Privacy Policy

DIGITAL TECH CENTRE LTD

Version 1.0 Effective Date: April 2026

1. Introduction

Digital Tech Centre Ltd ("Digital Tech Centre Ltd", the "Company", "we", "us", or "our") is committed to protecting the privacy and personal data of individuals who use our services, visit our website, or otherwise interact with us. This Privacy Policy (the "Policy") describes the categories of personal data we collect, the purposes for which we process such data, the legal bases for processing, and the rights available to data subjects.

This Policy is issued in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018, and all other applicable data protection and privacy legislation. It forms part of our Terms & Conditions and governs the processing of personal data in connection with all services provided by the Company.

By using our services, you acknowledge that you have read and understood this Policy. We may update this Policy from time to time and will notify you of material changes by publishing the revised version on our website and, where appropriate, by email. Unless otherwise stated, the revised Policy takes effect 30 days after publication. We encourage you to review this Policy periodically.

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors.

2. Categories of Personal Data We Collect

2.1 Information Provided Directly by You

When you register for our services, complete application forms, or communicate with us, we may collect the following categories of personal data:

Full name, date of birth, place of birth, and nationality;
Residential and correspondence address;
Email address, telephone number, and other contact details;
Identity document information (passport number, national ID number);
Bank account details and payment instrument information;
Employment and business information;
Security credentials (passwords, security questions);
Any other information you voluntarily provide to us.

2.2 Information Collected Automatically

When you access our website or use our services, we automatically collect certain technical and usage data, including:

IP address and device identifiers;
Browser type, operating system, and screen resolution;
Pages visited, time spent on pages, and navigation patterns;
Referral source and exit pages;
Date, time, and frequency of access.

This data is collected through server logs and, where you have provided consent, through cookies and similar tracking technologies (see Section 10 below).

2.3 Information Obtained from Third Parties

We may receive personal data from external sources in the course of providing our services. These sources include:

Credit reference and fraud prevention agencies;
Payment processors, acquiring banks, and card schemes;
Affiliated companies within our group;
Publicly available registers and commercially available databases;
Other financial institutions and business partners.

2.4 Enhanced Verification

In certain circumstances — for example, where we are unable to verify information you have provided, where transaction volumes exceed specified thresholds, or where our risk assessment warrants additional scrutiny — we may request supplementary documentation. This may include recent utility bills, bank statements, proof of source of funds, or other supporting evidence. We may also conduct background checks through credit reference or fraud prevention agencies, to the extent permitted by applicable law.

3. Purposes and Legal Bases for Processing

We process your personal data for the following purposes:

Service delivery: processing transactions, managing your account, and providing customer support;
Identity verification: confirming your identity and conducting know-your-customer procedures;
Legal and regulatory compliance: fulfilling our obligations under AML/CTF legislation, tax law, and other applicable regulations;
Fraud prevention: detecting, investigating, and preventing fraudulent or unauthorised activity;
Risk management: assessing and managing credit, operational, and financial crime risks;
Service improvement: analysing usage patterns, conducting research, and enhancing our products and services;
Communications: sending service-related notifications, policy updates, and, where you have consented, marketing materials;
Dispute resolution: investigating complaints, resolving disputes, and enforcing our contractual rights;
IT security: maintaining and protecting our information technology infrastructure.

The legal bases for processing include: performance of a contract to which you are a party; compliance with legal obligations to which we are subject; our legitimate interests (provided these are not overridden by your rights and freedoms); and, where applicable, your explicit consent.

4. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Following the closure of your account, we are required to retain your data for a minimum of five (5) years to comply with our obligations under AML/CTF legislation. After the expiry of the applicable retention period, your data will be securely deleted or anonymised.

5. Sharing of Personal Data

5.1 Affiliated Companies

We may share your personal data with subsidiaries, holding companies, and other entities within our corporate group. All affiliated entities are required to process personal data in accordance with this Policy and applicable data protection law.

5.2 Third-Party Service Providers

We may share your data with third parties who process data on our behalf, including payment processors, acquiring banks, IT service providers, fraud prevention agencies, credit reference agencies, and professional advisors. Such sharing is governed by data processing agreements that require the third party to implement appropriate technical and organisational safeguards.

5.3 Regulatory and Law Enforcement Disclosures

We may disclose your personal data where required to do so by law, regulation, court order, or the binding request of a competent authority. This includes disclosures to regulatory bodies, law enforcement agencies, tax authorities, and judicial bodies.

5.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred to the successor entity. We will notify you of any such transfer and of any changes to the processing of your personal data.

5.5 Other Users

When you use our services to send or receive payments, certain information (such as your name and contact details) may be shared with the other party to the transaction to the extent necessary to facilitate the payment. Your sensitive financial information (such as bank account details) will not be disclosed to other users without your express permission, unless required by law or payment scheme rules.

5.6 International Transfers

Where your personal data is transferred outside the European Economic Area (EEA) or the United Kingdom, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, or transfer to jurisdictions that have been recognised as providing an adequate level of data protection.

5.7 No Sale of Personal Data

We do not sell or rent your personal data to third parties for their marketing purposes.

6. Data Security

Digital Tech Centre Ltd implements appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, firewall protection, access controls, regular security assessments, and staff training on data protection and information security.

While we take all reasonable precautions to safeguard your data, no method of transmission over the internet or electronic storage is entirely secure. You are responsible for maintaining the confidentiality of your account credentials and should notify us immediately if you suspect any unauthorised access to your account.

7. Data Storage

Your personal data is stored on secure servers located within the European Economic Area (EEA) and, where necessary, in other jurisdictions in compliance with applicable data protection legislation.

All storage arrangements are subject to appropriate technical and contractual safeguards.

8. Your Rights

Under applicable data protection law, including the GDPR, you have the following rights in relation to your personal data:

Right of access: to obtain confirmation of whether we process your personal data and, if so, to request a copy of that data;
Right to rectification: to request correction of inaccurate or incomplete personal data;
Right to erasure: to request deletion of your personal data, subject to our legal retention obligations (including the five-year AML/CTF retention requirement);
Right to restriction: to request that we restrict the processing of your personal data in certain circumstances;
Right to object: to object to the processing of your personal data where we rely on legitimate interests as the legal basis;
Right to data portability: to receive your personal data in a structured, commonly used, machine-readable format, where processing is based on consent or contract and carried out by automated means;
Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please submit a written request to b2b@cmpss.xyz. We will respond within 15 days of receiving your request, and in any event within one calendar month. In complex cases, this period may be extended by up to two additional months, and we will inform you of any such extension.

9. Marketing Communications

You have the right to opt out of receiving marketing communications from us at any time. You may exercise this right by contacting us at the email address provided below or by using the unsubscribe mechanism included in any marketing communication you receive from us. Opting out of marketing communications does not affect our ability to send you service-related notifications necessary for the operation of your account.

10. Cookies and Tracking Technologies

Our website uses cookies — small text files placed on your device — to enhance your browsing experience, analyse site usage, and support the functionality of our services. We use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a defined period).

Before any non-essential cookies are placed on your device, you will be presented with a notice requesting your consent. You may accept or decline cookies through your browser settings; however, disabling certain cookies may limit the functionality of our website. We do not store sensitive personal or financial information in cookies.

11. Third-Party Websites and Services

Our website may contain links to third-party websites, applications, or services that are not operated or controlled by us. This Policy does not apply to such third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party service before providing your personal data.

12. Legal Disclaimer

Digital Tech Centre Ltd reserves the right to disclose your personal data as required by applicable law, regulation, court order, or governmental request. The Company shall not be liable for any loss of personal data resulting from circumstances beyond its reasonable control, including but not limited to unauthorised access caused by your failure to maintain the confidentiality of your account credentials.

All communications between you and the Company may be recorded and retained for quality assurance, training, regulatory compliance, and dispute resolution purposes.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

Data Protection Officer: b2b@cmpss.xyz

General Enquiries: b2b@cmpss.xyz

Registered Address: Dept 6165, 43 Owston Road, Doncaster, DN6 8DA, United Kingdom