GeniusPay™ Apps Privacy Policy

This Privacy Policy explains how RampATM Merchant Services, Inc. ("RampATM," "we," "our," or "us") collects, uses, shares, and protects information when you use the GeniusPay™ mobile applications we publish, including the apps listed in Section 2 (each an "App" and together the "Apps").

This policy applies to our mobile Apps. Our websites may be governed by separate notices.

1. Who We Are

The Apps connect to the GeniusPay™ payment network. GeniusPay™ is part of the Ethpar network, and payments settle on the Ethpar blockchain network. Support and privacy requests are handled through Ethpar at contact@ethpar.com.

2. Apps Covered by This Policy

This policy also applies to any other App we publish that links to it.

3. How the GeniusPay™ Network Works (and Our Role)

GeniusPay™ lets merchants accept, and consumers spend, regulated payment stablecoins using bank-issued debit cards, wallets, and paper wallets.

• We are non-custodial. We do not hold customer fiat funds, stablecoin balances, or private keys. Funds move directly between the bank, merchant, and wallet.
• Merchants are independent businesses. When you pay a merchant using a GeniusPay™ App, the merchant receives your transaction details and handles its own records under its own privacy practices.
• Your card issuer verifies your identity. Identity verification (KYC) is performed by the bank that issued your card, not by us.

4. Information We Collect

We collect only what we need to operate the Apps and process payments. What we collect depends on which App you use.

4.1 Merchant Apps (e.g., GeniusPay Merchant)

Merchant and terminal information

• Merchant name, merchant ID, and the blockchain receiving address where the merchant is paid.
• Token configuration (token contract address and decimals).
• Terminal enrollment data such as terminal serial number, terminal ID, activation code, and the credentials and access tokens issued to the terminal.

Transaction information

• Sale amount, fees, total, currency or token, merchant name, destination address, terminal ID, date and time, transaction status, and transaction, preflight, approval, and network tracking identifiers.

Customer payment card information (contactless / NFC)

• When a customer taps a card, the App reads the card number over NFC into device memory only.
• The full card number is never saved on the device and is never sent to our servers in full. Before anything leaves the device, it is converted into an irreversible protected value and/or a masked number (for example, 411111**1111). These are designed so that the full card number cannot be recovered from them.
• Depending on the transaction, we may also receive the card brand, expiration date, entry mode (e.g., contactless), and the approval code returned by the card network, as needed to authorize and confirm the payment.

Paper wallet sweeps (QR codes)

• When a merchant scans a paper wallet QR code, the App reads the private key or payment code and holds it in memory only for the duration of the sweep, to move funds to the merchant's receiving address. It is not saved on the device and is not kept after the sweep ends.

Camera

• The camera is used only to scan QR codes. Video frames are analyzed on the device (using Google ML Kit's on-device barcode scanning) and are not saved or uploaded.

Bluetooth printers

• The App lists paired Bluetooth devices to connect to a receipt printer. Printer names and addresses are used on the device only and are not sent to us.

4.2 Consumer Apps

• Wallet information: public wallet addresses and token balances.
• Transaction information: payment amounts, merchant or terminal identifiers, date and time, status, and transaction identifiers.
• Payment authorizations: when you tap or scan to pay, the App signs a payment authorization on your device. Your private keys and signing credentials (such as passkeys or secure-enclave keys) remain on your device or with your chosen signer and are not sent to us.
• Contact information: only if you choose to contact us for support (for example, your name and email address).

4.3 Information Collected by All Apps

• Technical and log data: when an App connects to our servers, our servers process standard technical data such as IP address, request time, and the API endpoint called, for security, fraud prevention, and troubleshooting.
• App settings: configuration you enter into the App, stored on your device (see Section 8).

4.4 Public Blockchain Data

Stablecoin payments settle on a public blockchain. Wallet addresses, amounts, and transaction records written to a blockchain are public and permanent by design. The Apps also read public blockchain data (such as balances) to complete transactions.

4.5 What We Do Not Collect

• We do not collect your precise or approximate location.
• We do not use advertising SDKs or the Android Advertising ID.
• We do not use third-party analytics or crash-reporting SDKs.
• We do not track you across other apps or websites.
• We do not access your contacts, photos, files, messages, or call logs.
• We do not sell your personal information.

5. Device Permissions

You can deny or revoke any permission in your device settings. Some features (for example, card reading or printing) will not work without the related permission.

6. How We Use Information

We use information to:

• Process, authorize, confirm, cancel, and record payments and paper wallet sweeps.
• Enroll and authenticate payment terminals and Apps.
• Calculate and apply transaction fees.
• Print and display receipts.
• Detect, prevent, and investigate fraud, abuse, and security incidents.
• Provide customer support and respond to your requests.
• Maintain, troubleshoot, and improve the Apps and our services.
• Comply with legal, regulatory, and payment network requirements.

We do not use your information for advertising or to build marketing profiles.

7. How We Share Information

We share information only as needed to operate the Apps and the payment network:

• Payment network participants: card issuers, card networks, merchants, acquirers, and ATM operators involved in your transaction, to authorize and complete it.
• Service providers: companies that process information on our behalf, such as cloud hosting and blockchain infrastructure providers. They may use the information only to provide services to us.
• Public blockchains: transaction details written to a blockchain become publicly visible.
• Legal and safety: when required by law, regulation, subpoena, or court order, or when needed to protect the rights, property, or safety of our users, the public, or us.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this policy.
• With your consent: in any other case, only with your permission.

We do not sell personal information and do not share it for cross-context behavioral advertising.

8. Data Stored on Your Device

The Apps store limited settings in private app storage on your device, which other apps cannot access. For merchant Apps this includes the merchant name, receiving address, token configuration, and terminal enrollment credentials. Full card numbers, private keys scanned from paper wallets, and camera images are never stored on the device.

You can delete this data at any time by clearing the App's storage or uninstalling the App.

9. Data Retention

We keep transaction and enrollment records for as long as needed to provide the services, resolve disputes, prevent fraud, and meet legal, tax, accounting, and payment network requirements. When information is no longer needed, we delete or anonymize it. Records written to a public blockchain cannot be deleted by us or anyone else.

10. Security

We use reasonable technical and organizational safeguards, including encryption in transit (HTTPS/TLS), on-device protection and masking of card numbers, in-memory-only handling of sensitive values such as full card numbers and scanned private keys, and access controls on our servers. No system is completely secure, and we cannot guarantee absolute security.

11. Your Choices and Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Delete your information (subject to legal retention requirements).
• Object to or restrict certain processing.
• Receive a copy of your information in a portable format.
• Withdraw consent where processing is based on consent.
• Not be discriminated against for exercising your rights.

How to make a request (including data deletion): email contact@ethpar.com with the subject line "Privacy Request," and tell us which App you use and what you are asking for. We may need to verify your identity before acting on your request. We will respond within the time required by applicable law.

California and other U.S. states: we do not sell or share personal information as those terms are defined under California and similar state privacy laws.

EEA / UK users: we process personal information to perform our contract with you (processing payments), to comply with legal obligations, and for our legitimate interests in securing and improving our services. You may lodge a complaint with your local data protection authority.

12. Children

The Apps are intended for adults and businesses and are not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will delete it.

13. International Transfers

We are based in the United States and our servers are located in the United States. If you use the Apps from outside the U.S., your information will be transferred to and processed in the U.S., where data protection laws may differ from those in your country. Where required, we use appropriate safeguards for these transfers.

14. Changes to This Policy

We may update this policy from time to time. We will post the updated version at this URL and change the "Last updated" date. If changes are material, we will provide additional notice, such as in the App.

15. Contact Us

RampATM Merchant Services, Inc.
Publisher of the GeniusPay™ Apps
600 River Pointe Dr, Ste 200
Conroe, TX 77304-2868
United States
Email: contact@ethpar.com
Website: https://geniuspay.me · https://rampatm.com