Cosgrove Technology Inc., PT Cosgrove Teknologi Indonesia and PT Evora Vera Teknologi (collectively, "Paymonei", "Company", "we", "us", or "our") are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Paymonei platform and related services (the "Services"). This Policy applies to all information collected through our Services, as well as any related services, sales, marketing, or events.

Please read this Privacy Policy carefully. By using our Services, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this privacy policy, please do not access the Services.

1. Information We Collect

We collect information that you provide to us, information that is automatically collected, and information from third parties. The types of personal information ("Personal Data") we may collect include:

1.1. Information You Provide to Us

• Personal Identification Information: Your full name, date of birth, physical address, email address, phone number, and nationality.
• Formal Identification Information: Government-issued identification numbers (e.g., Passport, Driver's License), and other documents requested for our Know-Your-Customer ("KYC") and Know-Your-Business ("KYB") verification processes, including photographs or "selfies" for identity confirmation.
• Business Information: For entity accounts, we may collect business name, registration details, articles of incorporation, and information about beneficial owners and directors.
• Financial Information: Bank account numbers, routing information, and other payment details necessary to facilitate fiat currency settlements.
• AI Agent Configuration Data: The parameters, rules, and logic you define for any AI Agents you deploy through our protocol.

1.2. Information We Collect Automatically

• Transactional Information: Information about the transactions you or your AI Agents perform, including public wallet addresses, transaction amounts, timestamps, and network data. Note that this information is also publicly available on the blockchain.
• Device and Usage Data: IP address, device type, operating system, browser type, unique device identifiers, and information about your interaction with our Services (e.g., pages viewed, features used, access times).
• Log Data: We may collect logs of activity, including access to our systems, API calls, and other events for security and debugging purposes.

1.3. Information From Third Parties

• Identity Verification Partners: We use third-party services to verify your identity by comparing the information you provide with public records and other third-party databases.
• Financial Partners: Our licensed financial partners may share information with us regarding the status of your fiat transactions and account linkage.
• Blockchain Data: We collect public data from blockchain networks to monitor transactions and ensure the proper functioning of our Services.

2. How We Use Your Information

We use the information we collect for various purposes, grounded in legitimate business needs and legal obligations:

• To Provide and Maintain the Services: To create and manage your account, process transactions, deploy and monitor AI Agents, and provide customer support.
• For Compliance and Security: To conduct KYC/KYB checks, comply with our legal and regulatory obligations (e.g., Anti-Money Laundering and Counter-Terrorism Financing laws), prevent fraud, and monitor for and protect against security threats.
• To Improve Our Services: To analyze usage patterns, troubleshoot issues, and develop new features and functionalities.
• To Communicate With You: To send you transactional confirmations, technical notices, security alerts, and administrative messages.
• To Enforce Our Terms: To enforce our Terms of Service and other policies.

3. How We Share and Disclose Your Information

We do not sell your Personal Data. We may share your information with the following categories of third parties in specific circumstances:

• With Our Financial Partners: We share your identification and financial information with our licensed financial partners as necessary to provide regulated services like fiat settlement, custody, and payment processing.
• With Service Providers: We share information with third-party vendors and service providers who perform services on our behalf, such as cloud hosting (e.g., AWS, Google Cloud), identity verification, data analytics, and customer support. These providers are contractually obligated to protect your data.
• For Legal and Compliance Reasons: We may disclose your information if we are required to do so by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to comply with regulatory inquiries, prevent harm, or protect our rights or the rights of others.
• In Connection with a Business Transfer: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• With Your Consent: We may disclose your Personal Data for any other purpose with your consent.

4. A Note on Blockchain Data

Please be aware that information recorded on a public blockchain, such as your public wallet address and transaction details, is inherently public and permanent. This information is not controlled by Paymonei and is not covered by this Privacy Policy. Anyone can view this data.

5. Data Security and Retention

• Security. We implement and maintain industry-standard administrative, physical, and technical security safeguards to help protect your Personal Data from loss, theft, misuse, and unauthorized access. However, no electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
• Retention. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and to the extent necessary to comply with our legal obligations (for example, we are required to retain transaction and KYC data for at least five years to comply with AML regulations), resolve disputes, and enforce our legal agreements.

6. International Data Transfers

Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and that appropriate safeguards are in place.

7. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your Personal Data:

• The right to access, update, or delete the information we have on you.
• The right of rectification if that information is inaccurate or incomplete.
• The right to object to our processing of your Personal Data.
• The right to request that we restrict the processing of your personal information.
• The right to data portability for the information you provide to us.
• The right to withdraw consent at any time where we relied on your consent to process your information.

To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before responding to your request.

8. Policy Towards Children

Our Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Data from children under 18. If we become aware that we have collected Personal Data from a child under 18, we will take steps to delete such information.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: [email protected].