Privacy Policy

Juno Technologies Limited
Effective date: 29 September 2026

This Privacy Policy explains how Juno Technologies Limited (Juno, we, us, or our) collects, uses, discloses, retains, and protects personal information in connection with the Juno Pay application, website, and related services (the Service).

1. Scope, responsible entity, and contact

Juno Technologies Limited is responsible for the personal-information practices described in this Policy, except where another entity provides you with its own privacy notice and acts independently under applicable law.

Juno Technologies Limited（聚諾科技有限公司）
Company No.: 78834150
Registered address: RM 1508, 15/F., Office Tower Two, Grand Plaza, 625 Nathan Road, Mong Kok, Hong Kong
Privacy contact: support@junopay.co

The early-access form on our website is optional and separate from opening a Juno Pay account. By joining, you agree that we may email you a private test invitation and a public-launch notification. Joining does not guarantee an invitation or require a deposit. We use Netlify, our website hosting and form service, to process the form, and submissions are available to authorised Juno personnel. Email addresses submitted through our earlier public-launch-only form remain subject to their original purpose: one public-launch notification, not private test invitations or unrelated marketing.

2. Information we collect

Depending on the Service you use and applicable law, we may collect:

• account, contact, and authentication information;
• the email address, optional Telegram username, selected category, submission time, and campaign-link details (such as UTM source, medium, campaign, and content) associated with your visit that you provide through our early-access form, together with technical request data needed to operate and protect it; we only receive campaign-link details when they are included in the link you used. Earlier public-launch-only submissions contain the information collected under that original form;
• identity-verification and eligibility information, such as the details and images of an identity document, a photograph or liveness information where used, verification results, and information needed to check source of funds, sanctions, or fraud risk;
• transaction, recipient, payment, fee, and refund information;
• wallet-address and public-blockchain transaction information;
• device, usage, technical, diagnostic, and security information;
• communications, support requests, complaints, and records needed to resolve them; and
• cookie, preference, and marketing information where applicable.

Some information is necessary to verify eligibility or process a payment. If required information is not provided or cannot be verified, we may be unable to enable the relevant transaction feature. Where law requires a separate notice or consent for biometric information or another sensitive category, it will be provided before the relevant collection or use.

3. Sources of information

We may obtain personal information:

• directly from you;
• automatically when you use the Service;
• from service providers, financial institutions, payment participants, and other parties involved in providing or securing the Service; and
• from public blockchains, public records, sanctions lists, fraud-prevention sources, authorities, or other legally permitted sources.

4. How and why we use information

We use personal information as reasonably necessary to:

• create, operate, and secure accounts and the Service;
• manage new early-access registrations, use the selected category to prioritise possible private test invitations (including people who already have USDC and need to pay in Indonesia), understand which tagged campaign links led to registrations, and send private test invitations and public-launch notifications; if you provide an optional Telegram username, we may also use it to contact you about invitations and coordinate testing, with invitations sent first by email; we do not use these registrations for unrelated marketing. Earlier public-launch-only registrations are used only for the originally requested public-launch notification;
• verify identity, age, eligibility, source of funds, and other information needed for know-your-customer, anti-money-laundering, sanctions, and fraud checks;
• process transactions and provide transaction information;
• comply with legal, regulatory, anti-money-laundering, sanctions, tax, and recordkeeping obligations;
• prevent fraud, misuse, and security incidents;
• provide support and resolve errors, complaints, and disputes;
• maintain and improve the Service; and
• send service communications and, where permitted, marketing communications.

Depending on applicable law, our legal bases may include performing a contract, taking requested pre-contract steps, complying with a legal obligation, protecting legitimate interests, or obtaining consent. Where consent is required, we will request it separately. You may withdraw consent for future processing where the law allows, without affecting prior lawful processing or processing required on another lawful basis.

Automated tools may assist with identity verification, sanctions screening, fraud detection, security, and eligibility. Where applicable law gives you a right to contest a qualifying automated decision or request human review, you may contact us using the details in Section 11.

5. How we disclose information

We may disclose personal information, only as reasonably necessary for the purposes described in this Policy, to:

• service providers that support the operation, hosting, security, communications, or support of the Service;
• financial institutions, payment participants, wallet or blockchain infrastructure providers, and transaction counterparties;
• identity-verification, compliance, sanctions-screening, and fraud-prevention providers;
• professional advisers, auditors, insurers, and consultants;
• regulators, courts, law-enforcement authorities, tax authorities, and other competent bodies where required or permitted by law;
• parties involved in a proposed or completed financing, merger, acquisition, restructuring, or sale; and
• another party at your direction or with your consent.

We generally identify recipients by category rather than name. We may identify a recipient where required by law, necessary for informed use, or because it acts independently or contracts directly with you. Some recipients process information for Juno; others may have their own legal obligations and privacy notices.

6. Public blockchain information

Wallet addresses and transaction information recorded on a public blockchain may remain publicly available indefinitely and may be copied or analysed by others. Juno cannot alter or delete a public blockchain record. Personal information held outside the blockchain remains subject to this Policy and applicable law.

7. International processing

Personal information may be processed in countries other than the country where you live. Where required by law, Juno uses measures designed to protect personal information when it is transferred internationally.

8. Retention and security

We keep different categories of personal information for different periods. Account and support information is kept while needed to provide the Service and resolve requests. Identity-verification, transaction, recipient, compliance, and related records may need to be kept after a payment or account closure to meet legal recordkeeping duties, investigate fraud, resolve disputes, or establish and defend legal claims. Security logs and technical data are kept for as long as reasonably needed for security, troubleshooting, and applicable legal duties.

Records that Juno is required to retain under applicable U.S. Bank Secrecy Act rules for money services businesses are kept for at least five years from the date specified by the relevant rule. This may include required transaction, verification, reporting, and supporting records. The five-year rule does not automatically apply to every item of personal information; another applicable law or a legal hold may require a longer period.

For new early-access registrations, we keep the email address, optional Telegram username, selected category, submission time, and any campaign-link details while needed to manage invitations, understand which tagged links led to registrations, and send the public-launch notification, then remove or de-identify them when those purposes are complete or the list closes, unless another lawful retention duty applies. Earlier public-launch-only email addresses remain restricted to their original purpose and are kept until that notice is sent or the original list closes. You may withdraw from either list or request access to or deletion of your registration using the contact in Section 9. We do not use either list for unrelated marketing.

We do not apply one fixed retention period to every category. The applicable period depends on the information, the purpose, and the laws that apply to Juno's activity and the relevant transaction. When retention is no longer justified, we delete or de-identify information where reasonably practicable and legally permitted. Closing an account or withdrawing consent does not automatically erase records that we must or may continue to retain on another lawful basis. Public blockchain records may remain available indefinitely and cannot be deleted by Juno.

Juno maintains administrative, technical, and organisational safeguards designed to protect personal information. No method of transmission, storage, or digital-asset service is completely secure.

9. Your privacy rights

Depending on where you live and applicable law, you may have rights to access and correct personal information, request its deletion or a copy, restrict or object to certain processing, withdraw consent, opt out of certain processing, contest a qualifying automated decision, appeal a decision, or complain to a privacy authority.

To submit a request, email support@junopay.co with the subject Privacy Request and describe the information or action requested. We may verify your identity and authority before disclosing or changing information. We will respond within the period required by applicable law and explain any part of a request we cannot fulfil where we are permitted to do so.

These rights are not absolute. For example, we may need to retain identity-verification or transaction records for applicable anti-money-laundering, sanctions, fraud-prevention, tax, legal, security, or dispute purposes, and Juno cannot alter or delete a public blockchain record. A request to close an account or delete information does not by itself cancel a payment or remove those continuing obligations.

10. Children, cookies, and communications

The Service is intended for adults and is not directed to children. We do not knowingly collect personal information from children in violation of applicable law. If you believe a child has provided personal information, contact us.

We may use cookies or similar technology necessary to operate and secure the Service. Where law requires consent or a choice for optional analytics or marketing technology, we will provide it. You may opt out of marketing communications, but necessary account, transaction, security, compliance, and policy communications will continue while relevant.

11. Changes and contact

We may update this Policy prospectively when our Service, data practices, or legal obligations change. We will provide notice of a material change and obtain consent where required by law.

For privacy questions, requests, or complaints:

Juno Technologies Limited（聚諾科技有限公司）
Subject: Privacy Request
Email: support@junopay.co
Registered address: RM 1508, 15/F., Office Tower Two, Grand Plaza, 625 Nathan Road, Mong Kok, Hong Kong
Website: https://junopay.co