Privacy Policy

1. Information We Collect

We collect limited personal information necessary to operate our Platform and ensure regulatory compliance:

• KYC Information: When required by law or our partners, you may be asked to provide identification documents, selfies, or proof of address. This data is collected and stored by our regulated third-party provider Sumsub.
• Wallet Address & Activity: We collect your wallet address when you connect a wallet to our Platform. We may also analyze public blockchain data for compliance monitoring.
• Basic Identifiers: Email address (if provided), country of residence, and transaction metadata.
• Usage Data: Log files, IP address, browser type, referral pages, and interactions with the Platform.
• Cookies: We use cookies and similar technologies to improve user experience, analyze traffic, and support compliance. See Section 9 below.

2. Use of Information

We use the collected information for the following purposes:

• To operate and maintain the Platform
• To facilitate identity verification via Sumsub
• To fulfill regulatory obligations (e.g., AML/CTF compliance, sanctions screening)
• To process transactions via our regulated partners (e.g., Unblock)
• To improve user experience and detect suspicious activity
• To communicate with users about service issues or updates

We do not sell or rent your personal data.

We also do not use personal data collected through the Platform for training, fine-tuning, or developing artificial intelligence or machine learning models. Should we ever wish to do so in the future, we will request your explicit, informed, and opt-in consent before such use.

3. Sharing of Information

We disclose information only to trusted, regulated partners to fulfill our services:

• Sumsub: Our KYC/AML provider. Your personal identity documents and verification data are collected and stored securely by Sumsub. View their Privacy Policy and Terms of Use.
• Unblock: If you choose to use Unblock's fiat on-ramp/off-ramp services via our Platform, your KYC token (generated by Sumsub) will be securely shared with Unblock to meet their regulatory compliance needs. By using these services, you agree to Unblock's Privacy Policy, Unblock Terms of Use, and EPMAP Terms and Conditions.
• Regulated partners: We rely on licensed partners to handle travel rule messaging, blockchain monitoring, and sanctions enforcement.
• Service Providers: Hosting, analytics, customer support, and IT infrastructure vendors.
• Authorities: Where required by legal or regulatory obligation.

We do not allow our partners to use your data for their own marketing or unrelated purposes.

4. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy or comply with legal obligations.

We apply the following retention periods:

• KYC Data: 5 years after the relationship ends.
• Wallet Data: Up to 7 years.
• Usage Logs: 12 months.
• Basic Identifiers (e.g., email): Account duration + 2 years.

5. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access and review your personal data
• Request deletion or correction
• Object to certain processing activities
• Lodge complaints with data protection authorities

You may exercise these rights by contacting us directly at support@gyzernetwork.com

6. Data Security

We use industry-standard measures to protect your personal data from unauthorized access, disclosure, or destruction. However, no internet-based system is 100% secure, and you assume risk associated with use of the Platform.

7. International Data Transfers

Your information may be transferred to and processed in countries outside your own. Where applicable, we rely on contractual safeguards, adequacy decisions, or regulatory frameworks to ensure lawful transfers (e.g., EU Standard Contractual Clauses).

8. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors.

9. Cookies & Tracking Technologies

We use cookies and similar technologies for:

• Authentication and session management
• Analytics and user experience improvement
• Fraud prevention and security

You can control cookie settings in your browser. If required by local law (e.g., GDPR), we will obtain consent via a cookie banner.

10. Risks of Crypto Use

You acknowledge the following risks:

• Volatility: Crypto prices fluctuate rapidly
• Irreversibility: Blockchain transactions cannot be reversed
• Technical Risk: Wallet loss, phishing, or smart contract errors
• Regulatory Risk: Legal status of crypto assets may vary by region

You assume full responsibility for your crypto-related decisions and activities.

11. Jurisdiction-Specific Disclosures

• EU/EEA: We rely on lawful bases under the GDPR, including legitimate interests and legal compliance. You have the right to data portability, access, and erasure.
• UK: This policy aligns with UK GDPR requirements. No personal data is processed for unsolicited marketing.
• U.S.: We are not a financial institution under GLBA. California residents may have additional rights under the CCPA/CPRA.
• Singapore: We follow PDPA guidelines and process personal data only where lawful and reasonable.
• UAE: Data is processed by third-party providers compliant with UAE standards. We do not locally store sensitive identifiers.
• Canada: We comply with PIPEDA. You have the right to access your personal data held by us.

We do not conduct profiling or automated decision-making.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a new effective date. Continued use of the Platform signifies your acceptance.

For material changes (including any new uses of your data, such as AI training), we will provide direct notice to you (via email or prominent in-app notification) and request your affirmative consent before applying the changes.

13. Contact Us

If you have questions or concerns, contact us at: support@gyzernetwork.com

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