# Privacy Policy

### Overview

This Privacy Policy explains how **Unipay Pte. Ltd.** ("**Unipay**," "**we,**" "**our,**" or "**us**") collects, uses, discloses, and protects information when you access or use our websites, dashboards, APIs, smart‑contract interfaces, documentation, or any other online product or service linked to this policy (collectively, the **"Services"**).

> **Key Tokens**
>
> * **USDu** — dollar‑referenced stablecoin issued via the Unitas smart contracts.
> * **sUSDu** — staked yield‑bearing derivative of USDu.

***

#### 1. Scope

This policy applies to Personal Data processed by Unipay when you:

1. Visit our sites or social media pages;
2. Access dashboards, developer portals, or APIs;
3. Mint, stake, redeem, or otherwise interact with USDu and sUSDu via our UIs;
4. Join community calls, events, or surveys;
5. Contact us directly.

It **does not** apply to third‑party wallets, dApps, or websites that integrate with Unitas.

#### 2. Information We Collect

| Category                     | Examples                                                                 | Purpose                                            |
| ---------------------------- | ------------------------------------------------------------------------ | -------------------------------------------------- |
| Wallet Data                  | Public blockchain address, on‑chain transactions                         | Core functionality, analytics, fraud detection     |
| KYC/AML Data (when required) | Name, DOB, nationality, government ID, proof of address, source‑of‑funds | Regulatory compliance                              |
| Contact Data                 | Email address, social‑media handle                                       | Support, service notices, marketing (with consent) |
| Usage Data                   | IP, browser, device ID, pages visited, cookies                           | Site analytics, performance, security              |
| Communications               | Support tickets, survey responses                                        | Customer service, product improvement              |

#### 3. How We Use Data

* Operate and maintain the Services;
* Comply with legal obligations (KYC/AML, sanctions, tax);
* Protect security and integrity, prevent fraud;
* Communicate with you (support, updates, technical notices);
* Improve and develop new features;
* Market our Services with appropriate consent.

#### 4. Legal Bases (GDPR‑style)

* Contractual necessity
* Legal obligation
* Legitimate interests (not overridden by your rights)
* Consent (for optional marketing)

#### 5. Sharing & Disclosure

We **do not sell** Personal Data. We share only:

1. With vetted service providers (cloud, KYC vendors, analytics);
2. Within the Unipay corporate group;
3. To comply with law or valid legal requests;
4. In a merger, acquisition, or asset sale (subject to confidentiality);
5. With your consent or at your direction.

#### 6. International Transfers

Data may be transferred to jurisdictions such as Singapore, the United States, or others where our providers operate, protected by lawful transfer mechanisms (e.g., SCCs).

#### 7. Security

We employ encryption in transit, access controls, routine audits, and vendor due diligence. No system is 100 % secure.

#### 8. Retention

Personal Data is kept only as long as necessary, including to meet legal and accounting requirements (e.g., AML laws may mandate 5‑10 years).

#### 9. Your Rights

Depending on your jurisdiction, you may request access, correction, deletion, restriction, portability, or object to certain processing. Withdraw consent anytime. Email us to exercise rights.

#### 10. Children

Services are not directed to minors under 18. We do not knowingly collect data from children.

#### 11. Changes

We may update this policy. Material changes will be posted here. Continued use after the effective date constitutes acceptance.

#### 12. Contact

**Email: <legal@unipay.fi>**


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