Privacy Policy

Effective Date: 02 June, 2025

This Privacy Policy explains how we collect, use, disclose, and protect your personal information
when you use the WoWbat mobile application ("WoWbat" or the "App"), operated by WIN WIN
ORGANIZASYON VE DANISMANLIK LIMITED SIRKETI ("WinWin", "we", "us", or "our").
By using WoWbat, you agree to the practices described below.

1. Who We Are
Data Controller:
WIN WIN ORGANIZASYON VE DANISMANLIK LIMITED SIRKETI
Registration No: 414233-5
Address: Aksaray Mah. Kocibey Sk. Ozel Ishani No: 2 Ic Kapi No: 11, Fatih, Istanbul, Turkey
Contact (for privacy matters): legal@wowbat.asia
WinWin is the sole developer and operator of the WoWbat mobile application. We do not provide
payment services directly, but facilitate access to third-party services through the App.

2. Scope of This Policy
This Privacy Policy applies to all users of the WoWbat mobile application and associated services,
including residents of Vietnam. It describes how your personal data is collected, used, stored,
transferred, and what rights you have in relation to that data.

3. What Personal Data We Collect
a. Information You Provide- Wallet data: Public blockchain wallet addresses (e.g., MetaMask, Binance)
- Email address: If you contact us for support or register voluntarily
- Verification data: Identity documents and selfies (if KYC is required)
- Support communications: Messages you send to our team
b. Information We Collect Automatically
- Device and OS details (e.g., model, version, language)
- IP address and location approximation
- Log files (e.g., time of activity, usage patterns)
- App interactions (e.g., QR scans, plan activations)
We do not collect private keys, seed phrases, or access your wallet contents.

4. Legal Basis for Processing
We collect and process personal data on the following legal grounds:
- Performance of contract
- Legal obligation
- Legitimate interest
- Consent

5. How We Use Your Information
- Enable you to connect a wallet and access your digital balance
- Facilitate Viet QR-based payments through authorized local partners
- Perform KYC and fraud checks if required
- Provide customer support and address user inquiries
- Improve App performance through anonymized analytics
- Comply with applicable laws and regulations

6. Sharing of Data with Third Parties
We may share personal data with:
- KYC verification providers
- Local liquidity partners and payment processors in Vietnam
- Analytics and infrastructure providers
- Government authorities or regulators when required by law

7. International Data Transfers
Your data may be stored or processed outside your home country, including in Turkey and other
jurisdictions. We implement appropriate safeguards. By using WoWbat, you consent to such
transfers.

8. Data Retention
- KYC and transactional data: up to 3 years
- Support records: up to 12 months
- Technical and usage logs: up to 6 months

9. Your Rights
Depending on your jurisdiction, you have the right to:
- Access your personal data
- Request correction or deletion
- Restrict or object to processing
- Withdraw consent
To exercise your rights, contact support@wowbat.asia.

10. Children's Data
WoWbat is not for users under 18. Contact us if a minor's data is inadvertently collected.

11. Data Security
We use encryption, SOC 2-ready infrastructure, access controls, and anonymization techniques.

12. Cookies and Tracking
WoWbat does not use web-based cookies. App-level identifiers may be used for diagnostics.

13. Changes to This Policy
We may update this Privacy Policy. Continued use of the App constitutes acceptance.

14. Contact Information
support@wowbat.asia
legal@wowbat.asia