Bitrabo Limited (hereinafter referred to as "we", "us", "our", "Website", "App", "Bitrabo" or "Bitrabo Limited") respects the privacy of every individual who visits our website or uses our services. This Privacy Policy ("Policy") governs your use of the website located at www.bitrabo.com, the Bitrabo application (the "App"), and any services or products offered by Bitrabo (collectively, the "Services").

---

This Policy describes our practices regarding the collection, use, storage, and disclosure of information that identifies, relates to, or could reasonably be associated with you, your household, or your device ("Personal Data"). Personal Data does not include publicly available information from government records, deidentified or aggregated data, or information excluded from the scope of applicable data privacy laws, such as the General Data Protection Regulation (GDPR) or California Consumer Privacy Act (CCPA). By accessing or using the Services, you consent to our collection, use, and disclosure of your information as described in this Policy. If you do not agree with this Policy, you should not use the Services.

Important Notice Regarding the Bitrabo Wallet: The Bitrabo App includes a self-custody, non-custodial cryptocurrency wallet. Bitrabo does not collect, store, or have access to your Private Key, Recovery Phrase, Wallet PIN Code, Passphrase, or Keystore at any time. These credentials are generated on and stored exclusively on your device. The privacy practices in this Policy primarily relate to the Bitrabo Community Platform (app.bitrabo.com) and website, where personal account registration is required.

1. Information We Collect

We collect information to provide, personalize, and improve our Services. The types of information we collect depend on how you interact with our Services, and specifically whether you are using the non-custodial wallet component or the Community Platform. Below are the categories of Personal Data we have collected over the past 12 months:

Category	Examples	Collected?
A. Identifiers	Name, alias, email address, postal address, phone number, account username, IP address, device identifiers, or other similar identifiers. Note: Bitrabo does not collect Private Keys, Recovery Phrases, or Wallet PIN Codes.	Yes (Community Platform)
B. Protected Classifications	Race, sexual orientation, religion, disability, veteran status, or genetic information.	No
C. Commercial Information	Subscription details, services considered, or on-chain transaction records visible on public blockchains.	Limited
D. Biometric Information	Fingerprints, faceprints, voiceprints, iris scans, or health data. Note: Bitrabo does not collect biometric data. Biometric authentication (Face ID / Touch ID) is processed locally on your device only.	No
E. Internet or Network Activity	Browsing history, search history, interactions with websites or applications.	Yes
F. Geolocation Data	Approximate location based on IP address.	Yes
G. Sensory Data	Audio, visual, thermal, or olfactory information.	No
H. Professional or Employment Information	Job history or performance evaluations.	No
I. Non-Public Education Information	Education records under the Family Educational Rights and Privacy Act (FERPA).	No
J. Inferences	Profiles reflecting preferences, behaviors, or interests based on collected data.	Yes
K. Wallet Credential Data	Private Keys, Recovery Phrases, Wallet PIN Codes, Keystores, Passphrases.	Never

We collect Personal Data in the following ways:

• 1.1. Directly from You: When you provide information voluntarily, such as:

  • Creating or registering an account on the Community Platform (app.bitrabo.com).

  • Subscribing to newsletters, participating in surveys, contests, or promotions.

  • Contacting customer support or submitting inquiries via help.bitrabo.com.

  • Posting user-generated content, such as comments, reviews, or community posts.

  • Participating in the Bitrabo Rewards System.

• 1.2. Automatically: When you interact with our Services, we may collect:

  • IP address, browser type, device type, operating system, and settings.

  • Browsing behavior, such as pages visited, time spent, and links clicked.

  • Approximate geolocation based on IP address for location-based services and regulatory compliance.

  • Email interaction data (e.g., whether you opened or clicked an email).

  • Data collected via cookies, web beacons, or similar technologies (see Section 4).

  • App usage analytics, such as features accessed and session duration, to improve the Bitrabo App.

• 1.3. From Third Parties: We may receive information from:

  • Service providers, such as analytics, advertising, or payment processors.

  • Social media platforms, if you connect your account to our Services.

  • Business partners offering joint services or promotions.

• 1.4. What We Do Not Collect (Wallet): The non-custodial wallet component of the Bitrabo App is specifically designed so that Bitrabo does not collect or have access to:

  • Your Private Key

  • Your Recovery Phrase (seed phrase)

  • Your Wallet PIN Code

  • Your Keystore file

  • Your Passphrase

  • Your biometric data (Face ID or Touch ID are processed on-device only)

  • Optional Cloud Backup: If you choose to enable wallet backup, an encrypted version of your Keystore may be stored in your personal iCloud (iOS) or Google Drive (Android) account. This backup is encrypted with your Wallet PIN Code before leaving your device. Bitrabo does not have access to your cloud storage account or the backed-up data. The security of your cloud backup is governed by Apple's and Google's respective privacy policies, not this Policy. This feature is entirely optional and within your control.

  These items are generated on and stored exclusively on your device and are never transmitted to Bitrabo's servers.

You may choose not to provide certain information, but this may limit your access to some features of the Services, particularly the Community Platform.

2. How We Use Your Information

We use your information to operate, enhance, and personalize our Services. Specific purposes include:

• 2.1. Service Delivery: To manage accounts, process transactions, deliver content, and provide customer support.

• 2.2. Personalization: To tailor content, recommendations, and community features based on your interests and usage patterns.

• 2.3. Marketing and Communications: To send newsletters, promotional offers, or updates, with your consent where required.

• 2.4. Analytics and Improvement: To analyze usage trends, diagnose technical issues, and improve the functionality and user experience of our Services, including the Bitrabo App and Community Platform.

• 2.5. Security: To detect and prevent fraud, unauthorized access, or other illegal activities, including monitoring for sanctions compliance and access from restricted jurisdictions.

• 2.6. Legal Compliance: To comply with legal obligations, enforce our Terms and Conditions, or protect the rights, safety, or property of Bitrabo, our users, or third parties.

• 2.7. Reward System: To manage and administer our Bitrabo Rewards System, including tracking eligible activities and distributing Bitrabo Points.

• 2.8. App Functionality: To enable core wallet and DeFi features of the Bitrabo App, such as displaying asset balances, transaction history sourced from public blockchains, and market data from third-party providers.

• 2.9. Community Platform: To facilitate user interactions on the Community Platform, including account management, content moderation, and community notifications.

We rely on legal bases such as your consent, our legitimate interests, or contractual necessity to process your Personal Data, as permitted by applicable law.

3. Blockchain and On-Chain Data

You should be aware of the following regarding the public nature of blockchain technology:

• 3.1. Public Blockchain Data: All transactions broadcast to a blockchain network are recorded on a public, immutable, and decentralized ledger. Blockchain transaction data — including wallet addresses, transaction amounts, timestamps, and smart contract interactions — is publicly visible to anyone and is not controlled by Bitrabo. Bitrabo does not have the ability to delete, modify, or restrict access to on-chain transaction data.

• 3.2. Wallet Address Linking: If you publicly associate your wallet address with your identity (for example, on the Community Platform or on social media), third parties may be able to associate your on-chain activity with your identity. Bitrabo encourages you to be mindful of this when sharing wallet addresses publicly.

• 3.3. Transaction History Display: The Bitrabo App retrieves and displays your transaction history and asset balances by querying public blockchain data. This retrieval is performed to provide you with a convenient view of your on-chain activity and does not involve Bitrabo storing copies of your transaction history on its own servers beyond what is necessary to provide the Service.

• 3.4. DeFi and Third-Party Protocol Interactions: When you interact with decentralized protocols, DEXs, bridges, staking platforms, or perpetual futures protocols through the Bitrabo App, those interactions are recorded on the relevant blockchain and may be subject to the data practices of those third-party protocols. Bitrabo does not control the data practices of third-party smart contracts or protocols.

• 3.5. Third-Party Protocol Integrations: When you use certain third-party protocol integrations within the Bitrabo App, Bitrabo may receive compensation as part of the normal operation of the Services. Your trading activity and on-chain data in connection with such integrations is subject to the relevant protocol's own data practices. Bitrabo does not share your personal identity with third-party protocols beyond what is inherent to the blockchain transaction itself.

4. Disclosure of Your Information

We may share your Personal Data with the following parties under strict conditions:

• 4.1. Service Providers: With third-party vendors (e.g., hosting, analytics, payment processors, or email platforms) who process data on our behalf under data processing agreements that ensure confidentiality and compliance with applicable laws.

• 4.2. Affiliates: With our corporate affiliates, who are required to adhere to this Policy.

• 4.3. Advertisers: With advertising partners to deliver targeted ads, measure ad performance, or track conversions. You may opt out of such sharing by emailing [email protected].

• 4.4. Business Partners: With partners offering joint services or promotions, under agreements that protect your data.

• 4.5. Other Users: Information you post publicly on the Community Platform (e.g., comments, posts, profile information) may be visible to other users of the platform.

• 4.6. Legal Requirements: When required by law, court order, or government authority, or to protect our rights, safety, or property, or that of our users or others. This may include disclosures required by anti-money laundering laws, sanctions regulations, or other applicable legal obligations.

• 4.7. Business Transfers: In connection with a merger, acquisition, or asset sale, where your data may be transferred to a third party under equivalent privacy protections.

• 4.8. Anonymized Data: We may share aggregated or deidentified data that cannot reasonably identify you for analytics, research, or marketing purposes.

• 4.9. Third-Party Protocols: When you interact with third-party DeFi protocols, DEXs, bridge providers, or the Hyperliquid Perps protocol through the Bitrabo App, your wallet address and on-chain activity become visible to those protocols as part of the transaction process. This is inherent to how decentralized blockchain technology operates and is not a disclosure by Bitrabo.

We do not sell your Personal Data for monetary compensation, but certain sharing with advertising partners may be considered a "sale" under laws like the CCPA. You may opt out of such sharing as described in Section 11.

5. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar technologies to enhance your experience and collect usage data.

• 5.1. Types of Cookies:

  • Essential Cookies: Required for core functionality, such as maintaining user sessions or enabling secure transactions.

  • Performance Cookies: Collect data on site performance and user interactions to improve our Services.

  • Functional Cookies: Enable personalized features, such as remembering your preferences.

  • Advertising Cookies: Used by third-party advertisers to deliver targeted ads based on your interests.

• 5.2. Consent: We provide a cookie consent tool upon your first visit to our website, allowing you to manage preferences for non-essential cookies. You may also control cookies through your browser settings.

• 5.3. Opting Out: Disable cookies via your browser or opt out of targeted advertising at Google Ads Settings, Network Advertising Initiative, or Your Online Choices (EU). Note that disabling cookies may impact Service functionality.

• 5.4. Flash Cookies: Some features may use Flash cookies, which can be managed at Adobe Flash Player Settings.

• 5.5. Mobile App Analytics: The Bitrabo mobile application may use mobile analytics tools to collect anonymized data about app usage, crash reports, and performance metrics. This data is used solely to improve the app and does not include any wallet credential data.

For more information about cookies, visit www.aboutcookies.org.

6. Social Media Features and Widgets

Our Services may include social media features, such as "Like" or "Share" buttons for platforms like Facebook, Twitter, or LinkedIn. These features may collect your IP address, page visits, or set cookies to function properly. Your interactions with these features are governed by the privacy policies of the respective platforms. We are not responsible for their practices.

7. Third-Party Links and DApps

Our Services may contain links to third-party websites, decentralized applications (DApps), or services accessible through the Bitrabo DApp browser. We are not responsible for the privacy practices or content of any third party. We encourage you to review the privacy policies of any third-party service before sharing Personal Data or connecting your wallet. Interactions with third-party DApps through the Bitrabo App are governed by those DApps' own terms and privacy practices, not this Policy.

8. Security of Your Information

We implement industry-standard security measures to protect your Personal Data, including:

• 8.1. Encryption: Secure Socket Layer (SSL) and Transport Layer Security (TLS) for data transmission.

• 8.2. Access Controls: Limiting access to authorized personnel on a need-to-know basis.

• 8.3. Security Audits: Regular assessments to identify and mitigate vulnerabilities.

• 8.4. Non-Custodial Architecture: The Bitrabo wallet's non-custodial design means your most sensitive data — Private Keys and Recovery Phrases — never leaves your device and is never transmitted to or stored by Bitrabo. This is the strongest privacy and security protection we can offer for your wallet credentials.

No method of transmission or storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. If you believe your privacy has been breached in connection with our Services, please contact us immediately at [email protected].

9. Data Retention and Account Termination

We retain Personal Data only as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, or enforce agreements. Retention periods vary based on the data's purpose and legal requirements. For example:

• 9.1. Community Platform Account Data: Retained while your account is active and for a reasonable period thereafter to comply with legal or business needs.

• 9.2. Transaction Data: On-chain transaction data is permanently recorded on the relevant public blockchain and cannot be deleted by Bitrabo or any other party.

• 9.3. Support and Communication Data: Retained for the period necessary to resolve your inquiry and as required by law.

• 9.4. Anonymized Data: May be retained indefinitely for analytics purposes.

• 9.5. Wallet Data: Bitrabo does not retain your Private Key, Recovery Phrase, Wallet PIN Code, or Keystore. This data exists only on your device. Deleting the Bitrabo App does not automatically delete your wallet — your wallet continues to exist on the blockchain and can be accessed with your Recovery Phrase through any compatible application.

To close your Community Platform account, visit the account settings page or contact us at [email protected]. After account closure, we may retain certain data as required by law or for legitimate business purposes.

10. Advertising and Analytics Platforms

We use third-party platforms to deliver advertisements and analyze usage.

• 10.1. Google Ads: Used to serve targeted ads, which may track your browsing across sites. Opt out at https://adssettings.google.com/partnerads.

• 10.2. Google Analytics: Collects data on site usage. Opt out using the Google Analytics Opt-out Browser Add-on.

• 10.3. Other Platforms: Additional services may be used, disclosed via our cookie consent tool or this Policy.

Opting out of personalized ads does not eliminate all ads; you may see non-personalized ads. By using our Services, you consent to these technologies as described.

11. Your Data Protection Rights

Depending on your location, you have the following rights regarding your Personal Data that Bitrabo holds about you:

• 11.1. Right of Access: Request access to your Personal Data that Bitrabo holds.

• 11.2. Right to Rectification: Request correction of inaccurate or incomplete data.

• 11.3. Right to Erasure: Request deletion of your data, subject to legal exceptions. Please note that on-chain blockchain data cannot be deleted by Bitrabo or anyone else — this is a fundamental characteristic of blockchain technology.

• 11.4. Right to Restriction of Processing: Limit how we process your data under certain conditions.

• 11.5. Right to Data Portability: Receive your data in a structured, machine-readable format.

• 11.6. Right to Object: Object to processing for purposes like direct marketing.

• 11.7. Right to Withdraw Consent: Withdraw consent where processing is consent-based, without affecting the lawfulness of processing that occurred before withdrawal.

• 11.8. Right to Non-Discrimination: We will not discriminate against you for exercising these rights.

To exercise these rights, contact us at [email protected]. We may verify your identity and respond within legally required timeframes (e.g., 30 days for GDPR). EU residents may lodge complaints with their local data protection authority.

12. California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

• 12.1. Right to Know: Request details about the categories, sources, purposes, and recipients of your Personal Data.

• 12.2. Right to Delete: Request deletion, subject to exceptions.

• 12.3. Right to Opt-Out of Sale: Opt out of the "sale" of your Personal Data (e.g., sharing with advertisers). Email [email protected] to opt out.

• 12.4. Right to Non-Discrimination: We will not discriminate against you for exercising CCPA rights.

To exercise these rights, contact us at [email protected] or https://www.bitrabo.com/contact/. We will verify your identity and respond within 45 days, extendable by 45 days if needed.

13. EU GDPR — Additional Information for European Residents

For individuals located in the European Economic Area (EEA), United Kingdom, or Switzerland, we adhere to relevant and applicable EU data protection laws and provide the following additional information.

13.1. Legal Bases for Processing: We process Personal Data subject to the GDPR on one or more of the following legal bases:

• Legal obligation: To comply with applicable laws, regulations and legal obligations, including anti-money laundering requirements, sanctions compliance, fraud prevention, and responding to requests from public authorities.

• Contractual necessity: To comply with our contractual obligations to you under our Terms of Use, including to provide you with our Services and customer support.

• Consent: To provide and market our Services to you based on your consent. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

• Legitimate interest: To monitor usage of the Services, prevent fraud, conduct security checks, engage in direct marketing activities where permitted, and protect your rights. When we process your personal data for our legitimate interests, we consider and balance any potential impact on you and your rights under data protection laws.

13.2. European Residents' Rights: In addition to the rights in Section 11, European residents have the following rights under the GDPR:

• Right to Access and Rectification of Personal Data Bitrabo holds about you

• Right to Erasure (subject to limitations, including the inability to delete public blockchain data)

• Right to Restriction of Processing and Right to Object

• Right to Data Portability in a structured, electronic format

• Right to withdraw consent at any time

• Right to lodge a complaint with a supervisory data protection authority

13.3. Automated Decision-Making: We may engage in automated decision-making for purposes of risk and fraud detection, including restricting access from sanctioned jurisdictions. When we do, we implement suitable measures to safeguard your rights and freedoms, including the right to obtain human intervention and to contest a decision.

14. Children's Privacy

The wallet and DeFi features of the Bitrabo App are not intended for use by individuals under the age of 18. The Community Platform is not intended for individuals under the age of 16. We do not knowingly collect Personal Data from children below these age thresholds. If we discover such data has been collected, we will delete it promptly. Contact us at [email protected] if you believe we have collected such data.

15. International Data Transfers

Your Personal Data may be transferred to, stored, or processed in countries outside your residence, including Nigeria and the United States, where data protection laws may differ from those in your jurisdiction. We use safeguards such as Standard Contractual Clauses (SCCs) for transfers to non-adequate jurisdictions under GDPR. Our cloud providers (e.g., Amazon Web Services, Google Cloud) have data processing agreements compliant with applicable laws.

16. Do Not Track Signals

Some browsers transmit "Do Not Track" (DNT) signals. Our Services do not currently respond to DNT signals, as there is no industry-standard protocol. You may manage tracking preferences via our cookie consent tool or browser settings.

17. Changes to Our Privacy Policy

We may update this Policy to reflect changes in our practices, the Services we offer, or applicable legal requirements. We will notify you of material changes by posting the updated Policy on our website with a revised "Last Updated" date, or via email or in-app notification as required by law. Your continued use of the Services after such changes constitutes acceptance of the revised Policy.

18. Contact Us

For questions, concerns, or requests regarding this Policy or our data practices, contact us at:

• Email: [email protected]

• Help Center: https://help.bitrabo.com

• Website: https://www.bitrabo.com/contact/

By using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.