Privacy Policy

Introduction

Welcome to the Privacy Policy for Skillet Group, Inc. doing business as Kettle Pay and Kettle (“Kettle,” “Kettle Pay,” “Company,” “we,” or “us”). This Privacy Policy describes how we collect, use, and disclose information from individuals and entities that interact with our payments infrastructure, including merchants who integrate Kettle Pay and their customers who transact through it (collectively, the “Services”).

For purposes of this Privacy Policy, “you” and “your” means the party using the Services, whether you are a merchant integrating the Services into your platform or an end user making a transaction via a supported wallet. If you are using the Services on behalf of a company or entity, “you” includes both you and that entity, and you represent and warrant that you are authorized to bind the entity to this Privacy Policy.

The Services can only be accessed and used subject to the Company Terms of Service and this Privacy Policy. By accessing or using the Services, you agree to both. If you do not agree, you may not access or use the Services.

1. Types of Information We Collect

We may collect the following categories of information (“Information”):

• Wallet information. Public wallet addresses and related metadata necessary to facilitate transactions (e.g., ETH, BTC, USDC, USDT, and other supported assets).
• Transaction data. Details about payments processed through Kettle Pay, including transaction amounts, digital assets used, timestamps, and merchant identifiers.
• Identity verification information. Where required for compliance (e.g., AML/KYC), we may collect names, identification documents, and related verification data from merchants and, where applicable, their customers.
• Communications. Information you provide when you contact us by email, phone, or other channels.
• Technical/usage data. IP addresses, browser/device identifiers, log data, and interactions with our APIs and dashboard tools.

We may use the above Information to comply with regulatory requirements, provide payment services, enforce the Terms of Service, protect our users, and improve the security and performance of the Services.

2. How We Collect Information

• From you directly. For example, when merchants onboard, submit KYC/KYB documentation, or communicate with us.
• From transactions. We automatically capture wallet addresses, transaction hashes, and settlement data as part of providing the Services.
• From compliance partners. We use third-party providers such as Persona, SumSub, and others to perform identity checks and transaction monitoring.
• From technology integrations. Cookies, APIs, and analytic tools may collect limited technical data to improve performance, detect fraud, and ensure regulatory compliance.

3. Cookies and Tracking Technologies

We may use cookies or similar tools in our merchant dashboards, API environments, or support portals. Most browsers allow you to block or delete cookies, though doing so may limit certain Service functionality. We do not respond to Do Not Track (DNT) signals.

4. Use of Your Information

We may use Information for the following purposes:

• To enable and process crypto-to-fiat or crypto-to-stablecoin transactions.
• To provide settlement, reconciliation, and related reporting to merchants.
• To comply with legal and regulatory obligations (e.g., anti-money laundering and sanctions screening).
• To detect and prevent fraud or other illegal activity.
• To improve our infrastructure, monitor usage trends, and enhance security.
• To communicate with you about your account, transactions, or product updates.

5. Sharing of Information

We will not sell or rent your Information. We may share it only in the following limited circumstances:

• With compliance partners (e.g., MoonPay, SumSub, Bridge) for AML/KYC and transaction monitoring.
• With service providers that support settlement, custody, or reconciliation.
• For legal purposes: when required to comply with applicable law, regulation, subpoena, or lawful request.
• Business transfers: in the event of merger, acquisition, or other corporate transaction.

All third parties are required to process your data consistent with this Privacy Policy and applicable law.

6. Your Choices

Merchants and end users may contact us at hello@kettle.fi to exercise data rights (such as access, correction, or deletion), subject to legal and regulatory requirements that may require us to retain certain records. Please note that restricting certain data may impact our ability to provide Services.

7. Third-Party Wallets

All payments made through Kettle Pay involve third-party wallets (e.g., MetaMask or hardware wallets). Your interactions with those wallets are governed by their own privacy policies. We disclaim liability for actions of third-party wallets.

8. Children’s Privacy

Kettle Pay does not knowingly collect personal data from children under 13. If we become aware of such data, we will delete it.

9. Data Security and Retention

We implement reasonable administrative, technical, and physical safeguards to protect Information. We retain Information as long as necessary to provide Services, comply with legal obligations, resolve disputes, and enforce agreements.

10. Updates to This Policy

We may update this Privacy Policy from time to time. Updates will be effective when posted, unless otherwise required by law. Material changes may be communicated through reasonable means, including email or dashboard notices.

11. California Privacy Rights

If you are a California resident, you may request details about how we share Information for marketing purposes. You may also request removal of certain content you have provided. Contact us at hello@kettle.fi for more details.

12. Contact Us