LEGAL / PRIVACY

Privacy Policy

Processing of personal data of ETTIA users and of the Ettios Platform

Version 1.0 (draft for review) · Effective from: [publication date]

1. Data controller

The controller of personal data is ETTIOS Sociedad Anónima, RUC N.° 80144462-4, domiciled at [Teniente Caballero López 1491, Asunción, Republic of Paraguay] (“ETTIOS”). Contact for privacy matters: [privacidad@ettiosblockchain.io]. [Data Protection Officer: name and contact, when designated.]

2. Scope

This Policy explains what personal data we process when a person visits www.ettiosblockchain.io, creates an account, completes identity verification, acquires or uses ETTIA, uses the Ettios wallet or communicates with us; for what purposes, with whom we share it and what rights they have.

3. Legal framework

We process data in accordance with the Constitution of the Republic of Paraguay (arts. 33 and 135), Law N.° 7593/2025 on Personal Data Protection, Law N.° 6534/2020 where applicable and, regarding persons located in other jurisdictions, the applicable mandatory regulations, including Regulation (EU) 2016/679 (GDPR) for residents of the European Economic Area.

4. Data we process

CategoryData
Identification and contactName, date of birth, nationality, document number and image, address, email, phone.
Verification (KYC/KYB)Photograph or liveness video, verification biometric data, proof of address, occupation, PEP status, data of representatives and ultimate beneficial owners.
Financial and operationsOrigin of funds, means of payment, wallet addresses, history of Operations, amounts.
TechnicalIP address, device and browser type, identifiers, access logs, approximate geolocation, cookies.
CommunicationsInquiries, claims and correspondence with support.
From third partiesResults of sanctions and PEP lists, blockchain analysis and public sources.

We do not request sensitive data other than the biometric data necessary to verify identity. We never request private keys or recovery phrases.

5. Purposes and legal bases

PurposeLegal basis
Create and manage the account; execute Operations; provide support.Performance of the contract.
Verify identity, prevent ML/TF and fraud, screen sanctions, report to authorities, keep records.Legal obligation.
Platform security, abuse prevention, service improvement and statistics.Legitimate interest.
Biometric verification.Express consent and legal identification obligation.
Sending news and commercial communications; non-essential cookies.Consent, revocable at any time.

6. Data on the blockchain

Transactions made on the Network (addresses, amounts, date and time) are public, permanent and immutable by design; ETTIOS cannot delete or alter them. We do not record names, documents or other direct identifying data on the chain. The link between an address and its holder's identity is kept off-chain, in our systems, and the rights under clause 11 may be exercised over that link.

7. Who we share data with

  • •

    Providers acting on our behalf: identity verification, on-chain analysis, hosting, messaging, payment processing and auditing, under confidentiality and security agreements: [list main providers].

  • •

    Competent authorities (including SEPRELAD, judicial authorities and supervisors), when required by law.

  • •

    Professional advisors and, in the event of reorganization, merger or transfer of the business, the successor entity, with the same guarantees.

We do not sell personal data.

8. International transfers

Some providers are located outside the data subject's country of residence. In such cases we apply appropriate safeguards (contractual clauses, countries with an adequate level of protection or consent, as appropriate).

9. Retention

We keep data while the relationship exists and, afterwards, for the legal periods: identification and Operations data, a minimum of [5] years in accordance with AML/CFT regulations; marketing data, until consent is revoked; technical logs, up to [12] months. Once the periods expire, the data is deleted or anonymized.

10. Security

We apply reasonable technical and organizational measures: encryption in transit and at rest, need-to-know access control, strong authentication, activity logging, security testing and staff training. In the event of an incident affecting personal data, we will notify the authority and the affected persons when the law requires it. No system is completely secure; the data subject must protect their credentials.

11. Data subject rights

The data subject may, free of charge: access their data; rectify or update it; request its deletion; object to processing or request its restriction; request portability; revoke consent; and not be subject to decisions based solely on automated processing that produce legal effects, being able to request human intervention.

To exercise them, write to [privacidad@ettiosblockchain.io] proving your identity. We will respond within [__] business days. Certain data may not be deleted while a legal retention obligation subsists. The data subject may also complain to the National Personal Data Protection Agency of Paraguay or to the supervisory authority of their place of residence.

12. Automated decisions

We use automated tools for identity verification, list screening and risk scoring. Rejections are reviewed by a person when the data subject requests it.

13. Cookies

We use essential cookies for the operation and security of the site and, with consent, analytics cookies. The user can configure them from the site banner or from their browser: [link Cookie Policy, if published separately].

14. Minors

The services are directed exclusively to persons over 18 years of age. We do not knowingly process data of minors; if we detect any, we will delete it.

15. Changes to this Policy

We may update this Policy. We will publish the new version with its date and, if the changes are substantial, we will notify by email or by prominent notice on the Platform.

16. Contact

ETTIOS Sociedad Anónima · [Teniente Caballero López 1491, Asunción, Paraguay] · [privacidad@ettiosblockchain.io] · www.ettiosblockchain.io

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