Privacy Policy

This Privacy Policy is designed to help you understand how Dinara Technologies, Inc. (“Dinara,” “we,” “us,” or “our”), collects, uses, processes, and shares your personal information, and to help youmunderstand and exercise your privacy rights.


1. SCOPE OF THIS PRIVACY POLICY
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. RETENTION OF PERSONAL INFORMATION
8. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
9. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
10. CHILDREN’S INFORMATION
11. OTHER PROVISIONS
12. CONTACT US

1.             SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our website, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our website, mobile application, and other offerings are collectively called the “Services.” Our Services relate to business-to-business digital asset and fiat currency management and related services and are not intended or applicable for individual’s personal use and are for enterprise use only.

 

An Important Note regarding Blockchain Technologies: If you use our Services relating to the creation, management, participation, or operation of a transaction on a blockchain, such as for use with cryptocurrencies, smart contracts will be employed that necessarily collect information, such as your digital wallet address (which some legal jurisdictions may consider personal information) or other information that could relate to an individual person, and that information will be stored on a public blockchain ledger that we do not control. A smart contract is computer code that automatically processes events when certain conditions are met; for example, when cryptocurrency is to be added to a digital wallet, a smart contract will automatically execute the proposed action when certain conditions are met (for example, if two people agree to exchange an amount of cryptocurrency from one wallet to another). In these situations, your personal information may be stored on that blockchain through the execution of a smart contract and may not be able to be modified or deleted due to the immutable nature of the blockchain.  

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2.    PERSONAL INFORMATION WE COLLECT

Personal information that we collect includes informationabout an individual from which that person can be identified, but does notinclude data where the identity has been removed (anonymous data). The categories of personal information we collect depend on how youinteract with us, our Services, and the requirements of applicable law. Wecollect information that you provide to us, information we obtain automaticallywhen you use our Services, and information from other sources such asthird-party services and organizations, as described below.

 

A.    Personal Information You Provide to Us Directly

 

We may collect personal information that you provide to us.

Account Creation and Administration. We may collect personal information from you in connection with the administration of your account. This personal information may include, but is not limited to, your name, date of birth, age, nationality, country of residence, gender, occupation, signature, professional details, photographs, video footage, phone number, home address, email address, government issued identification such as passport, driver’s license, national identification card with photograph, tax identification number, social security number, visa information and/or any other information deemed necessary to comply with our legal obligations under anti-money laundering and counter terrorism financing laws and procedures.

Transactional Information. We may collect personal information and details associated with your transactions including, but not limited to, information about the transactions you make using the Services, the purpose of the transactions, information on sources of your funds, sender and receiver of funds, and ultimate beneficiary information.

Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

B.    Personal Information Collected Automatically

 

We may collect personal information automatically when you use our Services. This includes information about how you use the Services and Technical Data about your equipment, browsing actions and patterns. “Technical Data” includes your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address) Internet service provider, operating system and platform and other technology on the devices you use to access the Services. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.

We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. [Please see our Cookie Policy for further details.]

 

C.   PersonalInformation Collected from Other Sources

 

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

 

Credit Bureaus and ID Verification Partners. We may obtain personal information about youfrom credit bureaus and identity verification partners.

BlockchainInformation. We may obtain personal information about youthrough our analysis of blockchain information.

3.    HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes,including to provide our Services, for administrative purposes, and to marketour products and Services, as described below.

 

A.    Provide Our Services

 

We use your information to fulfil our contract with you and provide you with our Services, such as:

• Managing your information and accounts;

• Facilitating the on-ramp and off-ramp Services for the currencies you request;

• Providing access to certain areas, functionalities, and features of our Services;

• Answering requests for customer or technical support;

• Communicating with you about your account, activities on our Services, and policy changes;

• Processing your financial information and other payment methods for products or Services purchased;

• Processing applications if you apply for a job we post on our Services; and

• Allowing you to register for events.

B.    Administrative Purposes

 

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

• Measuring interest and engagement in our Services;

• Improving, upgrading, or enhancing our Services;

• Developing new products and services;

• Ensuring internal quality control and safety;

• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;

• Debugging to identify and repair errors with our Services;

• Auditing relating to interactions, transactions, and other compliance activities;

• Sharing personal information with third parties as needed to provide the Services;

• Enforcing our agreements and policies; and

• Carrying out activities that are required to comply with our legal obligations.

C.    Operational Purposes

 

Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

 

o  Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.

 

o  Pixel Tags/Web Beacons. A pixel tag(also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

 

We use your information and Technical Data collected through these Technologies for various operational purposes and uses that fall into the following general categories:

 

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;

Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);

Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools, such as Google Analytics, to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services.

Biometric Information. If you consent to our collection of biometric information or if our collection of biometric information is otherwise permitted, you agree that we may use facial recognition technology to extract biometric information contained in facial images that you provide to the Services. For example, we may compare the face on your government-issued photo ID against a selfie that you provide to us. We use this biometric information for identity verification and fraud prevention. This information may be shared with our service providers to facilitate these purposes. Where required by law, we will delete your biometric information within three years from your last interaction with the Services.

 

D.    Marketing and Advertising our Products andServices

 

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted byapplicable law.

 

Someof the ways we market to you include email campaigns, custom audiences advertising,and “interest-based” or “personalized advertising,” including throughcross-device tracking.

 

Ifyou have any questions about our marketing practices, you may contact us at anytime as set forth in “Contact Us” below.

 

E.    Other Purposes

 

We also collect, use, and share your personal information for other purposes as requested by you or as permitted by applicable law.

 

With Your Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

 

De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create. This is not considered personal information as it does not directly or indirectly reveal your identity.

4.    HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

 

A.    Disclosures to Provide our Services

 

The categories of third parties with whom wemay share your personal information are described below.

 

Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services and the improvement of the Services’ functionality. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

 

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

 

Verification Partners. We may provide an opportunity through our Services to share your personal information, such as your selfie photos or government identification, with our verification partners to verify your identity to use portions of our Services and to comply with our legal obligations. In these instances, we will notify you when you are going to provide personal information to our Verification Partners for this purpose.

 

Third-Party Services. Certain features and functionalities of the Services may link to or allow you to interface, interact, or share information with, access and/or use third-party websites, services, products, and technology (collectively, “Third-Party Services”). For example, you may use the Services to interact with Third-Party Services such as bank partners, financial institutions, cryptocurrency exchanges, etc. Any information disclosed to or otherwise collected by a Third-Party Service may be subject to the Third-Party Service’s privacy policy. We do not provide or control any aspect of the Third-Party Services and are not responsible for any compatibility issues, errors or bugs in the Services or Third-Party Services caused in whole or in part by the Third-Party Services or any update or upgrade thereto. We encourage our users to read the privacy policies of each Third-Party Service with which theyinteract. We are not responsible for such Third-Party Services. Providing information to or interacting with Third-Party Services is at your own risk.

 

Affiliates. We may share your personal information with our company affiliates.

 

Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

 

APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

 

B.    Disclosures to Protect Us or Others

 

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

 

C.    Disclosure in the Event of Merger, Sale, or Other Asset Transfers

 

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5.    YOUR PRIVACY CHOICES AND RIGHTS

 

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

 

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

 

•  Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

 

•  “Do Not Track. Do Not Track (“DNT”)is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

•  Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

 

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance.

Please note you must separately opt out in each browser and on each device.

 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

 

•  Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);

 

•  Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;

 

•  Request Deletion of your personal information;

 

Request Restriction of or Object to our processing of your personal information; and

 

•  Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal

 

If you would like to exercise any of these rights, please contact us asset forth in “Contact Us” below. We will processsuch requests in accordance with applicable laws.

6.    SECURITY OF YOUR INFORMATION

 

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7.    RETENTION OF PERSONAL INFORMATION

 

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s)for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.  

 

8.    SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

 

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Dinara has collected about them, and whether Dinara disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding twelve months. California residents can find this information below:

Category   of Personal Information Collected by Dinara

Category   of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers  

• Service providers

• Business partners

• Verification Partners

• Third-Party Services you share or interact with

• Affiliates

• Advertising partners

Personal  information categories listed in the California Customer Records statute  (Cal. Civ. Code § 1798.80(e))

• Service providers

• Verification Partners

• Business partners

• Third-Party Services you share or interact with

• Affiliates

Protected  classification characteristics under California or federal law

• Service providers

• Verification Partners

• Business partners

• Third-Party Services you share or interact with

• Affiliates

Commercial  information

• Service providers

• Third-Party Services you share or interact with

• Affiliates

• Advertising partners

Biometric  information

• Service providers

• Verification Partners

• Affiliates

Internet  or other electronic network activity

• Service providers

• Third-Party Services you share or interact with

• Affiliates

• Advertising partners

Sensory  data

• Service providers

• Third-Party Services you share or interact with

• Affiliates

• Advertising partners

Inferences  drawn from other personal information to create a profile about a consumer

• Service providers

• Business partners

• Third-Party Services you share or interact with

• Affiliates

• Advertising partners

 

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

 

“Sales” of Personal Information under the CCPA

 

For purposes of the CCPA, Dinara does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

 

Additional Privacy Rights for California Residents

 

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

 

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent and contact us as set forth in “ContactUs” below for additional instructions.

 

Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling your request. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, or to answer questions regarding your account and use of our Services.

 

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

 

9.    SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS


If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

 

10.    CHILDREN’S INFORMATION


The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you have any questions, please contact us as set forth in Contact Us below.

 

11.    OTHER PROVISIONS

 

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. Any personal information you choose to give to unrelated third parties is not covered by our Privacy Policy. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

 

12.    CONTACT US

 

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at regulatory@dinara.com.

 

 

Last Updated: October 10, 2022