> For the complete documentation index, see [llms.txt](https://pait.gitbook.io/pait/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://pait.gitbook.io/pait/legal/privacy-and-cookie-policy.md).

# Privacy & Cookie Policy

This Privacy Policy describes how PA Network iT Ltd., a company incorporated and registered in United Kingdom, under company number CR-432537, with its registered office at TTA Corporate Services Limited, Harbour Place, 2nd Floor, North Wing, 103 South Church Street, P.O. Box 472, George Town, Grand Cayman KY1-1106, Cayman Islands ("PAiT", the "Company", "We", "Us" or "Our"), collects, uses, stores, and shares your Personal Data when you use our mobile application, website, and related services (collectively, the "Platform").\
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By using the Platform, You agree to the collection and use of information in accordance with this Privacy Policy.\
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1\. DEFINITIONS\
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1.1. For the purposes of these Terms and any documents incorporated by reference, including the Privacy Policy, the following terms shall have the meanings set out below:\
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1.1.1. "Applicable Law" means any applicable law, statute, regulation, directive, rule, ordinance, judgment, order, regulatory guidance, or requirement of any governmental, regulatory, supervisory, tax, or enforcement authority in any relevant jurisdiction;\
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1.1.2. "Cookies" means small data files stored on a User’s device when accessing the Platform, including similar tracking technologies;\
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1.1.3. "Data Protection Legislation" means all applicable data protection and privacy laws in any relevant jurisdiction, including, where applicable:\
(i) the UK GDPR and the Data Protection Act 2018;\
(ii) the EU General Data Protection Regulation (EU) 2016/679 (GDPR);\
(iii) any other applicable national implementing or supplementary laws.\
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1.1.4. "Earn Service" (or "Earn Function") means an optional digital asset deployment feature made available through the Platform under which eligible users may instruct PAiT to arrange for supported Digital Assets to be deployed, re-deployed, allocated, or otherwise used in connection with supported strategies, protocols, or third-party infrastructure, subject to these Terms;\
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1.1.5. "Personal Data" means any information relating to an identified or identifiable natural person, as defined under:\
(i) the UK GDPR and the Data Protection Act 2018;\
(ii) where applicable, the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”);\
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1.1.6. "Platform" means the PAiT Website, mobile application, and related interfaces, software, tools, content, and services made available by PAiT;\
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1.1.7. "Privacy Policy" means the privacy policy published by PAiT, as amended from time to time, which describes how Personal Data is collected, used, and processed;\
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1.1.8. "User", "You" or "Your" means any person who accesses or uses the Platform. To the extent this Privacy Policy refers to Personal Data, it applies to information relating to identified or identifiable natural persons.\
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1.1.9. "Digital Assets" means any digital representation of value or rights that may be transferred and stored electronically, using distributed ledger technology or similar technology, including but not limited to cryptocurrencies, stablecoins, and tokens.\
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2\. ACCEPTANCE OF THIS PRIVACY POLICY\
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2.1. By accessing, using, or engaging with the Platform or the Earn Service, you acknowledge that you have read and understood this Privacy Policy and that your Personal Data will be processed in accordance with it.\
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2.2. We will not use your Personal Data for purposes incompatible with those described in this Privacy Policy or the Terms unless we are permitted or required to do so under Applicable Law or, where required, have obtained your consent.\
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2.3. By using the Platform, you acknowledge that your Personal Data may be processed in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you should discontinue use of the Platform. Please note that certain Personal Data is necessary for us to provide the Platform and comply with Applicable Law.\
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3\. PERSONAL DATA\
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3.1. This Privacy Policy applies to the processing of Personal Data of users located in the United Kingdom, the European Economic Area (EEA), and other jurisdictions, to the extent that such laws apply. We may collect and process the following categories of Personal Data:\
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3.1.1. when registering for an account and accessing the Platform, you may be required to provide:\
3.1.1.1. full name;\
3.1.1.2. date of birth;\
3.1.1.3. nationality;\
3.1.1.4. residential address;\
3.1.1.5. email address;\
3.1.1.6. signature;\
3.1.1.7. other identifying information;\
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3.1.2. to comply with Applicable Law, including anti-money laundering, counter-terrorist financing, and sanctions requirements, we may collect and process:\
3.1.2.1. identification documents (passport, ID card, driver’s licence);\
3.1.2.2. proof of address;\
3.1.2.3. tax identification data;\
3.1.2.4. source of funds and source of wealth information;\
3.1.2.5. purpose of account usage;\
3.1.2.6. sanctions and screening results;\
3.1.2.7. risk scoring and compliance assessments;\
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3.1.3. We generally do not collect special categories, such as biometric data, of Personal Data. However, where biometric authentication is used (e.g. facial recognition or fingerprint login), such data may be processed with your explicit consent, where required under Data Protection Legislation.\
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3.1.4. When you use the Platform, we may collect technical and usage data:\
3.1.4.1. IP address;\
3.1.4.2. device information;\
3.1.4.3. operating system;\
3.1.4.4. browser type;\
3.1.4.5. network information;\
3.1.4.6. session and usage data;\
3.1.4.7. blockchain addresses associated with your activity;\
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3.1.5. In addition, We may collect and process transaction and financial data:\
3.1.5.1. blockchain transaction data;\
3.1.5.2. wallet addresses;\
3.1.5.3. deposit and withdrawal requests;\
3.1.5.4. account balances and activity;\
3.1.5.5. payment and banking information (where applicable);\
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3.1.6. We may collect and process information contained in communications with you, including:\
3.1.6.1. emails;\
3.1.6.2. support requests;\
3.1.6.3. live chats;\
3.1.6.4. call logs (where applicable);\
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3.1.7. We may generate additional data based on your activity, including:\
3.1.7.1. transaction patterns;\
3.1.7.2. behavioral analytics;\
3.1.7.3. risk indicators;\
3.1.7.4. fraud detection signals.\
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3.2. The above provided information may be used to verify your identity, enable access to the Platform, operate and improve the Platform and the Earn Service (including transaction execution), ensure security, comply with legal and regulatory obligations (including monitoring for fraud and suspicious activity), and may be obtained from or shared with third-party service providers where necessary; communications may also be recorded and retained for compliance, evidential, and operational purposes.\
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4\. HOW WE COLLECT PERSONAL DATA\
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4.1. We collect Personal Data through a combination of direct interactions, automated technologies, and third-party sources.\
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4.2. In particular, Personal Data may be collected:\
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4.2.1. when you register for an account, log in, or otherwise access or use the Platform;\
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4.2.2. when you communicate with us, submit inquiries, or provide feedback;\
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4.2.3. through Cookies and similar tracking technologies used on the Platform;\
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4.2.4. through automated systems monitoring your use of the Platform, including technical and usage data;\
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4.2.5. from third-party sources, where permitted by Applicable Law, including:\
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4.2.5.1. identity verification and compliance service providers;\
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4.2.5.2. blockchain analytics and transaction monitoring providers;\
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4.2.5.3. public databases, registries, and sanctions lists;\
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4.2.5.4. payment service providers and technical infrastructure partners.\
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4.3. Where Personal Data is required for the provision of the Platform or compliance with Applicable Law, failure to provide such data may prevent us from establishing or maintaining a relationship with You, including restricting, suspending, or terminating access to your Account and the Platform.\
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5\. HOW WE USE YOUR PERSONAL DATA\
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5.1. We process your Personal Data for the following purposes and on the following legal bases:\
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5.1.1. performance of a contract (Art. 6(1)(b)) – account creation, transactions, Earn Service;\
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5.1.2. compliance with legal obligations (Art. 6(1)(c)) – AML/KYC, sanctions;\
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5.1.3. legitimate interests (Art. 6(1)(f)) – fraud prevention, platform security, analytics;\
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5.1.4. consent (Art. 6(1)(a)) – marketing communications, non-essential cookies, biometric authentication.\
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5.2. We may use your Personal Data:\
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5.2.1. to provide and operate the Platform and the Earn Service, including account management, transaction processing, withdrawals, and the allocation and management of Digital Assets across supported strategies, protocols, and counterparties;\
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5.2.2. to verify your identity and comply with Applicable Law, including anti-money laundering (AML), counter-terrorist financing (CTF), sanctions, and regulatory requirements;\
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5.2.3. to ensure the security and integrity of the Platform, including detecting and preventing fraud, unauthorized access, phishing, cyber-attacks (including DDoS), and other misuse, as well as to analyze and improve the performance, functionality, and user experience of the Platform;\
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5.2.4. to communicate with you in relation to your Account, transactions, security matters, and the operation of the Platform, including providing customer support and responding to inquiries;\
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5.2.5. where required by Applicable Law, we may process your Personal Data based on your consent, including for marketing communications. You may withdraw your consent at any time.\
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6\. DATA STORAGE AND SECURITY\
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6.1. We implement and maintain appropriate technical and organizational measures designed to protect Personal Data against unauthorized or unlawful processing, accidental loss, destruction, or damage.\
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6.2. Such measures include, where appropriate:\
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6.2.1. encryption of data in transit and at rest;\
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6.2.2. access controls and role-based permissions;\
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6.2.3. authentication and account security mechanisms;\
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6.2.4. monitoring, logging, and intrusion detection systems;\
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6.2.5. regular testing, assessment, and evaluation of security measures;\
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6.2.6. internal policies governing data handling and access.\
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6.3. Personal Data may be stored and processed on secure servers operated by PAiT or by third-party infrastructure providers, including cloud service providers, in accordance with applicable contractual and regulatory requirements.\
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6.4. Access to Personal Data is restricted to personnel, contractors, and service providers who require such access for the performance of their duties and are subject to appropriate confidentiality and data protection obligations.\
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6.5. While we take reasonable steps to protect Personal Data, no method of transmission over the internet or method of electronic storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security of Personal Data.\
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6.6. To the extent permitted by Applicable Law, PAiT shall not be liable for unauthorized access to or loss of Personal Data resulting from events beyond its reasonable control, provided that PAiT has implemented appropriate safeguards in accordance with Data Protection Legislation.\
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6.7. Users are responsible for maintaining the confidentiality of their account credentials and for taking appropriate steps to protect access to their devices and accounts.\
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7\. DATA RETENTION\
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7.1. We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including for the provision of the Platform and the Earn Service, and to comply with Applicable Law. Due to the nature of blockchain technology, certain data (such as public wallet addresses and transaction records) may be permanently recorded and cannot be altered or deleted.\
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7.2. In particular, we are required under Applicable Law to retain certain records, including identity verification (KYC) materials and transaction data, for a minimum period of five (5) years following the end of the business relationship. Such data may be retained for longer where required or permitted under Applicable Law, including for regulatory, legal, or fraud prevention purposes.\
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7.3. We may also retain Personal Data for longer periods where necessary for the establishment, exercise, or defense of legal claims, the prevention and detection of fraud or financial crime, or to comply with regulatory or law enforcement requests.\
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7.4. At the end of the applicable retention period, Personal Data will be securely deleted, anonymized, or otherwise processed in accordance with Data Protection Legislation.\
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8\. SHARING YOUR PERSONAL DATA\
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8.1. We do not sell your Personal Data. However, we may disclose, share, or otherwise make available your Personal Data to third parties where necessary for the purposes set out in this Privacy Policy, in accordance with Applicable Law.\
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8.2. In particular, we may share your Personal Data in the following circumstances:\
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8.2.1. We may share Personal Data with third-party service providers who support the operation of the Platform and the Earn Service, including:\
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8.2.1.1. identity verification and KYC/AML providers;\
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8.2.1.2. cloud hosting and infrastructure providers;\
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8.2.1.3. blockchain analytics and transaction monitoring providers;\
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8.2.1.4. payment processors and financial institutions;\
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8.2.1.5. customer support and communication service providers;\
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8.2.1.6. IT, security, and system administration providers.\
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8.2.2. We may disclose Personal Data to competent authorities, regulators, law enforcement agencies, courts, or other third parties where:\
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8.2.2.1. required or permitted by Applicable Law;\
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8.2.2.2. necessary to comply with legal or regulatory obligations (including AML, CTF, and sanctions requirements);\
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8.2.2.3. necessary to respond to lawful requests, court orders, or investigations;\
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8.2.2.4. necessary to protect our legal rights or defend against claims.\
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8.2.3. We may share Personal Data where necessary for transaction and operational purposes:\
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8.2.3.1. execute transactions and withdrawals;\
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8.2.3.2. interact with third-party protocols or service providers involved in the operation of the Earn Service;\
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8.2.3.3. facilitate payment processing or settlement activities;\
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8.2.3.4. ensure the proper functioning of the Platform.\
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8.2.4. We may disclose or transfer Personal Data in connection with corporate transactions:\
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8.2.4.1. a merger, acquisition, restructuring, or sale of assets;\
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8.2.4.2. financing arrangements or investment transactions;\
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8.2.4.3. due diligence processes involving prospective investors or partners.\
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8.2.5. We may share Personal Data with third parties where necessary to fraud prevention and security:\
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8.2.5.1. detect, prevent, or investigate fraud, financial crime, or security incidents;\
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8.2.5.2. protect the Platform, our users, or third parties from harm;\
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8.2.5.3. enforce our Terms and policies.\
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8.3. We may share anonymized or aggregated data that does not identify you with third parties for analytical, research, or business purposes.\
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8.4. Where you interact with third-party services through the Platform, your Personal Data may be processed by such third parties in accordance with their own privacy policies. We are not responsible for the privacy practices of such third parties.\
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8.5. Where Personal Data is transferred outside the United Kingdom or the European Economic Area, we implement appropriate safeguards in accordance with applicable Data Protection Legislation, including, where relevant, adequacy regulations, adequacy decisions, and/or Standard Contractual Clauses approved by the competent authorities.\
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9\. YOUR LEGAL RIGHTS\
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9.1. Subject to applicable data protection laws, including the UK GDPR and, where applicable, the EU GDPR, you may have the following rights in relation to your Personal Data:\
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9.1.1. Right to be informed – to receive clear information about how your Personal Data is collected and used;\
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9.1.2. Right of access – to obtain confirmation as to whether we process your Personal Data and to access such data;\
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9.1.3. Right to rectification – to request correction of inaccurate or incomplete Personal Data;\
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9.1.4. Right to erasure (right to be forgotten) – to request the deletion of your Personal Data where there is no valid legal basis for its continued processing. This right is subject to important limitations, including where we are required to retain data for compliance with legal and regulatory obligations (including AML, KYC, and fraud prevention requirements), or for the establishment, exercise, or defence of legal claims.\
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9.1.5. Right to restrict processing – to request limitation of processing under certain circumstances;\
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9.1.6. Right to data portability – to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another controller;\
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9.1.7. Right to object – to object to processing based on legitimate interests, including direct marketing;\
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9.1.8. Right to withdraw consent – where processing is based on consent, to withdraw such consent at any time without affecting the lawfulness of prior processing.\
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9.2. You may exercise your rights by contacting us using the contact details provided in this Privacy Policy. We may request additional information to verify your identity before responding to your request. Requests will be handled in accordance with applicable legal timeframes and requirements.\
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9.3. Please note that certain rights may be limited where processing is necessary for:\
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9.3.1. compliance with legal and regulatory obligations (including AML, CTF, and fraud prevention requirements);\
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9.3.2. the establishment, exercise, or defense of legal claims;\
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9.3.3. the protection of the rights and freedoms of others.\
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9.4. If you believe that your Personal Data has been processed in violation of applicable data protection laws, you have the right to lodge a complaint with a competent supervisory authority, including:\
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9.4.1. in the United Kingdom – the Information Commissioner’s Office (ICO);\
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9.4.2. in the European Economic Area – the supervisory authority in your country of residence or place of work.\
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10\. FOR USERS IN THE UNITED STATES\
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10.1. This section applies to individuals located in the United States, to the extent that applicable U.S. state privacy laws apply, including, where relevant, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and similar state laws.\
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10.2. At or before the point of collection, we collect the following categories of Personal Data:\
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10.2.1. identifiers (e.g., name, email address, IP address);\
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10.2.2. identity verification data (e.g., date of birth, identification documents);\
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10.2.3. financial and transaction data (e.g., wallet addresses, transaction history);\
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10.2.4. internet or network activity information (e.g., device data, usage logs);\
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10.2.5. commercial information (e.g., interactions with the Platform);\
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10.3. We collect this information for the following purposes:\
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10.3.1. to provide and operate the Platform and the Earn Service;\
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10.3.2. to verify identity and comply with legal obligations (including KYC/AML);\
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10.3.3. to process transactions and manage allocations;\
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10.3.4. to detect and prevent fraud and security incidents;\
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10.3.5. to improve and develop our services;\
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10.3.6. for communication and support purposes;\
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10.3.7. for marketing and analytics, where permitted by law.\
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10.4. We retain Personal Data in accordance with the Data Retention section of this Privacy Policy.\
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10.5. We do not sell your Personal Data. We do not “share” Personal Data for cross-context behavioural advertising within the meaning of applicable U.S. privacy laws, except where such activity may be considered “sharing” under applicable law (e.g., use of certain analytics or advertising technologies). To the extent such processing qualifies as “sale” or “sharing” under applicable law, you have the right to opt out. You may exercise this right by contacting us using the details provided in this Privacy Policy.\
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10.6. Depending on your state of residence, you may have the right to:\
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10.6.1. request access to the Personal Data we collect about you;\
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10.6.2. request deletion of your Personal Data (subject to legal exceptions, including AML/KYC obligations);\
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10.6.3. request correction of inaccurate Personal Data;\
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10.6.4. opt out of the sale or sharing of Personal Data (if applicable);\
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10.6.5. limit the use of sensitive personal information (where applicable);\
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10.6.6. not be discriminated against for exercising your rights.\
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10.6.7. We will respond to verifiable consumer requests in accordance with applicable law.\
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10.7. To protect your Personal Data, we may require you to verify your identity before processing your request. This may include matching information you provide with information we hold.\
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10.8. We will not discriminate against you for exercising your rights under applicable U.S. privacy laws.\
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11\. COOKIES AND SIMILAR TECHNOLOGIES\
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11.1. We use cookies and similar technologies (including pixels, tags, and local storage) (collectively, “Cookies”) to collect and process information about your interaction with the Platform.\
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11.2. Cookies are small text files stored on your device when you access or use the Platform and are widely used to ensure functionality, enhance user experience, and support security and analytics.\
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11.3. We use the following categories of Cookies:\
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11.3.1. strictly necessary Cookies are essential for the operation of the Platform and enable core functionality, including:\
(i) authentication and account access;\
(ii) security and fraud prevention;\
(iii) session management;\
(iv) network management.\
These Cookies do not require your consent;\
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11.3.2. functional Cookies allow the Platform to remember choices you make and provide enhanced functionality and personalization;\
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11.3.3. analytics Cookies enable us to analyze how users interact with the Platform, including usage patterns, performance, and diagnostics, in order to improve our services;\
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11.3.4. marketing Cookies may be used to deliver relevant content, measure effectiveness, and support marketing and advertising activities;\
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11.4. We use Cookies in accordance with applicable data protection and electronic communications laws:\
(i) strictly necessary Cookies are processed on the basis of legitimate interests and/or necessity to provide the Platform;\
(ii) all other Cookies are used only where you have provided your consent.\
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11.5. You can control and manage Cookies through:\
(i) the Cookie consent tool available on the Platform;\
(ii) your browser settings, which allow you to block or delete Cookies.\
Please note that disabling certain Cookies may affect the functionality and availability of the Platform.\
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12\. CHANGES TO THIS PRIVACY POLICY\
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12.1. We may update or amend this Privacy Policy from time to time to reflect changes in our practices, legal or regulatory requirements, or the functionality of the Platform.\
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12.2. The updated version will be made available on the Platform and will indicate the date of the latest revision. Where required by Applicable Law, we will notify you of any material changes through appropriate communication channels.\
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12.3. Your continued use of the Platform following such updates constitutes your acknowledgement of the revised Privacy Policy.\
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13\. CONTACT US\
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13.1. If you have any questions regarding this Privacy Policy, or if you wish to exercise your rights in relation to your Personal Data, you may contact us via email <admin@pait.fi>.