1. Introduction

Ironbit Spółka z ograniczoną odpowiedzialnością, trading as iWallet (“iWallet”, “we”, “us”, or “our”), is committed to protecting the privacy, confidentiality, and security of personal data.

This Privacy Policy explains how we collect, use, process, store, and share personal data when you access or use our website, platform, applications, APIs, or related financial technology services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that your personal data will be processed in accordance with this Privacy Policy.

2. Data Controller

For the purposes of applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the data controller is:

Ironbit Sp. z o.o.
Trading as iWallet

Email: legal@iwallettech.com
Website: www.iwallettech.com
Registered Address: Żurawia 6, 00-503 Warszawa, Poland

If you have questions regarding this Policy or the processing of your data, you may contact us using the details above.

3. Personal Data We Collect

We may collect and process the following categories of personal data:

a) Information You Provide Directly

• full name, contact details, and identification information;

• email address and telephone number;

• company name, role, and business contact information;

• identification documents and verification materials (KYC/KYB);

• proof of address and corporate documentation;

• billing, payment, and transaction-related information;

• communications, support requests, and correspondence.

b) Automatically Collected Information

When you interact with our Services, we may automatically collect:

• IP address and device identifiers;

• browser type and operating system;

• usage activity, session data, and interaction metrics;

• access timestamps and log data;

• cookie and tracking technology information.

c) Information from Third Parties

We may receive personal data from trusted third-party sources, including:

• identity verification and compliance providers;

• financial institutions and payment partners;

• fraud prevention and risk-scoring providers;

• public registries and corporate databases.

4. Purposes of Processing

We process personal data for the following purposes:

• providing, operating, and maintaining the Services;

• verifying identity and conducting compliance checks;

• fulfilling anti-money laundering (AML) and counter-terrorist financing obligations;

• managing accounts and customer relationships;

• facilitating payments, transactions, and integrations;

• improving platform performance and user experience;

• detecting, preventing, and investigating fraud or security incidents;

• complying with legal, regulatory, and contractual obligations;

• responding to lawful requests from authorities.

5. Legal Basis for Processing

We process personal data on one or more of the following legal bases:

• Performance of a contract — where processing is necessary to provide Services;

• Legal obligation — including compliance with AML/KYC, financial crime prevention, and regulatory requirements;

• Legitimate interests — including platform security, fraud prevention, and service improvement;

• Consent — where required by law, including for marketing communications or optional features.

Where processing is based on consent, you may withdraw consent at any time.

6. Sharing of Personal Data

We may share personal data with:

• regulated financial institutions, banking partners, and card networks;

• identity verification, compliance, and fraud prevention providers;

• technology vendors, hosting providers, and infrastructure partners;

• professional advisers, auditors, and legal counsel;

• competent regulatory or law enforcement authorities where required by law;

• affiliated companies providing operational or technical support.

We do not sell, lease, or rent personal data to third parties.

7. International Data Transfers

Due to the global nature of our Services, personal data may be transferred to and processed in countries outside the European Economic Area (EEA).

Where such transfers occur, iWallet implements appropriate safeguards, including:

• Standard Contractual Clauses approved by the European Commission;

• contractual data protection obligations;

• technical and organizational security measures.

8. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration, including:

• encryption of data in transit and at rest;

• secure infrastructure and firewall protections;

• role-based access controls;

• continuous monitoring and vulnerability testing;

• authentication and device security measures.

While we apply industry-standard protections, no system can guarantee absolute security.

9. Data Retention

Personal data is retained only for as long as necessary to:

• provide the Services;

• comply with legal or regulatory obligations;

• resolve disputes and enforce agreements;

• meet financial recordkeeping and AML retention requirements.

Retention periods may extend beyond account closure where required by law. Data is securely deleted or anonymized once retention obligations expire.

10. Your Data Protection Rights

Subject to applicable law, you may have the right to:

• access your personal data;

• request correction of inaccurate or incomplete data;

• request deletion of personal data;

• restrict or object to processing;

• request data portability;

• withdraw consent where processing relies on consent;

• lodge a complaint with a supervisory authority.

Requests may be submitted to: legal@iwallettech.com

We may request identity verification before fulfilling requests.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• operate and secure the platform;

• analyze usage and performance;

• improve user experience;

• deliver relevant communications where permitted.

You may manage cookie preferences through browser settings. Additional information is available in our Cookie Policy.

12. Children’s Privacy

The Services are not intended for individuals under eighteen (18) years of age. We do not knowingly collect personal data from minors. If such data is identified, it will be deleted promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect legal, operational, or technical changes.

Where material changes are made, we will provide appropriate notice. Continued use of the Services following updates constitutes acceptance of the revised Policy.

14. Contact Information

For questions, requests, or data protection inquiries:

Ironbit Sp. z o.o.
Trading as iWallet

Email: legal@iwallettech.com
Website: www.iwallettech.com
Address: Żurawia 6, 00-503 Warszawa, Poland