CiNKO Digital Wallet Privacy Policy
This Privacy Policy was last updated on February 9, 2026.
Effective date: December 1, 2025
CiNKO ("we," "us," "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, and share your personal data. Where required by law, we will seek your consent for certain processing activities.
By using our Services, you acknowledge the practices described in this Privacy Policy. Where required by applicable law, we will seek your consent for specific processing activities. This Privacy Policy should be read in conjunction with our General Terms and Conditions (the “Terms”) and any other applicable policies, which together govern the use of your personal data in connection with your CiNKO Account and the Digital Asset Services offered through the CiNKO Platform. Capitalized terms not defined in this Privacy Policy shall have the meaning assigned to them in the Terms.
We recommend that you periodically review this policy to stay informed about how we collect, use, and protect your information.
1. Information we collect
We collect various types of information, including:
Personal information
Information provided when creating your Account, such as your name, email address, phone number, and other identifying information.
Sensitive information
This may include biometric data, such as biometric templates (e.g., a photograph of your face for identity verification purposes) or any images you upload to our applications for authentication and security purposes. Sensitive data will only be collected with your express consent and will be used in accordance with applicable regulations.
Transaction data
Information related to the use of Digital Wallet Services, such as payments, transfers, and transaction history.
Location data
When permitted, we collect precise location data while the CiNKO Platform is running, either in the foreground or background. You can disable location tracking in your device settings.
Device and usage data
We collect technical information related to your mobile device and your interaction with the Platform, which may include:
Technical data: Internet Protocol (IP) address used to connect your device to the internet, login data, browser type and version, time zone, device language, operating system and platform, as well as the use of a virtual private network (VPN).
Device information: the type of device used, including a unique identifier (such as the IMEI number or mobile phone number), mobile network information, and the device's operating system.
Interaction with the Platform or mobile application: information about how you interact with our Platform or App, such as pages or services viewed, links selected, response times, and errors detected.
Transaction-related data: information about transactions carried out through the Platform, including date, time, amount, currency, beneficiary details, and IP addresses of both the sender and the recipient. We may also collect information about the payment method and the device used.
Stored information: if you grant permission, we may access information stored on your device—such as contacts, login credentials, photographs, or other digital content—to facilitate certain platform features.
2. How we use your information
We use your data for the following purposes:
- Provide, maintain, and improve the CiNKO Platform and Digital Wallet Services.
- Verify your identity and authenticate your Account.
- Provide Digital Wallet Services and manage your Account.
- Detect, prevent, and investigate fraud, security breaches, and other suspicious activities, in compliance with anti-money laundering (AML) regulations.
- To communicate with you about service updates, issues related to your account, or changes to policies.
- Responding to requests and inquiries made through the CiNKO Platform and/or maintaining contact with you, managing comments, complaints, and suggestions, and providing you with assistance.
- Improve our Services through statistical analysis and studies, as well as monitor how CiNKO Users interact with the Services.
- Comply with legal and regulatory obligations. In addition to specific industry regulations, other provisions relating to the prevention of money laundering and terrorist financing, general reporting regimes, tax collection regimes, and requirements of administrative and/or judicial authorities, among others, are also applicable.
We may use your contact information (email, phone number) to send you news, updates, and promotions about our services. We may also work with advertising platforms and social networks using limited contact information in encrypted or hashed form to deliver personalized advertising and perform audience measurement and analysis. You may opt out of these uses as detailed below.
We will only use the personal data collected for the specific purposes for which you have given your consent. If we need to use your data for a purpose other than that initially stated, we will notify you in advance and, where appropriate, request your express consent before proceeding.
3. Sharing of information
We may share your information in the following circumstances:
With service providers
We work with trusted third parties who provide services on our behalf—such as digital wallet processing, cloud services, customer service centers, regulatory compliance, and IT services. These third parties are subject to strict confidentiality obligations and must protect your data in accordance with standards equivalent to ours.
Legal and regulatory requirements
We may disclose your information to comply with applicable laws or regulations, judicial or administrative proceedings, or to protect the rights or property of CiNKO. For example, we may share your personal data with competent state authorities, government agencies, financial institutions, or courts when such disclosure is necessary to comply with the law, exercise or defend our rights, or protect your vital interests or those of third parties.
With affiliates and partners
We may share information with our partners, affiliates, agents, and suppliers to process transactions or for research and development purposes.
Advertising and marketing partners
We may share limited personal information—such as your email address or phone number—with advertising platforms and social networks to create custom audiences, deliver relevant ads, measure campaign effectiveness, and generate lookalike audiences. These partners will use the information to identify CiNKO users and provide us with advertising tools and measurement services in accordance with their own terms and applicable privacy obligations.
Business transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transition process.
4. Data security
We recognize the importance of protecting and managing your personal information. All personal information we use will be treated with the utmost care and security. We implement a combination of physical, technical, and administrative security measures, including:
- Encryption: Data is encrypted both during transmission and at rest.
- Access controls: Access to your information is limited exclusively to authorized personnel.
- Monitoring: We regularly monitor for unauthorized access or suspicious activity.
While we take reasonable measures to protect your data, no system is completely secure, and we cannot guarantee absolute security.
If you use a password, PIN, or authorization code to access your CiNKO Account or use the Digital Wallet Services, you are responsible for keeping that information strictly confidential. Do not share it; we will never ask you for it.
5. Transactions carried out on the blockchain
Blockchain technology functions as a decentralized, immutable ledger that allows transactions to be recorded and tracked. Each transaction is securely stored in a "block" and linked to the previous block, creating a chain of information that is virtually impossible to modify once confirmed. This immutability is an essential feature of blockchain.
Transactions carried out using blockchain involve the storage of data that may include personal information. Once a transaction has been recorded, CiNKO has no control over this data and cannot modify or delete it. Due to its decentralized nature, no entity—including CiNKO—can alter or delete information confirmed on the blockchain.
5.1 Data involved in blockchain transactions
When conducting a transaction on a blockchain network through the CiNKO platform, certain personal information may be recorded, including:
- Address of the source wallet.
- Destination wallet address.
- Transaction amount.
- Date and time of the operation.
Due to the inherent design of blockchain, this information will become part of a public and immutable record, which could limit the exercise of certain data protection rights, such as the right to erasure or rectification. Although some technologies can restrict third-party access, the data will remain permanently stored and cannot be completely deleted.
5.2 Considerations for CiNKO Users
If you use CiNKO's Digital Wallet Services that utilize blockchain technology, we recommend that you consult our Frequently Asked Questions (FAQ) section for additional information on how these transactions work. We also advise you to conduct your own research before operating with blockchain, especially if you are concerned about the impact this technology may have on the exercise of your privacy rights.
6. User rights
As a CiNKO User, you have certain rights regarding your personal information, including:
- Access and rectification: you can access your personal information or update it directly from your Account.
- Data portability: you may request a copy of your personal data in a commonly used format.
- Data deletion: You may request the deletion of your data, subject to legal obligations (e.g., AML regulations).
- Marketing opt-out: You may opt out at any time from receiving promotional communications or from the use of your data for direct marketing purposes via the Platform or by contacting us. If you exercise this option, your data will not be shared with advertising partners for these purposes.
To exercise any of these rights, you can contact us at [email protected].
In the event of a data security breach, we will notify the relevant supervisory authority and inform affected CiNKO Users when such breach poses a high risk to their personal information.
7. Location data and consent
We collect precise location data to provide and improve the Services. You can disable tracking from the CiNKO Platform; however, certain features may be affected.
8. AML compliance and legal obligations
CiNKO complies with AML regulations and applicable legislation in all jurisdictions where it operates. We may be required to report suspicious transactions or activities to the relevant authorities. Your data may be used and disclosed in accordance with these legal obligations.
9. International data transfers
Since CiNKO operates globally, your information may be transferred to other countries. When we make international transfers, we will implement appropriate safeguards and legal mechanisms to protect your information.
10. Data retention
We will retain your personal information for as long as necessary to provide our Services and comply with legal obligations. Transaction data may be retained for regulatory purposes, including AML compliance.
11. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If substantial changes are made, we will notify you via the CiNKO Platform, by email, or other prominent means. We recommend that you review this policy periodically.
12. Contact us
If you have any questions or concerns regarding this Privacy Policy, you can write to us at [email protected].
