PRIVACY POLICY

Prometheus Payment Systems, Inc. ("Prometheus," "us," "we," "the Company" or "our") is dedicated to ensuring and protecting your privacy. Prometheus Payment Systems is a Delaware Corporation, registered as a Money Service Business with FinCEN. (Registration Number: 31000307873438) Services are provided under American Law.

This Privacy Policy ("Policy") describes and clarifies to you how we use, collect, share, and secure your personal data collected by us when you visit our websites located at prometheus.inc or any other websites, pages, features, or content we own or operate (in aggregate, the "Site(s)"), when you use the Prometheus SDK or third party applications relying on such SDK, or when you use the Prometheus API or third party applications relying on such API, and related services (referred to collectively hereinafter as "Services").

You are agreeing to the terms of this Policy by using and accessing our Services. Where we require your consent to use or process your personal data, we will ask for your consent to the collection, use, and disclosure of your personal data in advance, and such consent is voluntary and can be withdrawn at any time.

We may change this Privacy Policy from time to time at our own discretion. We will provide you with notice if we make a change to this Policy that we believe materially affects how we process your personal data or reduce your rights via your stored e-mail address. This Policy was last updated at the date listed at the beginning of this policy.

If you withdraw such a consent to process your Data, it is likely that Prometheus may not be able to provide you Services. If you do not agree with or you are not comfortable with any part of this Policy, please immediately discontinue access or use of our Services. If you have questions regarding the policy, please reach out to us before usage of our Services using the contact information provided in the Contact Us section below.

We also reserve the right to provide "real-time" disclosure or additional information about our data collection, use and sharing practices of specific Services. These notices may supplement or clarify Prometheus's privacy practices or may provide you with additional choices about how we process your personal data.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us at the following email address: team@prometheus.inc

You may also submit any questions or concerns regarding this Privacy Policy directly through the contact form on our primary website: prometheus.inc

Our Entities

Prometheus Operates through Prometheus, INC, a Delaware corporation. Prometheus may share information with related entities in the future, but does not share information with subsidiaries or other affiliated entities currently. Prometheus currently has a subsidiary in the European Union, Prometheus, UAB, with which Prometheus may share information.

The Personal Data We Collect

Prometheus collects three types of information about you and your use of our Service. Prometheus groups this information into three different types of categories. These categories currently include:

  • Category 1 - Information you provide to us directly.
  • Category 2 - Information we collect from you programmatically through your usage of the Service.
  • Category 3 - Information we collect about you from third parties necessary for the usage and provisioning of the Service.

Category 1

We may collect the following types of personal data from you. Collection of this personal data is either required by law, or necessary to provide the requested service.

  • Personal Identification Information: Full name, date of birth, place of birth, and/or email address and other identifying information.
  • Financial Information: i.e., crypto currency addresses information, wallet address(s), transaction history, trading data or history.
  • Customer Service: Records and copies of your correspondence (including email addresses), if you contact us via email, social media, or any customer service/management tool.
  • Employer/employee Information: Start date, company name, and/or title, education, and training Information (schools/universities attended, course of study, academic grades, degrees obtained, and/or professional certification and licenses).
  • Biometric Information: biometric information, government identification, and selfie (i.e., photograph of you). Please note that our service provider collects your biometric information, government identification, and selfie from you but does not disclose this biometric information to Prometheus, Inc. Instead, Prometheus receives the results of our service provider's processing of your biometric information along with a copy of your government ID and selfie.

Category 2

Information we automatically collect from you. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services.

This information helps us improve the performance of our Sites and Services, addresses customer support issues, as well as provide you with a streamlined and personalized experience, and additionally protects your account from fraud by detecting unauthorized access.

We may collect following types of information automatically from you: Information About Your Use of the Service: when you browse our Sites, we automatically collect information such as your Internet Protocol ("IP") address, your device type, previously visited domains and sites, browser type, referring and exit pages and URLs, pages viewed and the order of these page views, time of accessing our pages and Services, speed and duration of time on our Site.

Category Three

Information we collect from third parties.

From time to time, we may obtain information about you from third party sources as required or permitted by law such as your service providers and through publicly available sources. For example, payment providers you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well other data necessary to carry out transactions. We may also collect data from AISP if you choose to use this identification and/or payment method (on the basis of your explicit consent given to AISP to obtain account information).

Cookies - Definition

A cookie is a text file that a Web browser stores on a user's machine. Cookies are a way for Web applications to maintain application state. They are used by websites for authentication, storing website information/preferences, other browsing information and anything else that can help the Web browser while accessing Web servers.

Cookies and Similar Tracking Technologies

We and third parties on our behalf may employ various tracking technologies, such as cookies and other similar technologies (collectively, "Tracking Technologies") to collect additional Personal data automatically as you interact with our Services, that help us to personalize your experience with our Service, and help us better manage content on our Service by informing us what content is effective.

Prometheus retains the right to use Cookies or technologies that provide similar information as Cookies in the provisioning of our services. Prometheus may or may not use cookies in service of the goals. This list in relation to cookies is indicative but not exhaustive, and is subject to change from time-to-time.

  • Store information about your preferences - including storing payment information to make it simple for users to complete purchases.
  • Analyze our web traffic using an analytics package - this information can be used to improve our user experience, drive user growth activities and prevent unwanted activity from being passed through our Services
  • Identify whether any individual has already visited our Sites or used our Services
  • To recognize when any individual returns to our Sites
  • Test content on our Sites

From time to time Our Sites may use a 'load balancer' to store an identifier on your browser to help keep you connected to the same web server throughout your visit, for a smoother browsing experience. Similarly, session cookies enable our individual web servers to keep track of your progress throughout your visit. When you submit data through a form such as a contact page or comment box, cookies may be set to remember your user details for future correspondence.

We may use the following third-party cookies:

  • Google Analytics - Google Analytics is a well-known and widely used tool for tracking and analyzing web traffic data. We reserve the right to use Google Analytics and similar services to analyze and track traffic through our Sites and Services.
  • Cloudflare - to keep the connection stable and to identify spammers.

Please note: If you do not wish Prometheus to deploy cookies in your browser, you can instruct your browser to block some (or all) cookies as well as alert you when a site attempts to place cookies in your browser. If you instruct your browser to reject/disable cookies, you can still use the Website, although your ability to use some of the features will likely be impacted. Instructions for disabling, rejecting or restricting cookies are readily available via freely available internet guides.

How we use Analytics

Our Sites and our third-party technology providers use third-party analytics services (such as Google Analytics) to evaluate your use of the Sites, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Sites and Internet usage.

These third parties use cookies and other technologies to help analyze and provide us the data. If you would like to disable Google Analytics cookies, please use this link as a reference point. There is a wealth of easily accessible information on disabling both cookies and Google Analytics.

The Purpose of Using Your Personal Data

Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized (where appropriate) experience. In general, we use personal data to create, develop, operate, deliver, and improve our Services. We may use your personal data to:

Provide Prometheus's Services. We process your personal data to provide the Services to you. When you use Prometheus to conduct a transaction, we require information such as your identification, and payment information. We are unable to provide you with Service without the aforementioned information. Prometheus works with a network of industry leading data and analytics firms - and these aforementioned third parties may also access and/or collect your personal data when providing fraud prevention services, identity verification and restricted individual (OFAC/PEP) screening.
Maintain Legal and Regulatory Compliance. Prometheus's Services may be subject to regulations and laws mandating that Prometheus collect, use, and store your personal data in the service of maintaining regulatory compliance. As an example, Prometheus must identify and verify customers using our Services in order to comply with anti-money laundering laws of various jurisdictions. If you do not provide personal data required by law, we will have to close any accounts created with your information.
Enforce Terms in Our Agreements. Prometheus handles sensitive information, such as your identification information and financial information, so it is very important for us and our users that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted Terms of Service.
Detecting and Prevent Fraud and Security Risks. We may process your personal data to help monitor, prevent and detect any form of fraud and/or abusive use of our Service, enhance security, and combat other security risks what might result in funds loss.
Response to Requests. We may process your personal data when you contact us, such as with questions, concerns or feedback. We may share this information with our service providers or partners to the extent necessary to provide you a response that we are satisfied with.
Provide Services Communications. We may send administrative, account and/or transaction related communications to you to keep you updated about our Services, inform you of relevant security issues, or provide other information related to your transactions.
Provide Marketing Communications. We may process your personal data or service usage information to send you marketing communications that we believe may be of interest to you, such as marketing newsletters and commercial information about our Services. We only process your personal data for this purpose with your consent and you may opt out from receiving marketing communication when registering an account with us.
Research and Development of Our Services. We process your personal data to build statistical models, to better understand the way you use and interact with our Services to improve our existing Services and to build new Services.
Personalize Your Experience. Please see the relevant piece of this privacy policy "Cookies - Definition" and "Cookies and Similar Tracking Technologies." As permitted under the applicable law, we may also use cookies to process your information to personalize your experience and to enable you to more easily interact with our Services across platforms and devices. Please see Cookies and Other Similar Tracking Technologies section for more information.
Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

Legal Bases for Processing Your Personal Data

We generally only process your data where we are legally required to; where processing is necessary to perform any contracts we entered with you or to take steps at your request prior to entering into a contract with you; where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms, or where we have obtained your consent to do so.

How We Share Your Personal Data

We share your personal data as needed to fulfill the purposes described in this Policy and as permitted by applicable law. We may share your personal fata in the following circumstances:

Within Our Corporate Organization. We may share information between and among Prometheus subsidiaries and affiliated companies for purposes of KYC/CDD checks, fraud detections, decision making, customer support, and other business purposes.
When We Work with Service Providers. We may share your information with service providers that provide us with support services, such as secure website hosting, cloud storage, information technology maintenance, transaction monitoring, network infrastructure, payment processing, security, fraud detections, KYC/CDD checks, customer support and analytics.
With Payment Processors. Upon your authorization, we may share your personal data with financial institutions that we partner with to process payments.
With Our Professional Business Advisors. We may share your personal data with our professional advisors who provide banking, legal, compliance, and other consulting services in order to complete required legal audits of our operations, or otherwise comply with our legal obligations.
Corporate Transactions. We may disclose personal data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by us is among the assets transferred. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal data.
As Required by Law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of Prometheus or our customers.
With Your Consent. We may disclose your personal data for any purpose with your consent. For example, to other data controllers whose terms of service you consented to.

Third-Party Sites and Services

Our Services may contain links to third-party websites. Please note that third parties you interact with may have their own privacy policies, and Prometheus is not responsible for their operations or their use of data they collect. We encourage you to check the applicable third-party privacy policy and terms of use when visiting or using any third-party services.

Our services are typically accessed via third-party websites. Please note that these third parties that you interact with before your interaction with Prometheus may have their own privacy policies, and Prometheus is not responsible for their operations or their use of data they collect. We encourage you to check the applicable third-party privacy policy and terms of use when visiting or using any third-party services.

Your Privacy Rights

Depending on applicable law of where you reside, you may be able to assert certain rights related to your personal data and information. These rights include:

  • The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • The right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation.
  • In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to Prometheus;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;
  • the right to object to, or request that we restrict, our processing of your personal data in certain circumstances. There may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
  • the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us;

You can exercise your rights by contacting us via email at team@prometheus.money. Further information about your rights may be obtained by contacting the supervisory data protection authority located in your current jurisdiction.

Retention of Your Personal Data

We will only retain your personal information for as long as it is necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes.

For the purposes of our compliance with Anti-Money Laundering obligations, for example, we will store your personal data for five years beginning on the date on which our business relationship has come to an end. Please note that this means your data is stored for five years post your final transaction with Prometheus, not your initial transaction with Prometheus.

We will cease the retention of your personnel data, or remove the means by which the data can be linked with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for maintaining our compliance, regulatory or legal obligations.

Prometheus Data Protection Safeguards Explained

We maintain (and contractually requires third parties that share your personal data to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of your personal data both during transmission and at rest.

For example, we use industry standard encryption methods, such as TLS/SSL protocol, for all data transmissions and we store all data in encrypted databases to ensure the security of your data.

No data storage system or data transmission can be guaranteed to be 100% secure. We cannot guarantee that the information you supply will not be intercepted while being transmitted over the Internet. E-mail, in particular, that is sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Sensitive documents and information should always be submitted via our portal rather than sent over e-mail, which may be less secure. You are responsible for protecting your password(s) and maintaining the security of your browsers and devices.

If you have reason to believe that your personal data is no longer secure, please contact us immediately at: team@prometheus.inc.

California Residents - Policies and Procedures

This section only applies to California residents. The purpose of this section is to inform California residents ("consumers" or "you"), at or before the time of collection of "personal information" (as that term is defined in the California Consumer Privacy Act ("CCPA")), about our data collection practices and your privacy-related rights under California law). Your "right to know" about personal information collected, used, and disclosed by Prometheus includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you entrust to us.

Categories of Personal Data Collected

For California Residents, the chart below describes the categories of personal information that Prometheus has collected in the preceding 12 months, the sources and purpose of such collection, and the parties to whom the information was shared for business purposes.

Rights Under the CCPA

Access to Specific Information and Data Portability Rights – Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. If you are a California Resident who wishes to access your data under the rights under CCPA, please reach out to the Prometheus team using the contact information listed in the "Contact Us" section of this Privacy Policy.

Once we receive your request and verify your identity, we will disclose to you:

  • The categories of personal information we have collected about you;
  • The categories of sources for the personal information we have collected about you;
  • Our business or commercial purpose for the information collection;
  • The categories of third parties with whom we share that personal information; and
  • The specific pieces of personal information we collected about you.
Sale of Personal Information – You have the right to request that we disclose to you: the categories of your personal information that we sold, and the categories of third parties to whom your personal information was sold. Prometheus does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent.
Deletion Request Rights – Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained.
Non-Discrimination – We recognize and respect that you have the right to not receive discriminatory treatment by the business for exercising any of your CCPA rights.
Exercising Access, Data Portability, and Deletion Rights – To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to us by contacting us as described in the "Contact Us" section below.
Use of an Authorized Agent to Submit a Request – Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

Children's Personal Data

As Prometheus's terms of service prohibit transacting with individuals under 18, we do not knowingly request to collect personal data from any person under the age of 18. Individuals under the age of 18 who attempt to transact with Prometheus's services will be rejected before they can complete any action on the Services.

If a user submitting personal data is suspected of being under the age of 18, we will require the user to close his or her account, terminate the user's access to our Service, and take steps to delete the personal data collected as soon as possible. If you are aware of any Child using our Services, please notify us via the method identified in the Contact Us section below so we can take action to prevent access to our Services.