Privacy Policy


Data Controller:
FUNPAY LLC (Limited Liability Company)
IN 412753685 (Identification number, LEPL National Agency of Public Registry)
Legal Address: Georgia, Tbilisi, Samgori District, Akaki Paghava Str., N 27 B

Data Protection Officer:

FUNPAY LLC (Limited Liability Company) IN 412753685 ("Funpay", "Company", "We", "Us", "Website" or "Controller") processes data in accordance with the provisions of European Regulation 2016/679 (General Data Protection Regulation) and the current legislation of the Russian Federation, Ukraine and Georgia on the protection of personal data.


1.1. We take your privacy seriously and are committed to safeguarding your personal information at Funpay. We value you as our customer, respect your privacy and are committed to protecting it through our compliance with this Policy.

1.2. This Policy describes the sources of your personal information that we may collect from you or that you may provide to us, our purposes for collecting and processing your information, and our practices for collecting, using, maintaining, retaining, protecting and disclosing that information.

1.3. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our platforms. By accessing or using our platforms, you agree to this privacy policy.

1.4. We may update this Policy from time to time and if we make any material changes, we will notify you when we do so.

1.5. If you have any questions or concerns about this privacy policy or your personal information, please contact us using the details provided in Section 9 – 'Contact us' or you can reach us by using webform ( – this is the best and fastest way to contact us.

1.6. Please note we have a separate - DSAR Guidance ( that clarifies our Policy on Data Requests.


2.1. This section gives a brief overview of Our information-collection practices and can provide you with several examples of what personal data we collect and how are We using it.

2.2. The personal information we collect on or through our platforms may include:

• 2.3. Trading information and orders.

2.3.1. Any personal data that you provide, publish or make otherwise available when placing or responding to a trade offer, exchanging trade details, discussing or making an order on our Website will be stored and processed according to Section 2 and Section 3 of this Policy. Including but not limited to: account details, login information, emails, etc.

• 2.4. Information that you provide by filling in forms.

2.4.1. This may include information provided at the time of registering to use our services or when visiting our Website (, subscribing to our services, registering for newsletters, reporting a problem with our Website or services. Examples of data we collect in this way is as follows, but not limited to: your name, IP address, email, company name, address, cookies, etc.

• 2.5. Records and copies of your correspondence

2.5.1. When you contact us, your messages and comments you make on our platform as well as any conversations or messages exchanged between you and other users can be stored and processed in accordance with Section 2 of this Policy. We use this data to provide you with a better service and to increase the quality of our products. We also need this information in cases where there is a dispute or any technical issue encountered. We reserve the right to request additional personal data from you, as it may be required for a successful dispute resolution. When leaving reviews: any personal data included in you review and any related information you supply to us when providing us with your feedback. This includes feedback, reviews and comments posted on our platform.

• 2.6. Dispute Resolution

2.6.1. Dispute Resolution is vital for our business model. We strive to support our customers at every step of their user experience and when they use our services. For this reason, we store and process any information you provide to us during the mediation process, other dispute resolution methods, when receiving technical support or when providing information related to the abovementioned methods. We may also require additional personal data to adhere to our legal and contractual obligation, including complying with local laws in the countries we operate. Due to the extensive and dynamic nature of the dispute resolution process, the types of personal data that we may require or ask from you can change and are based on the dispute's nature. Funpay reserves the right to refuse to mediate or resolve a dispute if the required personal data is not supplied (provided it is impossible to reach a decision without obtaining the data first). We may also use, publish or otherwise make publicly available some types of your personal data if this is necessary for maintaining our brand integrity and public image.

• 2.7. Technical information and analytics

2.7.1. Technical information and analytics, such as browser types, usage details, time of requests, operating system, IP addresses, information from Google Analytics and similar tools and information collected through cookies and other tracking technologies. Funpay also monitors and analyses web traffic and user behaviour within its services to verify their functionality, quality and interest. The data involved in this activity are cookies and usage data, such as the parts of our services that users visit, the date and duration of the visit and the type of device that is used during the visit. All the data indicated in this paragraph are collected and further processed in a way that does not allow the identification of the user.

• 2.8. Aggregated statistical data.

2.8.1. We do not use automatic decision-making or profiling.


3.1. We work closely with third parties and receive information about you from them as well. This may include third-party services such as Google Analytics, Yandex Mail, Zendesk, Freshdesk, online payment processing services, such as Tome and other trusted third parties.

3.2. We might need to retain certain data (such as credit card details or other metrics) because we are required to do so by Law, our existing contracts with third-party providers or when it is necessary for providing our services or technical support of our Website and platform.

3.3. All personal data of users that is collected in this way is stored and managed in accordance with the international EU and US Law as well as local laws of the Russian Federation, Ukraine, and Georgia.


4.1. We request you to provide us accurate and complete information about yourself and any other person whose personal information you provide us and for updating when it becomes incorrect or out of date by contacting us. This is a condition to the provision of our services to you and may influence the availability of certain products or functions that we can offer you when you decline.


5.1. In addition to the examples provided in the section 2 of this Policy.

5.2. Any of the information we collect from you may be used for one or more of the following purposes:
5.3. to provide you with authorisation to login and use your user account;
5.4. to verify your identity and age;
5.5. to maintain correct and up-to-date information about you;
5.6. to identify you as a contracting party;
5.7. to improve our Website;
5.8. to enable automated handling of the subscriptions;
5.9. to resolve any disputes or provide technical support in a purchase-related incidents.
5.10. to otherwise be able to provide the Services to you according to this Policy.


5.11.1. Occasionally, at our discretion, we may include or offer third-party products or services on our Website. We may also use third-party tools or other technical solutions (e.g. our payment partner Tome) that may require you to submit your personal data on a third-party website. These third-party websites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these websites.


6.1. The data is processed:
6.2. in full compliance with applicable legislation, based on the information provided and in a fair and transparent manner;
6.3. collecting a minimum number of data and in any case collecting only the data strictly necessary for the functioning of the Website;
6.4. in a precise and updated way;
6.5. retaining the data only for the time necessary to guarantee the functioning of the site and to comply with any regulatory obligations. The data will then be deleted or anonymised.

6.6. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorised access.


7.1. A cookie is a text file that is downloaded to your device when you visit a website. It can help identify your device whenever you visit that Website. To make the best use of our Website and related services (such as mediation or other dispute resolution methods), we would recommend you set your device or web browser to accept cookies. However, you can always choose to refuse our cookies. If you do so, you may not be able to use some portions of our Website or some of our services.

7.2. For more information on how we use cookies please see our Cookie Policy:

7.3. We can use cookies to:
7.4. analyse how websites and apps perform and are used.
7.5. give you content that matches your preferences.
7.6. some cookies can help us to make sure your information is secure when using our services.
7.7. ensure the Website's pages look consistent.


8.1. Cookies are small text files that websites use to store and collect information through the browser. They are mainly used to measure and improve the quality of the site through the analysis of visitor behaviour, to personalise pages and remember user preferences. We may automatically collect the following information when you use our service:

8.2. Your device, browsing actions and patterns are collected automatically as you navigate through our websites.
8.3. The choices you make when using our Website, such as preferred currency, location, language.
8.4. Information you supply during registration or when using our log in service.
8.5. Information about you collected by third-party cookies, web beacons and other tracking technologies

8.6. Please see our Cookie Policy ( for more information about cookies and consult Our Cookie Preferences tool ( to adjust your choices.


9.1. Due to the technical nature of our data processing, this largely depends on where you reside.

• 9.2. EU/EEA and International data

9.2.1. If you reside in the EU/EEA area or anywhere else in the world except Russia or Belarus - your personal data is handled and stored within the EU/EEA. Every international data transfer of your data is protected with appropriate organisational measures and specific contractual clauses to safeguard your privacy and provide you with the best possible protection. This applies to data transfers both within our company and when we are sharing or receiving data from our authorised partners. If we make any material changes to this section, we will notify you when we do so.

• 9.3. Russia and Belarus

9.3.1. If you reside in Russia or Belarus - your personal data is handled and stored in Russia. Every international data transfer of your data is protected with appropriate organisational measures and specific contractual clauses to safeguard your privacy and provide you with the best possible protection. This applies to data transfers both within our company and when we are sharing or receiving data from our authorised partners. If we make any material changes to this section, we will notify you when we do so.


10.1. We do not trade or otherwise transfer for value any personally identifiable information to outside parties. This does not include trusted third parties or subcontractors hired to provide services on our behalf.

10.2. This includes those who act as data processors on our behalf, acting strictly under contract and in accordance with Article 28 of GDPR. With your confidentiality and protection in mind, we will always strive to protect your data when dealing with third-party vendors and other data processors. They can only use your data in the ways specified by us.

10.3. As permitted by Law, we may share the information we collect from and about you with third parties as follows:

10.4. Third-Party Service Providers. Your information may be shared with or collected by third-party service providers who provide us with services, including but not limited to data hosting or processing, credit card processing or processing and fulfilling of purchases. We require these providers to exercise reasonable care to protect your personal information and restrict the use of your personal information to the purposes for which it was provided to them. Currently, the site uses only Google Analytics and Yandex Metrica. You can access their Privacy Policies at the following addresses: and respectively.

10.5. Aggregate Information. We may share your information with affiliated or non-affiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.


11.1. We retain your records in accordance with national best practice guidance and we only process your personal data as long as it is necessary for the purposes for which the information in question is processed as described in section 2.

11.2. After the purpose of the information has been fulfilled, all information is anonymised or erased by us.

11.3. Where your personal data is processed by us on the basis of your consent we will delete or anonymise your data if you withdraw your consent. We will not terminate our existing contracts or your existing legal obligation based solely on this withdrawal. However, we may not be able to provide you with some services or offer you unrestricted access to our Website and some of its functions. This is because we may need your consent for the processing of personal data for the provision of the abovementioned services.


12.1. Whenever we rely on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at: email address. Please read and review our Data Subject Access Request Guidance (DSAR) ( before contacting us, as it may clarify some of your questions or concerns.

12.2. You also have specific rights under the GDPR and The Data Protection Law (N 152-ФЗ) to:

12.3. understand and request a copy of the information we hold about you.
12.4. ask us to correct any incorrect information about you;
12.5. ask us to restrict the processing of your personal data where you believe such data to be inaccurate; our processing is unlawful; or we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
12.6. object to the processing of your personal data where the legal justification for our processing of your personal data is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
12.7. request that your personal data be moved to another controller of personal data by receiving your personal data, to the extent it has been provided by you, in an electronic format which is generally used in order to be able to transfer it to another party (the right of data portability).
12.8. request that your personal data be erased (subject to legal obligations, we might have to keep your data). If there are no legal obligations for us to retain your data – it will be deleted at your request.


13.1. If this Privacy Policy is translated into any other language, and there is any inconsistency or conflict between the English and translated versions of this Privacy Policy, the English version shall prevail.


14.1. For any questions or concerns, you can contact us in one of the following ways.

14.2. By webform: – this is the best and fastest way to reach us. By submitting this form, you provide us with crucial information that may help us expedite your request and deal with the issue faster.

14.3. Alternatively, you can email us at: Please note that it may take us longer to process your request this way.

Effective date: 2022-02-14
Permanent link: