Privacy Policy

1. Who we are

This Privacy Policy explains how Omicron Gama S.A. ("Omicron Gama", "we", "us") collects, uses, shares and protects personal information. Omicron Gama S.A. is the data controller responsible for the processing of personal information described in this policy.

Omicron Gama S.A.
Taxpayer ID (RUC): 80117195-4
Calle Fulgencio Yegros entre Pedro Juan Caballero y 15 de Agosto
Caaguazú
Paraguay
Email: [email protected]

2. Scope

This policy applies to personal information processed through the omicrongama.com website, our onboarding process, our commercial relationships with business customers, the orders we fulfill and our private API. Omicron Gama works with businesses and with individuals acting for business purposes; this policy covers the individuals whose information we receive in that context, such as customers who are individuals, representatives, employees, directors and beneficial owners of business customers, and visitors to our website.

3. Information we collect

3.1. Information you provide

• Business contact information: name, position, company, email address, telephone number and the content of your communications with us.
• KYC information (individuals): first and last name, date of birth, nationality, residential address, taxpayer identification number, government-issued identity documents and proof of address.
• KYB information (businesses): legal name, registration and tax details, corporate documents, address, ownership structure, and identification of beneficial owners, directors and authorized representatives.
• Financial information: bank details, bank statements, information on the source of funds or wealth and answers to our due diligence questionnaires.
• Politically exposed person information: whether a person is a politically exposed person, or a family member or close associate of one.

3.2. Identity verification

We use Veriff, a third-party identity verification provider, to verify identities. Depending on the case, Veriff may process images of identity documents, facial images, selfies, short videos or other liveness checks, and the results of the verification. Veriff processes this information on our behalf to provide the verification service.

3.3. Transaction and payment information

• Orders, invoices, delivery records, API request records and records of advance payments (Prepaid Balance).
• Payment details needed to process and reconcile payments, such as bank transfer references and transaction identifiers.
• Card payments are processed by third-party payment service providers. Sensitive payment data is handled by the corresponding payment providers. Omicron Gama does not store card security codes (CVV/CVC) after authorization.

3.4. Technical information

When you visit our website or use our API, our servers record technical information such as IP address, browser type, pages requested, date and time of access and, for the API, request records. We use this information to operate, secure and troubleshoot our services.

3.5. Information from other sources

We may receive information from identity verification providers, sanctions and politically exposed person screening sources, public registries, payment processors, suppliers and banks, where necessary for the purposes described in this policy.

4. How we use personal information

• To carry out KYC/KYB due diligence and onboarding, including identity, business and representative verification.
• To evaluate applications, provide our services, fulfill orders and provide API access.
• To process payments, advance payments, invoices and refunds.
• To prevent fraud and to comply with anti-money laundering, counter-terrorist financing and sanctions requirements, including activity monitoring, review of unusual activity and internal escalation when appropriate.
• To comply with legal obligations and respond to valid requests from competent authorities.
• To communicate with you about your business relationship with us and, where permitted, about our products. You can opt out of commercial communications at any time.
• To secure our website, systems and API.
• To handle claims and payment disputes and to establish, exercise or defend legal claims.

5. Legal bases

We process personal information in accordance with the laws of the Republic of Paraguay, including the right to privacy and the habeas data guarantee of the National Constitution (articles 33 and 135), Law No. 6534/2020 on the protection of personal credit data where applicable and, once it enters into force, Law No. 7593/2025 on the Protection of Personal Data in the Republic of Paraguay, as well as any other law applicable to a specific processing activity. We rely on: the performance of a contract or steps taken before entering into a contract; compliance with legal obligations; our legitimate interests in operating a secure and compliant business, preventing fraud and protecting our rights; and your consent, where consent is required.

6. How we share personal information

We do not sell personal information. We share personal information only as described below:

• Service providers that act on our behalf, such as identity verification (Veriff), website and data hosting, email and communications, payment processing and IT services.
• Suppliers and Issuers, when necessary to fulfill an order, for example to credit a top-up to an identifier provided by the customer.
• Banks and payment processors, to process payments and handle payment disputes.
• Professional advisors, such as lawyers and auditors, under confidentiality obligations.
• Competent authorities, when required by applicable law or a valid legal request.
• Corporate transactions, in connection with a merger, acquisition, reorganization or sale of assets, subject to appropriate confidentiality.

7. International transfers

Omicron Gama is based in Paraguay and works with business customers in several regions. Personal information may be processed in Paraguay and in other countries where we or our service providers operate, such as our identity verification provider. When we transfer personal information outside Paraguay, we take measures to ensure an adequate level of protection, such as contractual safeguards with our providers, in accordance with this policy and applicable law.

8. Retention

We keep KYC/KYB records and transaction records for at least five (5) years after the end of the business relationship, or longer where required by applicable law. We keep other personal information only for as long as necessary for the purposes described in this policy, after which it is deleted or anonymized.

9. Security

We use technical and organizational measures, such as encryption in transit, access controls and restricted credentials, to protect personal information against unauthorized access, loss or misuse. No system is completely secure; you must keep your own credentials, including API credentials, confidential and notify us of any unauthorized access.

10. Your rights

Depending on applicable law, you may have the right to access, rectify, update or delete your personal information, to object to certain processing, to request a copy of your information in a portable format and to withdraw consent where processing is based on consent. Under the National Constitution, you may also use the habeas data guarantee. Once Law No. 7593/2025 enters into force, you may also lodge a complaint with the National Agency for the Protection of Personal Data (Agencia Nacional de Protección de Datos Personales). To exercise these rights, contact [email protected]. We may need to verify your identity before responding. Some information may need to be retained to comply with legal obligations, such as anti-money laundering record-keeping requirements.

11. Minors

Our services are intended for businesses and are not directed to persons under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected such information, we will delete it.

12. Cookies

The omicrongama.com website currently does not use cookies for analytics or advertising. If we introduce such technologies in the future, we will update this policy before doing so.

13. Changes to this policy

We may update this Privacy Policy to reflect changes in our services or in applicable law. The updated version will be published on this page with its date. Where required by law, we will notify you of material changes.

14. Contact

For questions or requests regarding this Privacy Policy, contact [email protected] or write to Omicron Gama S.A., Calle Fulgencio Yegros entre Pedro Juan Caballero y 15 de Agosto, Caaguazú, Paraguay.

This policy may be published in several languages. The English version is the master version and prevails in the event of any inconsistency.