Privacy Policy

Terms and definitions

Terms used in this Policy have the following meanings (some terms are defined by applicable law):

• Personal data (personal information) any information relating to an identified or identifiable natural person. This includes recorded information about a specific person, or information that can be linked to a specific person directly or indirectly by reference to one or more factors specific to their physical, economic, cultural, civil, or social identity. Personal data encompasses biographical and identifying data, personal characteristics, information on marital status, financial situation, health status, and similar information.
• Personal data array any structured set of personal data pertaining to an indefinite number of subjects, regardless of the medium or technology used for processing (e.g. archives, file cabinets, electronic databases).
• Personal data confidentiality regime the set of rules establishing restrictions on access to and disclosure of personal data, as well as conditions for their transfer, provision, and storage.
• Personal data subject (data subject) an individual (Client) to whom the personal data in question relates.
• Holder (owner) of a personal data array the Company, as the entity that determines the purposes and means of processing the personal data (equivalent to a “data controller”).
• Processor an individual or legal entity, appointed by the Company, that processes personal data on behalf of the Company based on a contract.
• Collection of personal data any action by which the Company obtains personal data from data subjects or other sources, in accordance with applicable law.
• Processing of personal data any operation or set of operations performed on personal data (whether automated or not), including but not limited to collection, recording, storage, updating, structuring, blocking, erasure, and destruction of personal data.
• Consent of the personal data subject a free, specific, informed, and unambiguous indication of the data subject’s wishes (in the form required by law) by which he/she signifies agreement to the processing of personal data relating to him/her.
• Transfer of personal data the provision or disclosure of personal data by the Company to a third party.
• Cross-border transfer of personal data any transfer of personal data by the Company to a recipient in a country other than the country where the data was originally collected (outside the Company’s jurisdiction).
• Updating of personal data the prompt amendment or correction of personal data to ensure it is accurate, in accordance with procedures established by applicable law.
• Blocking of personal data the temporary suspension of processing (other than storage) of personal data, for example, to investigate accuracy or to halt use.
• Destruction (erasure) of personal data actions taken to irreversibly delete or destroy personal data, making it impossible to restore the information’s content.
• Company’s facilities (services platforms) the Company’s service interfaces through which it provides services, namely the FeeSaver website and the official Telegram bot @FeeSaver_bot.

Principles of work with personal data

When handling personal data, the Company adheres to the following fundamental principles:

• Lawfulness We collect and process personal data in a lawful manner and as permitted or required by applicable law.
• Purpose limitation We collect and process personal data only for the specific, legitimate purposes stated in this Policy (and not further processed in a manner incompatible with those purposes).
• Data minimization and accuracy We ensure that personal data collected is relevant and limited to what is necessary in relation to the purposes. We also take reasonable steps to ensure the accuracy of personal data and update it as necessary.
• Storage limitation We store personal data strictly for the period necessary to fulfill the purposes for which it was collected, and destroy or anonymize the data once those purposes have been achieved or the data is no longer required.
• Integrity and confidentiality We store and protect personal data using appropriate security measures to guard against unauthorized access, alteration, addition, disclosure, or destruction of the data. We maintain the confidentiality of personal information and prevent unlawful or accidental access to personal data.

Basic rights and obligations of personal data subjects

Your Rights: As a personal data subject (Client), you have the right to:

• Obtain full information about your personal data processed by the Company, and access your personal data. This includes the right to receive a copy of any record containing your personal data, except in cases where the law provides otherwise.
• Request that your personal data be clarified, updated, blocked, or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing.
• Take measures provided by law to protect your rights. This includes the right to lodge complaints or appeals with the appropriate supervisory authority for data protection in the UAE, or to file a claim in court, if you believe your rights have been violated.
• Exercise any other rights granted to you by applicable law regarding personal data.

Your Obligations: As a personal data subject, you are obliged to:

• Provide the Company with accurate and truthful personal data about yourself, and only to the extent necessary for the purposes of processing.
• Provide any information and documents containing your personal data that are reasonably requested by the Company for the stated purposes (for example, documents required for identity verification or compliance checks).
• Promptly notify the Company of any updates, corrections, or changes to your personal data to ensure that the information we hold is current and correct.

What personal data the company collects, processes and stores

Categories of Data: The personal data that the Company may collect, process, and store about you includes, but is not limited to, the following:

• Identity details Full name (surname, first name, middle name); date of birth; nationality; gender.
• Identification documents Passport details or other government-issued identification information.
• Contact information Postal address and actual place of residence; telephone number; email address.
• Online identifiers Telegram username (nickname) or user ID (for those who interact with us via the Telegram bot); IP address or other device/network identifiers.
• Financial information Payment card details (for processing fiat payments, if applicable); cryptocurrency wallet addresses or identifiers (for processing cryptocurrency transactions).
• Transaction information Records of transactions or exchanges you perform via our services, such as amounts, dates, and counterparties (especially relevant to blockchain transactions).

In addition to the above, the Company may request additional financial or due diligence information from you for compliance or verification purposes. For example, we might ask for information to verify your eligibility for certain transactions or to fulfill regulatory requirements, including details on your source of funds, proof of address, or other know-your-customer (KYC) documentation. In some cases, we may inquire about your financial profile (e.g. investment experience or annual income) if required by law or policy to assess suitability for particular products or services.

It is important that the personal information the Company holds about you is accurate and up-to-date. Please inform us whenever your personal data changes during your relationship with the Company so that we can update our records.

Data from Third Parties: The Company may receive information about you from third-party sources, if required or permitted by applicable law. Such sources may include affiliates or subsidiaries of the Company, analytics or search information providers, identity verification services, or publicly available databases. For example, we might obtain information from sanctions lists, politically exposed persons (PEP) databases, commercial registries, or other public records to check whether you are subject to any legal restrictions or to verify the accuracy of the information you have provided. Any information collected from third parties will be handled in accordance with this Policy and applicable law.

Website visitors, contact form and comments

This section applies to everyone who visits feesaver.com, whether or not you are a registered Client of the Company.

Contact form

If you send us a message through the contact form, we collect the type of enquiry you select, your name, your company (optional), your contact details as you enter them (for example a Telegram username, email address or phone number) and the text of your message. We also record the date and time, the page from which you sent the form and your IP address, which we use to protect the form from abuse (the number of submissions from one IP address is limited). The form cannot be sent without ticking the consent checkbox.

We use this data only to respond to your enquiry and to keep a record of it. The enquiry is delivered to the Company’s team mailbox and is also written to our server logs, so that no request is lost if email delivery fails. Our legal basis is your consent. We keep the data for as long as necessary to handle your enquiry and to meet our legal obligations.

Comments on blog articles

If you leave a comment under an article, we store the name you enter, the text of the comment, the date and your IP address (used to prevent spam and abuse). Comments are moderated: a comment, together with the name you entered, becomes publicly visible only after we approve it. Please do not include personal data in a comment that you do not want to be public. You can ask us to remove your comment at any time.

Technical data

When you visit the website, our servers and our network provider (Cloudflare, which proxies and protects the website) automatically process technical data such as your IP address, browser and device type, requested pages, referring page and the time of the request. We use this data to deliver the website, to keep it secure and to diagnose errors.

Your requests

To exercise your rights described in this Policy, including access, correction or deletion of your data, contact us on Telegram: @feesaver_support.

Purposes of collection and processing of personal data

The Company collects and processes your personal data (on its own or through authorized third-party processors) for the following purposes:

• Account setup and service access To verify your identity when you register or create an account (or wallet) with us, and to provide you with access to the Company’s services.
• Payment processing To process your transactions and payments, including cryptocurrency transactions, and to facilitate the services you request.
• Communication To communicate with you about your account or transactions, respond to your inquiries, support requests, applications, or complaints, and provide customer support.
• Service improvement To develop and improve our products, services, features, and functionality. This may include analyzing how you use our services so we can enhance user experience and design new features.
• Legal compliance (AML/KYC) To fulfill the Company’s legal obligations under anti-money laundering (AML), counter-terrorist financing (CTF), and other applicable laws. This includes conducting know-your-customer (KYC) checks and other compliance due diligence, as required by UAE law or other regulations.
• Fraud prevention and security To prevent fraudulent or unauthorized use of the Company’s services, to detect and prevent abuse of our platform, and to protect the Company’s rights, property, and the security of our platform and other clients.
• Other legal obligations To comply with any other laws and regulations that apply to the Company, and to respond to lawful requests from governmental or regulatory authorities.

The Company stores information about any cryptocurrency wallets or similar credentials you use in an encrypted form, and does not use this information for any purpose other than to provide you with our services and to fulfill the Company’s legal obligations. For example, if we store a private key or access token for your wallet (for service functionality), it will be encrypted and protected, and not used for any purpose outside of servicing your needs and complying with the law.

In order to comply with applicable laws on preventing money laundering and terrorist financing, the Company is required to collect, store, and analyze certain documentation and personal data about you. This includes documents that confirm your identity (such as copies of your passport or ID), your contact details, and records of your transactions and account activities. We may also gather verification data from third-party sources, for example by checking publicly available databases, commercial registers, or international sanctions lists. Any additional types of information required by law (such as proofs of address or source of funds) will also be collected and processed for these compliance purposes. These measures are part of our AML and KYC procedures and are taken to meet our legal obligations and to ensure the integrity of our services.

Personal data of persons under 18 years of age

The Company’s services are not intended for use by minors. We do not knowingly collect or process personal data of children (individuals under 18 years of age). Only persons who are at least 18 years old are permitted to use the Company’s services and platforms, and to provide their personal information to us. If the Company becomes aware that any person under 18 has provided (or attempted to provide) personal information or has used our services, we will take steps to permanently delete that information from our records. If you are a parent or guardian and you believe that a minor has provided personal data to us, please contact us immediately so that we can investigate and delete the data.

Special categories of personal data

The Company does not collect, process, store, or use any special categories of personal data about you. In other words, we will not ask for or intentionally gather personal data that reveals or concerns any of the following: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric identifiers (such as fingerprints or facial recognition data), health information, or information about a person’s sex life or sexual orientation. We also do not require or process information about your criminal convictions or offenses, unless required by law (for example, as part of sanctions screening). Any such sensitive personal data, if inadvertently received, will not be used and will be handled in accordance with applicable laws.

Cookies, analytics and advertising technologies

Our website uses cookies and similar technologies (such as pixels and local storage). Cookies are small data files stored on your device. Some are essential for the website to work, for example a cookie that remembers your chosen language. Others are used to track and analyse how visitors use the website and to measure the effectiveness of our advertising. A banner on the Website lets you accept or refuse analytics and advertising cookies; details are in our Cookie Policy (feesaver.com/en/cookie-policy).

We use the following third-party tools on feesaver.com. These providers may collect identifiers such as your IP address, cookie identifiers, device and browser information, the pages you view and how you interact with them, and may link this information across the websites and services where their tools are used:

• Google Analytics and Google Tag Manager (Google) traffic and usage statistics, tag management and measurement of our marketing campaigns.
• Yandex Metrica (Yandex) traffic statistics, click maps, link-click tracking and session replay (“Webvisor”), which records how visitors interact with pages, such as mouse movements, clicks and scrolling.
• Telegram Ads pixel (Telegram) measuring the results of advertising campaigns that lead visitors to our website.
• Botfaqtor detection of invalid or fraudulent clicks on our advertising.

We do not sell your personal data. The providers above process data under their own privacy policies and may be located, and may process data, outside the UAE. By continuing to use our website you agree to the use of these technologies as described in this Policy.

How to control tracking: You can block or delete cookies in your browser settings, but some features of the website may then stop working. You can also opt out of Google Analytics with the Google Analytics Opt-out Browser Add-on (tools.google.com/dlpage/gaoptout) and of Yandex Metrica at yandex.com/support/metrica/general/opt-out.html. Please contact us if you would like your data to be deleted.

Personal data protection measures

The Company takes all necessary legal, organizational, and technical measures to ensure the protection and security of your personal data. These measures are designed to prevent unauthorized or accidental access, alteration, blocking, copying, transmission, distribution, or destruction of personal data, as well as to safeguard against other unlawful forms of processing. We employ industry-standard security practices – including encryption, access controls, firewalls, and secure data storage – to protect your personal information against unauthorized access or disclosure.

All employees and agents of the Company who have access to personal data as part of their duties are bound by strict confidentiality obligations. These personnel are trained in data protection requirements and are required to safeguard personal data at all times. The obligation to maintain confidentiality continues even after these individuals cease to work with or for the Company. We restrict access to personal data only to those persons who need it for the purposes described in this Policy.

Storage period of personal data

We will retain your personal data for as long as is necessary to fulfill the purposes for which it was collected, as outlined in this Policy. Specifically, in order to comply with our legal and regulatory obligations (for instance, anti-money laundering record-keeping requirements), the Company will keep information about you and your transactions for five (5) years after the termination of our business relationship with you. Termination of the relationship may be indicated, for example, by a prolonged period of inactivity (such as if you have not used the Company’s services for more than two years) or by the closure of your account.

When the applicable retention period expires and the purposes for which the personal data was collected have been achieved, we will delete or permanently destroy the personal data in our records. If deletion or destruction is not immediately feasible (for example, if data is stored in secure backups), we will ensure that the data is kept securely and not processed further until it can be deleted.

Transfer of personal data

The Company respects the privacy of your data and will only share your personal data with third parties in certain circumstances and in accordance with this Policy. The cases in which we may transfer or disclose your personal data include:

• Service providers (processors) We may outsource certain data processing activities to trusted third-party companies that assist us in providing our services. This includes, for example, companies that help process or verify your transactions, payment processing gateways, identity verification (KYC) services, fraud prevention services, or other operational support services. These third-party processors act on our behalf and under our instructions. They are contractually bound to use your personal data only for the purpose of providing services to us (and ultimately to you), and not for their own purposes. We take reasonable steps to ensure that all such processors implement adequate security measures to protect your personal data and to prevent any unauthorized access, disclosure, or loss.
• Affiliates and subsidiaries The Company may share your personal data with its affiliated entities or subsidiaries, but strictly for the purpose of providing services to you or supporting our operations. Any personal data shared with affiliates/subsidiaries will be processed in accordance with this Policy and with the same level of protection. These group entities will not use your data for any purposes other than those we have set out in this Policy.
• Business transfers In the event of a potential or actual corporate transaction such as a merger, acquisition, investment, reorganization, or sale of the Company (or a portion of its business or assets), personal data may be transferred to the new owning or merging entity. In such cases, we will ensure that the new owner will continue to be bound by terms that are at least as protective of your personal data as those in this Policy. The new entity will only be permitted to use your personal data for the same purposes for which we originally collected it, unless you consent to a new purpose.
• Legal and regulatory compliance The Company may disclose your personal data to government authorities, law enforcement agencies, regulators, courts, or other third parties as required by applicable law or when such disclosure is necessary (i) to comply with a legal obligation or court order, (ii) to respond to lawful requests (for example, to comply with subpoenas or investigative requests), or (iii) to investigate, prevent, or take action regarding suspected illegal activities, fraud, or violations of our terms of service. We will ensure any such disclosure is done in a manner that is consistent with our legal duties and that we only disclose the minimum amount of data necessary.

In all cases of data transfer to third parties, the Company remains committed to protecting your privacy. Where feasible, we will inform you about such disclosures (unless we are legally restricted from doing so). We require all third parties who receive your personal data to treat it confidentially and to ensure its security.

Cross-border data transfer

Currently, the Company does not transfer the personal data of its Clients outside of the United Arab Emirates. Client account and transaction data we collect is stored and processed on servers located within the UAE, and our service providers are chosen such that your data remains under UAE jurisdiction whenever possible. This means that your personal information is protected in accordance with UAE data protection laws and standards.

The only exceptions are the website-related data described in the sections “Website visitors, contact form and comments” and “Cookies, analytics and advertising technologies”, which are processed by our hosting and network providers and by the analytics and advertising tools listed there, some of which may be located outside the UAE.

In the event that we need to transfer your personal data to a country outside the UAE in the future (for example, if we engage an international service provider or cloud storage located abroad), we will do so only in compliance with applicable data protection laws. Specifically, we will ensure that the recipient country or entity provides an adequate level of data protection, or we will implement appropriate safeguards (such as standard data protection clauses or obtaining your consent) as required by law to protect your privacy. We will also update this Policy to reflect any significant changes in our data transfer practices.

By using the Company’s services, you acknowledge that your personal data is handled as described in this Policy. If you have questions about how or where your data is processed, you may contact us using the information provided in the “Contacts” section of this Policy.

Transaction transparency

Due to the inherent transparency of blockchain networks, certain details of cryptocurrency transactions you conduct through our services may become publicly available by nature of the technology. For example, when you execute a transaction on a blockchain (such as the TRON network, in the context of FeeSaver’s services), information such as your blockchain wallet address (public key), the recipient’s wallet address, the amount of cryptocurrency sent or received, and any data or notes you include with the transaction could be visible on the public blockchain ledger. This information is generally outside of the Company’s control once it is recorded on the blockchain.

Because blockchain transactions are recorded on a public ledger, it is possible that transaction data and wallet addresses could be analyzed by third parties to infer information about the identity of the wallet owners. For instance, if your personal identity is linked to your blockchain address (now or in the future), someone examining the blockchain could potentially correlate transactions to you personally. You should be aware that blockchain analytics by third parties, including law enforcement agencies, might be able to piece together information about transactions and identities over time. While the Company will never publish your personal details on a blockchain, the nature of decentralized networks means transaction metadata is visible to all participants. By using blockchain-based services, you acknowledge that such transparency is a feature of blockchain systems and is outside the Company’s direct control.

Language

This Policy may be made available in multiple languages for the convenience of our users. In case of any discrepancies or inconsistencies between different language versions of this Policy, the English version shall prevail and be considered the authoritative version. All communications with regard to this Policy and the handling of personal data will be conducted in English, unless otherwise agreed.

Contacts

If you have any questions about this Policy or about how the Company processes your personal data, or if you wish to make a complaint or inquiry regarding your personal data, please contact us as follows:

• Email [email protected]
• Telegram Support @feesaver_support

The Company will endeavor to respond to your inquiries and address your concerns as quickly as possible. We may ask you to verify your identity before addressing certain requests (especially those involving access to or deletion of personal data) to ensure that we protect your information from unauthorized access.

Changes to the policy

This Policy is current as of the Last updated date indicated above. The Company reserves the right to update or modify this Privacy Policy at any time, in accordance with applicable data protection regulations. If we make any changes, we will post the revised Policy on our website (at feesaver.com) and via the FeeSaver Telegram bot (@FeeSaver_bot), and we will indicate the new effective date of the Policy. We encourage you to periodically review the Privacy Policy to stay informed about how we are protecting your information.

If the changes are material (significant), we will make a reasonable effort to notify you of the updates. This may include sending a notice to your registered email address (if we have it) or providing an in-app/website notification. Your continued use of the Company’s services after any modifications to the Policy have been posted will constitute your acknowledgment and acceptance of the updated terms. However, if we seek to use your personal data for a new purpose not originally stated, we will obtain any consent that may be required under law.

We remain committed to protecting your privacy and will not reduce your rights under this Policy without your explicit consent.