Last updated: [Month DD, YYYY]

1. Scope

This policy explains how [Full legal name] (“Viaora,” “we,” “us”) handles personal information when you use our website, app, or services, contact us, or otherwise interact with us. Viaora’s product materials describe multi-currency accounts, payments and remittances, currency exchange, identity verification, cryptocurrency, and real-world-asset (“RWA”) services. Available features depend on your location and eligibility. Feature-specific privacy notices may also apply.

2. Information we collect

Depending on the features you use, we may collect:

• Account details: email address or phone number, username, password credentials, invitation code, and communication preferences.

• Identity and verification details: name, date of birth, nationality, address, government ID and images, selfie, and verification results. A verification provider may process facial measurements or other biometric identifiers where applicable; we will provide notice and obtain consent where required.

• Financial and transaction details: account or wallet identifiers, payment, funding and payout details, transfers, transaction history, currency exchange, and requested services or assets.

• Device and usage details: IP address, device and browser type, operating system, language, logs, pages and features used, and interactions with Viaora.

• Support communications: information you provide when contacting us.

• Blockchain records: if you use a blockchain feature, related public addresses and transactions may be visible on public networks and may not be removable.

3. How we use information

We use personal information to create and secure accounts; verify identity and eligibility; provide requested financial and other services; process transactions; prevent fraud and protect security; meet applicable legal and regulatory obligations; provide support; maintain and improve our services; send service notices and permitted marketing; and establish or defend legal claims. Where required, we rely on contract, legal obligations, consent, or legitimate interests. We will provide any additional notice or choice required for sensitive information or new purposes.

4. How we share information

We may share information as needed with:

• Service providers supporting hosting, authentication, identity checks, fraud prevention, compliance, support, analytics, security, and transaction processing.

• Banks, payment networks, financial institutions, and remittance or exchange partners involved in a service you request.

• Public blockchain networks when you use a blockchain feature. Blockchain records may be publicly visible and retained independently of Viaora.

• Apple or Google when you use their sign-in services.

• Professional advisers, regulators, law enforcement, courts, or other parties when needed to meet legal obligations, protect people or services, or handle legal claims.

• A successor or transaction party in connection with a business reorganization or transfer, subject to applicable law.
  
  

5. International transfers and retention

Viaora and its providers may process information outside your country. Where required, we use appropriate safeguards for international transfers.

We keep personal information only as long as needed to provide services, meet legal obligations, maintain necessary records, resolve disputes, and protect Viaora. We then delete, anonymize, or securely isolate it unless further retention is required or permitted. Account deletion may not remove legally required records or public blockchain data.

6. Security

We use administrative, technical, and organizational measures designed to protect personal information. No method of storage or transmission is completely secure.

7. Your privacy choices and rights

Depending on your location, you may be able to request access, correction, deletion, or a portable copy of your information; object to or restrict certain processing; withdraw consent; opt out of certain advertising or data sharing; or complain to a privacy regulator. These rights are subject to applicable laws and exceptions.

8. Cookies and third-party services

We may use essential cookies to operate and secure Viaora and remember settings. If we use analytics, advertising, or other non-essential technologies, we will describe them and provide choices where required. Browser settings can block cookies, though some features may not work. Third-party services have their own privacy notices.

9. Children and automated checks

Viaora is not intended for anyone below the minimum age for the relevant financial service in their location.

We or our providers may use automated tools to support identity checks, fraud prevention, security, or compliance. Where required by law, you may request information or review by contacting us.

10. Changes and contact

We may update this policy by posting a revised version and updating the date above. We will provide additional notice or obtain consent when required by law.