Privacy Policy

September 2026

Defteros Frouros Ltd (referred to as 'we', 'us', 'our', 'DF', or 'Defteros Frouros') is committed to protecting your privacy and handling your data in an open and transparent manner. The personal data that we collect and process depends on the service requested and agreed upon in each case.
This privacy statement:

provides an overview of how we collect and process your personal data and tells you about your rights under the EU General Data Protection Regulation ('GDPR'),
is directed to natural persons who are either current or potential clients of Defteros Frouros, or who have provided, or are authorised representatives/agents or beneficial owners of legal entities or natural persons which/who are current or potential clients of Defteros Frouros,
is directed to natural persons who currently have or who had a business relationship with Defteros Frouros in the past,
is directed to any other natural persons whose personal data has or may in the future be lawfully obtained by Defteros Frouros in the normal course of its business,
contains information about when we share your personal data with third parties (for example, our service providers or suppliers, or the third-party payment providers with whom we help you establish relationships).

1. Who we are
Defteros Frouros Ltd is a limited company incorporated and registered under the Laws of Gibraltar, with Registration number 126881. We are a payment infrastructure consultancy. We source, structure, onboard and manage payment stacks built entirely on third-party providers, rails and markets, giving businesses the flexibility to operate and scale across regions, currencies and payment methods. Defteros Frouros does not process payments or hold funds itself; our role is the strategy, sourcing and ongoing coordination of the licensed third-party providers who do.

2. Information we collect from you
You may give us information about yourself by accessing our website https://www.dfservices.ltd or by corresponding with us through our contact form, by email at info@dfservices.ltd, or otherwise.
The following information could be necessary for us to provide our specific services (meaning the payment-infrastructure consulting and coordination services made available to you by Defteros Frouros to fulfil the engagement between us):

First and last name of your representatives and contacts
Email address
Phone number
Company or business name, jurisdiction and business model
Details about your payment operations, target markets and requirements
Corporate details of the entity you represent, including incorporation and regulatory status, where relevant to sourcing and onboarding third-party providers

Please note that any customer due diligence, "know your customer" (KYC) or anti-money-laundering checks required to onboard you to a payment provider are carried out by the licensed third-party providers themselves, in accordance with their own policies and regulatory obligations, not by Defteros Frouros.

3. Information we automatically collect from you
When you visit our website, we automatically collect information, including personal information, about the parts of the Defteros Frouros website you use, and how you use them. This information is necessary for the adequate performance of the engagement between us and is based on our legitimate interest in being able to provide our services:

Information about your device — your visits to and use of the website (including without limitation your IP address, geographical location, browser/platform type and version), internet service provider, and operating system.
Information about your use of the website — length of visit, page views, website navigation and search terms that you use, referral source/exit pages.

4. Purposes for which we use your personal information
In general, we use information that we collect about you or that you provide to us, including for the following purposes:

Provision of services: to provide you with the payment-infrastructure consulting services that you request from us and to fulfil our obligations under the engagement we agreed to provide;
Client management: to manage your relationship with us, respond to your enquiries, and provide you with the necessary support. We will also provide you with notices about our services, including notices about changes to any services we offer or provide;
Sourcing and onboarding: to identify, introduce and coordinate suitable third-party payment providers on your behalf, and to support your onboarding with them;
Advertising: following explicit consent, to communicate with you about services that may be of interest to you either from us, our affiliates, or other third parties;
Functionality and security: to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
Compliance: to enforce our terms and to comply with our legal obligations as these derive from applicable laws or our regulators;
Analysis and statistics on aggregate data: We process personal data to:

(i) carry out aggregate analyses and statistics relevant to our business and improve our services;
(ii) prepare anonymized datasets for our research and development activities;
(iii) ensure the quality of client service;
(iv) internally manage and control our activities;
(v) manage the loss and/or destruction of data or any unauthorized access;
(vi) collect and process data in anonymous form relating to the devices used in order to obtain useful information on the use of the services;
(vii) debug and identify errors in our website.

5. Disclosure of your personal information
We do not share your personal information with third parties except as indicated below:

Third-party payment providers: To source, structure and onboard your payment stack, we share relevant information with the licensed third-party providers, acquirers and rails we help you establish relationships with, so that they can assess, onboard and service you.
Affiliates: We share the above categories of personal information with our subsidiaries and affiliates to the extent this is necessary for the purposes of provision of services, client management, advertising (if consented), security, and compliance.
Service providers: To our authorized service providers who perform certain services on our behalf (such as external lawyers, auditors, and IT or hosting providers), including for provision of the services you requested, client management, and security.
Legal successors: To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets.
Other: To the extent necessary to fulfil any other purpose for which you provided personal information and, if applicable, your consent separately from this Privacy Policy.

6. Transfer of information to European and non-European countries
Defteros Frouros operates in various jurisdictions. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.
By using our website, you acknowledge and agree to such transfers and processing from countries not belonging to the European Union or the European Economic Area (so-called Third Countries) to Europe and vice versa, recognized by the European Commission as having an adequate level of protection of personal data or governed by other contractual guarantees according to GDPR. For further information, please contact us at info@dfservices.ltd.

7. How we store your personal information
We take reasonable precautions following applicable laws and best practices to protect personal data from loss, misuse, and unauthorized access. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure.

8. Retention periods
We store your personal data for as long as necessary to carry out the purposes for which we originally collected it, and based on:

the length of time required to achieve the business or commercial purpose for which it was obtained,
legal or regulatory requirements applicable to such information,
internal operational needs, and
any need for the information based on any actual or anticipated investigation or litigation.

9. Analytics
We allow others to provide analytics services on our behalf across the website. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our website, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. For more details, please see our Cookie Policy.

10. Data subject rights and requests
Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to or request that we restrict certain processing. If you would like to exercise any of these rights, please contact us at info@dfservices.ltd.

11. Marketing
We may send you certain direct marketing communications if it is in our legitimate interests to do so for marketing and business development purposes, or you have provided your consent. You can withdraw this consent by contacting us via the website or by email at info@dfservices.ltd.

12. Changes to our Privacy Policy
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide additional notice. We encourage you to review this Privacy Policy regularly.

13. No rights of third parties
This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.

14. No error-free performance
We do not guarantee error-free performance under this Privacy Policy. We will use reasonable efforts to comply and take prompt corrective action when we learn of any failure to comply. We shall not be liable for any incidental, consequential, or punitive damages relating to this Privacy Policy.

Defteros Frouros Ltd Unit G02, Eurocity, Europort Avenue, Gibraltar, GX11 1AA info@dfservices.ltd
© 2026 Defteros Frouros

Privacy Policy

provides an overview of how we collect and process your personal data and tells you about your rights under the EU General Data Protection Regulation ('GDPR'),

is directed to natural persons who are either current or potential clients of Defteros Frouros, or who have provided, or are authorised representatives/agents or beneficial owners of legal entities or natural persons which/who are current or potential clients of Defteros Frouros,

is directed to natural persons who currently have or who had a business relationship with Defteros Frouros in the past,

is directed to any other natural persons whose personal data has or may in the future be lawfully obtained by Defteros Frouros in the normal course of its business,

contains information about when we share your personal data with third parties (for example, our service providers or suppliers, or the third-party payment providers with whom we help you establish relationships).

First and last name of your representatives and contacts

Email address

Phone number

Company or business name, jurisdiction and business model

Details about your payment operations, target markets and requirements

Corporate details of the entity you represent, including incorporation and regulatory status, where relevant to sourcing and onboarding third-party providers

Information about your device — your visits to and use of the website (including without limitation your IP address, geographical location, browser/platform type and version), internet service provider, and operating system.

Information about your use of the website — length of visit, page views, website navigation and search terms that you use, referral source/exit pages.

4. Purposes for which we use your personal information In general, we use information that we collect about you or that you provide to us, including for the following purposes:

Provision of services: to provide you with the payment-infrastructure consulting services that you request from us and to fulfil our obligations under the engagement we agreed to provide;

Client management: to manage your relationship with us, respond to your enquiries, and provide you with the necessary support. We will also provide you with notices about our services, including notices about changes to any services we offer or provide;

Sourcing and onboarding: to identify, introduce and coordinate suitable third-party payment providers on your behalf, and to support your onboarding with them;

Advertising: following explicit consent, to communicate with you about services that may be of interest to you either from us, our affiliates, or other third parties;

Functionality and security: to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;

Compliance: to enforce our terms and to comply with our legal obligations as these derive from applicable laws or our regulators;

Analysis and statistics on aggregate data: We process personal data to:

Third-party payment providers: To source, structure and onboard your payment stack, we share relevant information with the licensed third-party providers, acquirers and rails we help you establish relationships with, so that they can assess, onboard and service you.

Affiliates: We share the above categories of personal information with our subsidiaries and affiliates to the extent this is necessary for the purposes of provision of services, client management, advertising (if consented), security, and compliance.

Service providers: To our authorized service providers who perform certain services on our behalf (such as external lawyers, auditors, and IT or hosting providers), including for provision of the services you requested, client management, and security.

Legal successors: To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets.

Other: To the extent necessary to fulfil any other purpose for which you provided personal information and, if applicable, your consent separately from this Privacy Policy.

the length of time required to achieve the business or commercial purpose for which it was obtained,

legal or regulatory requirements applicable to such information,

internal operational needs, and

any need for the information based on any actual or anticipated investigation or litigation.

4. Purposes for which we use your personal information
In general, we use information that we collect about you or that you provide to us, including for the following purposes: