User Consent to Personal Data Processing of the BeriPay Service (Operator: NextLab LLC)

Date of Last Update: September 30, 2026

By registering, authenticating, and/or performing any actions within the BeriPay information technology service (including the website https://beripay.net, mobile application, and Telegram bot https://t.me/BeriPay_bot), acting freely, of my own free will, and in my own interest, and confirming my legal capacity, I hereby give my explicit and unconditional consent to NextLab LLC (ООО «НекстЛаб»), Registration No. 326188-3301-ООО, INN 00203202610365, legal address: Office 4a, 141 Toktogula St., Pervomaisky District, Bishkek, Kyrgyz Republic (hereinafter, the “Operator”), for the processing of my personal data under the following terms:

1. Purposes of Personal Data Processing

  • Conclusion and execution of the Agreement on the Use of the Service (Public Offer);
  • Provision of access to the information technology functionality of the Service for interacting with issuing partners for the issuance and use of Virtual Cards;
  • Execution of identity verification (KYC), biometric check (Liveness), and sanctions screening procedures in compliance with statutory AML/CFT regulations;
  • Sending service and transactional notifications, responding to Support requests, and preventing fraudulent activities.

2. Scope of Personal Data Processed

  • Identification Data: Full name, date and place of birth, citizenship, identity document details (series, number, date of issue, issuing authority), document photos/scans;
  • Biometric Data: Facial photo image obtained during biometric verification (Liveness check);
  • Contact and Account Data: Phone number, email address, username, display name, and numeric Telegram ID;
  • Technical Data: IP address, cookie files, device type and identifiers, operating system, session logs;
  • Transaction Data: Top-up request history, Virtual Card details, accounting balance records.

3. Data Transfer to Third Parties and Cross-Border Transfer

3.1. I give my consent to entrust the processing, transfer, and cross-border transfer of my personal data to authorized third parties:

  • Specialized accredited identity verification and compliance analytics partners (KYC/AML providers) — for document verification, Liveness checks, and sanctions screening;
  • Virtual Card issuing partners and card program operators — for card issuance, transaction authorization, and card maintenance;
  • Payment gateway and IT infrastructure providers — to ensure the technical operation of the Service.

4.1. This consent is effective from the moment of acceptance (registration/usage of the Service) and remains valid throughout the entire period of Service usage and Account activity.

4.2. Data Retention Duty for AML Purposes: I acknowledge and agree that, pursuant to international and national AML regulations, personal data collected during verification and transaction accounting shall be retained by the Operator and its partners for at least 5 (five) years following the termination of the relationship or Account closure.

4.3. This consent may be revoked by submitting a written notice to the email address: compliance@beripay.net. I understand that revocation of consent results in the immediate termination of Service provision and Account closure, subject to the Operator’s statutory AML retention obligations.