This Privacy Policy (“Privacy Policy”) explains how your personal information is collected, used, stored, and protected. BETELGEUSE CORPORATION LTD (“Betelgeuse,” “we,” “our,” or “us”) is the operator of the Deffio mobile application (the “App”) and is primarily responsible for processing personal data related to your use of the App itself. 

The cryptocurrency wallet and exchange services (“VASP Services”) accessible through the App are provided by PELOTON SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (“Peloton”), a registered Virtual Asset Service Provider in Poland (VASP License: RDWW-1567). For personal data processed in connection with these VASP Services, including data collected for Know Your Customer (KYC) and Anti-Money Laundering (AML) purposes, Peloton acts as an independent data controller.

This Policy describes the data processing practices of Betelgeuse for the App and informs you about data processing conducted by Peloton for its VASP Services. Please also read the Terms of Use (the “Terms”), which describe the terms under which you use the Services. 

INFORMATION WE COLLECT

We receive or collect information when we operate and provide our Services, including when you install, access, or use our Services. 

INFORMATION YOU PROVIDE

Your Transactions. Your Network private key, which you utilize to access your funds and initiate transactions, is stored only on your own device. However, to facilitate your transactions and provide you with your account balance, we (Betelgeuse, in providing App Services, and Peloton, in providing VASP services) store the Network public key address associated with your Network private key. 

Information for VASP Services Provided by Peloton To use the VASP Services provided by Peloton, you will be required to provide certain personal information directly to Peloton or to Betelgeuse, which will securely transmit it to Peloton. This information is necessary for Peloton to comply with its legal and regulatory obligations, including customer identification (KYC) and anti-money laundering (AML) requirements. Such information includes, but is not limited to:

• full name 
• contact details (phone number, email, residence address) 
• date of birth 
• electronic identifiers (IP address, browser and operating system information, device fingerprint) 
• identity documents details (such as driver license, passport) 
• photographical images 
• banking details 
• employment details 
• information on transactions you make on our platform 
• information on sources of funds 
• other information you could provide us upon a request 

Customer Support. We (Betelgeuse) may collect additional information you may disclose to our customer support team. Peloton may also collect such information if your support request pertains to VASP Services.

AUTOMATICALLY COLLECTED INFORMATION

Metrics and Performance Data. We (Betelgeuse) may collect service-related, diagnostic, and performance information. This includes high-level information about your activity (such as how you use our Services and how you interact with others using our Services), and diagnostic, crash, website, and performance logs and reports. Device and Connection Information. We (Betelgeuse) may collect device-specific information when you install, access, or use our Services. This may include your IP address and, if you choose to allow push notifications, your device’s unique push token. Status Information. We (Betelgeuse) may collect information about your online status on our Services, such as when you last used our Services (your “last seen status”). 

HOW WE USE THE INFORMATION WE COLLECT

Betelgeuse uses your information primarily to operate, provide, improve, customize, support, and market the App Services. This includes using:

• Metrics and Performance Data to improve the App’s functionality. 
• Device and Connection Information for providing and securing the App Services. 
• Status Information related to your use of the App. 

PELOTON SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ uses the information you provide, particularly information listed under “Information for VASP Services Provided by Peloton,” for the following purposes:

• To provide the VASP Services and related customer support you request. 
• To comply with legal and regulatory obligations, including KYC, AML, and transaction monitoring requirements.
• To resolve disputes and troubleshoot problems related to VASP Services. 
• To prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted User Agreement related to VASP Services. 
• To customize, measure, and improve the VASP Services and the content and layout of our application related to VASP Services. 

Both Betelgeuse and Peloton may use your information to deliver targeted marketing and service update notices based on your communications preferences, where legally permissible, and to customize, measure, and improve the Services and the content and layout of our application. We will not use your information for purposes other than those purposes we have disclosed to you, without your permission. 

HOW WE SHARE INFORMATION WITH THIRD PARTIES

Sharing between Betelgeuse Corporation Ltd and Peloton: To enable the provision of the integrated Services, Betelgeuse and Peloton will share necessary information with each other. For example, Betelgeuse will transmit information you provide for VASP Services registration and KYC to Peloton. Peloton may provide Betelgeuse with information regarding the status of your VASP account or transactions to be displayed within the App. This sharing is conducted securely and only for the purposes outlined in this Privacy Policy and the Terms of Use.

We work with third-party providers to help us operate, provide, improve, customize, support, and market our Services. For example, we work with companies to distribute our apps, provide our infrastructure, delivery, and other systems. These providers may provide us information about you in certain circumstances; for example, app stores may provide us reports to help us diagnose and fix service issues. We may also share information with law enforcement, government officials, or other third parties when: We are compelled to do so by a subpoena, court order, or similar legal procedure; or We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Terms. Finally, we may share information with companies or other entities that we plan to merge with. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policy. 

DATA RETENTION

Please note that even if you delete your Wallet or addresses from the mobile application, uninstall mobile applications from your device, or request that your information be deleted, Betelgeuse and Peloton still may retain some information that you have provided. Specifically, Peloton is required by law (e.g., AML regulations) to retain personal data related to VASP Services, including KYC documentation and transaction records, for a legally prescribed period, even after you cease using the VASP Services. Betelgeuse will retain data related to App Services in accordance with its data retention policies and applicable laws to maintain our systems or to comply with the laws and regulations. 

DATA SECURITY

We are committed to making sure your information is protected in accordance with applicable laws and our data privacy policies. We work to protect the security of your personal information during transmission by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information and secure all connections with industry standard transport layer security. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk. 

CONDITIONS OF USE, NOTICES, CHANGES AND UPDATES TO PRIVACY NOTICE If you choose to use our App, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy, please contact us with a complete description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority. We reserve the right to update and revise this Privacy Notice at any time. We occasionally review this Privacy Notice to make sure it complies with applicable laws and conforms to changes in our business. If we do revise this Privacy Notice, we will update the “Effective Date” at the top of this page so that you can tell if it has changed since your last visit and will do our best to notify you. Please review this Privacy Notice regularly to ensure that you are aware of its terms. Any use after an amendment to our Privacy Notice constitutes your acceptance of the revised or amended terms. 

CONTACT US

If you have any questions about our Privacy Policy, please do not hesitate to contact us at [email protected]. 

LEGAL INFORMATION

Data Controller for App Services:

Company Name: BETELGEUSE CORPORATION LTD

Company Number: 14716123 Legal Address: 13 John Prince’s Street, 2nd Floor, London, England, W1G OJR 

Data Controller for VASP Services:

Company Name: PELOTON SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

Company Number (KRS): 0001132722

NIP: 8133922725

Legal Address: ul. Jana III Sobieskiego 17, 35-002 Rzeszów, Poland

If your query specifically relates to the processing of your personal data by Peloton for VASP Services, your query will be routed accordingly.