PolyWin Privacy Policy

This Privacy Policy explains how Polywin LTD collects, uses, processes, shares and protects information in connection with the PolyWin website, mobile applications, protocols and related services.

Data Controller: Polywin LTD
Place of Registration: British Virgin Islands
Privacy Contact: business@polywin.me

1. Information We May Collect

Depending on how the Services are used, we may process the following categories of information.

Account information

• email addresses
• usernames
• UIDs
• authentication information
• settings and preferences

Device and network information

• IP address
• device type
• operating system
• browser
• App version
• language
• network information
• approximate geographic location

Usage information

• login history
• page visits
• feature usage
• interactions
• error logs
• performance data
• security records

Transaction and blockchain information

• wallet addresses
• blockchain networks
• transaction hashes
• digital assets
• transaction amounts
• smart-contract interactions
• settlement-related information

Compliance and risk information

• determining physical location
• implementing geographic restrictions
• determining eligibility
• fraud prevention
• anomaly detection
• legal and regulatory obligations

Communications

• emails
• support communications
• support requests
• feedback
• attachments or other submitted information

2. How We Use Information

• provide and maintain PolyWin
• create and manage accounts
• provide trading and settlement functionality
• provide wallet and digital-asset features
• process smart-contract and blockchain interactions
• determine geographic and service eligibility
• implement security and risk controls
• prevent fraud and abuse
• detect network and technical issues
• improve products and user experience
• provide customer support
• comply with legal and regulatory obligations
• establish and protect lawful rights

3. Current Blockchain Network

As of the Last Updated date, relevant public on-chain activity associated with PolyWin primarily operates and is recorded on the Polygon network.

PolyWin Chain has not yet launched on mainnet. The current target mainnet launch date is September 30, 2026.

Following mainnet launch, certain on-chain activity may progressively migrate to or be recorded on PolyWin Chain.

4. Public Blockchain Information

Public blockchains are transparent, verifiable and generally immutable. Once a blockchain transaction is confirmed, wallet addresses, transaction hashes, assets, amounts, timestamps, smart-contract interactions and other public blockchain information may remain publicly accessible.

PolyWin generally cannot delete, hide or alter information confirmed on a public blockchain.

5. Geographic Information

PolyWin may use IP addresses, device information, network information, account information and other reasonably necessary technical information to determine current location and service eligibility.

This may be used to implement geographic restrictions, prevent circumvention, detect fraud and satisfy compliance obligations. Users must not use VPNs, proxies or location spoofing to circumvent geographic restrictions.

6. Cookies and Similar Technologies

PolyWin may use necessary cookies, local storage and similar technologies to maintain sessions, remember basic preferences, improve security, detect errors and improve performance.

Where required by applicable law, non-essential technologies requiring consent will be handled in accordance with applicable requirements.

7. Sharing of Information

Where reasonably necessary to operate and protect PolyWin, information may be shared with categories of providers including:

• cloud infrastructure providers
• network service providers
• blockchain and node infrastructure providers
• data and market-information providers
• cybersecurity providers
• analytics and performance providers
• wallet or digital-asset infrastructure providers
• compliance and risk-management providers
• legal, audit and professional advisers

Such third parties should process information only to the extent necessary to provide the relevant services or satisfy applicable obligations.

8. Legal Disclosure

PolyWin may disclose information where required by applicable law, court order, lawful regulatory request, law-enforcement request or other legally valid process, including to comply with law, prevent fraud, handle security incidents and protect lawful rights.

9. Security

PolyWin uses reasonable technical and organizational measures designed to protect information, including access controls, data isolation, logging, monitoring, anomaly detection, infrastructure security and other appropriate safeguards.

No internet, mobile, software or blockchain system can guarantee absolute security.

10. Retention

Information is retained only for as long as reasonably necessary for service provision, account management, legal obligations, compliance, risk management, security investigations, fraud prevention, dispute handling, record keeping and protection of lawful rights.

Public blockchain information may remain permanently available on the applicable blockchain.

11. International Processing

Polywin LTD is registered in the British Virgin Islands. PolyWin users, infrastructure and service providers may be located in multiple jurisdictions, and information may therefore be processed outside the user's country or region.

Where required by applicable law, reasonable measures will be used to protect internationally processed information.

12. User Rights

Depending on applicable data-protection law, users may have some or all of the following rights:

• access personal information
• correct inaccurate information
• request deletion of eligible information
• restrict processing
• object to certain processing
• receive copies of data
• request data portability
• withdraw consent where processing is consent-based

Such rights may be subject to legal retention requirements, risk and security requirements, compliance obligations, blockchain immutability and other lawful limitations. Requests may be sent to:

business@polywin.me

13. Minors

PolyWin is not intended for persons under 18 years of age. Where applicable law requires a higher minimum age, that higher age applies. PolyWin may take appropriate measures where it reasonably determines that a person does not meet the age requirement.

14. Third-Party Services

PolyWin may contain or rely on independent third-party services. Those parties may operate under their own terms, privacy policies, cookie policies and data-processing practices. PolyWin does not control their data-processing conduct.

15. Changes

This Privacy Policy may be updated due to product developments, PolyWin Chain deployment, technical changes, legal requirements, regulatory developments or changes in data-processing activities. Material updates may be communicated through the website, App or other reasonable methods.

16. Contact

business@polywin.me
Data Controller: Polywin LTD
British Virgin Islands