Privacy Policy

Version 1.0, effective as of September 15, 2026.

1. Who we are

1.1. This Privacy Policy describes how Kairos Solutions Group LLC, a limited liability company organized under the laws of the State of Wyoming, United States of America, with its registered office at 30 N Gould St, Ste N, Sheridan, WY 82801, United States ("Kairos"), processes the personal data of those who use the KairosPay application and services (the "Service").

1.2. This Policy forms part of the Terms of Use. Capitalized terms not defined here have the meaning given in the Terms of Use.

2. Data we collect

2.1. Registration data: first name, last name, email address, phone number and other data provided when creating the account.

2.2. Identity verification data: identity documents, tax identification number, date of birth, nationality, address, facial image and proof of liveness, collected by a specialized identity verification provider engaged by Kairos.

2.3. Operational data: source and destination blockchain addresses, history of deposits, withdrawals and conversions, Balance, and Card transaction data to the extent shared by the Issuing Partner.

2.4. Technical data: IP address, device identifiers and characteristics, operating system, access logs and application usage records.

2.5. Communications: messages exchanged with the support channel.

3. What we use the data for

3.1. To provide the Service: create and maintain the account, execute deposits, withdrawals, conversions and the operations described in the Terms of Use, and enable the issuance and use of the Card by the Issuing Partner.

3.2. To comply with legal obligations: identity verification, anti-money laundering and counter-terrorism financing, sanctions screening, transaction monitoring, responses to authorities and record keeping.

3.3. Security: authentication, fraud prevention, detection of unauthorized access and protection of the integrity of the Service.

3.4. Communication: operational notices, transaction notifications, changes to the Terms and to this Policy, and Customer support.

3.5. Kairos does not sell personal data.

4. Grounds for processing

4.1. Processing is carried out in accordance with applicable law, based on the performance of the contract entered into with the Customer, compliance with legal and regulatory obligations, Kairos' legitimate interest in protecting the Service against fraud and abuse, and consent, where required.

5.1. The Card's Issuing Partner, to the extent necessary for the issuance, operation and settlement of Card transactions.

5.2. The identity verification provider, for the purposes of clause 3.2.

5.3. Fiat conversion partners, when the Customer uses features that depend on them, to the extent necessary for the operation.

5.4. Infrastructure providers (hosting, communication and technical services), which process data on Kairos' behalf and under contractual obligations.

5.5. Public authorities, when required by law, regulation or judicial order, including without prior notice to the Customer where the law so provides.

6. International transfers

6.1. Kairos is a US company and data may be processed in the United States and in other countries where Kairos and its providers operate. By using the Service, the Customer is aware that their data may be transferred to and processed outside their country of residence, with the safeguards required by applicable law.

7. How long we keep data

7.1. Data is kept while the account is active and, after closure, for the period necessary to comply with legal and regulatory obligations, including anti-money laundering obligations, and for the regular exercise of Kairos' rights.

8. Data subject rights

8.1. In accordance with the law applicable to their residence, the Customer may request: confirmation of processing, access to data, correction of incomplete or outdated data, deletion of unnecessary data (subject to the legal retention periods of clause 7), portability where applicable and information about the sharing carried out.

8.2. Requests are made through the support channel of clause 12.2. Kairos may require identity verification before responding and may refuse requests that conflict with legal obligations, stating the reason.

9. Security

9.1. Kairos adopts technical and organizational security measures in the safekeeping of private keys, in data storage and in the operation of the Service. No system is immune to failure.

10. Cookies and local storage

10.1. The Service uses cookies and local storage strictly necessary for its functioning, such as session and authentication. Should Kairos come to use analytics or advertising cookies, this Policy will be updated beforehand.

11. Minors

11.1. The Service is not intended for persons under 18 years of age and Kairos does not knowingly collect data from minors. Accounts identified as belonging to minors will be closed.

12. Changes and contact

12.1. Kairos may amend this Policy. Material changes are communicated at least 30 days in advance, by email and in the application. Changes required by law may take effect immediately.

12.2. Contact for privacy matters: through the application's support channel or the email address published at kairospay.app.

12.3. In the event of any discrepancy between the Portuguese version and any translation, the Portuguese version prevails.