Privacy Policy

1. Introduction
In accordance with applicable data protection laws, Daxil provides its customers (including prospective customers), their authorized
representatives, and other related parties (“Data Subjects”) with information regarding the processing of personal data.
This Privacy Policy applies to the use of services provided via https://daxil.com.

2. Who We Are
Daxil
A service platform providing financial and payment services via Internet-based technologies, including business accounts, payment
processing, transfers, and related services.
Data Controller:
LLC All Pay Way
Registration number: 400147211
Address: Georgia, Tbilisi, 46 Vazha-Pshavela Avenue
Email: support@daxil.com

3. How We Collect Personal Data
We collect data:
● directly from the Data Subject (via website, applications, communication channels)
● from authorized third parties (e.g. business partners, service providers)
● from publicly available sources (registers, official databases, etc.)

4. What Data We Process
Personal Data
● Identification data (passport, ID, etc.)
● Contact data (email, phone)
● Address
● Photo / video (for verification)
● Device and technical data (IP, OS, identifiers)
We do not intentionally collect sensitive personal data (e.g. political views, health data, etc.)

5. Cookies
We use cookies to:
● ensure platform functionality
● improve user experience
● analyze usage
Cookies may collect:
● device data
● session data
● usage behavior

6. Purpose of Data Processing
We process data for:
● onboarding and account management
● providing business wallet and payment services
● processing transactions
● customer support
● fraud prevention and risk monitoring
● compliance with AML/CFT and legal obligations

7. KYC / KYB Verification
To comply with regulatory requirements, we perform identity verification.
We use third-party providers to:
● verify identity documents
● perform biometric verification
● conduct compliance and risk checks
Data may be shared with such providers strictly for compliance purposes.

8. Data Sharing
We may share data with:
● banks and payment institutions
● KYC/KYB providers
● regulators and authorities
● service providers and contractors
Personal data is never sold.

9. Data Processing Methods
Data is processed:
● electronically and manually
● with appropriate security measures
● to ensure confidentiality, integrity, and availability

10. Data Retention
Data is retained:
● as long as necessary for service provision
● as required by law (including AML obligations)

11. Fraud Prevention
We use automated systems to:
● monitor transactions
● detect suspicious activity
● prevent fraud
This may include automated decision-making.

12. Data Subject Rights
You have the right to:
● access your data
● correct inaccuracies
● request deletion
● restrict processing
● object to processing
● withdraw consent

13. Regulatory Disclosure
We may disclose data to:
● regulatory authorities
● law enforcement
● courts
when required by law.

14. Third-Party Services
We may use:
● Google Analytics
● Meta Pixel
These services process data according to their own privacy policies.