CYFND Privacy Statement

1. Who is responsible for your data

CYFND Digital Inc. is the data controller responsible for the processing described in this statement.

Registered office: East 55th Street, SL55 Building, 21st Floor, Office 3, Panama District, Panama Province, Republic of Panama.

Privacy contact: info@cyfnd.com

2. Personal data we process

Depending on how you interact with CYFND, we may process:

• Contact and application data: name, email address, country, contact-form subject and message, intended participation amount, application responses, and acknowledgments.
• Wallet and blockchain data: public wallet address, wallet signatures used to prove ownership, token eligibility status, and public transaction, payment, transfer, and distribution records.
• Identity and compliance results: identity-verification provider and session or applicant references, normalized verification status, jurisdiction and sanctions-screening results, review outcomes, timestamps, and audit events.
• Support and community data: support correspondence and, when you use CYFND Telegram services, Telegram user ID, username, display name, wallet linkage, and access events.
• Technical and security data: IP address, approximate country derived from network information, browser and device information, request metadata, security events, session information, and essential cookie or local-storage data.

CYFND does not ask for or store your seed phrase or private key. CYFND's platform databases do not store passport images, selfies, Social Security numbers, driver's-license images, full dates of birth, or other raw identity documents. An independent identity-verification provider may collect and process identity documents directly under the notice shown during verification.

3. Why we use personal data

We process personal data to:

• operate the website, application, accounts, support, and communications;
• confirm wallet ownership and maintain approved-wallet controls;
• assess eligibility, jurisdiction, KYC, anti-money-laundering, and sanctions requirements;
• process and verify purchases, payments, token delivery, transfers, and distributions;
• prevent fraud, abuse, account compromise, and other security threats;
• maintain records, investigate incidents, enforce terms, and meet legal, regulatory, audit, and compliance obligations; and
• improve reliability and understand how CYFND services are used.

Our legal bases may include your consent, steps requested before or in connection with a contract, performance of a contract, compliance with legal obligations, and legitimate interests such as securing and administering the services, where permitted by applicable law.

4. How we share personal data

We may share only the data reasonably necessary with service providers that support hosting, cybersecurity, identity verification and compliance screening, Solana blockchain and RPC access, email, Telegram and communications, analytics necessary to operate the service, and professional, legal, accounting, audit, or regulatory functions. We may also disclose data when required by law, to protect users or the services, or in connection with a corporate transaction subject to appropriate safeguards.

Public wallet addresses and on-chain transactions are visible on the Solana blockchain. They may be copied and processed independently by others, and blockchain records generally cannot be altered or deleted by CYFND.

CYFND does not sell personal data and does not use it for cross-context behavioral advertising.

5. Cookies and local storage

CYFND uses essential cookies, browser storage, and similar technologies for authentication, security, session continuity, abuse prevention, and language preferences. We may use limited operational measurement to maintain and improve the services. We do not use this information to sell personal data or serve cross-context behavioral advertising.

6. International processing

CYFND and its service providers may process data in countries other than the country where you live. Where required, we use contractual, organizational, and technical safeguards intended to protect data transferred across borders.

7. Retention

We keep personal data only for as long as reasonably necessary for the purposes described above and to satisfy applicable legal, regulatory, compliance, security, accounting, dispute-resolution, and audit requirements. Retention periods vary by record type. Raw identity documents are retained by the identity-verification provider, if collected, according to its own notice and legal obligations rather than in CYFND's platform databases. Public blockchain records are permanent or outside CYFND's ability to delete.

8. Security

We use administrative, technical, and organizational measures designed to protect personal data, including access controls, encrypted transport, security monitoring, wallet-signature verification, and restricted administrative access. No system is completely secure, so please contact us promptly if you believe your account, wallet linkage, or personal data may have been compromised.

9. Your privacy rights

Subject to applicable law and exceptions, you may request access to, rectification of, cancellation or deletion of, opposition to processing of, or portability of your personal data. You may also withdraw consent where consent is the legal basis. These are commonly known in Panama as ARCO rights, together with portability.

Send requests to info@cyfnd.com. We may need to verify your identity and authority before acting. We may retain information when required by law or where deletion is technically unavailable, including public blockchain records. You may also submit a complaint to Panama's National Authority for Transparency and Access to Information (ANTAI). See the ANTAI personal-data guidance.

10. Children

CYFND services are not directed to children. You must be at least 18 years old, or the higher age of legal capacity applicable where you live, to use participation features.

11. Other services and links

Third-party services, wallets, identity-verification providers, messaging platforms, and external sites have their own privacy notices. Review those notices before providing data directly to them. CYFND is not responsible for independent third-party privacy practices.

12. Changes to this statement

We may update this statement when our services, data practices, or legal obligations change. We will post the updated statement here and revise the effective date. Material changes may also be communicated through the application or another appropriate channel.