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Privacy Policy

Privacy Policy Pagadera

Last updated: July 10, 2026

Draft for review. This document is a working draft and must be reviewed and approved by qualified legal counsel before it is published or relied upon.

This Privacy Policy explains how the Pagadera Payment Network (“Pagadera”, “we”, “us” or “our”) collects, uses, shares and protects personal information when you visit our website, become a member, or use the Pagadera payment network to make online and mobile payments.

In short: Pagadera is a payment network that lets you pay merchants without ever exposing your card or bank credentials. Your full financial credentials always stay with your provider (your bank, credit union or other financial institution) and are never shared with the merchant or passed through Pagadera to complete a payment.

1. Who We Are (Data Controller)

Pagadera Payment Network is the data controller responsible for the personal information described in this policy. Pagadera operates a payment network that enables financial institutions to offer Consumer-to-Business (C2B) payment services to their customers, with a particular focus on smaller and Caribbean markets.

Pagadera is a licensed Payment Service Provider (PSP) established in Curaçao and regulated by the Centrale Bank van Curaçao en Sint Maarten (CBCS). PSP license number: to be confirmed by the operator.

You can reach us using the details in the Contact Us section below.

2. Information We Collect

We collect only the information we need to operate the network, keep it secure, and meet our legal obligations. Depending on how you use Pagadera, this may include:

  • Account and membership information: the details you provide when you become a member and create or link an e-wallet, such as your name, membership identifier and account status.
  • Contact details: email address, telephone number and, where relevant, postal address.
  • Wallet identifiers: the identifiers of the e-wallets you create or link within the network and the provider associated with each wallet.
  • Transaction metadata: information about payments you initiate, such as amount, currency, date and time, the merchant involved, and a transaction reference or status. This lets us route and confirm payments.
  • Technical and usage data: information collected automatically when you use our website or mobile services, such as device and browser information, IP address, and interaction logs used for security and diagnostics.

3. Financial Credentials We Never Receive

A core feature of the Pagadera model is that no financial information is ever shared with the merchant, and full card or bank credentials never pass through Pagadera to complete a payment.

When you pay, your card number, bank account credentials, PINs and similar sensitive financial data remain solely with your provider — the bank, credit union or other financial institution that issued your wallet. The merchant receives no financial data on its servers, and Pagadera does not store your full card or bank credentials. Pagadera facilitates authorisation and settlement between you and the merchant using transaction metadata and wallet identifiers rather than your underlying financial credentials.

4. How We Use Your Information

We use personal information to:

  • Register and manage your membership and e-wallets.
  • Route, authorise, process and confirm payments you initiate between you and merchants.
  • Provide customer support and respond to your enquiries.
  • Detect, prevent and investigate fraud, abuse and security incidents.
  • Comply with legal, regulatory, anti-money-laundering and reporting obligations.
  • Maintain, improve and secure our website, apps and the network.

6. How We Share Information

We do not sell your personal information. We share it only as needed to operate the network and meet our obligations, including with:

  • Providers (financial institutions): the banks, credit unions and financial institutions that issue and hold your e-wallet, so that payments can be authorised and settled. Your full financial credentials stay with them.
  • Merchants: limited transaction confirmation information needed to complete a purchase. Merchants do not receive your financial credentials.
  • Regulators and authorities: the Centrale Bank van Curaçao en Sint Maarten (CBCS) and other competent authorities where required by law or regulation.
  • Service providers: trusted vendors who process data on our behalf (for example, hosting, security and support) under appropriate confidentiality and data-protection commitments.

7. International Transfers

Pagadera operates across multiple markets, and some recipients of information (such as providers, merchants or service providers) may be located outside Curaçao. Where personal information is transferred internationally, we take steps to ensure it remains protected by appropriate safeguards consistent with applicable law.

8. Data Retention

We keep personal information only for as long as necessary to provide our services, comply with legal, regulatory, accounting and anti-money-laundering obligations, resolve disputes and enforce our agreements. When information is no longer required, we delete or anonymise it.

9. Security

We use technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse or alteration. Because full card and bank credentials remain with your provider and do not pass through Pagadera, your most sensitive financial data is not held on our systems. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Subject to applicable law, you may have the right to:

  • Access the personal information we hold about you.
  • Request correction of inaccurate or incomplete information.
  • Request deletion of your information where there is no overriding legal reason to retain it.
  • Object to or request restriction of certain processing.
  • Request portability of information you provided to us.
  • Withdraw consent where processing is based on consent.

To exercise any of these rights, contact us using the details below. You may also have the right to lodge a complaint with the competent supervisory authority.

11. Cookies & Similar Technologies

Our website uses cookies and similar technologies to enable core functionality, remember your preferences, keep the site secure, and understand how the site is used. You can control cookies through your browser settings; disabling some cookies may affect how the site works.

12. Governing Law

This Privacy Policy and any matter relating to it are governed by the laws of Curaçao, without regard to conflict-of-laws principles.

13. Contact Us

If you have questions about this Privacy Policy or how we handle your personal information, please contact us:

This Privacy Policy is a draft provided for general guidance only and does not constitute legal advice. It must be reviewed and approved by qualified legal counsel and adapted to applicable local laws before publication.

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