Last updated: September 1, 2025
This Privacy and Personal Data Protection Policy aims to inform users (“Users”) of CoinPay.cr, a brand operated by Raw Industries CCM S.R.L., a company incorporated under the laws of the Republic of Costa Rica, about the processing of their personal data when using the digital services and platforms of CoinPay.cr (hereinafter referred to as “the Company”, “we”, or “our”).
CoinPay.cr is committed to protecting the privacy and personal information of all its users, complying with Law No. 8968 “Protection of the Individual Against the Processing of Personal Data”, its Regulation (Executive Decree No. 37554-JP), the FATF/GAFI Recommendations on financial protection and traceability, and the principles of the European Union’s General Data Protection Regulation (GDPR).
The use of CoinPay.cr services implies the User’s express acceptance of this Policy.
CoinPay.cr collects and processes only the information necessary for the provision of its services, identity verification (KYC), compliance with legal obligations, and the prevention of fraud and money laundering.
a) Identification data
● Full name, identification number, passport, or corporate ID.
● Date of birth, nationality, and country of residence.
● Photographs of documents and biometric verification (if applicable).
b) Contact data
● Physical and/or mailing address.
● Phone number and email address.
c) Financial and transactional data
● Information about bank accounts, payment methods, and digital wallets.
● Details of transactions made, amounts, currencies, and blockchain addresses.
● Proof of funds and financial supporting documents.
d) Technical and connection data
● IP address, browser, operating system, and device model.
● Information derived from platform use, cookies, and traffic analytics.
e) Compliance data (KYC/AML)
● Information on economic activity and occupation.
● Declarations regarding the origin and destination of funds.
● Checks against international lists (OFAC, UN, EU, etc.).
CoinPay.cr does not collect sensitive data (such as political, religious, or medical information), unless required by law and with the user’s express consent.
The personal data collected are used exclusively for the following purposes:
1. Legal and regulatory compliance:
● Prevention of money laundering and terrorist financing (AML/CFT).
● Identity verification and transaction monitoring.
● Customer service and technical support.
2. Service provision:
● Opening and management of CoinPay.cr accounts.
● Execution of transfers, payments, and currency exchanges.
● Customer service and technical support.
3. Commercial and operational management:
● Sending operational notifications, security alerts, or policy updates.
● Internal audits, risk control, and continuous platform improvement.
4. Technological security and fraud prevention:
● Monitoring of unusual or suspicious usage patterns.
● Protection of systems and user information.
5. Compliance with contractual and tax obligations.
CoinPay.cr does not use personal data for mass marketing purposes nor sells it to third parties.
The processing of personal data is carried out based on the following legal grounds:
● The user’s express consent upon registration or use of services.
● Compliance with legal obligations regarding AML/CFT, tax, or regulatory matters.
● Execution of a contract between CoinPay.cr and the User.
● The Company’s legitimate interest in ensuring the security, traceability, and reliability of operations.
CoinPay.cr may share personal data only when strictly necessary and under the principles of proportionality, confidentiality, and security.
a) Entities with which data may be shared
● Authorized local or international financial and banking providers.
● Competent authorities (judicial, regulatory, tax, or law enforcement) upon formal request.
● Technological partners or providers of security, compliance, or infrastructure services, under confidentiality agreements and equivalent protection standards.
b) International transfers
Data may be transferred to servers or entities located outside Costa Rica only to jurisdictions with adequate levels of data protection.
Under no circumstances will CoinPay.cr transfer information to countries considered high-risk or non-cooperative by FATF/GAFI.
In accordance with Law No. 8968, the User has the following rights:
● Access: To know the personal data processed by CoinPay.cr.
● Rectification: To request correction of inaccurate or outdated information.
● Deletion (erasure): To request deletion of data when it is no longer necessary or when the legal basis has expired.
● Objection: To object to processing in certain legitimate cases.
● Withdrawal of consent: To revoke previously granted authorization.
To exercise any of these rights, the User may contact:
Official email: [email protected]
Headquarters: San José, Costa Rica.
Requests will be addressed within a maximum of 10 business days.
CoinPay.cr retains personal data only for as long as necessary to fulfill the stated purposes or as required by applicable law.
The data are protected through:
● Encryption in transit and secure storage.
● Access control and multi-factor authentication.
● Continuous system monitoring and internal audits.
● Encrypted backups and environment segregation.
In the event of a security breach, CoinPay.cr will promptly notify the competent authorities and affected individuals, in accordance with applicable legislation.
The CoinPay.cr website uses cookies and similar technologies to:
● Maintain active user sessions.
● Improve browsing experience.
● Analyze usage and performance statistics.
The User may configure their browser to reject or delete cookies; however, this may limit the functionality of certain sections of the site.
No third-party cookies are used for advertising or off-site behavioral tracking.
CoinPay.cr services are intended exclusively for individuals over 18 years of age.
We do not knowingly collect information from minors. If a parent or guardian identifies that a minor has provided information, they may request its immediate deletion by writing to [email protected].
CoinPay.cr may modify this Privacy Policy at any time to adapt to legal, technological, or corporate changes.
Updated versions will be published at www.coinpay.cr/privacy, indicating the date of the last update.
Continued use of the services after such modifications constitutes acceptance of the new version.
For questions or complaints related to personal data protection, the User may contact:
CoinPay.cr / Raw Industries CCM S.R.L.
San José, Costa Rica
Email: [email protected]
Website: www.coinpay.cr
This Policy is governed by the laws of the Republic of Costa Rica, and any disputes shall be submitted to the courts of San José, Costa Rica.
Language clause
This Privacy Policy is published in Spanish and English.
In case of discrepancy or conflict of interpretation, the Spanish version shall prevail.