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Privacy Policy - wiTRY Limited

Last Updated: 19.03.2025

This Privacy Policy explains how wiTRY Limited (“we”, “us”, “our”) collects, uses, stores, and protects your personal data when you visit our website or join our waitlist.

wiTRY Limited (“we”, “us”, or the “Company”) are committed to protecting the privacy of people who use our website, including users of wiTRY staking contracts, www.brix.money (the “Website”)- and app.brix.money (the “Application”) visitors, business contacts and other stakeholders. This Privacy Policy explains how we collect, use, disclose, transfer and store your personal information.

This Privacy Policy applies to personal information about you that we collect, use and otherwise process in connection with your relationship with the wiTRY ecosystem.

We are committed to complying with the EU General Data Protection Regulation (GDPR) and the British Virgin Islands Data Protection Act, 2021 (“BVI DPA”), which mirrors GDPR standards.

By accessing our website www.brix.money, by accessing and using app.brix.money, by submitting your information or using our services, you agree to the terms of this Privacy Policy.

1. Who We Are

Controller:

wiTRY Limited Craigmuir Chambers, PO Box 71, Road Town, Tortola, VG 1110, British Virgin Islands

Corporate Registration Number: 2190086 Email: admin@wiTRY.network

We act as the data controller for all personal data collected via this website.

2. What information is collected?

On the Website, we collect the following user’s personal data on a voluntary basis and with the users’ consent: Telegram contact, email, crypto wallet address. We may collect the above personal data and process this data in order to provide our services and access features on the application.

The Application may process pseudonymous blockchain identifiers (such as wallet addresses) and related technical metadata. Wallet addresses are provided voluntarily by users for the sole purpose of accessing and using the application’s features; however, certain features are not available without connecting a wallet. The application does not collect directly identifying personal data unless users voluntarily provide it.

Both the Application and the Website may in the future collect analytics data and data pertaining to the use of services on the Website and use of the Application, as well as data regarding interactions between users and the company.

We may collect and process additional personal data for specific purposes conditional to the data subject's consent, or simply to comply with the law or any judicial order.

We will get in touch with the data subject every time consent to process any data is required. The consent can be withdrawn at any time per request using any of our contact: admin@witry.network .

Both the Website as well as the Application collect cookies to perform and enhance the service provided to users.

2.1 Cookies

Cookies are small text files placed on your device when you visit a website / web app / portal, including on www.brix.money and www.brix.app . We may use cookies that are strictly necessary to:

  • operate and secure the website;

  • enable session management;

  • improve basic functionality and user experience.

We do not use cookies for targeted advertising. You can control cookies through your browser settings, but disabling certain cookies may affect website functionality.

2.1 Information You Provide Voluntarily and Directly

  • Email address

  • Telegram handle

  • Wallet address

  • Any additional information you voluntarily submit

  • Communications and support history

2.2 Automatically Collected Data

When you visit the Website and Application, we may automatically collect:

  • IP address

  • Browser type and version

  • Device information

  • Geographic location,

  • The operating system and version

  • Website usage analytics (page views, clicks, etc.)

    • the content viewed, and

    • features accessed on our Website

    • the web pages and the search terms entered

  • Pseudonymous blockchain identifiers (such as wallet addresses) and related technical metadata and activity data

  • Communication history between the user and the company

We do not collect special categories of personal data.

3. How is the information collected?

We collect personal information that the user provides directly through various channels:

  • Browsing our Website and Application

  • Signing up at the Website to join the waitlist

  • Connecting your wallet and using the Application

  • Information collected by third parties: We may also collect information when the user visits the Site, requires services, or interacts with the website.

4. How is the information used?

We may use the collected information for the following purposes:

4.1 To manage and operate our waitlist / contact database

  • To contact you with updates and announcements

  • To analyze website performance and improve user experience

  • To comply with applicable laws and regulatory obligations

  • To protect the website from fraud or malicious activity

  • Exercising or defending any legal rights

Looking into any complaints or queries

4.2 To allow use of the Application

4.3 To improve the service of the Website and App

4.4 To comply with BVI regulations.

We retain only what is necessary for the purposes set out in this Privacy Policy and what is necessary to comply with the regulations of the BVI.

4.5 Marketing

We do not operate a marketing program. If we ever use your contact details to send you information about updates or developments related to wiTRY Limited and Brix, we will do so only where permitted by law and where you have not objected.

You may opt out at any time by contacting admin@witry.network or using any unsubscribe function provided.

5. How the information is shared

We do not sell your personal data.

We may share your data with:

  • Service providers (Bridging service / swapping service / lending and borrowing service)

  • Affiliates within our corporate group, strictly for operational purposes

  • Legal, tax, compliance and other professional advisers;

  • Regulators or law enforcement, where required by law

All third-party processors are bound by confidentiality and data protection obligations compliant with GDPR and BVI DPA.

We may transfer personal information outside BVI. In such cases, we ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information.

In the event of a reorganisation, change of control or transfer of the business relating to wiTRY Limited, we may transfer personal information to the new operating entity. Where feasible, we will seek to inform you of any such changes.

We process your data under the following legal bases:

You give consent when you submit the waitlist form. You may withdraw consent at any time by emailing us at admin@wiTRY.network .

6.2 Legitimate Interests (Art. 6(1)(f) GDPR)

We have a legitimate interest in:

  • Operating and improving our website

  • Communicating with interested users

  • Protecting the security of our systems

If required by law, we may process or retain certain data.

7. Information Security

We ensure that the personal information collected is subject to appropriate security measures.

We only keep the strictly necessary information for a limited period of time and as long as is necessary for the relevant purpose - and also for as long as it is necessary to comply with legal obligations, laws or regulations, which may set a minimum period for which we keep the user's personal information.

Website

  • Waitlist data: up to 36 months after collection

  • Analytics data: up to 14 months

Application

  • Data relating to Use of the Website, the application and other interaction with company: up to 36 months after collection

  • Analytics data: up to 14 months

You may request deletion at any time (see Section 9).

8. Exercise of Rights

The user is entitled to a certain number of legal rights in relation to the personal information that we may process about the user. These rights can be exercised at any time by contacting us using the details set out below. Under GDPR and the BVI DPA, you have the right to:

  • Access your data

  • Correct inaccurate information

  • Delete your data (“right to be forgotten”)

  • Withdraw consent at any time

  • Object to processing

  • Restrict processing

  • Request portability of your data

  • Complain to a supervisory authority

To exercise any of these rights, please email us at admin@wiTRY.network .

9. Contact

For further information on the collection, use, disclosure, transfer, or processing of personal information or the exercise of any of the rights listed above, please contact us by sending an email to admin@wiTRY.network .

10. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top indicates when the latest revision took place.

Last updated