1. Introduction
LyteWire ("Company", "we", "our", "us") is committed to protecting your privacy while delivering the transparency benefits of blockchain technology. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Services.
We operate in compliance with UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, VARA regulations, CBUAE requirements, and for EU users, GDPR. Our blockchain architecture provides transaction transparency while protecting your personal data.
2. Information We Collect
2.1 Personal Information
We collect information you provide directly:
- Account Information: Name, phone number, email address, date of birth
- Identity Documents: Emirates ID, passport, proof of address (for KYC)
- Financial Information: Bank account details, transaction history
- Profile Information: Profile photo, preferences, settings
- Communications: Support messages, feedback, survey responses
2.2 Automatically Collected Information
When you use our Services, we automatically collect:
- Device Information: Device type, operating system, unique identifiers
- Usage Data: Features used, time spent, actions taken
- Location Data: IP address, approximate location (with consent)
- Log Data: Access times, pages viewed, errors encountered
- Cookies: Session data, preferences, analytics
2.3 Blockchain and Third-Party Information
We may receive information from:
- Identity verification services (KYC providers)
- Credit bureaus and financial institutions
- Blockchain networks (public transaction data on opBNB)
- Smart contract interactions (wallet addresses, transaction hashes)
- Marketing partners and social media platforms
Blockchain Transparency: Transactions on opBNB are publicly visible. Your wallet address and transaction history are on-chain, but we never link wallet addresses to personal identity publicly. AE Coin reserve attestations are published for transparency without exposing individual user data.
3. How We Use Your Information
We use your information to:
3.1 Provide Services
- Create and manage your account
- Process transactions and payments
- Verify your identity (KYC/AML compliance)
- Provide customer support
- Send transaction notifications and receipts
3.2 Improve Our Services
- Analyze usage patterns and trends
- Develop new features and products
- Personalize your experience
- Conduct research and testing
3.3 Security and Compliance
- Detect and prevent fraud
- Monitor for suspicious activity
- Comply with legal obligations
- Respond to law enforcement requests
- Enforce our Terms of Service
3.4 Marketing (with consent)
- Send promotional communications
- Display personalized advertisements
- Conduct surveys and collect feedback
4. Legal Basis for Processing
We process your data based on:
- Contract: Processing necessary to provide our Services
- Legal Obligation: Compliance with KYC/AML and other regulations
- Legitimate Interest: Fraud prevention, service improvement
- Consent: Marketing communications, optional features
5. Information Sharing
We may share your information with:
5.1 Service Providers
- Cloud hosting and infrastructure providers
- Payment processors and banking partners
- Identity verification services
- Analytics and monitoring tools
- Customer support platforms
5.2 Legal and Regulatory
- UAE Central Bank (CBUAE) - AE Coin licensing
- Virtual Assets Regulatory Authority (VARA) - Crypto compliance
- European regulators (GDPR, PSD2, AMLD5) for EU operations
- Law enforcement agencies (when legally required)
- Courts and legal proceedings
5.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction.
5.4 With Your Consent
We may share your information with third parties when you explicitly consent to it.
6. Data Retention
We retain your information for as long as:
- Your account is active
- Necessary to provide our Services
- Required by law (typically 5-10 years for financial records)
- Needed for legitimate business purposes
After account closure, we retain certain data for legal and compliance purposes, after which it is securely deleted or anonymized.
7. Data Security
We implement robust security measures including:
- End-to-end encryption for sensitive data
- TLS/SSL for all data in transit
- AES-256 encryption for data at rest
- Multi-factor authentication
- Regular security audits and penetration testing
- Employee security training and access controls
- 24/7 monitoring and incident response
Despite our efforts, no security measure is 100% effective. You are responsible for keeping your login credentials secure.
8. Your Rights
You have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data (subject to legal requirements)
- Restriction: Limit how we process your data
- Portability: Receive your data in a portable format
- Objection: Object to certain processing activities
- Withdraw Consent: Revoke previously given consent
To exercise these rights, contact us at privacy@lytewire.io or through the app settings.
9. International Transfers
Your data may be transferred to and processed in countries outside the UAE. We ensure appropriate safeguards are in place, including:
- Standard contractual clauses
- Adequacy decisions
- Certification mechanisms
10. Cookies and Tracking
We use cookies and similar technologies for:
- Essential: Session management, authentication, security
- Functional: Preferences, language settings
- Analytics: Usage statistics, performance monitoring
- Marketing: Personalized ads (with consent)
You can manage cookie preferences through your browser settings or our cookie banner.
11. Children's Privacy
Our Services are not intended for children under 18 without parental consent. Minors may use LyteWire only as part of a Family Pool with parental supervision.
If we learn we have collected information from a child without parental consent, we will delete it promptly.
12. Third-Party Links
Our Services may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to review their privacy policies before providing any personal information.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-app notification. Your continued use of our Services after changes constitutes acceptance of the updated policy.
14. Contact Us
If you have questions about this Privacy Policy or our data practices, contact us:
- Email: privacy@lytewire.io
- Data Protection Officer: dpo@lytewire.io
- Address: Dubai, United Arab Emirates
- Support: Support Center
15. Regulatory Information
LyteWire is registered and operates in the United Arab Emirates. We are subject to:
- UAE Federal Decree-Law No. 45 of 2021 (Personal Data Protection)
- Virtual Assets Regulatory Authority (VARA) guidelines
- UAE Central Bank regulations
- Anti-Money Laundering (AML) laws
You may file a complaint with the UAE Data Office if you believe your data protection rights have been violated.