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Last updated: 12 August 2025

1. Main Terms

This Privacy Policy describes how Oikoumene Digital Corp. (“Company”, “we”, “us”, or “our”) processes personal information collected through the Sana Wallet application or affiliated platforms (the “Application”) in connection with the Sana Wallet Service (“Service”).

The Company may provide additional privacy policies for specific products or services. This Privacy Policy does not apply to third-party apps or services accessible through the Application. Please refer to their respective privacy policies.

Notice to European users: Individuals in the EEA, UK, or Switzerland may have additional rights. Contact us for details.

2. Personal Information We Collect

a. Information you provide to us

Personal information you may provide directly to us through the Application or otherwise includes:

  • Your full name
  • Your phone number
  • Your email address

3. Automatic Data Collection

We, our service providers, or partners may automatically log information such as:

  • Time zone and language
  • Device information (e.g., IMEI)
  • Cryptocurrency-related data (e.g., wallet address, public key)
  • Other data not specifically listed here, used as described in this Privacy Policy
  • Device usage and interaction data
  • Location data (if permitted)
  • Operating system details

4. How We Use Your Personal Information

a. Service delivery and operations

  • Provide and improve the Service
  • Personalize the Service
  • Communicate with you
  • Offer support

b. Service improvement and analytics

We analyze usage to improve the Service and understand user behavior.

c. Research and development

We use data to develop new products and improve existing ones.

d. Marketing

We may send personalized marketing communications. You can opt out.

e. Events, promotions and contests

  • Administer promotions and contests
  • Communicate about contests
  • Follow up after events

f. Compliance and protection

  • Comply with legal obligations
  • Protect rights and safety
  • Audit internal processes
  • Enforce terms of service
  • Prevent fraud and cyberattacks

Legal bases (GDPR): Consent, contract performance, legal compliance, or legitimate interest.

5. How We Share Your Personal Information

We may share your personal information with the following parties:

  • Affiliates
  • Service providers
  • Partners
  • Operating system providers
  • Developers
  • Business partners
  • Professional advisors
  • Authorities and law enforcement
  • Other users and the public (e.g., blockchain visibility)

6. Your Choices

a. Declining to provide information

Some services may not be available if required data is not provided.

b. Privacy settings

We may offer settings to control data collection and personalization.

Note: Third-party links and integrations are not endorsements. Review their privacy policies independently.

7. Security

We implement safeguards to protect your data. However, no system is 100% secure. We will notify affected parties in case of a breach as required by law.

8. International Data Transfer

Your data may be transferred to countries with different privacy laws. We apply safeguards such as contractual clauses or adequacy decisions.

9. Children

The Service is not intended for users under 18. If we collect data from a minor unlawfully, we will delete it as required.

10. Data Retention

We retain data only as long as necessary for the purposes described. Afterward, it is securely deleted or anonymized.

11. Changes to This Privacy Policy

We may update this policy. Material changes will be communicated appropriately. Continued use of the Service implies acceptance of the updated policy.

12. Applicable Law

This Privacy Policy is governed by the laws of Panama.