Privacy Policy

Last Updated: February 6, 2026 — Effective Date: February 6, 2026

Plain English Summary (Quick Overview)

This summary is provided for convenience only and does not replace the full Privacy Policy below.

  • Wowbat is a non-custodial platform. We do not hold, store, or control user funds or private keys.
  • We collect personal data to operate the platform, provide access to services through licensed partners, and comply with applicable legal and AML/CFT requirements.
  • Identity verification (KYC), regulated transaction screening, and regulatory reporting are performed by licensed partners, not by Wowbat directly.
  • Wowbat may restrict or suspend access to the platform for compliance or security reasons but cannot freeze, seize, or reverse on-chain funds.
  • We do not sell personal data.
  • Users have data protection rights, subject to mandatory AML record-keeping obligations.

1. Information We Collect

At Wowbat, we are committed to safeguarding your privacy while delivering wallet services for users globally. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you engage with our Services, including our mobile application and related platforms (collectively, the "Services"). By using our Services, you consent to the practices described herein.

This Policy complies with applicable data protection laws, including the General Data Protection Regulation (GDPR), Turkish Personal Data Protection Law (KVKK), and other applicable regulations, with a focus on supporting Know Your Customer (KYC), Anti-Money Laundering (AML), and Countering the Financing of Terrorism (CFT) requirements applicable to licensed partners.

Personal Identification Information

We may collect:

  • Full name
  • Email address
  • Phone number
  • Date of birth
  • Nationality
  • Identity verification documents (e.g. passport, driver's license, or government-issued ID)

This information is collected during account registration and identity verification. Identity verification is conducted by certified third-party service providers acting on behalf of licensed payment partners.

Financial Information

We may process financial and transactional information, including:

  • Transaction timestamps and amounts
  • Wallet addresses and transaction references
  • Conversion records and payment metadata

This data is used to facilitate user-initiated transactions and to support operational, compliance, and audit requirements.

Cryptocurrency Wallet Data

We may process:

  • Public wallet addresses
  • Public keys
  • Blockchain transaction hashes

Wowbat does not have access to private keys and does not control user wallets or on-chain assets.

Technical Data

We may collect technical information such as:

  • IP addresses
  • Browser type
  • Operating system
  • Device identifiers
  • Application usage logs

This information is used to maintain platform security, detect abnormal behavior at the platform level, and improve performance.

Usage Data

We may collect information regarding interactions with the Services, such as navigation patterns, feature usage, and transaction frequency, to improve the platform and manage risk.

Aggregated or Anonymized Data

We may use aggregated or anonymized data for analytics, statistical analysis, and service optimization. Such data does not identify individual users.

2. How We Use Your Information

We process personal information for the following purposes:

Service Delivery

To provide access to the Wowbat platform, enable wallet functionality, initiate transactions through licensed partners, maintain platform operations, and provide customer support.

Legal and Regulatory Compliance (KYC / AML / CFT)

Know Your Customer (KYC)

Personal identification information is used to verify user identity as required by licensed partners and applicable regulations. Verification is performed by certified third-party identity verification providers.

AML / CFT Compliance

Wowbat applies platform-level controls and cooperates with licensed partners to support AML/CFT compliance. This may include:

  • enforcing transaction limits,
  • identifying abnormal usage behavior,
  • restricting or suspending platform access where required.

Regulated activities such as sanctions screening, blockchain transaction analysis, source of funds or source of wealth assessment, and regulatory reporting (including STR/SAR filings) are conducted by licensed partners, not by Wowbat directly.

Wowbat does not independently perform regulated source of funds or source of wealth assessments. Where required, Wowbat relies on the controls and determinations of licensed partners and may apply platform-level restrictions or request additional information to support compliance.

Security

To protect user accounts and the platform from unauthorized access, fraud, or misuse using reasonable and industry-standard security measures.

Improvement

To analyze usage patterns, troubleshoot issues, and improve functionality and user experience.

Communication

To send transactional notifications, service-related messages, security alerts, and — with explicit consent — promotional communications.

3. Disclosure of Your Information

We may share personal information under strict conditions with the following parties:

KYC / Identity Verification Partners

Certified third-party providers that perform identity verification services in support of licensed partners' regulatory obligations.

Licensed Payment and Exchange Partners

Licensed financial institutions that:

  • perform fiat-to-crypto conversions,
  • process merchant payments and payouts,
  • conduct regulated AML/CFT controls and reporting.

Third-Party Service Providers

Trusted providers supporting platform operations, including:

  • cloud infrastructure and hosting,
  • analytics and performance monitoring,
  • security and fraud prevention,
  • customer support tools.

All such providers are subject to confidentiality and data protection obligations.

Regulatory Authorities

Information may be disclosed where required by applicable law, court order, or mandatory regulatory obligations applicable to licensed partners.

International Transfers

Personal data may be processed in jurisdictions outside your country of residence. Where required, we rely on Standard Contractual Clauses (SCCs), encryption, and equivalent safeguards.

4. Security Measures

We implement reasonable and industry-standard security measures, including:

  • encryption of data at rest and in transit,
  • access controls and monitoring,
  • secure hosting environments.

Despite these measures, no system can be guaranteed to be completely secure.

5. Suspicious Activity and Platform Restrictions

Wowbat applies platform-level risk controls to protect users and comply with partner requirements.

  • Wowbat does not hold or control user funds.
  • Wowbat cannot freeze, seize, or reverse blockchain transactions.
  • Where potentially suspicious activity is identified at the platform level, Wowbat may:
    • restrict or suspend access to the platform,
    • request additional information,
    • notify relevant licensed partners.

Regulatory reporting obligations, including STR/SAR filings, remain the responsibility of licensed partners.

6. Retention of Your Information

We retain personal data only as long as necessary:

  • Active accounts: data is retained to provide ongoing services.
  • After account termination: AML-related records are retained for a minimum of five (5) years, or longer where required by law or contractual obligations.
  • Blockchain data: on-chain records are immutable and cannot be deleted or modified.

7. Your Rights

Subject to applicable law and AML obligations, you may request:

  • access to your personal data,
  • correction of inaccurate data,
  • deletion where legally permitted,
  • data portability,
  • withdrawal of consent.

Requests may be submitted to privacy@wowbat.asia.

8. Marketing Communications

We may send marketing communications only with your consent. You may opt out at any time using the unsubscribe mechanism or by contacting us.

9. Legal Basis and Availability of Services

We process personal data based on:

  • user consent,
  • contractual necessity,
  • compliance with legal obligations.

Availability of Services may be limited based on location, regulatory requirements, and partner capabilities. Certain features may be available only in specific jurisdictions.

10. International Data Transfers

As a global service, personal data may be transferred and processed internationally using appropriate legal safeguards.

11. Cookie Usage

When you access our website or use our Services, we may use cookies and similar technologies to improve your experience and ensure the security of your account. Cookies are small data files that your browser saves on your device when you visit our site. These cookies help us recognize you as a user, understand how you interact with our Services, and provide a more personalized experience. They also assist us in maintaining the security of your account by detecting irregular or suspicious activities.

We use cookies for several purposes, including:

  • Enabling essential functionalities (such as logging in and accessing your wallet)
  • Analyzing usage patterns to enhance our platform
  • Detecting fraud and suspicious activity at the platform level
  • With your consent, delivering personalized content

Some cookies are temporary and expire when you close your browser, while others may remain on your device for a longer period until they expire or you delete them.

You can choose to disable cookies through your browser settings, but please note that doing so may affect the functionality of our Services or your overall user experience. Additionally, some browsers offer a "Do Not Track" (DNT) feature. At this time, our Services do not respond to DNT signals, but you can manage your cookie preferences directly via your browser.

12. Updates to This Policy

We may update this Privacy Policy to reflect legal, operational, or technological changes. Updates will be published on our website and, where required, communicated through the application or email.

13. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors.

14. Third-Party Links

Our Services may contain links to third-party websites. Wowbat is not responsible for the privacy practices of such third parties.

15. Contact Us

For questions, concerns, or to exercise your rights, please contact us:

General Inquiries:
contact@wowbat.asia

Privacy Requests:
privacy@wowbat.asia

Support:
support@wowbat.asia

Registered Address:
WIN WIN ORGANIZASYON VE DANIŞMANLIK LİMİTED ŞİRKETİ
Aksaray Mah. Koçibey Sk. Özel İşhanı No: 2 İç Kapı No: 11
Fatih, Istanbul, Turkey
Company Registration No. 414233-5

Website:
wowbat.asia

16. Data Protection Officer (DPO)

For data protection matters, you may contact our Data Protection Officer at:

Email:dpo@wowbat.asia

Last Updated: February 6, 2026 — Effective Date: February 6, 2026