Privacy Policy

1. Introduction and Who We Are

This Privacy Policy describes how Faran and Co International Translations Limited (d/b/a "Green Transfer"), a company registered in Georgia with Business Registration Number (BRN) 71560534 and registered office at 1 VAKHTANG GORGASALI 1 STR, F.24 TBILISI 1105, GEORGIA ("we," "us," or "our"), collects, uses, stores, and protects your personal information.

As a registered Virtual Asset Service Provider (VASP) in Georgia, we are committed to protecting your privacy and handling your data in an open and transparent manner, in compliance with applicable data protection laws. This policy applies to your use of our website (https://greentransfer.org/) and all associated services (collectively, the "Service").

2. Information We Collect

We collect information that is necessary to provide our Service, comply with legal obligations, and improve your user experience. The types of information we collect are:

2.1 Information You Provide to Us Directly

• Account Information: When you create a Green Transfer account, we collect your name, email address, and password.
• Identity Verification (KYC) Data: To comply with our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) obligations, we are legally required to collect and verify your identity. This includes:
  • Full legal name, date of birth, and residential address.
  • A copy of your government-issued identification (e.g., passport, national ID card).
  • A photograph or "selfie" for biometric verification.
  • Proof of address documentation (e.g., utility bill, bank statement).
  • In some cases, information regarding your source of funds or wealth.
• Communications: When you contact our support team or communicate with us in any other way, we will collect the information you volunteer in such correspondence.

2.2 Information from Third-Party Service Providers

Our Service integrates with third-party on-ramp providers (e.g., onramp.money, PayBis) and identity verification services. We may receive information from these partners, such as:

• Transaction Data: We receive confirmation of your transaction status (e.g., successful, failed), the amount, and the public address of your cryptocurrency wallet. We do not receive or store your full credit card number or bank account details; this information is handled directly by our payment processing partners.
• KYC Verification Status: Our identity verification partner will inform us whether your identity has been successfully verified.

2.3 Information We Collect Automatically

• Usage Data: We collect information about how you interact with our Service, such as your IP address, browser type, device information, operating system, and pages visited.
• Cookies: We use cookies and similar tracking technologies to operate and personalize our Service. You can control the use of cookies at the individual browser level.

3. How We Use Your Information

We use your information for the following purposes, based on a clear legal basis:

• To Provide and Maintain Our Service (Contractual Necessity): To create and manage your account, facilitate transactions via our third-party partners, and provide customer support.
• To Comply with Legal and Regulatory Obligations (Legal Obligation): This is a primary use of your data. We use your KYC information to perform identity verification, conduct fraud monitoring, and comply with all applicable AML/CFT laws and regulations in Georgia. This includes reporting suspicious activities to the Financial Monitoring Service (FMS) of Georgia.
• To Improve Our Service (Legitimate Interest): To analyze usage patterns, troubleshoot issues, and enhance the user experience.
• To Ensure Security (Legitimate Interest): To protect our platform from fraud, abuse, and security risks.
• To Communicate With You (Legitimate Interest): To send you administrative information, security alerts, and updates to our policies.

4. How We Share and Disclose Your Information

We do not sell your personal data. We may share your information with the following categories of third parties:

• Identity Verification Services: We share your KYC data with specialized third-party services to verify your identity and conduct required background checks against sanctions lists.
• On-Ramp and Payment Partners: We share necessary information (such as your name and transaction details) with our integrated on-ramp providers to enable them to process your fiat-to-crypto transactions.
• Government and Law Enforcement: We are required to disclose your information to law enforcement, regulatory bodies (like the National Bank of Georgia), and other government officials when compelled by a subpoena, court order, or similar legal procedure.
• Service Providers: We may share information with vendors who perform services on our behalf, such as cloud hosting, data analytics, and customer support services. These providers are contractually obligated to protect your data and use it only for the purposes we specify.

5. Data Security

We implement robust technical and organizational security measures to protect your personal information from unauthorized access, use, or disclosure. These measures include data encryption in transit (TLS) and at rest (AES-256), access controls, and regular security assessments. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee its absolute security.

6. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We are legally obligated under Georgian AML laws to retain your identity verification data and transaction records for a minimum period of five (5) years after the end of your business relationship with us. After this period, we will securely delete or anonymize your information.

7. Your Data Protection Rights

You have certain rights regarding the personal information we hold about you. These include:

• The Right to Access: You have the right to request copies of your personal data.
• The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate.
• The Right to Erasure: You have the right to request that we erase your personal data, subject to our legal data retention obligations.
• The Right to Restrict Processing: You have the right to request that we restrict the processing of your data, under certain conditions.
• The Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you.

Please note that these rights are not absolute. We may be unable to fulfill a request (such as a request for erasure) if it conflicts with our legal and regulatory obligations. To exercise any of these rights, please contact us using the details below.

8. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete such information.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last Updated" date. We encourage you to review this policy periodically.

10. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Faran and Co International Translations Limited
(Operating as Green Transfer)
BRN: 71560534
Address: 1 VAKHTANG GORGASALI 1 STR, F.24 TBILISI 1105, GEORGIA
Email: privacy@greentransfer.org