Privacy Policy

“DRAGON INNOVATE LIMITED” LLC, a company incorporated and established under the laws of Hong Kong, with registration code  76406747, registered at Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central Hong Kong, 999077(“TalentPay” hereinafter), accessible from https://talentpay.io/ (referred to as “Website”) one of our main priorities is the privacy of our visitors and users.

This Privacy Policy describes how TalentPay (referred to as “we”, “our” hereinafter) collects, stores, uses, and discloses your Personal Data in accordance with the applicable law. The most relevant version of Privacy Policy is on our website  at this link.

“Personal Data” means any information relating to an identified or identifiable individual, including “Personal Information” under the General Data Protection Regulation (2016/679) (“GDPR”).

We collect only the minimum amount of personal data necessary for the purposes described in this Privacy Policy.

This Privacy Policy applies to all visitors, users, and others who access our products (collectively referred to as “Services”) and governs the information you provide to or share with TalentPay, taking into account different provisions depending on how you interact with the Website.

For the purposes of this Privacy Policy, “Services” also include interactions through messaging platforms, including but not limited to Telegram, where TalentPay may provide support or automated responses via AI-powered chatbots.

1. Consent

Please read this Privacy Policy carefully before using the Website. Your access to and use of the Services is conditioned on your acceptance of and compliance with this Privacy Policy.

For users who visit the Website for informational purposes (without registration):

By accessing our Website, you agree to the use of Cookies as described in this Privacy Policy. No Personal Data is collected or processed unless you register or interact with specific features of the Website that require such data. If you do not agree with the use of Cookies, you may manage your Сookie preferences through your browser settings. Your use of the Website signifies your acceptance of the use of Cookies in accordance with this Privacy Policy.

For users who register on the Website:

By accessing our Services, including registration, you expressly consent to the collection and processing of your Personal Data as described in this Privacy Policy. This consent is provided by actively confirming it during registration (by checking the checkbox). You may withdraw your consent at any time by contacting us. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

2. The categories of Personal Data we collect

a. Information you give to TalentPay

b. Information that TalentPay receives from your use of our Services

In order to provide you with access to and use of our Services, we collect and process the following categories of Personal Data that you provide to us during registration or in the course of using the Services:

• Full name (first name and last name)

• Phone number

• Email address

• Bank statement confirming the existence of a bank account

• Bank account details (including account number and name of the bank)

• Tax Residency Certificate (TRC)

• Actual residential address

• Identification numbers

• Passport details

• Diploma

• Residence permit

• Insurance certificate

• Marriage certificate

• Children's birth certificate

• Employment record book

• Name change certificate

• Professional skills, descriptions of completed work

• Cookies.

This information is necessary to verify your identity, ensure compliance with applicable legal and regulatory requirements, and to facilitate the secure and lawful provision of our Services. The processing of this data is based on Article 6(1)(b) and 6(1)(c) of the GDPR, as it is necessary for the performance of a contract and for compliance with legal obligations to which we are subject.

c. Information collected via messaging platforms and AI chatbots

When you interact with us via messaging platforms (such as Telegram), we may collect and process the following data:

• Username, display name, and user ID within the messaging platform

• Content of messages and inquiries you send to the chatbot

• Technical metadata (such as timestamps, interaction logs)

• Any Personal Data you voluntarily provide during such communication

This data is used solely to provide responses, improve our Services, and ensure proper functioning of the chatbot.

We use AI-powered chatbots to provide automated responses regarding the use of our Services.

Such chatbots:

Users are advised not to rely solely on chatbot responses.

Information for Providing our Services

When you use our Services, you may provide us with certain information that may qualify as Personal Data under applicable data protection laws, including GDPR. This information may be provided during registration, communication with our support team, filling out forms, uploading documents, or using other functionalities within the Services.

We emphasize that you are solely responsible for the content of the information you choose to provide to us. Please do not submit any Personal Data that is not necessary for the use of our Services.

Please note that by submitting any such information, you acknowledge that you understand the purpose of its processing, and you confirm that you have the authority to provide this data, especially in cases where it concerns third parties (e.g., in corporate or joint use scenarios).

If you have any doubts about which data is necessary or appropriate to submit, we encourage you to contact our support team before sharing any sensitive information.

We may collect and process marketing and communications data such as your preferences in relation to receiving marketing information from us. This also applies to the way we communicate with you when you give us your Personal Data by filling in forms corresponding with us by e-mail, or otherwise when you request marketing materials. We may also ask you to subscribe to receive newsletters. We will only process your data for the purposes in this Privacy Policy if we are allowed to do so under applicable law (because you consented to it or otherwise).

We will not use your personal data for direct marketing purposes without your explicit opt-in consent. You may opt out of receiving marketing communications at any time, free of charge.

Information that TalentPay receives from your use of our Services

TalentPay uses Cookies and similar technologies to provide, improve, secure, and promote its Services.

What are Cookies?

A Сookie is a small piece of information that is downloaded to your computer or mobile device, enabling certain functions. Cookies make it easier and more convenient to use websites and applications and provide a more personalized user experience.

TalentPay uses both first-party and third-party Cookies.

We use Google Analytics to gather overall Website statistics and track performance over time. Before using the Website, please review Google Analytics' privacy policy. If you wish to stop your data from being used by Google Analytics, you can easily opt out by following this link.

In addition to Cookies, we use or plan to use similar technologies, such as integration with electronic document management systems, Singnow, and API integrations.

- Pixel tags – snippets of code from third-party companies embedded in websites and emails.

- Integration with electronic document management systems allows for the exchange of documents and information in digital format. This speeds up document processing and signing, making them secure and convenient for users.

- Singnow is an electronic signature platform that helps users sign documents online, ensuring their legal validity and security.

 API Integrations are used to connect to various external Services and systems. APIs allow our platforms to exchange data with other software products, enhancing the functionality and flexibility of our Services.

Note: For simplicity, all these technologies are referred to as“Cookies” in this document.

How does TalentPay use Cookies?

TalentPay uses various categories of Cookies to provide Services, protect users, improve Website functionality, and promote products. Personal Data is stored only for as long as necessary for the specified purposes.

Strictly Necessary Cookies

These Cookies are essential for the operation of the Website and Services.

Category

Purpose

Data Types

Retention Period

Name

Strictly Necessary

Ensures the Website functions (authentication, security)

Authentication data, unique ID

24 hours

talentpay_session

Non-Essential Cookies

These Cookies are not required for the Website’s operation but are used when interacting with the Website:

Category

Purpose

Data Types

Retention Period

Third-Party

Providers

Name

Analytics

Cookies that help us and our partners understand how the Websites are used — e.g., through statistics or UI recovery — to improve and personalize services, identify technical issues.

Session and user data, encrypted session and analytics data, first visit timestamp, ad blocker detection, unique visitor ID, session replay and heatmaps, browser ID for analytics.

From 7 hours to 1 year 5 months

Advertising

Used to understand user interests and promote services based on collected information

Ad identifiers, unique user IDs, session data, cross-domain sync parameters, behavioral data, device technical parameters

From session (~20 min) to 1 year 2 months

Functional

Helpsremember settings and preferences to improve interaction with services.

Help/chat history, email address, Website usage data, unique IDs

From session (~20 min) to 1 year

We will not use your personal data for purposes materially different from those described above without obtaining your prior consent.

Cookie Management

You have the option to manage your Cookie preferences at any time through your browser settings. By adjusting these settings, you can accept or block Cookies.

Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.

Chrome: https://support.google.com/accounts/answer/32050

Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac

Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US

Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

If you are using any other web browser, please visit your browser’s official support documents.

Please note that refusing Cookies may impact the functionality of certain features of our Website.

We may use a consent management platform to record your preferences regarding Cookies and other tracking technologies. Periodically, we may ask for your consent again to ensure that your settings are up to date and reflect your preferences.

d.Information that TalentPay receives from third parties

We may also receive information from third parties to add to the information we receive from you. This is used to help us deliver relevant functionality of our Services to you, to prevent fraud and/or abuse, and to collect your geolocation for taxation purposes. We may also receive technical data from analytics providers such as Google Analytics. These third parties may use Cookies, beacons, tracking pixels, and other tools to collect information about your use of the Services. These third parties are not controlled directly by us, so we recommend that you check their privacy policies to understand how they use your data.

3.Personal Data we don’t collect

TalentPay does not intentionally collect any sensitive Personal Data, such as data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, or data concerning your health or sex life or sexual orientation, as defined under Article 9 of the GDPR and other applicable laws.

You are strongly advised not to submit any such information when using our Services, unless explicitly requested by TalentPay and required for a lawful purpose.

If, in exceptional cases, TalentPay reasonably needs to collect and process such sensitive Personal Data, we will provide you with a clear explanation of the purpose and lawful basis for such processing, and will request your explicit consent, where required by applicable data protection law.

TalentPay also implements reasonable measures to detect and delete any inadvertently collected sensitive Personal Data that is not required for the performance of the Services.

4.How do we use your information?

We process your Personal Data for the following purposes:

•To operate, improve, develop and provide you with our Services

•To respond to inquiries or comments from you

•To calculate marketing conversion rates and other elements of advertising performance

•To help tracking and correcting errors and bugs

•To customize your user experience (for example, by giving you more relevant ads and inform you about new optionsthat you might be interested in, unless you have told us not to (opt-out))

•To maintain the integrity and security of the Services

•To create reports, analyses or similar for the purpose of research and business intelligence and be able to track potential problems, behavior and trends

•To enforce our terms and conditions, such as our Terms of Use, and this Policy

•To send you newsletters and promotional notices and offers you have previously agreed

•To keep our Services fair, investigate and prevent fraud and illegal behavior

•To comply with applicable law and regulations

• To provide automated responses and user support via AI-powered chatbots, including processing user inquiries submitted through messaging platforms

We will not use your Personal Data for any other purposes than the purposes specified in this Policy.

Email and Marketing. In most instances, we give you options with regard to the Personal Data you provide, including choices with respect to marketing materials. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located at the bottom of marketing emails.

Legal Basis for Processing

We process personal data on the following legal bases:

5. Data sharing and disclosure

We may share your Personal Data with third parties in the following circumstances, in accordance with applicable law:

•With your consent

•When required to comply with legal obligations, such as responding to subpoenas or court orders

•With our service providers who assist us in providing our Services

•In the event of a merger, acquisition, or sale of our company assets, where your Personal Information may be transferred as part of the transaction, subject to appropriate protections

• Messaging platforms (such as Telegram), which may process certain data as independent data controllers in accordance with their own privacy policies 

• Providers of artificial intelligence technologies used to operate chatbots, solely to the extent necessary to generate responses

Messaging platforms act as an independent data controller. We do not control how Messaging platforms process personal data.

To provide our Services, we may share your personal data with other companies, organizations, and users of the platform. This includes sharing data with service providers, partners, financial institutions, and, where necessary, other users such as clients, contractors, or counterparties to facilitate transactions and contractual relationships.

We may also transfer your personal data to countries outside your jurisdiction. Where such transfers occur, we ensure that an adequate level of protection is provided through appropriate safeguards or based on your explicit consent.

All such data sharing is limited to what is necessary for the relevant purpose and subject to applicable data protection laws and confidentiality obligations.

We may share your information with the following partners:

Data may be transferred outside the EEA, including to jurisdictions where Telegram operates.

•Developers that develop our platform

•Market research agencies

•Bank organization

•eSignature platforms

•Companies and external consultants that help support our platform and Services

•Advertising partners and attribution platforms to help us understand the effectiveness of our marketing campaigns

•Marketing services partners.

Personal data may also be shared between users of the platform (including clients, contractors, and other counterparties) where necessary to facilitate transactions, perform services, or comply with legal obligations.

6.Your rights

You have the following rights, subject to some limitations, against the respective TalentPay responsible for the Website you are using:

•To request information about our use of your Personal Data (e.g., the pieces and categories of Personal Data we have; the categories of sources, purposes for collection, the third parties to whom we have disclosed Personal Data, and Personal Data we have disclosed)

•To review and access your Personal Data

•To rectify (correct, update or modify) the Personal Data we hold about you

•To erase (e.g., delete), de-identify, anonymize or block your Personal Data

•To restrict our use of your Personal Data

•To receive your Personal Data in a usable format and transmit it to a third party (also known as the right of data portability)

•To lodge a complaint with your local data protection authority.

You may withdraw your consent at any time. Upon withdrawal, we will stop processing your personal data unless another legal basis applies.

7.Data retention

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or – where the applicable law provides for longer storage and retention period – for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.

In particular:

•The time required to fulfill the purposes for which Personal Data is processed

•The time required to maintain user’s relationships

•The time required to comply with legal and regulatory retention requirements. In some circumstances, it may become necessary for us to share your information with government authorities, law enforcement officials, or regulatory bodies as required by law or for administrative purposes and to the extent that local law allows and/or requires this:

(i) To comply with applicable law, legal actions or lawful request of state authorities

(ii) To protect our rights, property or safety, our users or others under the applicable law

(iii) To fulfil our obligations under our agreement with you

(iv) To check, prevent, and investigate fraud, security, or technical issues.

Retention periods are determined based on legal, regulatory, and operational requirements, including anti-money laundering and financial regulations, which may require data to be retained for 5–7 years.

8.Data security

We strive to maintain the highest standards of security, and TalentPay has put in place robust technical and organizational measures for the protection of your Personal Data in accordance with the current, general state-of-the-art technologies, especially to protect the data against loss, falsification, or access by unauthorized third persons:

•We use reasonable security measures to protect the information we have against loss, theft and unauthorized use, disclosure or modification

•We continuously analyze and check our procedures of collection, storage, and use of information including trainings of our staff

•We use encryption for many of our products.

Please note that although we work hard to protect security of our Services and Websites, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorized access. We also ask you to take every precaution to protect your Personal Data when you are on the Internet.

9.Children’s Information

TalentPay does not knowingly collect or process Personal Data from children under the age of 16, unless a lower age limit (not below 13) is provided by the applicable data protection laws in the user's country of residence, and valid consent is obtained from the holder of parental responsibility over the child.

If you are a parent or guardian and you believe that your child has provided us with Personal Data without your consent, please contact us immediately at support@talentpay.io. We will take reasonable steps to verify and delete such data from our records in accordance with applicable data protection laws.

We encourage parents and guardians to observe, participate in, and monitor their children’s online activity to help enforce this Policy.

While we implement appropriate security measures, no method of transmission over the Internet is completely secure.

10.Contact us

If you have any questions or concerns about our Privacy Policy, please contact us at:

Telephone: +37491193416

Email: support@talentpay.io