Privacy policy
Last updated: July 1, 2026
THIS PRIVACY POLICY ("Policy") describes how Manerio Inc. andPay Lions GmbH (together, "we", "us", or "our"),operating through www.maner.io, collect, use, store, disclose, and otherwiseprocess personal data in connection with our website and services. Please readthis Policy carefully before using the Exchange or providing us with anypersonal data.
By accessing our website or using our services, you confirm that you haveread and understood this Policy. If you do not agree with the terms of thisPolicy, please refrain from using our website and services.
NOTICE — REVERSE SOLICITATION: Ourservices are provided on a reverse solicitation basis. If you haveindependently found us and are reaching out on your own initiative, we may beable to serve you regardless of your jurisdiction.
ARTICLE 1. IDENTITY OF THE DATA CONTROLLERS
1.1 The entities responsible forthe processing of your personal data in connection with the Website andServices are:
(a) Manerio Inc., a corporationincorporated under the laws of the Republic of Panama, Mercantile Folio No.155763217, with registered office at Advanced Tower, 1st Floor, Office C-D,Ricardo Arias Street, Panama City, Republic of Panama. Resident Agent: Mata& Pitti, Advanced Tower, 1st Floor, Ricardo Arias Street, Panama City,Republic of Panama. Contact: info@maner.io; and
(b) Pay Lions GmbH, a limited liabilitycompany incorporated under the laws of Switzerland, company registration numberCHE-162.544.982, with registered office at Gubelstrasse 11, 6300 Zug,Switzerland. Pay Lions GmbH is an accepted member of VQF — Verein zurQualitätssicherung von Finanzdienstleistungen, a FINMA-recognisedSelf-Regulatory Organisation ("SRO"), and operates in compliance withthe Swiss Federal Act on Combating Money Laundering and Terrorist Financing(GwG).
1.2 All activities conductedthrough maner.io are operated by Manerio Inc. in partnership with Pay LionsGmbH. References to "we", "us", or "our" in thisPolicy refer to both entities jointly. Each entity acts as an independent datacontroller in respect of the processing it conducts, and as joint controllerswhere processing is carried out jointly.
ARTICLE 2. DEFINITIONS
2.1 In this Policy, unless thecontext otherwise requires, the following terms shall have the meanings set outbelow:
"AML/CFT" means anti-money laundering andcounter-financing of terrorism.
"ApplicableLaw" means all statutes,regulations, rules, orders, and binding regulatory requirements of anyGovernment Agency applicable to the processing of personal data or to ourServices, including AML/CFT legislation.
"Exchange" means the virtual asset exchangeplatform operated by Manerio Inc. at www.maner.io.
"GwG" means the Swiss Federal Act on CombatingMoney Laundering and Terrorist Financing (Geldwäschereigesetz), as amended fromtime to time.
"KYC" means know-your-customer procedurescarried out for the purposes of verifying identity and complying with AML/CFTobligations.
"PersonalData" means any informationrelating to an identified or identifiable natural person, including name,identification number, location data, online identifier, or factors specific tothat person's physical, physiological, economic, cultural, or social identity.
"Processing" means any operation performed onPersonal Data, whether by automated means or otherwise, including collection,recording, storage, adaptation, disclosure, use, or erasure.
"Services" means the Exchange and all related features,tools, and applications made available through the Website.
"UAF" means the Financial Analysis Unit (Unidadde Análisis Financiero) of the Republic of Panama, the competent AML/CFTsupervisory authority for Manerio Inc.
"Website" means www.maner.io and all related subdomains.
"You/ Your" means theindividual or legal entity accessing our Website or using our Services.
2.2 In this Policy, unless thecontext otherwise requires: (a) references to the singular include the pluraland vice versa; (b) headings are for convenience only; and (c) in the event ofany inconsistency between the English version of this Policy and anytranslation, the English version shall prevail.
ARTICLE 3. CATEGORIES OF PERSONAL DATA COLLECTED
3.1 Data Provided Directly by You
We collect the following categories of Personal Data that you provide tous directly in the course of using our Services or contacting us:
(a) full name and surname;
(b) date of birth;
(c) email address and telephone number;
(d) country of residence and nationality;
(e) government-issued identity documents,including passport or national identity card — collected for the purposes ofKYC and AML/CFT compliance;
(f) proof of address documentation;
(g) source of funds and source of wealthinformation — required under AML/CFT obligations;
(h) company details, including registration numberand beneficial ownership information, where you act on behalf of a legalentity;
(i) bank account details, wallet addresses, orother payment information necessary for the provision of Services; and
(j) any other information you provide whencommunicating with us or submitting a request.
3.2 Data Collected Automatically
We collect the following categories of Personal Data automatically whenyou access or use our Website:
(a) Internet Protocol (IP) address andapproximate geolocation;
(b) browser type, version, and language settings;
(c) device type and operating system;
(d) pages visited, time and date of access, andtime spent on pages;
(e) referral source and navigation paths withinthe Website; and
(f) data collected through cookies and similartracking technologies (see Article 8 below).
3.3 Data Obtained from Third Parties
We may receive Personal Data from third parties in the followingcircumstances:
(a) identity verification and KYC/AML data fromauthorised third-party service providers engaged for the purpose of verifyingyour identity;
(b) sanctions screening data obtained fromregulatory databases maintained by the United Nations, OFAC, the EuropeanUnion, and other relevant authorities;
(c) transaction monitoring data generated inconnection with your use of the Exchange; and
(d) data received from business partners where youhave consented to such disclosure or where we are otherwise lawfully entitledto receive it.
ARTICLE 4. LEGAL BASES FOR PROCESSING
4.1 We process your Personal Dataon the following legal bases:
(a) Performance of a contract: processing that is necessary to provide youwith our Services, to execute transactions on your behalf, or to take steps atyour request prior to entering into an agreement with you;
(b) Compliance with a legal obligation: processing that is required to fulfil ourobligations under Applicable Law, including AML/CFT requirements, KYC obligations, tax reporting duties, and requests from competent regulatoryauthorities — including obligations under Panamanian AML legislation applicableto Manerio Inc. (UAF requirements) and under the Swiss GwG applicable to PayLions GmbH;
(c) Legitimate interests: processing that is necessary for the purposesof our legitimate interests, including fraud prevention, security monitoring,improvement of our Services, and record-keeping for dispute resolution, wheresuch interests are not overridden by your rights and freedoms; and
(d) Consent: where we rely on your consent as the legal basis for processing (forexample, in connection with marketing communications), you have the right towithdraw your consent at any time by contacting us at info@maner.io. Withdrawalof consent shall not affect the lawfulness of any processing carried out priorto such withdrawal.
ARTICLE 5. PURPOSES OF PROCESSING
5.1 We use your Personal Data forthe following purposes:
(a) to verify your identity and conduct KYC/AMLscreening prior to and during the provision of Services;
(b) to provide, operate, and maintain the Exchangeand related Services;
(c) to process transactions and manage yourAccount;
(d) to comply with our legal and regulatoryobligations, including AML/CFT reporting requirements and obligations under theGwG and Panamanian AML legislation;
(e) to screen your identity against applicablesanctions lists and to monitor transactions for suspicious activity;
(f) to communicate with you in connection withyour Account, transactions, or material changes to our Services;
(g) to respond to your enquiries and support requests;
(h) to detect, prevent, investigate, and prosecute fraud, security breaches, and other unlawful activity;
(i) to enforce our Terms of Use and any otheragreements between you and us;
(j) to analyse and improve the performance of our Website and Services; and
(k) to send marketing communications where youhave provided your prior consent.
ARTICLE 6. SHARING OF PERSONAL DATA
6.1 Disclosurebetween Manerio Inc. and Pay Lions GmbH
As operational partners providing Services through maner.io, Manerio Inc.and Pay Lions GmbH may share your Personal Data with each other to the extentnecessary to deliver Services, comply with their respective legal obligations,and fulfil AML/CFT and KYC requirements. Both entities are bound by obligationsof confidentiality and data protection in respect of any such shared data.
6.2 Third-PartyService Providers
We engage third-party processors who act upon our instructions and on ourbehalf. Such processors include:
(a) identity verification and KYC/AML service providers;
(b) cloud hosting and IT infrastructure providers;
(c) payment processing and banking partners;
(d) compliance and audit service providers; and
(e) legal, accounting, and professional advisors.
All third-party processors are contractually required to process yourPersonal Data only in accordance with our instructions and to implementappropriate technical and organisational security measures.
6.3 Regulatoryand Law Enforcement Authorities
We are required by Applicable Law to disclose Personal Data to competentauthorities, including the UAF (Panama), VQF, FINMA, and other regulatory orlaw enforcement bodies, in connection with AML/CFT reporting obligations,suspicious transaction reports, and regulatory examinations. Such disclosuresare made pursuant to legal obligation and may not require your prior consent.
6.4 BusinessTransfers
In the event of a merger, acquisition, restructuring, or sale of all orpart of our assets, your Personal Data may be transferred to the relevantsuccessor entity. We will notify you before any such transfer takes effect andbefore your Personal Data becomes subject to a materially different privacypolicy.
6.5 Disclosurewith Your Consent
We may disclose your Personal Data to third partiesfor any other purpose with your prior explicit consent, which you may withdrawat any time.
ARTICLE 7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
7.1 Your Personal Data may betransferred to and processed in countries other than your country of residence,including the Republic of Panama and Switzerland, and potentially otherjurisdictions in which our service providers operate. These jurisdictions mayhave data protection standards that differ from those applicable in your homejurisdiction.7.2 We take appropriate steps toensure that any international transfer of your Personal Data is subject toadequate safeguards, including the use of contractual protections with ourservice providers. By using our Services, you acknowledge and agree to thetransfer of your Personal Data as described in this Article 7.
ARTICLE 8. COOKIES AND TRACKING TECHNOLOGIES
8.1 General
We use cookies and similar tracking technologies onthe Website. Cookies are small data files placed on your device that help usoperate and improve our Website and Services.
8.2 Types of Cookies
We use the following categories of cookies:
(a) Strictly necessary cookies: essential for the operation of the Websiteand cannot be disabled. These cookies do not require your consent;
(b) Functional cookies: used to remember your preferences andsettings, enhancing your experience on the Website;
(c) Analytical and performance cookies: used to understand how visitors interact withour Website, including through tools such as Google Analytics; and
(d) Marketing cookies: used to deliver relevantcontent and measure the effectiveness of our communications. These cookies areonly placed with your prior consent.
8.3 Managing Cookies
You may control and manage cookies through your browser settings. Pleasenote that disabling certain cookies may affect the functionality of our Website. For further information on cookies and how to manage them, please visit www.allaboutcookies.org.
ARTICLE 9. RETENTION OF PERSONAL DATA
9.1 We retain your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:
(a) for the duration of your relationship with usand for a minimum period of five (5) years following the termination of thatrelationship — in accordance with AML/CFT retention obligations applicable toManerio Inc. under Panamanian law (UAF requirements) and to Pay Lions GmbHunder Swiss law (GwG, Article 7);
(b) for such longer period as may be required toresolve any outstanding dispute, enforce any agreement, or comply with anyregulatory investigation or legal proceeding; and
(c) in the case of usage data and analytics data,generally for a shorter period, unless such data is required for security purposes or by legal obligation. 9.2 Upon expiry of the applicable retention period, we will securely delete, destroy, oranonymise your Personal Data in accordance with our internal data management procedures.
ARTICLE 10. YOUR RIGHTS
10.1 Subject to Applicable Law and the limitations set out in clause
10.2, you have the following rights inconnection with your Personal Data:
(a) Right of access: to obtain confirmation of whether we processyour Personal Data and, if so, to receive a copy of such data together withinformation about how it is processed;
(b) Right to rectification: to request the correction of any inaccurateor incomplete Personal Data we hold about you;
(c) Right to erasure: to request the deletion of your Personal Datain certain circumstances, including where it is no longer necessary for thepurposes for which it was collected;
(d) Right to restriction of processing: to request that we restrict the processing ofyour Personal Data in certain circumstances, for example while the accuracy ofthat data is contested;
(e) Right to data portability: to receive your Personal Data in astructured, commonly used, and machine-readable format, and to transmit thatdata to another controller;
(f) Right to object: to object to processing based on legitimateinterests or carried out for the purposes of direct marketing; and
(g) Right to withdraw consent: where processing is based on your consent, towithdraw that consent at any time without affecting the lawfulness ofprocessing carried out prior to withdrawal.
10.2 Please note that certainrights may be limited, restricted, or overridden by our legal obligations underApplicable Law, including AML/CFT requirements, which may require us to retainyour Personal Data regardless of any request for deletion or restriction. Wewill inform you in writing if we are unable to fulfil a request and providereasons to the extent permitted by law.
10.3 To exercise any of yourrights under this Article 10, please submit a written request to info@maner.io. We will respond within thirty (30) calendar days of receipt of your request. Wemay require you to verify your identity before processing any such request.
ARTICLE 11. CHILDREN
Our Services are not directed at persons under the age of eighteen (18)years. We do not knowingly collect Personal Data from minors. If you believethat we have inadvertently collected Personal Data from a person under the ageof eighteen, please contact us immediately at info@maner.io, and we will takesteps to delete such data without undue delay.
ARTICLE 12. SECURITY
12.1 We implement appropriatetechnical and organisational measures to protect your Personal Data againstunauthorised or unlawful processing, accidental loss, destruction, damage, ordisclosure. Such measures include encryption in transit and at rest, accesscontrols and authentication procedures, and periodic security assessments.
12.2 Notwithstanding theforegoing, no method of transmission over the internet or method of electronicstorage is entirely secure. We cannot guarantee the absolute security of your Personal Data and shall not be liable for any unauthorised access that occursdespite our reasonable security measures.
ARTICLE 13. REVERSE SOLICITATION AND JURISDICTIONALNOTICE
13.1 Services provided through maner.io are made available on a reverse solicitation basis. Manerio Inc. and Pay Lions GmbH do not actively market, advertise, or solicit clients in anyjurisdiction. Nothing on this Website constitutes, or shall be construed as, anoffer, invitation, advertisement, or solicitation directed at any person in anyjurisdiction.
13.2 If you have independentlyidentified maner.io and are contacting us on your own unsolicited initiative,we may be able to provide Services to you and to process your Personal Data inconnection therewith. The fact that you have independently approached usconstitutes the basis upon which engagement may proceed.
13.3 Notwithstanding clauses 13.1 and 13.2, Services are not available, and we will not process Personal Data for the purposes of providing Services, to or in respect of:
(a) residents or citizens of the United States ofAmerica; or
(b) persons or entities located in, incorporatedin, or subject to the laws of any territory subject to comprehensive OFAC sanctions, including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk,and Luhansk regions.
13.4 Theserestrictions apply unconditionally and regardless of the manner in which therelevant person accessed the Website.
ARTICLE 14. THIRD-PARTY WEBSITES
Our Website may contain links to third-party websites and services thatare not operated or controlled by us. We are not responsible for the privacypractices or content of such third-party sites. We strongly recommend that youreview the privacy policy of every website you visit.
ARTICLE 15. AMENDMENTS TO THIS POLICY
15.1 We may update this Policyfrom time to time to reflect changes in our data processing practices,Applicable Law, or regulatory requirements. We will publish the updated Policyon the Website and update the effective date accordingly.
15.2 Where any amendment ismaterial, we will endeavour to notify you by email to the address registeredwith your Account, or by prominent notice on the Website, prior to the changebecoming effective. Your continued use of our Website or Services followingnotification of any material change shall constitute your acceptance of theupdated Policy.
ARTICLE 16. GOVERNING LAW
This Policy is governed by the laws of the Republic of Panama, withoutprejudice to any mandatory data protection requirements applicable in yourjurisdiction or under Swiss law in respect of the processing conducted by PayLions GmbH.
ARTICLE 17. CONTACT AND COMPLAINTS
17.1 For any questions, concerns,or requests regarding this Policy or our data processing practices, please contact us at:
Manerio Inc.
Advanced Tower, 1st Floor, Office C-DRicardo Arias Street, Panama City, Republic of Panama
Email: info@maner.io
Pay Lions GmbH
Gubelstrasse 11, 6300 Zug, Switzerland
17.2 If you believe that we have not handled your Personal Data in accordance with Applicable Law, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. In Panama, the competent authority is the UAF. In Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC).
THIS PRIVACY POLICY ("Policy") describes how Manerio Inc. andPay Lions GmbH (together, "we", "us", or "our"),operating through www.maner.io, collect, use, store, disclose, and otherwiseprocess personal data in connection with our website and services. Please readthis Policy carefully before using the Exchange or providing us with anypersonal data.
By accessing our website or using our services, you confirm that you haveread and understood this Policy. If you do not agree with the terms of thisPolicy, please refrain from using our website and services.
NOTICE — REVERSE SOLICITATION: Ourservices are provided on a reverse solicitation basis. If you haveindependently found us and are reaching out on your own initiative, we may beable to serve you regardless of your jurisdiction.
ARTICLE 1. IDENTITY OF THE DATA CONTROLLERS
1.1 The entities responsible forthe processing of your personal data in connection with the Website andServices are:
(a) Manerio Inc., a corporationincorporated under the laws of the Republic of Panama, Mercantile Folio No.155763217, with registered office at Advanced Tower, 1st Floor, Office C-D,Ricardo Arias Street, Panama City, Republic of Panama. Resident Agent: Mata& Pitti, Advanced Tower, 1st Floor, Ricardo Arias Street, Panama City,Republic of Panama. Contact: info@maner.io; and
(b) Pay Lions GmbH, a limited liabilitycompany incorporated under the laws of Switzerland, company registration numberCHE-162.544.982, with registered office at Gubelstrasse 11, 6300 Zug,Switzerland. Pay Lions GmbH is an accepted member of VQF — Verein zurQualitätssicherung von Finanzdienstleistungen, a FINMA-recognisedSelf-Regulatory Organisation ("SRO"), and operates in compliance withthe Swiss Federal Act on Combating Money Laundering and Terrorist Financing(GwG).
1.2 All activities conductedthrough maner.io are operated by Manerio Inc. in partnership with Pay LionsGmbH. References to "we", "us", or "our" in thisPolicy refer to both entities jointly. Each entity acts as an independent datacontroller in respect of the processing it conducts, and as joint controllerswhere processing is carried out jointly.
ARTICLE 2. DEFINITIONS
2.1 In this Policy, unless thecontext otherwise requires, the following terms shall have the meanings set outbelow:
"AML/CFT" means anti-money laundering andcounter-financing of terrorism.
"ApplicableLaw" means all statutes,regulations, rules, orders, and binding regulatory requirements of anyGovernment Agency applicable to the processing of personal data or to ourServices, including AML/CFT legislation.
"Exchange" means the virtual asset exchangeplatform operated by Manerio Inc. at www.maner.io.
"GwG" means the Swiss Federal Act on CombatingMoney Laundering and Terrorist Financing (Geldwäschereigesetz), as amended fromtime to time.
"KYC" means know-your-customer procedurescarried out for the purposes of verifying identity and complying with AML/CFTobligations.
"PersonalData" means any informationrelating to an identified or identifiable natural person, including name,identification number, location data, online identifier, or factors specific tothat person's physical, physiological, economic, cultural, or social identity.
"Processing" means any operation performed onPersonal Data, whether by automated means or otherwise, including collection,recording, storage, adaptation, disclosure, use, or erasure.
"Services" means the Exchange and all related features,tools, and applications made available through the Website.
"UAF" means the Financial Analysis Unit (Unidadde Análisis Financiero) of the Republic of Panama, the competent AML/CFTsupervisory authority for Manerio Inc.
"Website" means www.maner.io and all related subdomains.
"You/ Your" means theindividual or legal entity accessing our Website or using our Services.
2.2 In this Policy, unless thecontext otherwise requires: (a) references to the singular include the pluraland vice versa; (b) headings are for convenience only; and (c) in the event ofany inconsistency between the English version of this Policy and anytranslation, the English version shall prevail.
ARTICLE 3. CATEGORIES OF PERSONAL DATA COLLECTED
3.1 Data Provided Directly by You
We collect the following categories of Personal Data that you provide tous directly in the course of using our Services or contacting us:
(a) full name and surname;
(b) date of birth;
(c) email address and telephone number;
(d) country of residence and nationality;
(e) government-issued identity documents,including passport or national identity card — collected for the purposes ofKYC and AML/CFT compliance;
(f) proof of address documentation;
(g) source of funds and source of wealthinformation — required under AML/CFT obligations;
(h) company details, including registration numberand beneficial ownership information, where you act on behalf of a legalentity;
(i) bank account details, wallet addresses, orother payment information necessary for the provision of Services; and
(j) any other information you provide whencommunicating with us or submitting a request.
3.2 Data Collected Automatically
We collect the following categories of Personal Data automatically whenyou access or use our Website:
(a) Internet Protocol (IP) address andapproximate geolocation;
(b) browser type, version, and language settings;
(c) device type and operating system;
(d) pages visited, time and date of access, andtime spent on pages;
(e) referral source and navigation paths withinthe Website; and
(f) data collected through cookies and similartracking technologies (see Article 8 below).
3.3 Data Obtained from Third Parties
We may receive Personal Data from third parties in the followingcircumstances:
(a) identity verification and KYC/AML data fromauthorised third-party service providers engaged for the purpose of verifyingyour identity;
(b) sanctions screening data obtained fromregulatory databases maintained by the United Nations, OFAC, the EuropeanUnion, and other relevant authorities;
(c) transaction monitoring data generated inconnection with your use of the Exchange; and
(d) data received from business partners where youhave consented to such disclosure or where we are otherwise lawfully entitledto receive it.
ARTICLE 4. LEGAL BASES FOR PROCESSING
4.1 We process your Personal Dataon the following legal bases:
(a) Performance of a contract: processing that is necessary to provide youwith our Services, to execute transactions on your behalf, or to take steps atyour request prior to entering into an agreement with you;
(b) Compliance with a legal obligation: processing that is required to fulfil ourobligations under Applicable Law, including AML/CFT requirements, KYC obligations, tax reporting duties, and requests from competent regulatoryauthorities — including obligations under Panamanian AML legislation applicableto Manerio Inc. (UAF requirements) and under the Swiss GwG applicable to PayLions GmbH;
(c) Legitimate interests: processing that is necessary for the purposesof our legitimate interests, including fraud prevention, security monitoring,improvement of our Services, and record-keeping for dispute resolution, wheresuch interests are not overridden by your rights and freedoms; and
(d) Consent: where we rely on your consent as the legal basis for processing (forexample, in connection with marketing communications), you have the right towithdraw your consent at any time by contacting us at info@maner.io. Withdrawalof consent shall not affect the lawfulness of any processing carried out priorto such withdrawal.
ARTICLE 5. PURPOSES OF PROCESSING
5.1 We use your Personal Data forthe following purposes:
(a) to verify your identity and conduct KYC/AMLscreening prior to and during the provision of Services;
(b) to provide, operate, and maintain the Exchangeand related Services;
(c) to process transactions and manage yourAccount;
(d) to comply with our legal and regulatoryobligations, including AML/CFT reporting requirements and obligations under theGwG and Panamanian AML legislation;
(e) to screen your identity against applicablesanctions lists and to monitor transactions for suspicious activity;
(f) to communicate with you in connection withyour Account, transactions, or material changes to our Services;
(g) to respond to your enquiries and support requests;
(h) to detect, prevent, investigate, and prosecute fraud, security breaches, and other unlawful activity;
(i) to enforce our Terms of Use and any otheragreements between you and us;
(j) to analyse and improve the performance of our Website and Services; and
(k) to send marketing communications where youhave provided your prior consent.
ARTICLE 6. SHARING OF PERSONAL DATA
6.1 Disclosurebetween Manerio Inc. and Pay Lions GmbH
As operational partners providing Services through maner.io, Manerio Inc.and Pay Lions GmbH may share your Personal Data with each other to the extentnecessary to deliver Services, comply with their respective legal obligations,and fulfil AML/CFT and KYC requirements. Both entities are bound by obligationsof confidentiality and data protection in respect of any such shared data.
6.2 Third-PartyService Providers
We engage third-party processors who act upon our instructions and on ourbehalf. Such processors include:
(a) identity verification and KYC/AML service providers;
(b) cloud hosting and IT infrastructure providers;
(c) payment processing and banking partners;
(d) compliance and audit service providers; and
(e) legal, accounting, and professional advisors.
All third-party processors are contractually required to process yourPersonal Data only in accordance with our instructions and to implementappropriate technical and organisational security measures.
6.3 Regulatoryand Law Enforcement Authorities
We are required by Applicable Law to disclose Personal Data to competentauthorities, including the UAF (Panama), VQF, FINMA, and other regulatory orlaw enforcement bodies, in connection with AML/CFT reporting obligations,suspicious transaction reports, and regulatory examinations. Such disclosuresare made pursuant to legal obligation and may not require your prior consent.
6.4 BusinessTransfers
In the event of a merger, acquisition, restructuring, or sale of all orpart of our assets, your Personal Data may be transferred to the relevantsuccessor entity. We will notify you before any such transfer takes effect andbefore your Personal Data becomes subject to a materially different privacypolicy.
6.5 Disclosurewith Your Consent
We may disclose your Personal Data to third partiesfor any other purpose with your prior explicit consent, which you may withdrawat any time.
ARTICLE 7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
7.1 Your Personal Data may betransferred to and processed in countries other than your country of residence,including the Republic of Panama and Switzerland, and potentially otherjurisdictions in which our service providers operate. These jurisdictions mayhave data protection standards that differ from those applicable in your homejurisdiction.7.2 We take appropriate steps toensure that any international transfer of your Personal Data is subject toadequate safeguards, including the use of contractual protections with ourservice providers. By using our Services, you acknowledge and agree to thetransfer of your Personal Data as described in this Article 7.
ARTICLE 8. COOKIES AND TRACKING TECHNOLOGIES
8.1 General
We use cookies and similar tracking technologies onthe Website. Cookies are small data files placed on your device that help usoperate and improve our Website and Services.
8.2 Types of Cookies
We use the following categories of cookies:
(a) Strictly necessary cookies: essential for the operation of the Websiteand cannot be disabled. These cookies do not require your consent;
(b) Functional cookies: used to remember your preferences andsettings, enhancing your experience on the Website;
(c) Analytical and performance cookies: used to understand how visitors interact withour Website, including through tools such as Google Analytics; and
(d) Marketing cookies: used to deliver relevantcontent and measure the effectiveness of our communications. These cookies areonly placed with your prior consent.
8.3 Managing Cookies
You may control and manage cookies through your browser settings. Pleasenote that disabling certain cookies may affect the functionality of our Website. For further information on cookies and how to manage them, please visit www.allaboutcookies.org.
ARTICLE 9. RETENTION OF PERSONAL DATA
9.1 We retain your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:
(a) for the duration of your relationship with usand for a minimum period of five (5) years following the termination of thatrelationship — in accordance with AML/CFT retention obligations applicable toManerio Inc. under Panamanian law (UAF requirements) and to Pay Lions GmbHunder Swiss law (GwG, Article 7);
(b) for such longer period as may be required toresolve any outstanding dispute, enforce any agreement, or comply with anyregulatory investigation or legal proceeding; and
(c) in the case of usage data and analytics data,generally for a shorter period, unless such data is required for security purposes or by legal obligation. 9.2 Upon expiry of the applicable retention period, we will securely delete, destroy, oranonymise your Personal Data in accordance with our internal data management procedures.
ARTICLE 10. YOUR RIGHTS
10.1 Subject to Applicable Law and the limitations set out in clause
10.2, you have the following rights inconnection with your Personal Data:
(a) Right of access: to obtain confirmation of whether we processyour Personal Data and, if so, to receive a copy of such data together withinformation about how it is processed;
(b) Right to rectification: to request the correction of any inaccurateor incomplete Personal Data we hold about you;
(c) Right to erasure: to request the deletion of your Personal Datain certain circumstances, including where it is no longer necessary for thepurposes for which it was collected;
(d) Right to restriction of processing: to request that we restrict the processing ofyour Personal Data in certain circumstances, for example while the accuracy ofthat data is contested;
(e) Right to data portability: to receive your Personal Data in astructured, commonly used, and machine-readable format, and to transmit thatdata to another controller;
(f) Right to object: to object to processing based on legitimateinterests or carried out for the purposes of direct marketing; and
(g) Right to withdraw consent: where processing is based on your consent, towithdraw that consent at any time without affecting the lawfulness ofprocessing carried out prior to withdrawal.
10.2 Please note that certainrights may be limited, restricted, or overridden by our legal obligations underApplicable Law, including AML/CFT requirements, which may require us to retainyour Personal Data regardless of any request for deletion or restriction. Wewill inform you in writing if we are unable to fulfil a request and providereasons to the extent permitted by law.
10.3 To exercise any of yourrights under this Article 10, please submit a written request to info@maner.io. We will respond within thirty (30) calendar days of receipt of your request. Wemay require you to verify your identity before processing any such request.
ARTICLE 11. CHILDREN
Our Services are not directed at persons under the age of eighteen (18)years. We do not knowingly collect Personal Data from minors. If you believethat we have inadvertently collected Personal Data from a person under the ageof eighteen, please contact us immediately at info@maner.io, and we will takesteps to delete such data without undue delay.
ARTICLE 12. SECURITY
12.1 We implement appropriatetechnical and organisational measures to protect your Personal Data againstunauthorised or unlawful processing, accidental loss, destruction, damage, ordisclosure. Such measures include encryption in transit and at rest, accesscontrols and authentication procedures, and periodic security assessments.
12.2 Notwithstanding theforegoing, no method of transmission over the internet or method of electronicstorage is entirely secure. We cannot guarantee the absolute security of your Personal Data and shall not be liable for any unauthorised access that occursdespite our reasonable security measures.
ARTICLE 13. REVERSE SOLICITATION AND JURISDICTIONALNOTICE
13.1 Services provided through maner.io are made available on a reverse solicitation basis. Manerio Inc. and Pay Lions GmbH do not actively market, advertise, or solicit clients in anyjurisdiction. Nothing on this Website constitutes, or shall be construed as, anoffer, invitation, advertisement, or solicitation directed at any person in anyjurisdiction.
13.2 If you have independentlyidentified maner.io and are contacting us on your own unsolicited initiative,we may be able to provide Services to you and to process your Personal Data inconnection therewith. The fact that you have independently approached usconstitutes the basis upon which engagement may proceed.
13.3 Notwithstanding clauses 13.1 and 13.2, Services are not available, and we will not process Personal Data for the purposes of providing Services, to or in respect of:
(a) residents or citizens of the United States ofAmerica; or
(b) persons or entities located in, incorporatedin, or subject to the laws of any territory subject to comprehensive OFAC sanctions, including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk,and Luhansk regions.
13.4 Theserestrictions apply unconditionally and regardless of the manner in which therelevant person accessed the Website.
ARTICLE 14. THIRD-PARTY WEBSITES
Our Website may contain links to third-party websites and services thatare not operated or controlled by us. We are not responsible for the privacypractices or content of such third-party sites. We strongly recommend that youreview the privacy policy of every website you visit.
ARTICLE 15. AMENDMENTS TO THIS POLICY
15.1 We may update this Policyfrom time to time to reflect changes in our data processing practices,Applicable Law, or regulatory requirements. We will publish the updated Policyon the Website and update the effective date accordingly.
15.2 Where any amendment ismaterial, we will endeavour to notify you by email to the address registeredwith your Account, or by prominent notice on the Website, prior to the changebecoming effective. Your continued use of our Website or Services followingnotification of any material change shall constitute your acceptance of theupdated Policy.
ARTICLE 16. GOVERNING LAW
This Policy is governed by the laws of the Republic of Panama, withoutprejudice to any mandatory data protection requirements applicable in yourjurisdiction or under Swiss law in respect of the processing conducted by PayLions GmbH.
ARTICLE 17. CONTACT AND COMPLAINTS
17.1 For any questions, concerns,or requests regarding this Policy or our data processing practices, please contact us at:
Manerio Inc.
Advanced Tower, 1st Floor, Office C-DRicardo Arias Street, Panama City, Republic of Panama
Email: info@maner.io
Pay Lions GmbH
Gubelstrasse 11, 6300 Zug, Switzerland
17.2 If you believe that we have not handled your Personal Data in accordance with Applicable Law, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. In Panama, the competent authority is the UAF. In Switzerland, the competent authority is the Federal Data Protection and Information Commissioner (FDPIC).
Manerio Inc.
Incorporated under the laws of the Republic of Panama,
Mercantile Folio No. 155763217
Incorporated under the laws of the Republic of Panama,
Mercantile Folio No. 155763217
Advanced Tower, 1st Floor,
Office C-D, Ricardo Arias Street, Panama City,
Republic of Panama
Office C-D, Ricardo Arias Street, Panama City,
Republic of Panama
Activities conducted through maner.io are operated by Manerio Inc. in partnership with Pay Lions GmbH. Manerio Inc. operates in compliance with the applicable Anti-Money Laundering (AML) framework of the Republic of Panama, including the obligations of supervised non-financial entities under the Financial Analysis Unit (UAF) and applicable AML/CFT legislation. Pay Lions GmbH (CHE-162.544.982) is an accepted member of VQF — Verein zur Qualitätssicherung von Finanzdienstleistungen (member no. 101341), a FINMA-recognised Self-Regulatory Organisation (SRO), and operates in full compliance with the Swiss Federal Act on Combating Money Laundering and Terrorist Financing (GwG / LBA).