Privacy Policy

PRIVACY POLICY
Last updated on September 25, 2025

1. INTRODUCTION

Ayni Token Inc. (hereafter “Ayni Gold”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we handle your personal information, your privacy rights, and how the law protects you, when you:

Visit our websites, including https://ayni.gold, https://app.ayni.gold, https://updates-ayni.gold, or any other related subdomains and our mobile applications (collectively “Website and Apps”);
Subscribe to our newsletters, join waitlists, participate in surveys, or communicate with our team (“Voluntary provision of data”); and/or
Use our Services, including token purchases, staking, and related platform features.

2. IMPORTANT INFORMATION AND WHO WE ARE

Controller:
Ayni Token Inc. (Ayni Gold), a company duly incorporated and existing under the laws of the British Virgin Islands.
Registered address: 19 Waterfront Drive, P.O. Box 3540, Road Town, Tortola VG1110, British Virgin Islands.

We provide services through our websites and mobile applications, including participation in tokenized gold solutions, staking, and related blockchain-based features.

Contact for privacy matters:
privacy@ayni.gold

3. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy provides information on how Ayni Gold collects and processes your personal data when you use our websites, apps, or services, or when you provide data voluntarily. This includes data:

You may provide directly to us;
We may collect automatically through your use of the Website, Apps, or Services; and/or
You provide when subscribing to newsletters, completing surveys, or communicating with our support team.

It is important that you read this Privacy Policy together with any other privacy or fair processing notices we may provide in specific contexts, so you are fully aware of how and why we use your data.

This Privacy Policy supplements other policies we may provide and is not intended to override them. For the purposes of this Privacy Policy, Ayni Token Inc. (Ayni Gold) is the data controller responsible for your personal data (referred to as “we”, “us” or “our”).

4. CHANGES TO THIS PRIVACY POLICY

This version was last updated on September 25, 2025. We may update this Privacy Policy from time to time. The updated version will be indicated by the date above. If we make material changes, we may notify you by posting the new Policy on our websites or apps, or by contacting you directly. We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

5. THE DATA WE COLLECT ABOUT YOU

“Personal data” or “personal information” means any information about an individual that can be used to identify them. It does not include anonymized or aggregated data.

We collect, use, store, and transfer different kinds of personal data, grouped as follows:

5.1 Information you provide to us

This includes personal information that you give us when filling out forms, completing identity checks, or otherwise communicating with us through our websites (ayni.gold, app.ayni.gold, updates-ayni.gold), mobile applications, email, phone, or other channels. Examples include:

Identity documents and verification photos (“selfies”);
Date and place of birth;
Nationality and citizenship;
Email address and phone number;
Residential or business address and proof of address (e.g., utility bill, bank statement);
Wallet addresses and information about tokens you hold;
Source of funds or tokens used to purchase AYNI;
Other documents or information required to comply with AML/CFT laws and regulations.

All KYC/AML checks are performed by our provider Sumsub. If you do not pass these checks, you will not be able to access Ayni Gold’s services.

5.2 Payment information

When you use fiat payment providers (e.g., Banxa, Binance, Coinbase), we may receive information such as billing address, transaction history, and payment status. This information is used to process transactions, verify payments, prevent fraud, and ensure compliance.

We do not store full card numbers or sensitive financial information. Instead, these are processed securely by our payment partners in accordance with their own security standards.

5.3 Automatically collected information

When you interact with our websites, apps, or services, we may automatically collect certain technical data such as:

Device identifiers, browser type, and operating system;
IP address and approximate geolocation;
Access logs (date/time, user agent, referral URL);
Usage patterns and interactions with our platform.

Like many services, we use cookies, pixels, and similar technologies for analytics, security, and marketing. Where required by law (e.g., EU/UK), we request your consent via CookieYes.

5.4 Information from other sources

We may receive information about you from trusted third parties, such as analytics providers, advertising networks, or marketing partners, and combine it with the information we already hold. Where required, we will inform you about the type and source of such data within the time limits set by law.

5.5 Sensitive personal data

We do not collect special categories of personal data (such as race, religion, health, sexual orientation, or political opinions) and we do not collect information about criminal convictions or offences.

6. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we process your data in the following circumstances:

Consent – When you have given us consent (e.g., for receiving marketing communications, non-essential cookies, or optional services).
Legitimate Interests – Where processing is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override them. For example:
- Providing and improving our websites, apps, and services;
- Ensuring security and preventing fraud;
- Developing and improving our business;
- Enforcing our terms and policies.
Legal Obligation – Where we need to comply with applicable law or regulatory requirements, including:
- AML/CFT (anti–money laundering and counter-terrorist financing) laws;
- Responding to lawful government or judicial requests;
- Investigating or preventing suspected fraud or illegal activities.
Performance of Contract – Where processing is necessary to perform a contract with you, or to take steps at your request before entering into a contract. This covers account creation, identity verification, token purchases, staking, and reward distribution.

We are responsible for verifying your identity for AML/CFT purposes. For internal compliance, we identify all individuals or legal entities with whom we establish or intend to establish business relations or transactions. We also take reasonable measures to verify the beneficial owners (UBOs) of legal entities, including main investors, controllers, or fund managers.

Our websites and apps may use technologies from trusted third-party providers to help us:

Recognize your device and understand how you use our services;
Improve our products and tailor them to your interests;
Deliver advertising about our services that may be more relevant to you.

We may use hashed identifiers (e.g., derived from email addresses) for cross-device tracking and targeted advertising. By using our services, you acknowledge and consent to this type of processing where required by law.

7. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably determine that it is necessary for a related and compatible purpose. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis for doing so.

8. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with carefully selected parties as necessary for the purposes outlined in this Privacy Policy. These include:

Business Transfers – In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the new owner, who will be bound by this Privacy Policy.
Affiliates – Entities controlled by, controlling, or under common control with Ayni Gold.
Service Providers and Partners – Such as:
- KYC/AML: Sumsub;
- Payments: Banxa, Binance, Coinbase;
- Wallet infrastructure: Turnkey (user wallets), Gnosis Safe (treasury, multisig);
- Email & communications: Customer.io, Firebase;
- Hosting: AWS;
- Analytics & advertising: trusted providers including Google, LinkedIn, X/Twitter, Meta, TikTok.

We require all third parties to respect the security of your personal data and process it only for specified purposes under our instructions. They are not permitted to use your personal data for their own purposes or share it further without authorization.

9. INTERNATIONAL TRANSFERS

Your information may be transferred, stored, and processed by us and by trusted third parties with whom we share your data in various countries, including outside the British Virgin Islands, the European Economic Area (EEA), and the United Kingdom. These countries may have different privacy and data protection laws, which may in some cases provide a lower level of protection.

Where we transfer your personal data internationally, we implement safeguards in line with applicable law, such as the use of EU Standard Contractual Clauses (SCCs) or reliance on adequacy decisions. All third parties processing data on our behalf must follow equivalent rules and maintain appropriate protections.

We also follow industry best practices to secure your data, regardless of where it is processed.

10. DATA SECURITY

We implement appropriate technical and organizational security measures to protect your personal data against accidental loss, unauthorized access, alteration, or disclosure. These measures include:

Encryption of data in transit and at rest;
Use of firewalls, monitoring tools, and fraud detection systems;
Regular updates and security reviews.

Access to personal data is restricted to authorized employees, contractors, and service providers who are bound by confidentiality obligations and act under our instructions.

We have procedures in place to detect, investigate, and respond to data breaches. Where legally required, we will notify you and the relevant regulator of any such breach.

Please note that no method of internet transmission or electronic storage is completely secure. While we take steps to protect your information, we cannot guarantee absolute security. You should always access our services through secure networks and devices.

11. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law (e.g., AML/CFT, accounting, or tax obligations).

KYC/AML records are retained for 10 years after the end of the business relationship or as required by law.
Transactional and account data are kept for as long as needed to provide services, comply with obligations, resolve disputes, and enforce agreements.
Marketing data is retained until you withdraw consent or after a defined period of inactivity, subject to legal requirements.

Where possible, we anonymize or aggregate data so it can no longer identify you. Anonymized data may be used indefinitely for research, statistical, or analytical purposes.

12. YOUR LEGAL RIGHTS

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

Request access to your personal data;
Request correction of inaccurate or incomplete data;
Request erasure of your data (“right to be forgotten”);
Object to or restrict processing of your data;
Request data portability (transfer of your data in a structured format);
Withdraw consent where processing is based on consent;
Lodge a complaint with a supervisory authority.

If you are in the EU/UK, you may exercise these rights under the GDPR/UK GDPR. If you are in the US (including California), you may have additional rights such as to know, delete, or opt out of certain processing.

You may exercise your rights at any time by contacting us at privacy@ayni.gold. We will respond within one month (30 days) as required by law and may extend this period where permitted.

No fee is charged for exercising these rights, unless your request is manifestly unfounded or excessive. If you withdraw consent, this will not affect the lawfulness of prior processing, but it may limit the services we can provide.

13. THIRD-PARTY LINKS

Our websites, apps, and services may include links to third-party websites, services, plug-ins, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control third-party websites or services and are not responsible for their privacy practices. When you leave Ayni Gold’s websites or services, or interact with features hosted on third-party platforms, we encourage you to review the privacy policies of those providers.

13.1 APP AND SUBSCRIPTION: PRIVACY CONDITIONS AND REQUIREMENTS

Our mobile applications (iOS and Android) include a link to this Privacy Policy both in the App Store/Google Play metadata and within the app in an easily accessible manner.

Developer enrollment: The apps are published under Ayni Token Inc. (Ayni Gold).
Transparency: App metadata, descriptions, screenshots, and previews accurately reflect the core experience and are updated with new versions. We do not use misleading or copycat content.
Data collection: We only request access to data relevant to the core functionality of the app and required by applicable laws (e.g., KYC/AML checks). We do not collect or repurpose personal data without user consent, except where otherwise permitted by law.
Consent & rights: Users may withdraw consent and/or request deletion of their data at any time as set out in this Privacy Policy. Account creation and account deletion options are available within the app.
No profiling: Our app does not build user profiles beyond what is necessary for providing services (e.g., account management, staking, reward distribution). We do not attempt to re-identify anonymized data.
User permissions: We respect system-level permissions and do not manipulate or trick users into granting unnecessary data access.
Security: Appropriate security measures are applied to protect user data from unauthorized access, disclosure, or misuse.
Content standards: App content is created or licensed by Ayni Gold, complies with applicable laws and Apple/Google policies, and avoids offensive, insensitive, or misleading material.
Support: Users can easily contact us through in-app support channels or via privacy@ayni.gold.

We comply with the Apple App Store Review Guidelines, Google Play requirements, and applicable data protection laws (including GDPR, UK GDPR, and US privacy laws).

14. COOKIES

We may use cookies and similar tracking technologies (such as web beacons, SDKs, and pixels) to collect and store information.

Cookies are small text files placed on your device when you visit a website or open an email. By using our websites (including https://ayni.gold, https://app.ayni.gold, and related subdomains), you consent to our use of cookies in accordance with this Privacy Policy and your preferences recorded through our CookieYes consent banner.

We use cookies and similar technologies to:

Enhance your experience and remember preferences (e.g., language, region);
Personalize content and tailor your interaction with our services;
Analyse site and app traffic and understand how users interact with our platform;
Provide security and prevent fraud;
Deliver and measure advertising, including via third-party platforms such as Google, Meta, LinkedIn, X/Twitter, and TikTok.

Depending on your device settings, we may collect information such as your device identifier, IP address, operating system, mobile carrier, and approximate location, in accordance with applicable law. If any information collected through cookies qualifies as personal data, this Privacy Policy applies to its use.

You have control over your cookie preferences and may adjust them at any time using the CookieYes consent tool or your browser/device settings. Please note that disabling certain cookies may affect the functionality of our services.

We monitor developments in privacy regulations and will update this section when necessary. The most recent version of this Privacy Policy will always be available on our website.

14.1 WHAT ARE COOKIES

Cookies are small text files that are stored on your device when you visit websites or apps. They help remember your actions and preferences over time, such as language settings, session information, or content you’ve viewed. Cookies may record details like the pages you visit, advertisements you interact with, your device type, and the duration of your sessions.

Cookies are unique to your browser, device, or account:

Session cookies last only while your browser is open and are deleted when you close it.
Persistent cookies remain until you or your browser delete them, or until they expire at the end of their set retention period.

Ayni Gold sets specific retention periods depending on the function of the cookie.

For more information about cookies generally, you can visit: https://www.allaboutcookies.org/

14.2 HOW WE USE COOKIES

We use cookies and similar tracking technologies (such as web beacons, SDKs, and pixels) to store information, improve your experience, personalize content, analyse website and app traffic, and enable advertising and social media features. These technologies help us understand how you interact with our services, so we can make improvements and provide a more convenient online experience.

We categorize cookies as follows:

Necessary Cookies:
- Enable core functionality like page navigation and secure access;
- Balance traffic across servers for stable performance;
- Maintain your cookie and consent preferences;
- Ensure the website and apps function properly.
  These cookies do not require consent and cannot be disabled in our systems.
Preferences Cookies:
- Remember choices such as language, location, and display settings;
- Store your regional or country-specific preferences.
Statistics Cookies:
- Collect data on how users interact with our websites and apps;
- Help us improve features, services, and user experience;
- Measure and analyse performance (e.g., navigation flows, survey responses, satisfaction feedback).
Targeting Cookies:
- Provide advertising relevant to your interests;
- Support online behavioural/interest-based advertising;
- Allow different versions of a page to be shown for marketing purposes;
- Help us and partners (such as Google, Meta, LinkedIn, X/Twitter, TikTok) deliver tailored ads across devices and platforms.

We use web analytics and advertising services such as Google Analytics, along with other third-party analytics and ad pixels. For example, Google may use collected data to contextualize and personalize ads within its network.

If you wish to opt out of Google Analytics cookies, you may install the browser add-on provided by Google: https://tools.google.com/dlpage/gaoptout (compatibility depends on your browser).

Your consent preferences for non-essential cookies are managed via our CookieYes banner, where you can enable or disable categories at any time.

14.3 WHAT COOKIES DO WE COLLECT AND HOW DO THEY WORK

Our cookie banner, managed through CookieYes, ensures that non-essential cookies are only activated after you have provided consent. Until you give consent, only essential cookies required for the basic operation of our websites and apps will be active.

When you consent, analytics and advertising integrations such as Google Analytics, Google Ads, and other third-party pixels (including Meta, LinkedIn, X/Twitter, TikTok) will begin to function in line with your preferences.

Cookies are grouped by purpose as follows:

Necessary – e.g., security_storage
Preferences – e.g., functionality_storage
Statistics – e.g., analytics_storage
Targeting – e.g., ad_storage, ad_user_data, ad_personalization

For more technical details about Google’s consent mode and cookie mapping, you can visit:

14.4 WHO MANAGES THE COOKIES

Cookies placed on your device may be either first-party cookies or third-party cookies:

First-party cookies are placed directly by Ayni Gold to operate our websites and services.
Third-party cookies are placed by trusted partners such as Google, Meta, LinkedIn, X/Twitter, TikTok, and other analytics or advertising providers. These partners may process data collected through their cookies in accordance with their own privacy policies.

We do not directly share cookie data with unrelated third parties. Any data exchanges with advertising networks or analytics providers occur through integrated platforms (for example, via Google or other trusted providers) and are limited to the purposes set out in this Privacy Policy.

14.5 HOW PERSONAL DATA COLLECTION TAKES PLACE

The personal data we collect through cookies and similar technologies may include information such as:

How you use and navigate our websites and apps;
Your choice of internet browser and device type;
General geographic location (derived from your IP address).

All location data is processed in an anonymized way. We do not track the exact, identifiable location of individual users.

14.6 RETENTION PERIOD

We use cookies with varying retention periods, depending on their purpose:

Necessary Cookies:
- Session cookies: temporary, deleted when you close your browser.
- Persistent cookies: remain up to 12 months to store essential preferences or consent.
Preferences Cookies:
- Remain up to 24 months to remember your language, region, or other custom settings.
Statistics Cookies:
- Retained for up to 24 months to analyse usage and improve functionality.
Targeting Cookies:
- Retained for up to 12 months to deliver personalized advertising in line with your consent.

These retention periods align with industry standards and may be adjusted if required by applicable laws or updated practices.

14.7 SECURITY MEASURES

We have implemented measures to protect any data collected through cookies and tracking technologies. In particular:

Cookie data is processed in anonymized or aggregated form wherever possible, ensuring that no personally identifiable information is disclosed beyond what is necessary.
Access to cookie data is restricted to authorized staff and trusted partners operating under strict contractual and legal safeguards.
Security and privacy remain top priorities, and we continuously review and update our safeguards to meet applicable standards.

Ayni Gold is committed to maintaining the confidentiality and integrity of all user information collected through our services.

14.8 ONLINE BEHAVIORAL ADVERTISING

Online behavioral advertising, also known as interest-based advertising, allows us to display advertisements that are more relevant to your interests based on your browsing history and interactions.

We may use cookies, pixels, and partnerships with advertising networks and social media platforms (such as Google, Meta, LinkedIn, X/Twitter, TikTok) to:

Serve advertising tailored to your interests;
Retarget ads based on content you recently viewed;
Limit how often you see the same advertisement.

For these purposes, we may collect technical information such as IP address, device identifiers, operating system, mobile carrier, time zone, and platform type.

You can opt out of targeted advertising if you prefer not to have your ads personalized. Please note: opting out does not remove advertising altogether, but it will mean you see more generic ads that are not tailored to your interests.

14.9 OUR PARTNERSHIP WITH ADVERTISING NETWORKS

We only share data with advertising networks under strict safeguards and solely for the purpose of serving more relevant advertising. These partners are required to process your data in accordance with applicable privacy laws and contractual obligations.

You may opt out of personalized advertising from these networks at any time by visiting their opt-out pages or by adjusting your preferences in the CookieYes consent banner on our website.

14.10 MANAGING COOKIE PREFERENCES

You can manage your cookie preferences in several ways:

Adjust browser settings to block or delete cookies;
Use our CookieYes consent tool to allow only necessary cookies or to update your consent choices;
Opt out directly via advertising partners’ preference settings.

Please note: disabling or deleting cookies may limit functionality and prevent parts of our websites or services from working properly. For example, we may not be able to remember your language or region preferences, recognize that you accepted our Terms and Privacy Policy, or maintain your opt-out choices. If cookies are cleared, you may need to reset your preferences.

14.11 BROWSER SETTINGS

You may block, restrict, disable, or delete cookies through your browser settings. However, if you block all cookies, parts of our websites or apps may not function properly. These settings are usually found in the “options” or “preferences” menu of your internet browser.

14.12 THIRD-PARTY TOOLS

You may also use third-party cookie management tools to manage cookies. Please note that Ayni Gold does not provide or support such tools directly, unless otherwise stated in this Privacy Policy.

14.13 CLICKSTREAM DATA

Clickstream data refers to the sequence of pages or links you click on while using a website. We may collect clickstream data when you use our websites and apps, including referrals from other websites, to help us understand user behavior and improve the online experience. This data is used for statistical and analytical purposes only and is not stored as part of your customer record.

14.14 CONTACT US (Cookies)

If you have any questions about our use of cookies or tracking technologies, please contact us at: privacy@ayni.gold

15. OPT-OUT MECHANISMS

You have the right to opt out of targeted advertising. You can manage your preferences via our CookieYes consent banner, or by using recognized third-party industry tools such as:

Digital Advertising Alliance (DAA):
- Visit the WebChoices tool: https://optout.aboutads.info/
- Allows you to view and opt out of participating companies’ data collection for interest-based advertising.
Network Advertising Initiative (NAI):
- Visit the NAI opt-out page: https://optout.networkadvertising.org/
- Allows you to opt out of tracking by NAI member companies.
European Interactive Digital Advertising Alliance (EDAA):
- For users in the EEA, visit: https://www.youronlinechoices.eu/
- Manage preferences and opt out of companies using your data for targeted ads.

Please note: these tools rely on cookies to record your choices. If you delete or clear cookies, your opt-out preferences may need to be set again.

You can also control data collection at the browser or device level by adjusting your privacy settings. For instructions, please refer to the help section of your browser (e.g., Chrome, Firefox, Safari) or your device vendor’s guidance.

If you have concerns about our data processing or your privacy settings, you may contact us at: privacy@ayni.gold

16. JURISDICTION-SPECIFIC DISCLOSURES (EUROPE – GDPR/UK GDPR/Switzerland)

If you are located in the European Economic Area (EEA), Switzerland, or the United Kingdom (UK), the General Data Protection Regulation (GDPR) and equivalent laws may apply to the processing of your personal data.

Compliance with GDPR and UK GDPR
Ayni Gold processes personal data in line with the GDPR’s requirements, including lawful bases for processing, respecting your rights as a data subject, and ensuring adequate safeguards for international data transfers.

Lawful Bases for Processing (Art. 6 GDPR):
We will only process your personal data when we have a lawful basis to do so, which may include:

Consent – where you have clearly agreed to processing for a specific purpose.
Contract – where processing is necessary for performing a contract with you or taking steps at your request before entering a contract.
Legal Obligation – where processing is necessary to comply with applicable laws and regulations.
Legitimate Interests – where processing is necessary for our legitimate business interests (or those of a third party) and your fundamental rights and freedoms do not override those interests.

Your Rights under GDPR/UK GDPR
As a data subject, you have the following rights:

Right of Access – request a copy of the personal data we hold about you.
Right to Rectification – request correction of inaccurate or incomplete data.
Right to Erasure – request deletion of your personal data in certain circumstances.
Right to Restrict Processing – request limitation of how your data is processed.
Right to Data Portability – request the transfer of your data to another controller or directly to you, in certain circumstances.
Right to Object – object to processing, including processing for direct marketing.
Rights Related to Automated Decision-Making – not to be subject to decisions based solely on automated processing (including profiling) which produce legal or similarly significant effects.

International Transfers
If we transfer your personal data outside the EEA, Switzerland, or the UK, we ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs) approved by the European Commission or UK authorities;
Adequacy Decisions where the European Commission or UK government has recognized a country as providing adequate protection.

Retention & Safeguards
We retain personal data only for as long as necessary for the purposes collected, including legal, accounting, or reporting requirements. We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, or destruction.

Complaints
If you believe your data protection rights have been violated, you may lodge a complaint with your national Data Protection Authority (DPA). Contact details for DPAs can be found here:
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

17. DATA USAGE AND SHARING CLARITY

We collect and process personal data for clearly defined purposes, including:

Providing our services and platform functionality;
Conducting AML/KYC checks;
Performing contracts and processing transactions;
Complying with applicable legal obligations.

This may involve processing information such as your identity details, contact information, wallet addresses, and browsing behavior.

We may share this information with trusted third-party service providers and affiliates, but only to the extent necessary to fulfill the purposes outlined in this Privacy Policy. All third parties are required to process data securely, lawfully, and under our instructions.

18. POLICY UPDATES AND NOTIFICATIONS

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements.

When material updates occur, we will notify you by posting the revised Privacy Policy on our websites and apps, or by other appropriate means (such as email notifications). We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

19. CONTACT US

If you have any questions, comments, or requests about this Privacy Policy or our handling of personal data, please contact us at:

privacy@ayni.gold

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