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PRIVACY NOTICE - MIYI WALLET

LAST UPDATED: OCTOBER 4, 2026

MIYI (“we”, “our”, or “us”) is committed to respecting and protecting the privacy of our users, service providers, and application visitors. We take our data protection and privacy responsibilities with the utmost seriousness.

This Privacy Notice explains how we collect, use, disclose, transfer, and process your personal data when you access or use the MIYI Wallet software application, mobile interfaces, websites, and associated features (collectively, the “Services”). It also informs you of your privacy rights and how you may exercise them under applicable data protection laws.

The MIYI Wallet Services are operated and provided by MIYI, a company incorporated and registered under the laws of Saint Lucia. MIYI Wallet is a product and service operated by MIYI and is not a separate legal entity. MIYI acts as the data controller in relation to the personal data processing activities described in this Privacy Notice.

1. Important Scope Note: Non-Custodial Architecture

  • Private Keys and Recovery Phrases: Your cryptographic private keys, seed phrases, and wallet passcodes are generated and stored exclusively on your local device. MIYI does not collect, transmit, process, or store your private keys, secret recovery phrases, or PINs on any server.
  • Public Blockchain Data: Transactions executed via MIYI Wallet (such as Deposits, Withdrawals, and QR Scan-to-Pay transfers) are broadcast to public, decentralized blockchain ledgers. Public blockchain records (including wallet addresses, transaction hashes, amounts, and timestamps) are public by nature, immutable, and outside the direct control or custodianship of MIYI.

2. What Personal Data We Collect and Process

Personal data refers to any information that identifies or can be reasonably linked to an identified or identifiable natural person. Below are the categories of personal data we process:

  • Personal Identification Data (Where Required for Compliance)
  • Types of Data: Full name, email address, phone number, government-issued identifier, date of birth, nationality, proof of address, or photo/video verification.
  • Purpose: Verifying identity, fulfilling Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and global sanctions compliance obligations.
  • Legal Basis: Compliance with legal obligations under applicable law; legitimate interest in preventing fraud, financial crime, and unauthorized usage.
  • Wallet & Transaction Information
  • Types of Data: Public wallet addresses, transaction IDs (TxHash), transaction timestamps, token types, transfer amounts, and destination QR code parameters.
  • Purpose: Enabling deposit, withdrawal, and QR scan-to-pay transaction routing; updating user interface balances; network status verification.
  • Legal Basis: Performance of a contract to deliver requested wallet services; legitimate interest in ensuring operational accuracy and protocol security.
  • System & Network Technical Data
  • Types of Data: Internet Protocol (IP) address, device model, operating system version, unique device identifiers, time zone settings, app language, RPC endpoint logs, and crash reports.
  • Purpose: Maintaining platform security, debugging technical issues, preventing denial-of-service (DoS) attacks, optimizing app performance, and setting user preferences.
  • Legal Basis: Performance of a contract; compliance with technical security laws; legitimate interest in maintaining platform stability and integrity.
  • Communications & Support Data
  • Types of Data: Email address, support tickets, communication logs, user feedback, customer service chat history, and submitted screenshots.
  • Purpose: Addressing user queries, resolving technical issues, handling feedback, and delivering service notifications.
  • Legal Basis: Performance of a contract; legitimate interest in providing responsive customer support and improving user experience.

3. How We Share Your Personal Data

We do not sell, rent, or trade your personal data to third parties. We share your personal data only under the following specific circumstances:

  • Third-Party Service Providers: Shared with infrastructure vendors that perform specialized services on our behalf (cloud hosting, RPC node relayers, security analytics, customer support software, automated fraud detection). They are contractually bound to process data strictly under our instructions.
  • Blockchain Network Nodes: Transmitted to public blockchain nodes and network validators to confirm transactions on-chain whenever you initiate an outbound transfer or QR Scan-to-Pay transaction.
  • Legal Authorities and Compliance: Disclosed to law enforcement, judicial bodies, financial intelligence units, or regulators if required by applicable law, court order, search warrant, subpoena, or statutory Travel Rule mandates.
  • Corporate Reorganizations: Transferred as a business asset during any merger, acquisition, asset sale, corporate restructuring, or insolvency proceeding, subject to standard confidentiality safeguards.
  • With Your Explicit Consent: Disclosed for any additional purpose where you have explicitly provided informed consent.

4. International Data Transfers

  • Cross-Border Transfers: As an entity registered in Saint Lucia serving a global user base, MIYI may process and transfer your personal technical data to servers, affiliates, or third-party service providers outside your country of residence.
  • Transfer Safeguards: Where transfers occur to jurisdictions without equivalent data protection laws, MIYI implements appropriate technical, organizational, and legal safeguards—including Standard Contractual Clauses (SCCs), data protection agreements, and end-to-end encryption.

5. Security Safeguards

  • Non-Custodial Client Storage: Private keys, seed recovery phrases, and wallet PINs are encrypted and retained strictly on your local device hardware using native secure enclaves.
  • Data Encryption: All communications between the MIYI Wallet interface and backend API nodes are encrypted using Transport Layer Security (TLS/SSL) and industry-standard protocols.
  • Access Control: Internal access to support data and system logs is restricted strictly to authorized personnel on a least-privilege, need-to-know basis.

6. Data Retention

  • Technical & Usage Logs: Retained for up to 12 months for security audits, risk monitoring, and system optimization.
  • Compliance & KYC Records: Retained for the statutory period mandated under applicable AML/CTF laws (typically 5 to 7 years following account closure or transaction completion).
  • Anonymized Analytics: Fully aggregated and anonymized technical metrics (non-identifiable) may be retained indefinitely for business research and product improvement.

7. Data Deletion

  • Local Wallet Data: Your wallet data, including private keys, recovery phrases, and wallet passcodes, is stored locally on your mobile device. If you delete a wallet in the MIYI Wallet app or uninstall the app, the locally stored wallet data will be deleted from that device. MIYI does not store your private keys or recovery phrases on its servers and cannot restore them after deletion.

8. Your Legal Privacy Rights

Depending on your jurisdiction, you may exercise the following rights regarding your personal data:

  • Right to Access: Request confirmation of processing and a copy of your personal data.
  • Right to Rectification: Request correction of inaccurate or incomplete personal data.
  • Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data, subject to legal retention duties (Note: On-chain blockchain data cannot be altered or erased).
  • Right to Restrict Processing: Request temporary suspension of personal data processing under valid legal grounds.
  • Right to Data Portability: Request your personal data in a structured, machine-readable format to transfer to another controller.
  • Right to Object: Object to data processing based on legitimate interests or direct marketing.
  • Right to Withdraw Consent: Withdraw previously granted consent at any time without affecting prior lawful processing.

9. Third-Party Websites and External Protocols

  • External Links: The MIYI Wallet interface may contain links to third-party websites, decentralized applications (DApps), block explorers, or merchant payment portals.
  • Separate Policies: This Privacy Notice does not apply to third-party services. Their collection and processing practices are governed by their respective privacy policies.

10. Revisions to this Privacy Notice

  • Periodic Updates: We reserve the right to amend this Privacy Notice periodically to reflect changes in legal, regulatory, or operational requirements.
  • Notification Methods: Updates will be published within the MIYI Wallet application and on the official MIYI Wallet website (https://www.miyiwallet.com), with an updated "Last Updated" date. Material changes will be highlighted via in-app notices.

11. Contact Information and Complaints

To exercise your privacy rights or contact our Data Protection Officer, reach out through the following channels:

  • Legal Entity: MIYI, a company incorporated and registered under the laws of Saint Lucia. MIYI Wallet is a product and service operated by MIYI and is not a separate legal entity.
  • Customer Support: support@miyiwallet.com
  • Official Website: www.miyiwallet.com
  • Regulatory Authority: You maintain the right to lodge a complaint with your local data protection supervisory authority if you believe our data processing violates applicable privacy laws.