Datenschutzrichtlinie

Last Updated: January 15, 2026

This Privacy Policy describes how personal data is collected, used, stored, and shared within the CT Technologies ecosystem, including all mobile applications, websites, and related digital services (collectively, the “Services”). This Privacy Policy applies to all users of the Services.

1. Data Controller

The primary data controller for the Services is:

CT Technologies spółka z ograniczoną odpowiedzialnością

ul. Michała Kleofasa Ogińskiego 11/9, 03-318 Warszawa, Poland

KRS: 0001098738 | NIP: 5243003455 | REGON: 528307439

CT Technologies determines the purposes and means of processing personal data within the Services.

2. Ecosystem Participants and Data Roles

The Services operate through a multi-entity structure with clearly separated data roles:

2.1 CT Technologies

CT Technologies acts as the primary data controller and is responsible for:

• user account management;
• compliance with applicable data protection, AML, and regulatory requirements;
• approval and execution of cryptocurrency payouts;
• overall operation of the Services.

2.2 CryptoCompany OÜ

CryptoCompany OÜ (Estonia) acts as a data processor on behalf of CT Technologies and is responsible for:

• software development and maintenance;
• technical operation of mobile applications and web services;
• processing of payments via Google Play and Apple App Store strictly in accordance with the rules of the respective app store.

CryptoCompany processes personal data only on documented instructions from CT Technologies.

2.3 Zafiro Innovation Systems LLC

Zafiro Innovation Systems LLC (Costa Rica) acts as an independent entity for limited purposes related to:

• provision of corporate cryptocurrency liquidity;
• execution of cryptocurrency transactions associated with approved payouts;
• compliance checks related to cryptocurrency transfers.

Zafiro does not operate user accounts or provide consumer-facing services.

3. Categories of Personal Data Collected

Depending on how you use the Services, we may collect the following categories of personal data:

3.1 Account and Identification Data

• email address;
• username or account identifier;
• country of residence;
• age confirmation;
• identity verification data (only when required for AML/KYC).

3.2 Usage and Technical Data

• device identifiers;
• operating system and app version;
• IP address and approximate location;
• usage logs, timestamps, and interaction data;
• diagnostic and performance data.

3.3 Payment-Related Data

• transaction identifiers;
• purchase status and history;
• payment method type (store billing or cryptocurrency);
• blockchain transaction hashes (for cryptocurrency payments or payouts).

4. Purposes of Data Processing

Personal data is processed for the following purposes:

• providing and operating the Services;
• maintaining user accounts and access control;
• processing software license purchases;
• detecting fraud, abuse, and prohibited conduct;
• complying with AML/KYC and other legal obligations;
• executing approved cryptocurrency payouts;
• ensuring security, stability, and performance of the Services.

5. Legal Bases for Processing

We process personal data on the following legal bases:

• performance of a contract;
• compliance with legal obligations;
• legitimate interests (fraud prevention, security, service improvement);
• user consent, where required by applicable law.

6. Cryptocurrency Payments and Payouts

Cryptocurrency-related processing operates as follows:

• cryptocurrency payments for software licenses are made via CT Pay and are transferred directly to blockchain addresses controlled by Zafiro Innovation Systems LLC;
• CT Technologies does not custody user cryptocurrency funds;
• approved cryptocurrency payouts are executed by CT Technologies using corporate liquidity provided by Zafiro;
• blockchain transactions are publicly visible and irreversible by nature.

7. App Store Payments

Purchases made through Google Play or Apple App Store are processed by the respective app store in accordance with their privacy policies and billing rules.

CT Technologies and CryptoCompany receive only limited transaction-related information necessary to confirm purchase status and grant access to licensed software functionality.

8. Data Sharing and Transfers

Personal data may be shared only where necessary:

• between CT Technologies and CryptoCompany for technical operation;
• with Zafiro for cryptocurrency payout execution and compliance;
• with app stores for purchase validation;
• with competent authorities where legally required.
• Where personal data is transferred outside the European Economic Area, appropriate safeguards are applied in accordance with applicable data protection laws.

9. Data Retention

Personal data is retained only for as long as necessary to:

• provide the Services;
• comply with legal and regulatory obligations;
• resolve disputes and enforce agreements.

Retention periods may vary depending on the category of data and applicable law.

10. User Rights

Depending on your jurisdiction, you may have the right to:

• access your personal data;
• request correction or deletion;
• restrict or object to processing;
• request data portability;
• withdraw consent where processing is based on consent.

Requests may be submitted via the contact details below.

11. Security Measures

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, or alteration.

No system can be guaranteed to be 100% secure.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The most current version will be made available within the Services or on our official website. Continued use of the Services after updates constitutes acknowledgment of the revised Privacy Policy.

13. Contact Information

For privacy-related questions or requests:

[email protected]

CT Technologies spółka z ograniczoną odpowiedzialnością

ul. Michała Kleofasa Ogińskiego 11/9, 03-318 Warszawa, Poland