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.

Open Banking (on-ramp), off-ramp, and bank-to-bank transfer services (“Payment Services”) accessible through the App are provided by CAPITOLIO INC. (“Capitolio”), FINTRAC MSB No. M24928320, Canada. For personal data processed in connection with Payment Services, including data collected for KYC and AML/CTF purposes under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), Capitolio acts as an independent data processor and/or controller. Deffio does not process fiat funds and does not act as data controller for Payment Services data.

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 and by Capitolio Inc. for its Payment Services. Please also read the Terms of Use, 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 is stored only on your own device. 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 KYC and 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 

Information for Payment Services Provided by Capitolio Inc. To use the Payment Services provided by Capitolio Inc., you may be required to provide certain personal information directly to Capitolio Inc. or via the App, which will securely transmit it to Capitolio Inc. This information is necessary for Capitolio Inc. to comply with its AML/CTF obligations under PCMLTFA. Such information may include, but is not limited to:

•     full name
•     email address
•     bank account details (IBAN, BIC/SWIFT, account holder name)
•     source wallet address and transaction details
•     source of funds information where required by applicable regulations

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, including high-level information about your activity 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, including 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.

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. 

CAPITOLIO INC. uses the information you provide in connection with Payment Services for the following purposes:

•     To provide the Payment Services (on-ramp, off-ramp, bank-to-bank transfers) you request.
•     To comply with AML/CTF obligations under PCMLTFA, including customer identification, transaction monitoring, and reporting to FINTRAC where required.
•     To prevent and investigate prohibited or illegal activities in connection with Payment Services.
•     To resolve disputes and troubleshoot problems related to Payment 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. 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.

Sharing with Capitolio Inc.: To enable the provision of Payment Services, Betelgeuse and/or Peloton will share necessary information with Capitolio Inc. The App will transmit bank account details, email address, wallet address, and transaction information required for on-ramp and off-ramp operations to Capitolio Inc. Capitolio Inc. may share transaction status information with Betelgeuse to be displayed within the App. This sharing is conducted securely and only for the purposes outlined in this Privacy Policy.

Capitolio Inc. may further share your data with its regulated partners and liquidity providers as necessary to execute Payment Services, and with FINTRAC or other Canadian regulatory authorities as required under PCMLTFA.

We work with third-party providers to help us operate, provide, improve, customize, support, and market our Services. We may also share information with law enforcement, government officials, or other third parties when compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that disclosure is necessary to prevent physical harm or financial loss or to report suspected illegal activity.

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.

Capitolio Inc. is required under PCMLTFA and FINTRAC guidelines to retain records related to Payment Services, including KYC documentation, transaction records, and AML screening results, for a minimum of 7 years from the date of the transaction or the end of the business relationship. Capitolio Inc. may retain data for longer periods if required by a competent Canadian regulatory authority.

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. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including 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.

Data Processor for Payment Services:

Company Name: CAPITOLIO INC.

FINTRAC MSB Registration No.: M24928320

Legal Address: 700-602 12 Ave SW, Calgary, Alberta, T2R 1J3, Canada

Capitolio Inc. processes personal data in connection with Payment Services as an independent data processor/controller subject to PCMLTFA and applicable Canadian privacy law (PIPEDA). If your query specifically relates to the processing of your personal data by Capitolio Inc. for Payment Services, your query will be routed accordingly.