Privacy Policy
EasyPay – Digital Wallet
Last Updated: 24 July 2025

Who We Are
LLC “EasyPay” is a payment service provider registered in Georgia and licensed by the National Bank of Georgia. We operate a digital wallet platform that offers the following services:

• QR code payments
• Domestic and international money transfers
• Currency conversion
• Card-related services

We operate in strict compliance with the applicable laws of Georgia, including the Law on Personal Data Protection, and adhere to international data protection standards such as the General Data Protection Regulation (GDPR) and UK GDPR. Our regulatory authority is the National Bank of Georgia.

What Data We Collect

EasyPay collects only the data that is necessary for the proper functioning of the platform. This includes:

• Identification Data: Full name, personal identification number, date of birth
• Contact Information: Phone number, email address
• Financial Information: Account balances, payment history, transaction records
• Required Documentation: Identity document, selfie (for KYC verification purposes)
• Device Information: Device ID, model, operating system, app version
• Geolocation Data (Optional): Collected only with your explicit consent
• QR Scanning Data: Used exclusively within the app for processing payments

How We Use Your Data

Your personal data is used for the following purposes:

• Identification and Registration: To verify your identity and comply with KYC (Know Your Customer) and AML ( Anti-Money Laundering) requirements
• Transaction Processing: To execute payments, money transfers, and currency conversions
• QR Payment Processing: To facilitate payments made via QR code within the application
• Secure Processing of International Transfers: To ensure the safe and compliant transfer of funds across borders
• Development and Improvement of Financial Services: To enhance and expand the services offered through our platform
• Regulatory Compliance: To fulfill obligations under applicable Georgian legislation and regulatory standards
• Customer Communication: To improve and streamline communication with you as a user

Camera Access

The application requests access to your camera solely for the following purposes:

• Scanning QR Codes: For making payments or receiving funds
• Taking Selfies or Choosing Photos from Your Device’s Photo Library - We request access to your camera or photo library only to allow you to set a profile picture, and only if you choose to do so. We do not process or store any photos outside of the application without your explicit consent.

Who Has Access to Your Data

Your personal data is not shared with third parties, except in the following cases:

• Legal Requirements: When disclosure is required by law or regulation (e.g., in accordance with regulations set by the National Bank of Georgia)
• Transaction Processing: When necessary to complete a transaction (e.g., partner banks, payment systems)
• Trusted Technology Partners: When involving third-party service providers (e.g., hosting providers, KYC verification partners) who are contractually bound to maintain confidentiality and comply with data protection obligations

Your Rights Under Data Protection Laws

In accordance with the Law of Georgia on Personal Data Protection and, where applicable, the General Data Protection Regulation (GDPR/UK GDPR), you have the following rights regarding your personal data:

• Right of Access: You may request confirmation as to whether your personal data is being processed and obtain access to such data, subject to legal and regulatory limitations.
• Right to Rectification and Erasure: You may request the correction or deletion of your personal data; however, certain data must be retained to comply with legal or regulatory obligations, including those imposed by the National Bank of Georgia (NBG).

Important: Please note that if you request the deletion of essential personal data required for the provision of services (such as identification information necessary for KYC/AML compliance), this may result in the termination of your access to the EasyPay platform and the immediate termination of the service agreement.

• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Please note: Certain rights may be restricted where the processing of personal data is necessary to comply with legal or regulatory requirements, including those set forth by the National Bank of Georgia, such as anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. In such cases, we are obliged to retain and process your data accordingly, notwithstanding any deletion requests.

How to Exercise Your Rights

You may exercise your rights by contacting us through the following channels:

📩 Email: support@easypay.ge
📱 Phone: +995 32 2 050 767
🌐 Website: https://wallet.easypay.ge

Data Storage and Security

Your personal data is stored securely in encrypted form on certified servers located within the jurisdiction of Georgia.

The following security measures are implemented to protect your data:

• End-to-End Encryption
• Multi-Factor Authentication (MFA)
• Regular Data Backup and Archiving
• Servers are located in the jurisdiction of Georgia

Data Sharing

Your personal data is not disclosed to third parties, except in cases required by law or when necessary to provide the service in cooperation with our trusted partners, including:

• Credit institutions
• Payment systems
• International remittance providers
• Law enforcement authorities (only as required by law)

Data Retention Period

• Your personal data is retained for the duration specified by Georgian legislation or for as long as necessary to maintain the active status of your account.

Automated Decision-Making and Profiling

EasyPay’s security systems may automatically assess suspicious activities (e.g., unusual transactions or locations) and temporarily suspend transactions or block accounts.

However, legally or materially significant decisions affecting the user are never made solely on the basis of automated processing — human intervention is always ensured.

This practice complies with the GDPR and Georgian personal data protection legislation and field legislation.

You have the right to request a review and explanation of any automated decision affecting you.

Marketing Communications

You may opt out of receiving marketing communications at any time via our app or by contacting us via email.

International Data Transfers

If your data is transferred to service providers operating within the European Union or other countries, such transfers will be carried out only under appropriate safeguards in accordance with GDPR standards.