WITTY Privacy Policy

1. Introduction

WITTY Technology Limited ("WITTY", "we", "our", or "us") is committed to protecting the privacy and security of our users' personal information. This Privacy Policy explains how we collect, use, store, disclose, and protect your data when you access or use any of our products, including:

• WITTY Multicurrency Accounts for Exporters
• WITTY Multicurrency Accounts for Crypto P2P Traders
• WIZZY AI Assistant
• WITTY Business Growth Program (BGP)
• WITTY Mobile & Web Applications
• WITTY APIs & Integrations

By using any WITTY service, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

2. Data We Collect

We collect different categories of data depending on the products you use and the level of verification required.

A. Personal Identification Data

• Full name
• Email address
• Phone number
• Residential / Business Address
• Date of birth
• Nationality
• Identification documents (e.g., passport, driver's license, national ID)

B. Business Information (Exporters & BGP Users)

• Company name, registration number, legal structure
• Corporate documentation (incorporation certificate, tax ID, shareholder info)
• Business bank details
• Invoices, trade history, supplier & buyer data

C. Financial & Transaction Data

• Account balances and currency profiles
• Payment history (inbound & outbound)
• Crypto wallet addresses (for P2P traders)
• FX conversion activity
• Staking and rewards activity

D. Technology & Usage Data

• Device information (IP address, OS, model)
• Login history
• In-app actions (referrals, deposits, transfers, etc.)
• AI chat logs with WIZZY (for training, safety, and improvement)

E. Marketing & Behavioral Data

• Referral activity
• Engagement with email, SMS, WhatsApp, push notifications
• Clickstream analytics across WITTY platforms

3. How We Use Your Data

We process your information for the following purposes:

1. To provide account access and platform functionality
2. To complete transactions, settlements, and FX conversions
3. To verify identity and comply with AML/KYC regulatory obligations
4. To train and optimize WIZZY for personalized business assistance
5. To deliver Business Growth Program (BGP) insights and matchmaking
6. To detect fraud, security breaches, and unauthorized activity
7. To issue rewards, referral commissions, staking payouts, and WTY token conversions
8. To improve product performance and user experience
9. To communicate updates, legal notices, product announcements, and marketing promotions (with opt-out available)

4. Legal Basis for Processing Data

We process your data under one or more of the following legal bases:

• Contractual necessity - enabling use of WITTY accounts and services
• Regulatory compliance - AML, CFT, KYC, tax reporting, sanctions screening
• Legitimate interest - fraud protection, business optimization, service analytics
• User consent - marketing emails, data sharing with partners, AI training

You may withdraw consent for non-essential processing at any time by contacting our Data Protection Officer.

5. Data Sharing & Third Parties

We never sell personal data. However, we may share limited data with:

• Regulated banking & payment partners (for account issuance & payouts)
• Global FX and liquidity providers (for trade execution)
• Identity verification vendors (KYC/AML checks)
• Blockchain analytics providers (for crypto fraud monitoring)
• WIZZY AI infrastructure partners (for secure model processing)
• Insurance or supply chain finance partners (BGP users only)
• Regulators & law enforcement (when legally required)

All third parties are bound by data protection contracts and may not use your data for their own marketing or profiling.

6. Data Retention Policy

Retention varies by product type and legal requirement:

• KYC + Identity Records: 7-10 years (legal compliance)
• Transaction & Payment Logs: 7 years minimum
• WIZZY AI Chats: 2 years (unless deleted sooner by user request)
• BGP Trade Data: active contract duration + 5 years
• Referral & Rewards History: lifetime of account
• Marketing data: until unsubscribed or 24 months inactivity

7. Security Measures

WITTY implements enterprise-grade security:

• End-to-end encryption for data in transit and at rest
• SOC-2, ISO 27001 certified infrastructure partners
• AI anomaly detection on high-risk transactions
• Continuous monitoring of login patterns, IPs, devices
• Role-based access controls and internal data minimization

If we detect account compromise, we may freeze access until identity is reverified.

8. User Rights

You have the right to:

• Request a copy of your data (data export)
• Request correction of inaccurate information
• Request deletion (unless legally restricted)
• Restrict or object to processing
• Disable marketing communications
• Request human review for AI decisions

To submit a request, email: [email protected]

9. Cross-Border Data Transfers

Because WITTY operates globally, your data may be stored or processed in multiple jurisdictions.

All transfers follow GDPR, PIPEDA (Canada), and other international data protection regulations.

10. Children's Privacy

WITTY services are not intended for individuals under 18. We do not knowingly collect data from minors.

11. Changes to this Policy

We may update this Privacy Policy from time to time. Updated versions will be posted with a revision date at the top of the document.

12. Contact Information

Data Protection Officer (DPO)

WITTY Technology Limited

130-10691 Shellbridge Way, Richmond, BC, V6X 2W8, Canada

Phone: +18077888113