Stablepay Privacy Policy

Effective Date: July 28, 2026

1) Introduction

Thank you for using Stablepay’s websites and services that link to this Privacy Policy, including stablepay.com (the “Sites”). StablePay International, LLC and its affiliates, including Toptal, LLC, (collectively, “Stablepay,” “we,” “us,” and/or “our”) operates these Sites to provide our users (“you” and “your”) with tools and information about Stablepay and our services.

Stablepay provides users (“You” or “Users”) access to a platform to facilitate holding and moving stablecoin assets and other associated functions, including making payments, facilitating spend cards, and transferring your assets (the “Services").

Stablepay values your privacy rights, and we take our responsibilities and obligations about your privacy rights seriously. We want you to know that Stablepay is not in the business of selling your information. This privacy policy (“Privacy Policy”) explains our data practices in depth, so that you know how and why we collect and use your information in compliance with applicable data regulations.

2) Scope

This Privacy Policy explains how we collect, retain, and use information about Users, site visitors, and others if and as applicable information, including personal data (“Personal Data”) in accordance with applicable data protection laws and regulations as described below.

3) Collection and Use of Personal Data

The information we receive and how we use it varies based on our relationship with you. The sections below explain our data practices based on our different relationships with users. Use these links to quickly navigate to the section relevant to you:

Users ; and
Site Visitors.

a) Users

i) Information We Collect

(1) Information That You Provide to Us

We collect information from Users and third parties that we need to provide the Services. This information could include your:

Name;
Contact information;
Address;
Location;
Date of birth;
Citizenship;
Main source of income;
Employment status;
Employment details;
Photo;
Government-issued identification;
Bank account details; and
Transaction details.

During your time as a User and in your interactions with Stablepay, we may, with your consent, also record your audio and video calls with us to be used for our quality assurance or training purposes.

2. Biometric Data and Retention

We may request that you provide information to verify and confirm your identity. As part of this identity verification, we may ask you to take a photo of yourself and of your government-issued identification through an application on your mobile phone or computer (the “Verification Data”). The Verification Data is provided to our biometric technology service provider (currently, Sumbsub Inc. – “Sumsub”). Sumsub uses facial recognition technology to analyze the geometry of your face through the photographs you provide and extracts biometric information or biometric identifiers relating to you (collectively, “Biometric Data”), as well as validates the legitimacy of your government-issued identification to confirm your identity. Sumsub sends us the Verification Data that indicates whether Sumsub was able to verify your identity, and the details from your government-issued identification for reference and fraud investigation purposes pursuant to our legitimate interests. Sumsub securely stores a copy of your government-issued identification for as long as there is a continued and legitimate need for our verification of your identity in accordance with direction from Stablepay. Stablepay also retains the results and related Verification and Biographical Data (defined below), for as long as an account related to the individual being verified is active, for its legitimate purpose of verifying the identities of people applying or receiving services; to assist in complying with applicable laws and regulations; and/or to help prevent and investigate fraud and other violations of our systems.

As part of our onboarding process, we may require additional information to verify your identity in this remote environment. A member of our team may request additional details, such as your relevant address, (collectively, “Biographical Data”) to verify your identity. The Biographical Data is provided to our identity verification service provider and processed based on its privacy policy.

Sumsub may also use the Verification Data and Biographical Data to improve the accuracy, reliability, usability, and functionality of its identity verification technology, for fraud prevention and incident investigation efforts.

Sumsub does not sell your Biometric Data and permanently deletes it within thirty days of a verifiable deletion request. Sumsub retains your Biometric Data as described in Sumsub’s Privacy Policy. As noted above, Stablepay does not receive or have access to the Biometric Data. In no event does Sumsub retain Biometric Data for longer than the purpose described above, or three years from your last interaction with Stablepay, whichever is earlier unless required by law. Please refer to Sumsub’s Privacy Policy for more information.

(2) Information Obtained from Third Parties

We may collect information, such as your name, contact information, address, work experience, and education from publicly available sources, third-party data providers, or services. This includes sources such as professional job boards or social media websites, like LinkedIn. We use this information to supplement the information that you provide us. We may also collect information about you that you provide to our affiliates, such as Toptal, LLC.

(3) Automatically Collected Data

When you interact with Stablepay through the Site or services, we may automatically collect certain information. Please read the “Site Visitors” section below for more information.

ii) How We Use the Information

(1) To Provide the Service and Respond to Requests

We use your Personal Data to provide the Services and administer our contracts with you.

(2) For Certain Legitimate Interests

We also may use your Personal Data for certain business interests deemed legitimate under applicable law, including:

To send you administrative information, for example, information regarding the Site and changes to our terms, conditions, and policies.
To conduct analytics on how you use the Site and our Service for our internal purposes and to better understand your needs and interests to personalize your experience with our Services.
To maintain our Services.
To help prevent fraud, criminal activity, and misuses of our products or Services and to ensure the security of our IT systems, architecture, and networks.
For legal reasons, including to comply with legal obligations and legal processes, such as our compliance with sanctions about specific regions or specifically designated individuals, respond to requests from public and governmental authorities, enforce our agreements, protect our operations, protect our rights, privacy, safety or property, and/or that of you or others, and allow us to pursue available remedies or limit the damages that we may sustain.
If you ask us to delete your data and we are required to fulfill your request, we will keep basic data to identify you to prevent fraud or further unwanted processing.

(3) With Your Consent

We may also ask for your consent to use your Personal Data for a purpose that is not listed on this Privacy Policy, and we will use your Personal Data for that purpose to the extent that you freely provide your informed consent.

We may monitor, record, and transcribe audio or video calls with you during the application process or your time as a User for internal quality assurance and training purposes. Consenting is voluntary, and you may withdraw your consent at any time.

We may collect your voice, image, in-meeting messages, and any other Personal Data you choose to share during such calls. In addition, other participants in a video conference may be able to view your display name, email address and profile picture. Any third-party software we use for these audio or video calls may also collect and use your Personal Data. Please review the terms of any third-party site for their specific privacy practices.

For individuals in the EU and the UK, please see the EU and UK Individuals section below for information on our legitimate interests and your rights. For individuals that reside in California, please see the California section below for information on your rights.

b) Site Visitors

When you interact with Stablepay through the Site or the Services, we and service providers acting on our behalf will automatically collect information about you through cookies and other technologies. Please review the stablepay.com Cookie Policy to learn more about how we use cookies and other technologies on the specific Site you are using.

As a Site Visitor, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address from which we understand the country you are connecting from at the time you visit the Site, browser type and settings, and the date and time of your request.

We use this automatically collected data for our legitimate interests in maintaining the safe operation of our Site, maintaining our legal obligations and our legitimate interest in learning how Site visitors interact with our Site to improve your use of the Site.

4) Disclosing Your Personal Data

Stablepay is not in the business of selling your information. We consider information about you and our interactions to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties, as explained below:

a) Business Transfers

As we develop our business, we might acquire businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

b) Agents, Consultants and Other Service Providers

Stablepay, like many businesses, hires third parties to perform certain business-related functions. These third parties include website analytics companies, providers of digital advertising services, our hosting and cloud computing service providers, providers of customer relationship management software, marketing and sales software solutions, providers of billing and processing payments functions and providers of background check services. When we engage another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Pursuant to our instructions, these parties may access, process, or store Personal Data in the course of performing their duties to us and solely in order to perform the services we hired them to provide.

For more information about the particular third parties we may send your information to in order to facilitate the Services, please reach out to support@stablepay.com.

c) Legal Requirements

Stablepay may disclose your Personal Data if required to do so by law, for example, as part of our compliance with sanctions about specific regions and specifically designated individuals, or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Stablepay, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

5) Data Retention

Our policy is to keep your Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. If you elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

6) Region Specific Information

You may be able to exercise certain rights and access certain information depending on your location. Please review the following sections for more details. You can reach out to legal@Stablepay.com with questions about your information.

a) EU and UK Individuals

(1) Scope

This section applies solely to individuals in the United Kingdom and European Union, provided however that reference to the EU also includes certain non-EU countries including, where applicable, Switzerland and the European Economic Area countries of Iceland, Liechtenstein, and Norway. Our Privacy Policy describes why and how Stablepay collects, uses, and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing (please see “Your Rights” section below).

(2) Data Controller

Stablepay is the data controller for processing your Personal Data. The data controller is responsible for deciding how Personal Data about you is used. Please contact us with any questions at legal@Stablepay.com or at the address provided in the Contacting Stablepay section below, which also provides the contact details of our representative in the EU and the UK for purposes of the General Data Protection Regulation and the United Kingdom's Data Protection Act 2018.

(3) Your Rights

Subject to applicable EU and UK law and where possible, you have the following rights in relation to your Personal Data:

Right of access. You may ask us to confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. This may include the purposes of the processing, the categories of Personal Data, the recipients of the Personal Data, the right to lodge a complaint, and available information on the source of the Personal Data. If you require additional copies, we may charge a reasonable fee.
Right to rectification. If your Personal Data is inaccurate or incomplete, you may ask that we erase, amend, or rectify it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to erasure. You may ask us to delete or remove your Personal Data in certain circumstances, such as where our processing is based on your consent. We may retain certain information consistent with applicable law, such as to prevent fraud, or where we have a compelling legitimate ground to do so. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
Right to restrict processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to data portability. You may ask to obtain the Personal Data that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used, and machine-readable format.
Right to object. You may ask us at any time to stop processing your Personal Data, and we will do so unless we have a compelling legitimate ground for the processing. We will comply with requests to stop processing your Personal Data as your requests apply to direct marketing.
Rights in relation to automated decision-making and profiling. You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent. We use automated decision-making to ensure that we comply with various laws and regulations restricting what regions, individuals, and entities we are able to work with. You may contact us at legal@Stablepay.com to obtain an explanation of the decision or for a personal review, if possible.
Right to withdraw consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any data that we already processed.
Right to lodge a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under the “Contacting Stablepay” section below.

(4) Legitimate Interest

“Legitimate interests” means our interests in conducting and managing our organization and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you outweighs our interests unless we have your consent or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see the “Your Rights” section above.

(5) Data Transfers

Stablepay is based in the United States. When you use our Services as a User or Site Visitor or otherwise use our Sites, your Personal Data will be transmitted to servers in the United States as necessary to provide you with the Services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy, and your Personal Data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data across the border of the European Economic Area or United Kingdom, we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected.

b) California

Our Privacy Policy describes above why and how Stablepay collects, uses, and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing.

If you are a California resident, you, or a person verifiably authorized to act on your behalf, have certain rights under the California Consumer Privacy Act and its successor legislation, the California Privacy Rights Act, collectively the “CCPA.” For the purpose of this section, certain words, including “sale,” “share,” “business purpose,” and “personal information” have the meanings defined in the CCPA. For the purpose of this Privacy Policy, we use “Personal Data” to cover “personal information” as defined in the CCPA.

We update our Privacy Policy based on our current practices. As required by the CCPA, the information in this section is relevant for the last twelve-month time period. During that time, we collected the categories of Personal Data listed in the relevant section above (i.e., Users or Site Visitors) from the sources listed in those sections (i.e., from you, third parties, or automatically). During the last twelve-month period, we have not sold Personal Data.

During the last twelve-month period, we disclosed for business purposes the following categories of Personal Data:

Identifiers (i.e., names, email addresses, or online identifiers and IP addresses).
Biometric information (i.e., video and voice recordings).
Internet activity (i.e., information regarding your interaction with our websites or advertisements).
Geolocation data (i.e., information regarding where you access our site from).
Professional or employment information (i.e., job title, employer, or prior titles and employers).

For information about who we may share or disclose your Personal Data to, please review the relevant information in the above Users or Site Visitors sections.

Your rights under the CCPA include the following, which you may execute by contacting us at legal@Stablepay.com where possible and allowed by law:

Right to request deletion of your Personal Data. You may ask us to delete or remove your Personal Data. If we shared your Personal Data with others, we will tell them about the deletion where possible. If you ask us, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
Right to request Stablepay correct inaccurate Personal Data. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, we will also tell you with whom we shared your Personal Data so you can contact them directly.
Right to know what Personal Data is sold or shared and with whom. Stablepay is not in the business of selling your Personal Data. You may ask us to clarify what Personal Data, if any, is shared and with whom we share it, along with certain additional details.
Right to opt out of sale or sharing of Personal Data for behavioral advertising and right to not be retaliated against for opting out. If you would like to opt out of Stablepay sharing your Personal Data with third parties for cross-context behavioral advertising, you have the right to do so. To opt out:
Email your request to legal@Stablepay.com; and
Disable the use of analytics/advertising cookies as we describe in our Cookie Policy. You must complete this step on each of our websites from each browser and on each device that you use.
If you block cookies, we may be unable to comply with your opt out request with respect to device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies. If you clear your cookies, you may need to disable the use of all advertising cookies again.
Right to access your Personal Data. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may charge a reasonable fee.
Shine the Light Requests. You may also request that we provide you with a list of the categories of Personal Data, if any, that we disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and the identity of those third parties.
Right to Non-Discrimination. Stablepay will not discriminate against you if you exercise any of your rights under the CCPA.

If you would like to exercise your rights or have questions about your rights or information, please contact us at legal@Stablepay.com or at the post addresses included in the Contacting Stablepay section below.

7) Your Choices

You can use the Sites without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

8) Exclusions

This Privacy Policy does not apply to any Personal Data collected by Stablepay other than Personal Data collected through the Sites, Services, events, third parties or as otherwise stated in this Privacy Policy. This Privacy Policy shall not apply to any unsolicited information you provide to Stablepay through this Site or through any other means (without prejudice to your rights under the applicable law). This includes, but is not limited to, information posted to any public areas of the Sites, such as forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Stablepay shall be free to reproduce, use, disclose, distribute, and exploit such Unsolicited Information without limitation or attribution.

9) Children

Stablepay does not knowingly collect Personal Data from children under the age of 16. If you are under the age of 18, please do not submit any Personal Data through the Sites. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on these Sites without their permission. If you have reason to believe that a child under the age of 18 provided Personal Data to Stablepay through this Sites, please contact us, and we will endeavor to delete that information from our databases.

10) Links to Other Websites

The Sites may contain links to other websites not operated or controlled by Stablepay (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or review the Third-Party Sites. We suggest contacting those sites directly for information on their privacy practices and policies.

11) Security

Stablepay takes reasonable and appropriate steps to protect the Personal Data provided via the Sites or the services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.

12) Other Terms and Conditions

Your access to and use of Stablepay.com is subject to our Website Terms & Conditions. Your access to and use of other Sites may be subject to different terms and conditions. Please review those Sites for more information.

13) Changes to Stablepay’s Privacy Policy

The Sites and our business may change from time to time. As a result, at times it may be necessary for Stablepay to make changes to this Privacy Policy. Stablepay reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice, unless otherwise required by the applicable law. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy, without prejudice to your rights under the applicable law.

14) Contacting Stablepay

Please contact us if you have any questions about Stablepay’s Privacy Policy, the information practices of the Sites, or if you have questions about your rights.

We have a team responsible for overseeing questions regarding this Privacy Policy. You may contact the Stablepay Privacy Team as follows: by email at legal@Stablepay.com, or by mail at:

Stablepay, LLC

Attention: Privacy Policy Query

2810 N. Church St #36879

Wilmington, DE 19802-4447

If you are an individual in the EU or UK, you can also contact VeraSafe, who we appointed as Stablepay’s representative in the EU and UK for data protection matters, pursuant to Article 27 of the EU General Data Protection Regulation and the UK General Data Protection Regulation. You may contact VeraSafe directly about the processing of your Personal Data by using this contact form. Alternatively, you can contact VeraSafe at:

EUVeraSafe Ireland Ltd

Unit 3D North Point House

North Point Business Park

New Mallow Road

Cork T23AT2P

Ireland

UKVeraSafe United Kingdom Ltd.

37 Albert Embankment

London SE1 7TL

United Kingdom