PurpleRailLegal

Privacy policy

Version 0.1 (draft) · Last updated 5 November 2026

Draft for review by counsel. The operating entity and its registration details will be confirmed before launch; until then this policy describes the PurpleRail test environment, in which no real funds are processed.

1. Who we are

PurpleRail is a crypto payment service: it lets businesses ("merchants") accept payments in crypto-assets and receive fiat currency. The service is operated by [PurpleRail operating entity, registered address, company number] ("PurpleRail", "we"), with technology provided by Ecomstat. Custody of crypto-assets and fiat accounts is provided by licensed financial institutions and specialist providers named in section 6.

Contact for privacy questions: [privacy@ — to be confirmed].

2. Whose data this covers

3. What we collect and why

DataWhy we use itLegal basis (EU/UK GDPR)
Payment details: order reference and amount from the merchant, the token and network you choose, the deposit address we give you, the sending wallet address and transaction hash on the blockchainTo process the payment, detect and confirm it, refund it where needed, and keep records for the merchantPerformance of a contract with the merchant; our legitimate interest in providing the service
Anti-money-laundering and sanctions screening results about the sending walletTo meet legal obligations to prevent money laundering, terrorist financing and sanctions breachesLegal obligation; legitimate interest in preventing financial crime
Refund address you give usTo return fundsContract; legal obligation
Merchant user account data: name, business email, role, sign-in times, two-factor settingsTo provide secure access to the dashboard and appContract with the merchant; legitimate interest in security
Business and payout details: company information, bank account, payout historyTo pay merchants and meet record-keeping dutiesContract; legal obligation
Technical data: IP address, device and browser type, security logsTo keep the service secure and working, and to investigate abuseLegitimate interest

We do not ask payers for their name, email or card details to pay with crypto, unless the law or the merchant's risk policy requires additional information (for example under the Travel Rule for larger transfers). We do not sell personal data and we do not use it for advertising.

Blockchain data is public and permanent. Wallet addresses and transactions you make on a blockchain can be seen by anyone and cannot be deleted by us or by anyone else.

4. Automated decisions

Every payment is screened automatically for sanctions and financial-crime risk. Payments from sanctioned sources are blocked automatically, as the law requires; other elevated-risk payments are reviewed by a person. We may not be able to tell you why a payment was blocked, because the law can prohibit disclosing that ("tipping off"). You can contact the merchant or us to ask for a human review where the law allows it.

5. How long we keep data

6. Who we share data with

7. International transfers

We host in the EU/UK. Where a provider processes data outside the UK/EEA, we use appropriate safeguards such as the European Commission's standard contractual clauses or an adequacy decision.

8. Security

Data is encrypted in transit; passwords are stored only as strong one-way hashes; staff access is role-based with two-factor authentication and a full audit log; customer funds are held by licensed custodians under policies we cannot change on our own.

9. Your rights

Depending on where you live, you can ask to access, correct, delete or receive a copy of your personal data, to restrict or object to its use, and to complain to a data-protection authority (in the UK, the ICO; in the EU, your local authority). Some data cannot be deleted while we must keep it by law, and data written to a blockchain cannot be deleted by anyone. Contact us using the details in section 1.

10. Mobile app

The PurpleRail app for merchants uses the same data as the dashboard. It may use your camera only if you choose to scan a QR code, and sends notifications only if you allow them. It contains no advertising or third-party tracking.

11. Changes

We will post any changes on this page and update the date above. Significant changes will be notified to merchants in advance.

PurpleRail v0.1.0 · build 39f0527