Privacy Policy

Last updated: June 3, 2025

This policy explains what the Client may expect from Ilumapay and what Ilumapay needs from the Client in relation to personal data provided by the Client. Please read this carefully as this policy is legally binding when the Client uses Ilumapay Services. Unless the context otherwise requires, each capitalized term used but not defined herein shall have the meaning ascribed to it in the General Terms and Conditions.

If there are any questions about how Ilumapay protects or uses the data, please contact support@ilumapay.com.

1. How We Protect Your Personal Information

1.1 We are serious about guarding the security of your personal information and use secure servers to store your personal information. All information you provide to us is stored on our secure servers.

1.2 We restrict access to your personal information to employees of Ilumapay who have a business reason to access such information. We continuously educate and train our employees about the importance of confidentiality and customer data privacy. We maintain physical, electronic, and procedural safeguards that comply with relevant laws and regulations to protect your personal information from unauthorized access.

2. Information We May Collect From You

2.1 Information You Give Us

(a) You may provide us with personal details such as name, email address, phone number, identification documents, and other related information when signing up or continuing to use Ilumapay Services. This includes information provided via support interactions, surveys, or other features. It may also include your wallet activity, balance, and card issuance data.

(b) We may request additional commercial and/or identification information from you, especially in cases involving high-value or high-volume transactions, or to meet our anti-money laundering obligations under applicable law.

(c) If you provide personal data of any individual to us, you confirm that you have obtained their informed and explicit consent for our collection, use, and disclosure of such data in accordance with this Privacy Policy. You agree to provide proof of such consent upon our request.

2.2 Information We Collect About You

We may automatically collect:

(a) details of transactions you conduct using Ilumapay Services;
(b) technical data such as IP address, device details, and session metadata;
(c) in-app activity logs and website usage metrics.

2.3 Information We Receive From Other Sources

We may receive personal data from trusted third-party providers, including:

Sumsub (identity verification)
Interlace.money (card issuance)

These parties may access your data from outside of Hong Kong for service delivery purposes, although your data is stored in Hong Kong.

3. Cookies

Ilumapay does not use cookies or tracking technologies on our website or app.

4. Uses of Your Information

We use your information to:

(a) fulfill our contractual obligations and provide requested services;
(b) meet legal and regulatory requirements;
(c) notify you about changes to Ilumapay Services;
(d) ensure the security and integrity of Ilumapay Services;
(e) operate, maintain, and troubleshoot the Services;
(f) improve the effectiveness and usability of the Services;
(g) send marketing communications if you have explicitly opted in (via the app or written request);
(h) enable interactive features when you choose to use them.

5. Disclosure of Your Information

5.1 We may share your data with:

(a) KYC and card issuance providers (Sumsub and Interlace.money);
(b) business partners, suppliers, or contractors in connection with service performance.

5.2 We may disclose your information:

(a) to meet legal obligations or enforce agreements;
(b) to protect Ilumapay's rights, property, or users' safety;
(c) during investigations into suspected or actual unlawful activities;
(d) to recover debts or manage financial risk;
(e) in the event of a merger, acquisition, or asset sale.

6. Where We Store Your Data

All data is stored securely in Hong Kong. We do not transfer your data outside of Hong Kong for storage purposes, though third-party providers may access it from other locations to perform services.

7. International Data Access

Your data may be accessed from jurisdictions outside of Hong Kong by our verified service providers strictly for operational purposes. All such access is governed by contractual safeguards to ensure compliance with Hong Kong privacy standards.

8. Profiling and Automated Decision-Making

Ilumapay does not perform profiling or automated decision-making for marketing or user eligibility. Risk-based monitoring may be conducted in compliance with legal requirements (e.g., fraud or AML checks).

9. Data Retention

9.1 As a regulated financial institution, Ilumapay retains certain data beyond account closure as required by law.

9.2 We regularly review data retention periods and delete personal data no longer legally required.

9.3 Personal data is retained only as long as necessary to meet regulatory, legal, or operational requirements.

10. Your Rights

10.1 You may opt out of marketing communications through in-app settings or by contacting support@ilumapay.com.

10.2 You may correct any inaccurate or outdated information we hold.

10.3 You may request deletion of data when no longer necessary or legally required.

10.4 You may request the transfer of your personal data to another controller.

10.5 Ilumapay Services may include links to third-party websites, which are governed by their own privacy policies. Please review those policies before submitting data.

11. Access to Information

Subject to applicable laws, you may request a copy of your personal data held by Ilumapay. Requests can be made via support@ilumapay.com or in-app support tools.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page and, where appropriate, notified via email. Please review it periodically for any changes.

Version: 1.1

Effective Date: June 3, 2025