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Privacy Policy

Effective date: September 13, 2025

This Privacy Policy explains how Poly Coin Ltd. (“Poly Coin,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you access or use our websites, mobile or web applications, merchant tools, and related services (the “Services”). By using the Services, you agree to the practices described here. If you do not agree, please do not use the Services.

1. Information We Collect

1.1 Information you provide

  • Account details: name, email, phone number, password or passcode hints.
  • Profile & preferences: language, communication choices.
  • Support messages: content of messages you send to us, including attachments you choose to share.

1.2 Transactional information

  • Change transfers: date/time, merchant, lane/device metadata, amounts (local currency and USD), and associated fees or exchange rates.
  • USD Credits activity: issuance, balance, adjustments, reversals, expiration, and spending with participating partners or other redemption options (e.g., where offered, third-party e-gift cards).

1.3 Device & usage data

  • IP address, device type, OS, browser, app version, and diagnostic logs.
  • Interaction data: pages viewed, buttons tapped, time on page, crash reports, and performance metrics.

1.4 Cookies, local storage, and similar technologies

  • We use cookies/local storage to keep you signed in, remember preferences, measure usage, and secure sessions.
  • You can control cookies via your browser settings. Some features may not function without them.

1.5 Information from third parties

  • Partners and payment processors: confirmations of Credits issuance/redemption, settlement, fraud/risk signals.
  • Merchants: till/lane metadata tied to your change transfer and reconciliation.
  • Service providers: analytics, crash reporting, communications, hosting, and customer support tools.

2. How We Use Information

  • Provide the Services: process change transfers, issue/manage USD Credits, display balances/history, enable spending with partners and other redemption options.
  • Maintain security: detect, investigate, and prevent fraud, abuse, or prohibited conduct.
  • Improve and personalize: analyze usage, fix bugs, and enhance user experience.
  • Communicate with you: send confirmations, receipts, support responses, service updates, and important notices.
  • Legal compliance: meet regulatory and tax obligations, and respond to lawful requests.

3. SMS and Email Communications

We may send transactional SMS or emails (e.g., verification codes, receipts, security alerts). Message and data rates may apply. You can opt out of non-essential marketing messages at any time using provided instructions. We may still send essential service or security communications.

4. Legal Bases (where applicable)

Where a legal basis is required, we process personal information under one or more of the following: to perform a contract with you; our legitimate interests (to provide, secure, and improve the Services); compliance with legal obligations; and with your consent (where obtained).

5. When We Share Information

  • Partners & payment processors: to issue/manage USD Credits, process payments, complete redemptions, and prevent fraud.
  • Merchants: to attribute change transfers, handle reversals, reconcile activity, and support customer service.
  • Service providers: vendors who help operate our Services (hosting, analytics, messaging, customer support). They must follow our instructions and protect your data.
  • For legal reasons: if required by law, subpoena, court order, or to protect rights, safety, or integrity of the Services.
  • Business transfers: in connection with a merger, acquisition, financing, or sale of assets. We will take steps to ensure continued protection.

6. International Data Transfers

We may process and store information in countries outside your own. Where required, we implement safeguards for cross-border transfers (such as contractual protections) to help ensure your information is adequately protected.

7. Data Retention

We retain personal information for as long as needed to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary based on the category of data, the purpose of processing, and applicable laws.

8. Security

We use technical and organizational measures designed to protect personal information, including encryption in transit, access controls, and event auditing. No method of transmission or storage is completely secure; we cannot guarantee absolute security of your information.

9. Your Choices and Rights

  • Access & correction: you may access and update certain information in your account settings or by contacting us.
  • Deletion: you may request deletion of certain information, subject to legal or operational retention requirements.
  • Marketing preferences: unsubscribe from promotional emails or SMS as instructed in those messages.
  • Cookies: manage cookie preferences in your browser. Disabling cookies may impact functionality.
  • Regional rights: depending on your location, you may have additional rights (e.g., to object or restrict processing, data portability). We will honor valid requests as required by applicable law.

10. Children’s Privacy

The Services are not directed to children, and we do not knowingly collect personal information from children. If you believe a child has provided us personal information, please contact us so we can take appropriate action.

11. Third-Party Services and Links

Our Services may reference or integrate third-party services (e.g., partners who accept Credits, payment processors, analytics). Their handling of personal information is governed by their own policies. We are not responsible for the privacy practices of third parties.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be indicated by an updated “Effective date” above. Your continued use of the Services after changes become effective constitutes acceptance of the updated Policy.

13. Contact Us

Poly Coin Ltd.
Email: support@poly-coin.com
Time zone for notices: America/Port_of_Spain (GMT-4)