enhancements.
To exercise these rights, you can contact us via email: grievances@payairo.com or by referring to the contact details at the bottom of this document.
We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.
Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with applicable laws.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at grievances@payairo.com.
We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
Our Services are not directed to individuals under the age of 18. We do not knowingly collect, maintain, or use Personal Information from anyone under 18, in compliance with the Children's Online Privacy Protection Act (COPPA).
If we become aware that we have inadvertently collected Personal Information from a minor under 18, we will promptly delete such information from our records.
If you are a parent or legal guardian and believe that your child under 18 has provided Personal Information to us without your consent, please contact us at grievances@payairo.com so that we can take appropriate action.
Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
This Privacy Policy shall be governed by and construed in accordance with the laws of the United States of America, including all applicable federal privacy and data protection laws (including but not limited to the Gramm-Leach-Bliley Act (GLBA), the Children's Online Privacy Protection Act (COPPA), the Bank Secrecy Act/FinCEN requirements, together with the applicable state laws, without regard to its conflict of law principles.
For residents of states that have enacted specific privacy statutes including, but not limited to, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), the Utah Consumer Privacy Act (UCPA), and similar state laws this Privacy Policy is intended to comply with, and shall be interpreted consistently with, those requirements. Where applicable, we will extend comparable rights and protections to residents of other U.S. states to the extent required by law.
Any disputes arising out of or related to this Privacy Policy or our data practices shall be subject to the exclusive jurisdiction of the state courts of Texas and the federal courts located within Texas, unless otherwise required by applicable state privacy law.
Interpretation
• Any terms not expressly defined in this Privacy Policy shall be interpreted in accordance with their meaning under applicable U.S. privacy and data protection laws.
• In the event of a conflict between this Privacy Policy and any mandatory provisions of applicable law, the latter shall prevail.
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at grievances@payairo.com or contact us by post at:
Pay Airo INC USA
880, West Euless Blvd Euless, Texas 76040
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to processing of your personal information. These rights may be limited in some circumstances by applicable law. To request review, update, or delete your personal information, please contact: grievances@,payairo.com .
Last Updated: on October 28th, 2025