Privacy Policy
Last Updated: [2026-01-01]
This Privacy Policy (“Policy”) explains how PengoPay collects, uses, discloses, and protects information in connection with the services provided under the PengoPay brand (the “Services”).
PengoPay is operated by Pengo Technologies Ltd, a company incorporated in Abu Dhabi Global Market (ADGM) (“Pengo”, “we”, “us”, or “our”).
By accessing or using the Services, you acknowledge that you have read and understood this Policy.
Scope of This Policy
This Policy applies to information collected through:
the PengoPay website;
applications, dashboards, or APIs operated by PengoPay;
communications with users in connection with the Services.
This Policy does not apply to third-party services, including blockchain networks or wallet software providers, that are not operated by PengoPay.
Non-Custodial Nature of the Services
PengoPay is a non-custodial technology platform.
PengoPay does not hold, store, or safeguard user digital assets.
PengoPay does not control or have access to users’ private keys, seed phrases, or wallet credentials.
All digital asset transactions are initiated and executed directly by users through their own self-custodial wallets on public blockchain networks.
As a result, PengoPay does not collect or store sensitive wallet credentials or private key information.
Information We Collect
3.1 Information You Voluntarily Provide
We may collect limited information that you voluntarily provide, such as:
business or contact information (e.g., company name, email address);
communications sent to us (support requests, inquiries, or feedback).
PengoPay does not require users to submit government-issued identification documents or undergo full customer identity verification (KYC) as part of standard service access.
3.2 Technical and Usage Information
We may automatically collect limited technical information necessary to operate and secure the Services, including:
IP address or approximate location (for security, compliance, and restricted-jurisdiction controls);
device, browser, and system information;
timestamps, logs, and interaction records related to the use of the Services.
This information is collected on a minimal and proportional basis and is not used for advertising or profiling.
3.3 Blockchain-Related Information
Transactions facilitated through the Services may be recorded on public blockchain networks.
PengoPay does not control, modify, or delete data recorded on a blockchain. Any information made publicly available via a blockchain is governed by the applicable blockchain network protocols.
How We Use Information
We use collected information solely for legitimate operational, security, and compliance purposes, including to:
operate, maintain, and improve the Services;
provide user support and respond to inquiries;
ensure platform integrity, security, and abuse prevention;
comply with applicable legal and regulatory obligations, including anti-money laundering (AML) requirements where applicable;
enforce our Terms of Service and related agreements.
PengoPay does not sell personal data or use data for advertising, marketing profiling, or behavioral tracking.
Legal Basis for Processing
Where applicable, we process information based on one or more of the following legal grounds:
performance of a contract or provision of requested services;
compliance with legal or regulatory obligations;
legitimate interests in operating a secure, reliable, and compliant technology platform.
Data Sharing and Disclosure
We may share limited information only in the following circumstances:
with service providers that support our infrastructure, security, or compliance operations;
where required by applicable law, regulation, or lawful request from a competent authority.
PengoPay does not share user information with third parties for advertising or commercial data-monetization purposes.
International Data Transfers
As a global technology platform, PengoPay may process information in multiple jurisdictions.
Where information is transferred across borders, we implement reasonable safeguards designed to protect data in accordance with applicable data protection principles.
Data Retention
We retain information only for as long as necessary to:
provide and secure the Services;
comply with applicable legal, regulatory, or contractual obligations;
resolve disputes and enforce agreements.
Retention periods vary depending on the nature of the information and applicable laws.
Data Security
PengoPay implements technical and organizational measures designed to protect information against unauthorized access, loss, misuse, or alteration.
However, no digital system can be guaranteed to be completely secure. Users acknowledge the inherent risks associated with the use of internet-based and blockchain-based technologies.
Restricted Jurisdictions
The Services are not available to users located in certain jurisdictions, including Singapore and the United States, as further described in the Terms of Service.
Users are responsible for ensuring that their use of the Services complies with applicable local privacy and data protection laws.
Your Rights
Depending on your jurisdiction, you may have certain rights regarding your information, including the right to request access, correction, or deletion of information we hold about you.
Requests may be submitted by contacting us using the details below. We may require additional information to verify and process such requests.
Changes to This Policy
We may update this Policy from time to time. Any changes will be posted on our website with an updated “Last Updated” date.
Continued use of the Services after any update constitutes acceptance of the revised Policy.
Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact:
Pengo Technologies Ltd: [email protected]
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