Privacy Policy

1. Data Controller

The data controller is: Bitcage LLC — 10320 NW 53rd St, Sunrise, FL 33351, United States — Contact: [email protected]

2. Data Collected

We collect only the data needed to run the service:

• Account data: email address or phone number used to sign in, name and phone number if you provide them, wallet address, language and display currency
• Transaction data: payments, tickets and payment requests (amounts, merchant, blockchain transaction hashes, dates)
• Payment request data: the email address a merchant enters to send you a payment request
• Identity verification (KYC): when a threshold requires it, Didit collects your identity document, a selfie and a liveness check. Bitcage only keeps the verification status and reference, not your documents
• Technical data: IP address and browser information in our hosting providers' logs, and error reports (Sentry for our servers, PostHog for the website and the app)
• Audience measurement data: pages viewed, actions in the app and, on the website, where you click and scroll (heatmaps) (PostHog), linked to your account (identifier and email address) only if you accept analytics cookies
• Session replays in the app, only if you accept analytics cookies: a recording of the screens you view and what you do and type on them (PostHog), including what they display (such as your email address, wallet address and amounts). Passwords are never recorded. On Bitcage kiosks (terminals in merchants' premises), sessions are always recorded in the same way, to improve and troubleshoot the terminals. The website (www.bitcage.com) records no sessions

3. Purpose of Processing

Your data is used to:

• Create and secure your account and sign you in
• Process crypto payments and settle merchants
• Verify identity when required by anti-money laundering rules (KYC/AML)
• Send transactional emails (payment requests, invitations, verification reminders)
• Detect and fix errors, ensure security and prevent fraud
• Measure how the website and the app are used, to improve them

4. Legal Basis

The processing of your personal data is based on:

• Performance of the contract: account, payments, transactional emails
• Legal obligations: identity verification and transaction records (KYC/AML)
• Legitimate interest: security, fraud prevention, error monitoring, anonymous (cookieless) audience measurement and session replays on kiosks
• Your consent: analytics cookies, identifiers and session replays (PostHog), which you can withdraw at any time

5. Data Retention

We retain your data for:

• Account data: duration of use + 3 years
• Transaction records: 5 years (regulatory requirement)
• Identity verification data: 5 years after the end of the relationship (held by Didit)
• Technical logs and error reports: 12 months at most
• Analytics data: 25 months at most; analytics cookies expire after 12 months at most
• Session replays: 90 days at most

6. Data Security

We protect your data with:

• HTTPS encryption for all communications
• Signed authentication tokens and sign-in by wallet signature
• Non-custodial wallets: we never hold your private keys
• Access to personal data restricted to authorized staff
• Server error reports stripped of IP addresses, cookies, headers and request content

7. Service Providers and Recipients

We NEVER sell your data. We share it only with the providers that run parts of the service, each for its own purpose:

• Thirdweb (Thirdweb, Inc., United States): sign-in by email or phone, wallets and blockchain infrastructure
• Didit (Spain): identity verification (identity document, selfie, liveness check)
• Brevo (Sendinblue SAS, France): transactional emails
• Cloudflare (Cloudflare, Inc., United States): network delivery and protection of the website and the app, which receives your IP address, and anonymous performance measurement without cookies
• Vercel (Vercel Inc., United States): hosting of the website and the app
• Railway (Railway Corporation, United States): hosting of our servers and database
• Sentry (Functional Software, Inc., United States; data stored in the European Union): error monitoring of our servers
• PostHog (PostHog, Inc., United States; data stored in the European Union): audience measurement, session replays in the app (with your consent) and error reports from the website and the app
• Mapbox (Mapbox, Inc., United States): map of merchants, which receives your IP address and the area displayed when you open the map
• Merchants: the merchant you pay receives the transaction details and, where required, your verification status
• Legal authorities: only upon a valid legal request

These providers act on our instructions under data processing agreements, and only receive the data they need.

8. International Transfers

Bitcage LLC and several providers (Thirdweb, Cloudflare, Vercel, Railway, Mapbox, and the parent companies of Sentry and PostHog) are based in the United States, so your data may be processed there. These transfers rely on the EU-US Data Privacy Framework where the recipient is certified, and otherwise on the European Commission's standard contractual clauses. Error monitoring and analytics data are stored in the European Union.

9. Your Rights

Under the GDPR, you have the following rights:

To exercise these rights, contact us at:[email protected]

10. Blockchain Transparency

Blockchain transactions are public by nature. Transaction hashes, wallet addresses and amounts are visible on public blockchain explorers. Bitcage cannot delete or modify data recorded on blockchains.

11. Cookies and Similar Technologies

The website and the app store a few items on your device (cookies or browser storage):

• Strictly necessary (no consent required): your sign-in session and wallet session (Thirdweb), language and display preferences, terminal settings on Bitcage kiosks, your cookie choice, and app files cached for offline use
• Audience measurement and session replay (PostHog), only with your consent: an anonymous identifier that lets us follow your visits over time and, in the app, record your sessions and link them to your account and email address. It expires after 12 months at most
• Without your consent, or if you refuse: PostHog runs without cookies or storage on your device, records no session and only counts visits anonymously
• Map (Mapbox): when you open the merchant map, Mapbox may store a technical identifier to count map loads
• Server error monitoring (Sentry) uses no cookies

You can change your choice at any time with the "Cookie settings" link at the bottom of the website and the app, or by clearing your browser's data.

12. Minors

Bitcage is not intended for persons under 18 years of age. We do not knowingly collect data from minors.

13. Updates

This policy may be updated. Significant changes will be notified by email or in the app. The latest version is always available on our website.

14. Contact & Complaints

For any questions about your personal data: [email protected]

You also have the right to file a complaint with your data protection authority (in France, the CNIL: www.cnil.fr).