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"We may process your software or PC data. All personal information, which is sent by default by User's installed software, including without limitation: IP-address of the User, files content of cookies, personal information, which is conveyed by the browser or different software allowing you to have access to our Service, and also, time/date and the URL of your requested page, an ID of your digital wallet, CSP name, exact time/date of the sent SMS-message, as well as it's content."

The policy collects an unusually broad range of device data including digital wallet IDs, SMS message content and timestamps, and all information sent by installed software "without limitation" — going well beyond what's needed for basic service functionality.

"To work on email campaigns, business intelligence, and behavior statistics, we make use of the service called "Google Analytics", which is provided by Google LLC and is situated in the US. Among the information, which we supply to Google Analytics, there is your IP address, as well as data used by Google Analytics for gathering information about the Application usage by you."

User IP addresses and behavioral data are shared with Google Analytics for business intelligence and behavior statistics, and additional disclosures are made to lawyers, auditors, accountants, and other advisors.

"All changes to this Policy shall be made and published as outlined in the Agreement. A notification regarding changes may be rendered to you by publishing on the Plamfy Website."

Changes to the privacy policy can be made with notification only via website publication — no direct user notification is required, and users may not be aware of material changes.

"In certain instances, we are not able to specify beforehand the time periods during which your personal information will be kept. In such instances, the period of retention is determined according to the time period during which having access to the data is essential to us for providing services, getting payment, addressing customer support matters, other issues, or in the event of other legal or auditing reasons."

While specific deletion timelines are given for some data (30-90 days post-deletion), the policy includes a broad carve-out allowing indefinite retention when they deem it essential for vaguely defined purposes like "other issues."

"We will delete your confirming identity analytics data following 30 days period after account deletion. We will hide your public profile after 30 days since you delete your account. We will remove your login details, account and ID data, technical, and trade data 90 days after the deletion of your account."

Account deletion involves mandatory waiting periods of 30-90 days during which personal data including login details, ID data, and public profile information continue to be retained.

"Login details may involve: your full name, the Account Photo, nickname, ID, emails, birthdate, gender, city of residence, region, country, and also your social media user credentials. ... All personal information, which is sent by default by User's installed software, including without limitation: IP-address of the User."

The service collects IP addresses and detailed location information including city of residence, region, and country, which enables ongoing geolocation tracking of users.