Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for you to access our Service or parts of our Service.
• Company (referred to as either "the Company", "We", "Us", or "Our" in this Agreement) refers to Mitu Labs Inc., 131 Continental Dr, Suite 305, City of Newark, County of New Castle, Delaware 19713, United States.
• Cookies are small files that are placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history on that website among many other uses.
• Country refers to Delaware, United States.
• Device means any device that can access the Service, such as a computer, a cellphone, or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Mitu Labs Inc. website, mobile applications, and related services.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Mitu Labs Inc., accessible from https://mitu.ai.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, state, province, ZIP/postal code, city
• Date of birth
• Government issued identification documents
• Photograph for identity verification
• Name and address of the business (for business customers)
• Bank account details
• Stablecoin or digital wallet details
• Source of funds information where required for compliance
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your device's Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including but not limited to the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. The technologies we use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

Cookies can be Persistent or Session Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies
  Type: Session Cookies
  Administered by: Us
  Purpose: These Cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
• Cookies Policy / Notice Acceptance Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies
  Type: Persistent Cookies
  Administered by: Us
  Purpose: These Cookies allow us to remember choices you make when you use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid having to re-enter your preferences every time you use the Website.

For more information about the cookies we use and your choices regarding cookies, please contact us through the channels listed at the end of this policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage your Account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
• For the performance of a contract: the development, compliance, and undertaking of contracts for the products, items, or services you have purchased or any other contract with us through the Service.
• To comply with legal and regulatory obligations: including anti-money laundering, know your customer, sanctions screening, tax reporting, and other obligations applicable to financial services providers in the jurisdictions where we operate.
• To contact you: to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted out of receiving such information.
• To manage your requests: to attend to and manage your requests to us.
• For business transfers: we may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
• For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing, and your experience.

We may share your personal information in the following situations:

• With Service Providers: we may share your personal information with Service Providers to monitor and analyze the use of our Service, to perform identity verification and compliance checks, to facilitate payment processing, and to contact you.
• With banking and payment partners: we may share your information with our regulated banking and payment partners as required to facilitate the services you have requested and to comply with applicable laws and regulations.
• For business transfers: we may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• With business partners: we may share your information with our business partners to offer you certain products, services, or promotions.
• With other users: when you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed.
• With regulators and law enforcement: we may share your information with regulators, law enforcement, courts, and other government authorities where required by law or in response to valid legal process.
• With your consent: we may disclose your personal information for any other purpose with your consent.

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, where we are required to retain your data to comply with applicable financial services and anti-money laundering laws), resolve disputes, and enforce our legal agreements and policies.

In particular, customer identification and transaction records are retained for at least five years from the end of the customer relationship or the date of the transaction, in line with our regulatory obligations as a registered Money Services Business.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or where we are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (for example, a court or a government agency).

Other Legal Requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We implement technical and organisational measures designed to protect your Personal Data, including encryption in transit and at rest, access controls, secure data storage, and regular security reviews.

International Privacy Laws

Please be advised that if you access the Services from outside the United States, you are transmitting information (including Personal Data) to the United States, where some of our servers are located. Depending on the type of information and how it is maintained by us, it may be transmitted within the United States or to other countries outside of your place of residence. These countries may not have data protection regulations as comprehensive or protective as those in your own country. However, this Privacy Policy will always govern our collection, storage, and use of your Personal Data.

For EEA, Switzerland, and UK Only

The EU General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection require Mitu Labs Inc. to give users greater information regarding the processing of their Personal Data. Therefore, in addition to the information in this section, you should be aware that we process your information because:

• You have given us your consent
• The processing is required for our contractual relationship with you
• The processing is required for us to comply with our legal or regulatory obligations
• The processing is in our legitimate interest, for example to protect the security and integrity of our systems and to provide you with the services you have requested

Personal Data Transfers

We may need to move your Personal Data outside of the country from which it was originally submitted because Mitu Labs Inc. operates internationally. This may be intra group or to third parties with which we collaborate who are located in jurisdictions outside the EEA, Switzerland, and the United Kingdom, which may have different data protection legislation than those in Europe.

We take legally required steps to ensure that sufficient safeguards are in place to secure your Personal Data when we transfer it outside of the EEA, Switzerland, or the United Kingdom. This includes, where applicable, the use of Standard Contractual Clauses approved by the European Commission, the UK International Data Transfer Agreement, or other lawful transfer mechanisms.

Retention of Personal Data

We keep your Personal Data for as long as it is needed for the purposes for which it was collected or for other valid reasons, including complying with legal responsibilities, resolving disputes, or enforcing our agreements.

If you have an account with us, we will normally keep your Personal Data for as long as your account is active. After you close your account or your account becomes dormant, we will retain your Personal Data for at least five years to comply with our regulatory obligations as a Money Services Business, after which we will delete or anonymise it unless we are legally required to keep it longer.

Your Legal Rights

Depending on the laws that apply in your jurisdiction, you may have rights with respect to your Personal Data, including:

• The right to obtain a copy of the Personal Data we hold about you
• The right to request that we correct inaccurate or incomplete Personal Data
• The right to request that we restrict or delete your Personal Data
• The right to object to certain types of processing, including profiling
• The right to data portability
• The right to withdraw consent at any time, where we are processing your data on the basis of consent
• The right to unsubscribe from marketing communications

You can exercise these rights by contacting us through the channels listed at the end of this policy. We will evaluate requests on a case by case basis and will respond within the timelines required by applicable law.

Please note that in some cases we may not be legally permitted to comply with your request, for example where we are required to retain your data to comply with anti-money laundering or other regulatory obligations. If you have a complaint about how we treat your Personal Data, please contact us first to clarify your situation. If you are not satisfied with our response, you may file a complaint with the appropriate data protection authority in your jurisdiction.

Mitu Labs Inc. as a Data Controller and a Data Processor

Under EU and UK data protection law, organisations that process personal data for their own purposes are known as "data controllers", while organisations that process personal data on behalf of others are known as "data processors". Depending on the circumstances, Mitu Labs Inc. may operate as a data controller or a data processor in relation to your Personal Data. If you have a concern or complaint about how your Personal Data is handled, you should direct it to the relevant data controller.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 18 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

Links to Other Websites

Our Service may contain links to websites or services of third parties that are not owned or controlled by the Company.

The Company does not control and is not responsible for the content, privacy policies, or practices of any third party websites or services. You acknowledge and agree that the Company is not responsible or liable, directly or indirectly, for any damage or loss caused or claimed to be caused by or in connection with the use of or reliance on any such content, products, or services available on or through any such websites or services.

We strongly suggest you read the terms and conditions and privacy policies of any third party websites or services you visit.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service before the change becomes effective and update the "Updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• By email: hello@mitu.ai
• By visiting this page on our website: https://www.mitu.ai