Effective date: 15th Sept 2025
 Company name: Ciro Pay Ltd (“we”, “us”, “our”)
 Company number: 15090013
 Registered office: 251 Gray’s Inn Road, London, England, WC1X 8QT

We respect your privacy and are committed to protecting your personal data. This Privacy & Cookie Policy explains how we collect, use, disclose and safeguard your information when you visit our website, use our services, or otherwise interact with us.

1. Information We Collect

We may collect and process the following types of personal data:

• Identity data: name, job title, company.
  
  
• Contact data: email address, telephone number, postal address, Telegram/LinkedIn contact.
  
  
• Transaction data: details of payments made through our services.
  
  
• Technical data: IP address, browser type, operating system, device identifiers, website usage statistics.
  
  
• Marketing data: preferences for receiving updates from us.
  
  

We do not intentionally collect sensitive personal data unless required by law or regulation (e.g. for compliance with anti-fraud and AML obligations).

2. How We Use Your Information

We process personal data for the following purposes:

• To provide our payment processing and related services.
  
  
• To communicate with you regarding enquiries, onboarding, and support.
  
  
• To comply with legal, regulatory, and anti-fraud obligations.
  
  
• To improve our website, services, and user experience.
  
  
• To send marketing or business updates (only where lawful and consented).
  
  

3. Lawful Basis for Processing

We process your personal data under the following legal bases:

• Contractual necessity – to perform the services you request.
  
  
• Legal obligation – to comply with applicable regulations.
  
  
• Legitimate interests – to operate and improve our business.
  
  
• Consent – where required for marketing or optional communications.
  
  

4. Sharing of Data

We may share your personal data with:

• Our acquiring banks, payment partners, and service providers (for service delivery).
  
  
• Professional advisers (lawyers, auditors, consultants).
  
  
• Regulators, tax authorities, or law enforcement where required by law.
  
  
• Potential acquirers or investors in connection with corporate transactions.
  
  

We do not sell your data to third parties.

5. International Transfers

Where personal data is transferred outside the UK/EEA (e.g. to payment partners), we ensure adequate safeguards are in place, such as UK GDPR-approved standard contractual clauses.

6. Data Retention

We retain your data only for as long as necessary:

• Customer and transaction records – minimum 5 years (for compliance).
  
  
• Marketing and business contacts – until you opt-out or request deletion.
  
  

7. Your Rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
  
  
• Request correction of inaccurate or incomplete data.
  
  
• Request erasure of data (where legally possible).
  
  
• Restrict or object to processing.
  
  
• Data portability (to receive your data in a machine-readable format).
  
  
• Withdraw consent at any time (where processing is based on consent).
  
  

To exercise these rights, please contact us at [insert contact email].

8. Cookies

This website uses cookies to improve your browsing experience and analyse site usage. These are essential cookies only and do not include marketing or tracking cookies.

By continuing to use this website, you agree to our use of cookies. For more information, please see this Privacy & Cookie Policy.

9. Security

We use appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, misuse, or alteration.

10. Contact Us

If you have any questions about this Privacy & Cookie Policy or how we handle your data, please contact:

Data Protection Officer (DPO)
 Ciro Pay Ltd
 Email: payments@pedrogate.com
 Address: 251 Gray’s Inn Road, London, England, WC1X 8QT

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.