Privacy overview (draft placeholder)

Merchants integrating TOTOPAY, their end customers, authenticated dashboard users, and prospects browsing marketing properties—each interacts with subsets of processing activities.

Controllers vs processors distinctions must be articulated with your counsel when data crosses entities or subprocessors.

Typically account registration data, billing artifacts, telemetry (IPs, device hints), communications metadata, webhook payloads referencing customer handles, transaction references—but finalize inventory with DPIAs.

Crypto addresses may be pseudonymous yet linkable—treat combined datasets according to prevailing regulatory guidance.

Deliver core payment services, authenticate API traffic, mitigate fraud, satisfy accounting or regulatory asks, analyze reliability, communicate service updates—the precise lawful basis matrix depends on geography.

Marketing or analytics extras warrant explicit thresholds (consent vs legitimate interest assessments).

Define TTL policies for ledger artifacts, logs, backups, deleted-account tombstones—document restoration paths for litigation holds.

Subprocessor transparency (cloud hosts, observability stacks, messaging vendors) belongs in annexes alongside transfer mechanisms such as SCCs.

Depending on geography, subjects may invoke access, rectification, portability, objection, deletion—establish identity-verification flows before honoring sensitive requests.

Describe appeal channels when merchants disagree with outcomes.