Privacy Policy

Last Modified: April 11, 2026

This Privacy Policy (“Policy”) explains how SIVAX (“SIVAX,” “Company,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects information in connection with our website, applications, platform, and related services (collectively, the “Services”). This Policy operates together with our Terms of Service.

SIVAX is operated in connection with the laws of Panama, including applicable data protection requirements. Depending on how you use the Services, additional terms, disclosures, or consent requests may also apply.

1. Scope of This Policy

This Policy applies to information we collect when you:

• visit or use the Services

• connect a wallet to the Services

• submit information to us directly

• contact us for support or other inquiries

• interact with us through official communications, campaigns, or surveys

This Policy does not apply to third-party websites, wallets, protocols, exchanges, or services that we do not own or control.

2. Information We Collect

We may collect the following categories of information:

A. Wallet and blockchain-related information

When you connect a non-custodial wallet, we may collect your public wallet address and related publicly available blockchain data, such as transaction hashes, token balances visible on public ledgers, interaction timestamps, and other on-chain activity relevant to the Services. SIVAX’s current product flow is wallet-based and built around external wallet connection.

B. Information you provide directly

We may collect information you voluntarily provide to us, including:

• name or alias

• email address

• company or institutional affiliation, where relevant

• support messages, survey responses, and other communications

• any information you submit through forms or onboarding processes

C. Technical and usage information

When you access the Services, we may automatically collect certain technical data, such as:

• IP address

• browser type and version

• device type and operating system

• language and regional settings

• referring URLs

• access times, clickstream data, and pages viewed

• cookies and similar tracking data

D. Compliance and risk-review information

Where legally required or operationally necessary, we may collect or receive information used for fraud prevention, sanctions screening, AML review, cybersecurity monitoring, dispute handling, or other compliance-related purposes. This may include information from service providers, analytics vendors, security vendors, wallet-screening tools, or other third parties.

3. How We Use Information

We may use the information we collect for the following purposes:

• to provide, operate, maintain, and improve the Services

• to authenticate wallet connections and support product functionality

• to process subscriptions, redemptions, notifications, reporting, and related platform operations

• to personalize user experience and improve navigation and product usability

• to monitor performance, troubleshoot issues, and conduct analytics

• to detect, investigate, prevent, and respond to fraud, abuse, unauthorized access, security incidents, or illegal activity

• to comply with legal, regulatory, tax, audit, accounting, and enforcement obligations

• to communicate with you about your account, transactions, service updates, support requests, and important notices

• to enforce our Terms of Service and other contractual rights

• to create aggregated, de-identified, or anonymized insights where permitted by law

Where required by applicable law, we will rely on an appropriate legal basis for processing, including consent, performance of a contract, compliance with legal obligations, or legitimate business purposes permitted by law.

4. Cookies and Similar Technologies

We may use cookies, local storage, pixels, SDKs, and similar technologies to:

• keep the Services functional

• remember preferences and settings

• understand traffic and usage patterns

• improve performance and security

• support analytics and communications

You can manage certain cookie settings through your browser or device settings. Please note that disabling some cookies may affect the functionality of the Services.

5. How We Share Information

We do not sell your personal information.

We may share information in the following circumstances:

A. Service providers and infrastructure partners

We may share information with vendors, contractors, custodians, analytics providers, cloud providers, communications providers, security providers, wallet-screening providers, and other service providers who process information on our behalf and under appropriate safeguards.

B. Legal and regulatory compliance

We may disclose information if required to do so by applicable law, regulation, court order, subpoena, lawful request, or to cooperate with regulators, law enforcement, auditors, or competent authorities.

C. Security and protection of rights

We may disclose information where we believe it is necessary to investigate, prevent, or take action regarding suspected fraud, sanctions violations, money laundering, cyber threats, violations of our Terms, or harm to users, SIVAX, or others.

D. Corporate transactions

We may transfer information in connection with a merger, acquisition, restructuring, financing, sale of assets, bankruptcy, or similar transaction, subject to applicable legal requirements.

E. With your direction or consent

We may share information when you ask us to do so or otherwise give consent.

6. Blockchain and Public Ledger Notice

Certain elements of the Services may rely on public blockchain networks, including XRPL-related infrastructure. Information recorded on a public blockchain may be visible to others and may be difficult or impossible to delete, modify, or fully anonymize after publication.

Accordingly, while we may limit the personal data we directly collect and store, wallet addresses and blockchain transaction data associated with your use of the Services may remain publicly accessible on the relevant network.

7. International Data Transfers

Because we may use globally distributed infrastructure and service providers, your information may be processed or stored in jurisdictions other than your own, including jurisdictions that may not provide the same level of legal protection as your home jurisdiction.

Where required, we take commercially reasonable steps to implement appropriate safeguards for such transfers.

8. Data Retention

We retain information for as long as reasonably necessary to:

• provide the Services

• maintain business and operational records

• comply with legal, regulatory, tax, accounting, audit, and enforcement requirements

• resolve disputes

• enforce our agreements

Retention periods may vary depending on the type of information, the reason we collected it, and applicable legal obligations. Information may be retained longer where required for compliance, fraud prevention, or legitimate recordkeeping purposes.

9. Your Rights

Subject to applicable law, you may have the right to request:

• access to your personal data

• correction of inaccurate or incomplete personal data

• cancellation or deletion of certain personal data

• objection to certain processing

• withdrawal of consent where processing is based on consent

Under Panama’s data protection framework, individuals may have ARCO rights: Access, Rectification, Cancellation, and Opposition. These rights may be subject to legal exceptions, including where retention or processing is required for legal compliance, security, fraud prevention, or recordkeeping.

To exercise these rights, contact us using the details in the “Contact Us” section below. We may request additional information to verify your identity before responding.

10. Children’s Privacy

The Services are not directed to children, and we do not knowingly collect personal information from minors in violation of applicable law. If you believe that a child has provided personal information to us inappropriately, please contact us so we can review and take appropriate action.

11. Security

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction. However, no system, transmission method, or storage environment is completely secure.

You are responsible for maintaining the confidentiality and security of your wallet, private keys, devices, passwords, and authentication credentials. SIVAX does not control third-party wallets or blockchain networks and is not responsible for failures, exploits, or security incidents arising from them.

12. Third-Party Services

The Services may contain links to, or integrations with, third-party websites, wallets, custodians, exchanges, analytics providers, or other services. We are not responsible for the privacy, security, or data handling practices of those third parties. You should review their policies separately before using their services.

13. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we may provide notice through the Services or by other appropriate means. The “Last Modified” date at the top of this Policy indicates when this version became effective.

Your continued use of the Services after an updated Policy becomes effective constitutes acknowledgement of the revised Policy, to the extent permitted by law.

14. Contact Us

If you have any questions, requests, or concerns regarding this Policy or our handling of personal data, please contact us at:

[e-mail]