Last updated: April 10, 2025
Overflow website and services are provided by Baltic Block Sp.z o.o., a company incorporated in Poland, with its registered address at ul. PIOTRKOWSKA, nr 116, lok. 52, miejsc. ŁÓDŹ, kod 90-006, poczta ŁÓDŹ, kraj POLSKA, and with company registration number 0001076720 (KRS). Baltic Block Sp.z o.o. and its affiliates collect and use certain Personal Data from you.
Contact Information
• Website: overflow.money
• Address: ul. PIOTRKOWSKA, nr 116, lok. 52, miejsc. ŁÓDŹ, kod 90-006, poczta ŁÓDŹ, kraj POLSKA
• Email: compliance@overflow.money
Acceptance of Privacy Policy
By accessing or using our Services, or by creating an account, you agree that you have read, understand, and agree to all of the terms and conditions contained in this Privacy Policy. If you do not agree with or are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of Overflow Services.
Changes to this Privacy Policy
We reserve the right to alter, amend or modify this Privacy Policy from time to time, in our sole discretion. We will provide you with notice of such changes by sending you an email, providing notice on the homepage of the Website and/or by posting the amended Privacy Policy on the Website and updating the "Last Updated" date at the top of the Privacy Policy. The amended Privacy Policy will be deemed effective immediately upon posting on the Website. Your continued use of Overflow Services constitutes your agreement to be bound by any such changes to this Privacy Policy.
Definitions
"Customer" refers to any end-user or business partner who accesses, uses, or interacts with the Services provided through Overflow's infrastructure.
"Overflow Services" means the suite of virtual asset and payment services provided by Overflow, including but not limited to: (i) fiat-to-stablecoin conversion services, (ii) auto-settlement solutions, (iii) bulk payment processing, (iv) API integration services, and (v) custody services for digital assets.
"Services" refers to the combined offerings of: (i) the Overflow Services; and (ii) services provided by Third Party Providers or affiliates.
"Third Party Providers" refers to external entities engaged by Overflow to facilitate specific ancillary services necessary to support and deliver the foregoing, acting under the direction and responsibility of Overflow, such as payment processing, stablecoin liquidity providers, banking partners, and compliance tools.
Overview
This Privacy Policy outlines important information about who we are, as well as how and why we collect, store, use, and share your personal information (referred to as "Personal Data") in connection with your use of our Services. Additionally, it explains your rights regarding your Personal Data and provides details on how to contact us or the relevant regulatory authority should you have any concerns or wish to lodge a complaint.
We are the Controller of your Personal Data which we obtain via your use of our Services. When you use our Services, you may encounter services, links, or other platforms provided by our trusted Third-Party Providers. These links are included to assist with tasks such as identity verification or to offer ancillary products and services. Please note that these third-party websites may collect information about you in accordance with their own independent privacy policies. We encourage you to review the privacy policies of those third-party websites to understand how your information is handled.
Personal Data We Collect
Overflow processes your Personal Data because you use our Services. Below is an overview of the personal data we process:
• First and last name
• Job role
• Company information
• Country
• Payment details (for example your bank account number, wallet address, etc.)
• National ID
• Proof of Address
• Gender
• Date of birth
• Phone number
• Email address
• Biometric data including KYC liveness
• Data from cookie tracking
We may also collect and process the following information from you:
• Third-party data, used for identity verification details and records
• Combined data, used from third parties and merged with data collected through our Services, governed by this Privacy Policy unless stated otherwise
• Transaction data, including payment amounts, recipients, and transaction history
• Technical data related to API usage and system interactions
Purpose for Processing Personal Data
Overflow processes your personal data for the following purposes:
• Handling transactions or transaction instructions
• Enabling virtual IBAN issuance and management
• Processing auto-settlements between fiat and stablecoin formats
• Executing bulk transfers and disbursements
• Managing custody of digital assets
• Sending newsletters and/or promotional materials
• Contacting you via phone or email as needed for service delivery
• Informing you about changes to our services and products
• Allowing you to create an account
• Meeting legal obligations
• To perform our obligations towards you
• To enable and provide our Services to you
• To verify Customer identities and grant secure access to our Services
• To offer assistance and support when needed
• To enhance, personalize, and refine the Services and user experience, tailored to individual or shared preferences, feedback, and challenges
• To uphold our Terms of Service and other agreements established with Customers
• To adhere to applicable legal and regulatory obligations, including MiCA compliance and other EU regulatory frameworks
Overflow processes your personal data based on the following legal grounds in accordance with GDPR:
• To fulfill our contract with you, including enabling account creation, processing transactions and delivering services
• To comply with applicable legal and regulatory requirements, such as anti-money laundering and counter-terrorist financing obligations
• Where you have provided explicit consent, such as receiving marketing communications. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before withdrawal
• To enhance and improve our Services, ensure platform security, prevent fraud and develop new features. It is ensured that such processing does not override your privacy rights
Data Retention
The duration for which Overflow will retain your Personal Data depends on the following cumulative factors:
• We will retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected
• Personal Data will be kept as required to address potential or ongoing legal claims, complaints, litigation, or regulatory proceedings
• Applicable laws or regulations may specify a minimum retention period for your Personal Data
We may need to maintain records for a significant period of time after you cease being our client for legal or regulatory reasons, for example, when we need to retain information to help manage a dispute or legal claim. Additionally, we are subject to certain anti-money laundering laws which may require us to retain your personal data for a period of time after our business relationship with you has ended.
Sharing Personal Data with Third Parties
Overflow does not sell your personal data to third parties. Data is only shared when necessary to execute our agreement with you or to comply with legal obligations. For companies processing your data on our behalf, we sign processing agreements to ensure the same level of data security and confidentiality. Overflow remains responsible for these processes. Additionally, Overflow shares data with other third parties only with your explicit consent. Specifically,
• We may share some of your Personal Data with the Third-Party Providers with which you are transacting in order to process your transaction
• We may share your Personal Data with external service providers to verify your identity, confirm your eligibility, conduct checks in business and public registers, and comply with AML/CFT requirements
• If you access our platform through the website or other form of integration of one of our Partners, then we may share your Personal Data with that Partner
• We engage selected Third-Party Providers to perform services ancillary to our Services and may provide them access to your Personal Data
• We may share your Personal Data with our affiliated companies
• We may share your Personal Data with banking partners and financial institutions to facilitate fiat transfers and virtual IBAN operations
Transfer of Personal Data Outside the EEA
Overflow may transfer your Personal Data to countries outside the European Economic Area (EEA) as part of its operations. When we do so, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).
Such transfers may occur in the following circumstances:
• To our trusted third-party service providers or partners who assist in delivering our Services, including those located outside the EEA
• When it is necessary to fulfill legal obligations or respond to lawful requests from public authorities, including for national security or law enforcement requirements
In the absence of an adequacy decision by the European Commission for the country receiving the data, we rely on legally recognized safeguards, including:
• The use of Standard Contractual Clauses (SCCs) approved by the European Commission
• Binding Corporate Rules (BCRs) implemented by our partners where applicable
• Other appropriate legal and technical safeguards
You may request further information about the safeguards we use when transferring your data outside the EEA by contacting us at compliance@overflow.money.
Cookies and Similar Technologies
Overflow uses technical and functional cookies and analytical cookies that do not infringe on your privacy. Cookies are small text files stored on your device when you visit our website. These cookies are necessary for the website's technical functionality and user experience. They ensure the website works properly and can remember your preferences. You can disable cookies through your browser settings and delete previously stored information.
Your Rights
You have several rights concerning your Personal Data that you can exercise without cost. These rights include:
• Right of access: You can request a copy of your personal data
• Right to rectification: You can request that inaccurate data be corrected
• Right to erasure: You can request that your personal data be deleted, within certain limits
• Right to restrict processing: You can request that your personal data be restricted in certain circumstances
• Right to data portability: You can request a copy of your personal data in a machine-readable format so that you can transfer it to another organization
• Right to object: You can request that your personal data not be used in certain circumstances, or that automated decision-making based on your data be stopped
• Right not to be subject to automated decision-making: You can request that your personal data not be used in automated decision-making, including profiling
Lastly, you have a right to lodge a complaint with a competent supervisory authority.
If you wish to exercise any of your rights, you should contact us at compliance@overflow.money.
Further information about your rights may be obtained by contacting the supervisory data protection authority located in your jurisdiction. For Poland, the supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) - https://uodo.gov.pl/en.
How We Secure Personal Data
Overflow takes the protection of your data seriously and implements appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. We employ industry-standard encryption, access controls, and security protocols to safeguard your information. If you suspect that your data is not secure or have concerns about potential misuse, contact our customer service or email compliance@overflow.money.
Automated Decision-Making
Overflow does not engage in automated decision-making processes that would produce legal effects or similarly significant effects concerning you. All decisions involving your Personal Data are reviewed and made by authorized personnel to ensure fairness and compliance with applicable laws and regulations.
Contact Us
If you believe your rights have been violated, or have any concerns about your Personal Data, please contact us by mail at ul. PIOTRKOWSKA, nr 116, lok. 52, miejsc. ŁÓDŹ, kod 90-006, poczta ŁÓDŹ, kraj POLSKA, or by email at compliance@overflow.money.