Privacy Policy

Effective Date: Jan-15-2026
Last Updated: Jan-15-2026

This Privacy Policy explains how OK.de Services GmbH ("OK.de", "we", "us") processes personal data in connection with the OK.pay branded e-money interface and the non-custodial crypto wallet features made available within the OK.secure application (together, the "Financial & Wallet Services").

This Privacy Policy does not apply to:

  • The OK.secure messenger, communications, or AI features
  • Financial services provided independently by third parties acting as separate data controllers

1. Data Controller

The data controller within the meaning of Article 4(7) GDPR is:

OK.de Services GmbH
Uhlandstraße 165/166
10719 Berlin
Germany
Email: [email protected]

OK.de Services GmbH determines the purposes and means of processing only for the technical provision and integration of the Financial & Wallet Services described in this Policy.

2. Scope of This Privacy Policy

2.1 Services Covered

This Privacy Policy applies exclusively to:

  • The OK.pay branded e-money and payment interface
  • The non-custodial crypto wallet functionality
  • Technical integration and service availability related to those features
2.2 Excluded Services

This Policy does not apply to:

  • E-Money, payment, or card services provided by third parties
  • Cryptocurrency exchange, on-ramp, off-ramp, or spending services provided by third parties
  • Any services outside OK.pay and the crypto wallet

Such services are governed by the privacy policies of the respective providers.

3. Age Restriction

The Financial & Wallet Services are intended for users 18 years of age or older.

Where applicable law or third-party service requirements impose a higher minimum age, such higher age shall apply. We do not knowingly process personal data of individuals under 18 years of age.

4. Categories of Personal Data Processed

We process personal data in accordance with the principles of Article 5 GDPR (lawfulness, data minimization, purpose limitation).

4.1 Account and Identification Data

Limited identifiers are required to associate wallet and OK.pay functionality with a user account (e.g., internal account ID, service status).

4.2 Non-Custodial Wallet Technical Data
  • Public wallet addresses
  • Public keys
  • Transaction identifiers (hashes)
  • Token or asset identifiers
  • Transaction metadata required to display wallet activity

Private keys, recovery phrases, and seed phrases are not processed, stored, or accessible to OK.de Services GmbH.

4.3 Financial Integration Technical Data
  • Service availability and status information related to OK.pay
  • Error and diagnostic data related to API integration

No banking credentials, card numbers (PAN), CVVs, PINs, or transaction details are processed by OK.de Services GmbH.

4.4 Technical and Security Data
  • Device and app version data
  • Security and error logs
  • Temporarily processed IP addresses for security purposes

5. Purposes and Legal Bases of Processing

Personal data is processed for the following purposes and legal bases:

Purpose Legal Basis
Providing wallet and OK.pay integration Art. 6(1)(b) GDPR
Ensuring security and service integrity Art. 6(1)(f) GDPR
Legal and regulatory compliance Art. 6(1)(c) GDPR

6. Non-Custodial Crypto Wallet

6.1 Self-Custody Model

The integrated crypto wallet is a non-custodial (self-custody) wallet.

  • Users retain exclusive control over private keys and recovery phrases
  • OK.de Services GmbH does not hold or control crypto assets
  • Wallet recovery is not possible if recovery credentials are lost

Users are solely responsible for safeguarding their cryptographic credentials.

6.2 Public Blockchain Data

Blockchain networks are inherently transparent.

Public wallet addresses, transaction hashes, timestamps, and amounts may be publicly visible and accessible to third parties via blockchain explorers. OK.de Services GmbH does not control blockchain records.

6.3 Third-Party Crypto Service Providers

Buying, selling, exchanging, transferring, or spending cryptocurrency is provided exclusively by third-party services, including but not limited to:

  • Coinify ApS
  • OnRamper B.V.
  • Changelly
  • Bitrefill AB

These providers act as independent data controllers and may require identity verification (KYC) under applicable law. Their privacy policies govern such processing.

OK.de Services GmbH does not collect or process KYC data.

6.4 No Blockchain Surveillance by OK.de Services GmbH

OK.de Services GmbH does not perform blockchain surveillance, transaction monitoring, or sanctions screening. Any compliance checks are conducted solely by third-party crypto providers.

7. OK.pay E-Money and Payment Interface

7.1 Nature of OK.pay

OK.pay is a financial service product provided by Prisma Payments EP SA, an authorized electronic money institution.

OK.de Services GmbH provides only the technical interface and integration within the OK.secure app.

7.2 No Financial Institution Status

OK.de Services GmbH is not:

  • A bank
  • A payment service provider
  • An electronic money institution
  • A financial intermediary or advisor

OK.de Services GmbH does not hold funds, execute transactions, issue cards, or provide financial advice.

7.3 Financial Data Processing Responsibility

OK.pay service providers, like i.a. Prisma Payments EP SA and Orenda Financial Services Limited, as issuing bank, payment partners or platform providers act as independent data controllers for all personal data related to:

  • Financial accounts
  • Payments
  • VISA debit card issuance and usage
  • KYC/AML compliance

OK.de Services GmbH does not determine the purposes or means of such processing.

7.4 Visa Debit Card

OK.pay may include a VISA-branded debit card issued by an issuing bank partner.

OK.de Services GmbH does not process or store:

  • Primary Account Numbers (PAN)
  • CVVs
  • PINs
  • Sensitive card authentication data
7.5 Applicable Privacy Policies

Personal and financial data related to OK.pay services is governed by the Privacy Policy of the respective service partner, provided on the OK.pay platform.

Users should review that policy to understand financial data processing and to exercise data protection rights in relation to OK.pay services.

8. Data Sharing

OK.de Services GmbH may share limited technical data with:

  • Infrastructure and hosting providers (as processors)
  • Security and support service providers
  • Authorities where legally required

No data is sold or used for advertising.

9. International Data Transfers

Where personal data is processed outside the EU/EEA, appropriate safeguards are applied, including adequacy decisions and Standard Contractual Clauses (Art. 46 GDPR).

10. Data Retention

Personal data is retained only for as long as necessary to provide the Financial & Wallet Services or to comply with legal obligations, and is then deleted or anonymized.

11. Data Subject Rights

Users have rights under Articles 15–22 GDPR, including access, rectification, erasure, restriction, portability, and objection.

Requests may be submitted to: [email protected]

12. Supervisory Authority

Users have the right to lodge a complaint with a competent supervisory authority, in particular in the EU Member State of residence or the controller's establishment (Art. 77 GDPR).

13. Security Measures

OK.de Services GmbH implements appropriate technical and organizational measures, including encryption, access controls, and incident response procedures, to protect personal data.

14. Changes to This Policy

This Privacy Policy may be updated to reflect legal, technical, or operational changes. Material changes will be communicated appropriately.

15. Contact

OK.de Services GmbH
Email: [email protected]

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