Privacy Policy

Effective date: August 1, 2023

Overview

At Bitt, our purpose is to uplift everyone, everywhere, by implementing the best Central Bank Digital Currency products and services. We do the right thing while respecting others, and our culture serves our clients and customers as we deliver expectations. Trust and accountability are key tenants to Bitt’s success, and respecting your privacy is central to our purpose. Bitt strives to comply with all privacy laws in all countries and states where we operate. This privacy statement explains how and why Bitt collects, stores, uses, and shares personal information when you visit our websites or use our services, software, and products. Reading it will help you understand your privacy rights and choices. By using Bitt’s website or services, software, and products, unless explicitly modified by a written agreement executed by you and Bitt, you agree to the collection and use of information in accordance with this privacy statement and the applicable user agreement.

“Personal information” in this statement means information about you, including your identity, finances, and online behavior. It also includes other information that may be associated with your personal information.

“Bitt” in this statement means Bitt Inc. This privacy statement applies to any product, service, or software offered by Bitt and its direct or indirect subsidiaries and affiliates, and applies to all users. It applies to all individuals who use Bitt’s Services for personal purposes (the “Customers”) and those who use Bitt’s Services in the course of their trade or business (the “Merchants”) and applies to all users not identified in the foregoing categories.

Bitt is a global company. Your information may be transferred to another location or jurisdiction.

Your privacy rights and choices

You have rights and choices when it comes to how your personal information is collected, stored, used, and shared.

Understanding your rights

We respect your rights to access and correct your information, and to request that we delete your information if we no longer need it for a business purpose. If you or an authorized agent want to see or delete your personal information, you may contact us. We will not deny you services, charge you different prices, or provide you with a different level of service solely for exercising your privacy rights.

If you or an authorized agent request to see or delete your personal information, we’ll first need to verify who you are before we can respond to your request. If we can’t verify your identity, we will not be able to fulfill your request. If you request that we delete personal information, we still need to keep some personal information so we can:

• Provide goods or services you requested, or comply with our promises to you in the user agreement or other contract you have with us

• Detect and prevent malicious, fraudulent, or illegal activity
• Protect your, or another person’s legal rights
• Manage our internal business processes that are reasonably related to your expectations when using our services
• Maintain the integrity of any blockchain system with which we engage
• Comply with laws.

You may have different rights and choices for managing your personal information depending on where you live.

Bitt is not responsible for Merchant data mishandling. If you have questions about how your Merchant handles your personal information, please check the privacy statements provided by these companies and contact them directly for assistance with any privacy requests. When Bitt acts as a service provider (also called a data processor) for our Customers, and clients, we only process your information as instructed by our Merchant to provide Bitt’s services, and other appropriate purposes, like recordkeeping and compliance. We rely on our Merchants to provide you with appropriate privacy statements to manage your privacy rights.

1. When you access our website, information about the internet address of websites from which you link to our website and from which you came before landing on our website, the browser that you are using, and your navigation and preferences on our website are collected. All of this information is used internally for the purpose of understanding how our website is being used, and improving our website. We also use third party analysis tools to collect data about your use of our mobile applications. The information collected identifies the nature and timing of the actions you take within our mobile applications, including installation, registration, uploading, and certain types of navigation. All of this information is used internally for the purpose of understanding how our mobile applications are being used and to facilitate the improvement of mobile applications.

1. We aggregate data collected about the use of our website for administration purposes, to protect and improve our website and our systems, to better understand the preferences of our website visitors and optimize the content that we serve, to identify server problems, to compile aggregated statistics about our website usage, and to improve our marketing and research.

1. When you visit our website, we use action tags (also called pixel tags, clear GIF or beacons) to identify some of the pages that you visit and how you use the content on those pages. Action tags may collect and transmit this data in a manner that identifies you if you have registered with our website or are logged into our website. We also use action tags in our emails to determine whether an email was opened or whether it was forwarded to someone else. When you use our mobile apps, we use action tags where you are accessing websites from links in our mobile apps. These may identify the pages that you visit and how you use the content on those pages.

In all cases, the information we collect is subject to applicable laws and the choices you may have exercised. If you want to know more about how we use cookies, read our Cookie Notice.

Why we collect personal information about you

Like most banks or financial payment service providers, Bitt works with third party service providers that offer important functions for us to use, which facilitate or support Bitt’s services. We disclose user data to third parties, from time to time, so they can offer services. We do not sell your personal information. We collect personal information for many reasons, including to improve your experience, to advise our clients on how to better interact with and serve you, and to run our business. Sometimes we share the personal information we collect with third parties to help us provide services, protect our Customers from risk and fraud, market our products, and comply with legal obligations. Specific reasons why we collect your personal information include:

1. Run our sites and provide better services

1. Update your information, which includes name, address, phone number, email, username, photograph, IP address, account numbers, account types, government-issued identification numbers, date of birth, physical address, source of funds, statements and reports, currency, and any other account preferences.

1. Manage and improve our business.

1. Understand data generated by or about transactions you complete using Bitt services, including information related to the value, volume, nature, and other details of a transaction.

1. Protect our business and our Customers from risk and fraud, including fraud that involves our business partners, strategic ventures, or other individuals and Merchants

1. Contact you when you need us, such as answering a question you sent to our customer service team via our contact form, or if you requested a demo.

1. Enforce our agreements with you and other people who use our services.

1. Obtain other identification information required for us to comply with our anti-money laundering obligations under applicable law.

1. You consented or gave us permission to collect or share the information.

Please note that we may also use and disclose information that is not personally identifiable. For example, we may publish reports that contain aggregated or statistical data, such as reports showing usage trends. These reports do not contain any personal information.

Why personal information is disclosed to others

We may disclose your personal information to:

1. Other members of the Bitt corporate family, to provide services you’ve requested and authorized, manage risk, help detect illegal and fraudulent acts and other violations of our policies and agreements, and to help us manage the availability and connectivity of Bitt’s products, software, and services.

1. Merchants, financial institutions, and third parties as needed to enable Bitt’s services, products, or software, manage fraud, compliance and complaints, and for similar purposes

1. Our service providers, who use your information to provide services to us, and are required to protect it

1. Our affiliates, which may only use your information for the purposes described in the privacy statement

1. Financial institutions, like banks

1. Courts, governments, regulators, and law enforcement when accompanied by a subpoena or other legal documentation that requires Bitt to respond

1. People involved in a transaction, like other users, Merchants, and their service providers

1. Third parties that you asked us to connect with

1. Third-party tools used to help fight spam and abuse

1. Other third parties to:

• Comply with laws
• Investigate or enforce violations of our user agreement
• Facilitate a merger, purchase, or sale of part of all our business

• Comply with rules
• Enforce our contracts
• Protect our property, or the rights, property, or safety of others
• As needed for audits, compliance, and corporate governance
• To prevent physical harm or illegal activity

Data protection and security

Online privacy and security

Bitt has high standards when it comes to information security. Helping to keep your personal information safe against loss, misuse, unauthorized access, disclosure, and alteration is our priority.

To protect your personal information, we use technical, physical, and administrative security measures that include:

• Firewalls
• Data encryption

• Physical access controls at our data centers, if applicable
• Authorize access to your personal information only to employees who need it to fulfil their job responsibilities

While we use reasonable physical, electronic and procedural safeguards to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction, please be advised that we do not accept responsibility for the security of any data transmitted over the internet or information stored, posted or provided directly to a third-party website, which is governed by that third party’s policies. You are responsible for keeping your password(s) and account information private. You are also responsible for making sure your personal information is accurate and up to date.

When you visit our website, use our mobile applications, use our services or products, or engage with our emails and online ads, we may collect information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, and web beacons. In some cases, the information we collect is only used in a non-identifiable way. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns. We do not use this information to profile you or target our ads.

In other cases, we may use the information in an identifiable way. For example, we may authenticate you or your device, deliver personalized content or use the information for analytics, fraud detection, and security. We may also use the information for online ad targeting. Our Cookie Notice provides more information about our online data collection technologies and your choices.

Our websites may enable you to interact with us and others via social media platforms. We collect information from these platforms as permitted by the sites’ legal terms. We may also display ads to you when you are using these platforms. If you submit information to a social media platform or other online service, your information is governed by their privacy policies, which you should read carefully prior to use. Please be aware that social media platforms or online services may have different privacy policies than Bitt, and we are not responsible for the practices or procedures of third parties.

Residents of some states and countries have additional privacy rights. Information on these rights are provided in the supplemental privacy statements posted in https://www.bitt.com/policy.

Password Protection

We strongly recommend that you do not share your password(s) with anyone. An authorized Bitt representative will never ask you for your password. Therefore, any email or other communication requesting your password, or any similar information, should be treated as unauthorized and suspicious. If you receive such a communication, please promptly forward it to Bitt.

If you do share your password(s) with a third party for any reason, the third party will have access to your account and your personal information, and you, not Bitt, are responsible for all actions taken using your password.

Contact us

If you have any questions about this privacy statement, or would like help exercising your privacy rights, please contact us so we can help.

You can:

• Email us: [email protected]

Please do not include sensitive information, like financial or account numbers, in emails.

• Mail us a letter:

Bitt, Inc.

Attn: Legal Department

12180 S 300 E #117

Draper, UT 84020, USA