JoPay Labs Privacy Policy
Last updated: April 20, 2026· Disclosure version 2026-04-18-draft
This Privacy Policy explains how JoPay BV, acting in its JoPay Labs (“Labs”, “we”, “us”) capacity, collects, uses, and shares information when you use the Labs interface — the website, applications, merchant dashboard, partner portal, and related operator services (collectively, the “Interface”). Operated by JoPay BV, registered in the Netherlands. Labs is the data controller for Interface-collected personal data.
This policy covers the Interface. It does not cover the JoPay Protocol itself — the immutable smart contracts that record payments on public blockchains. The Protocol is autonomous code with no operator and no data controller; a description lives in the JoPay Protocol v1 spec, and a plain-English explainer lives at /about.
If you have questions, contact us at privacy@jopay.app.
1) What we collect
A) Information you provide
Through the Interface, Labs may collect:
- Account information (e.g., name, email, business name, country, phone if provided)
- Partner application info (company details, contact person, onboarding estimates)
- Support requests (messages, screenshots, and details you share)
B) Information collected automatically
When you use the Interface, Labs may collect:
- Device and usage data (IP address, browser type, pages viewed, timestamps)
- Cookies and similar technologies (see Cookies section below)
C) Payment-related information
The Interface lets you create payment links and QR codes that direct payers to complete payment, via the Protocol, to a merchant-designated wallet. Labs may process:
- Payment request metadata you provided to the Interface (amount, description, status, timestamps)
- Public blockchain data Labs indexes to render your dashboard and receipts (e.g., transaction hash, confirmations, wallet addresses)
Note: Labs does not custody funds and does not store private keys. The Protocol, being on-chain code, is not a data controller and does not “collect” personal data in the GDPR sense — it records transactions that are public by design of the underlying blockchain.
2) What the Protocol records vs what Labs records
The JoPay Protocol and the Labs Interface record different things, under different control. This distinction matters for data rights and retention.
Protocol side (on-chain, public)
- Transactions that you or your counterparties submit to public blockchains.
- Wallet addresses, amounts, transaction hashes, block confirmations.
- Permanent. Labs does not control this and cannot erase, redact, or rewrite it.
Labs side (off-chain, Interface)
- Account info, payment-request metadata, the pay-link the merchant created before a payment happens.
- Device, usage, cookie, and support data.
- Controlled by Labs. Your data-subject rights apply here.
When we talk about access, correction, deletion, or export of your data, we mean data Labs holds about you in connection with the Interface. Labs cannot accept a request to change or remove information recorded by the Protocol on a public blockchain, because that information is outside Labs’ control and is public by design.
3) How we use your information
Labs uses Interface data to:
- Provide and operate the Interface (account access, payment link creation, tracking)
- Route you to the correct portal (Labs or your partner) when you log in
- Communicate with you (service messages, support responses)
- Improve the Interface (analytics, debugging, performance)
- Prevent fraud, abuse, and security incidents
- Comply with legal obligations that apply to Labs as an Interface operator
4) Legal bases (EEA/UK)
If you are in the EEA/UK, Labs processes personal data under one or more of these bases:
- Contract (to provide the Interface services you request)
- Legitimate interests (security, fraud prevention, basic service improvement)
- Consent (marketing analytics cookies and tracking, where required)
- Legal obligation (compliance, record-keeping)
5) How we share information
Labs may share information with:
- Service providers (hosting, analytics, email delivery, customer support tools)
- Partners (if you are onboarded/managed by a partner, to provide support and Interface services)
- Compliance and verification providers (if KYC/KYB is required for Interface features like cash-out or higher limits)
- Legal authorities (if required by law)
We do not sell your personal data.
6) Cookies and analytics
The Interface uses cookies and similar technologies to:
- keep you signed in (where applicable),
- understand usage,
- improve site performance.
You can control cookies through your browser settings. We use analytics cookies only when you consent. We may also use limited third-party cookies for anti-bot and spam reduction on public forms.
Cookies used: jopay_mkt_consent (preference), jopay_mkt_session, jopay_mkt_anon, jopay_mkt_ft, jopay_mkt_lt
Providers: Primarily first-party analytics; limited third-party cookies may be used for anti-bot and spam protection.
Analytics preference
You can update your analytics consent at any time.
7) Data retention
Labs retains Interface personal data only as long as necessary for:
- providing the Interface,
- legal and compliance obligations that apply to Labs,
- resolving disputes and enforcing agreements.
Retention periods may vary by data type.
On-chain data: information recorded by the Protocol on public blockchains is retained by the blockchain indefinitely, not by Labs. Labs cannot set a retention period for on-chain data.
8) Security
Labs uses reasonable administrative, technical, and physical safeguards to protect Interface data. However, no method of transmission or storage is 100% secure.
Wallet security: You are responsible for securing your wallet and private keys. Labs does not store private keys and cannot recover a wallet whose keys have been lost or compromised.
9) International transfers
Your Interface information may be processed in countries other than your own. Where required, Labs uses appropriate safeguards for international transfers (e.g., Standard Contractual Clauses).
10) Your rights (EEA/UK)
Depending on your location, you may have rights regarding Interface data Labs holds about you, including rights to:
- access, correct, or delete your personal data,
- object to or restrict processing,
- data portability,
- withdraw consent (where processing is based on consent),
- lodge a complaint with a supervisory authority.
Scope of rights: These rights apply to data Labs controls as operator of the Interface. Labs cannot erase or alter records kept by the JoPay Protocol on public blockchains — those records are outside Labs’ control and are public by design of the blockchain itself. A request to Labs to “delete a blockchain transaction” cannot be honoured by Labs because Labs does not control the blockchain.
To exercise rights, contact privacy@jopay.app or submit a request below.
Privacy request form
We will respond within 30 days. Please use the email you want us to contact.
11) Children
The Interface is not intended for children under 18. Labs does not knowingly collect data from children.
12) Partner and third-party services
Partners and third parties (wallets, networks, cash-out providers) may process data under their own policies. Your use of those services is governed by their terms and privacy policies. The blockchains the Protocol runs on are public networks not operated by Labs.
13) Changes to this policy
We may update this Privacy Policy from time to time. We will post updates and revise the “Last updated” date and disclosure version.
14) Contact
Email: privacy@jopay.app
Address: Amsterdam, The Netherlands
Data Controller: JoPay BV (acting in its JoPay Labs capacity)