This document is a working draft that describes how BAJJPAY currently operates. It is pending review by BAJJPAY's legal counsel and will be updated when that review is complete.
Who we are
BAJJPAY ("BAJJPAY", "we") provides crypto and FX liquidity and settlement services to businesses and professional counterparties. This policy explains what personal information we collect through this website and the client portal, why we collect it, and how it is handled. Questions about it can be sent to desk@bajjpay.com.
Information we collect
When you contact us. The contact form asks for your name, work email address, company and the topic of your enquiry, with optional phone number, type of business, assets of interest, indicative monthly volume and a message. We keep a record of the enquiry and our reply.
When you open and use a portal account. We collect your name, email address and password (stored only in hashed form), your role in your organisation, and the details of the business you register: its legal name, registration details, address, directors and beneficial owners. To meet our onboarding obligations we collect the documents your organisation uploads, such as incorporation records, identity documents for authorised people, and proof of settlement accounts and source of funds.
When your organisation trades. We record requests for quote, quotes, trades, settlement instructions, the bank accounts and wallet addresses your organisation nominates, settlement references, approvals and support tickets.
Automatically. Our systems log the IP address, browser and device information, pages requested and the time of each request, and record sign-in events. We use this to keep the service secure and to investigate problems.
How we use it
- To respond to enquiries and to assess whether we can provide services to your organisation.
- To onboard your organisation, verify the people acting for it and meet our legal and regulatory obligations, including those relating to anti-money laundering and counter-terrorist financing.
- To provide the service: pricing, executing and settling trades, and communicating about them.
- To keep the service secure, including notifying you of new sign-ins and detecting misuse.
- To keep the records that financial services and tax laws require us to keep.
We do not sell personal information and we do not use it for third-party advertising.
Our basis for using it
We use personal information where it is necessary to perform a contract with your organisation or to take steps before entering one; where we are legally obliged to, for example to verify counterparties and keep transaction records; and where we have a legitimate interest, such as securing the service and answering enquiries, that is not outweighed by your interests.
Who we share it with
We share personal information only where necessary to provide the service and meet our obligations:
- Service providers that host our systems, store uploaded documents and deliver email on our behalf, under contracts that restrict their use of the information.
- Banks, payment networks and blockchain networks to the extent needed to settle a trade. Information sent with a bank transfer, such as an account name and reference, is visible to the receiving bank.
- Regulators, law enforcement and courts where we are required to by law or a valid request.
- Professional advisers such as auditors and lawyers, under confidentiality obligations.
How long we keep it
We keep enquiry records for as long as needed to respond and follow up. Onboarding records, transaction records and related communications are kept for as long as the relationship lasts and for the period afterwards that applicable financial services, anti-money laundering and tax laws require. Technical logs are kept for a limited period for security purposes.
Your rights
Depending on where you are, you may have the right to access the personal information we hold about you, to have it corrected, to have it deleted, to object to or restrict certain uses, and to receive a copy in a portable form. Some of these rights are limited where we are required by law to keep the information, for example transaction records. To exercise a right, email desk@bajjpay.com. You may also have the right to complain to a data protection authority.
Security
Portal access is by verified email address and password, and a notification is sent on every new sign-in. Uploaded documents are held in private, access-controlled storage and are visible only to your organisation and to the desk staff who review them. Actions in the portal and on the desk are recorded in an audit log. No system is completely secure; if you believe your account has been compromised, contact us immediately.
International transfers
Our service providers may process information in countries other than your own. Where that happens we take steps intended to ensure the information remains protected, including contractual safeguards with those providers.
Cookies
This website and the portal use a small number of strictly necessary cookies and browser storage items. They are described in the Cookie Policy.
Changes to this policy
We will update this policy when our practices change. The date at the top shows when it was last updated. Material changes affecting portal users will be notified through the portal or by email.
Questions about this document: desk@bajjpay.com
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