Privacy Policy

1. Introduction

This Privacy Policy explains how Senoa Technologies, Inc. ("Senoa," "we," "us") collects, uses, shares, and protects information when you use our website, apps, and related services (the "Platform").

2. Information We Collect

We collect this information directly from you (for example, when you sign up or complete verification), automatically as you use the Platform, and in some cases from our service providers, such as our identity-verification and custody partners.

3. Decentralized Identity (DID) & Data Separation

Senoa assigns each account a Decentralized Identifier (DID), a pseudonymous identifier used to personalize your experience without tying that activity to your name.

• Behavioral and preference data, including the activity we use for personalization, recommendations, feed ranking, and Advocate-targeting, is collected and profiled against your DID rather than your name or other directly identifying information.
• Personally identifying information collected for identity verification, such as your name, date of birth, and government or business ID documents (see the Identity verification row above), is stored separately from the data associated with your DID and is not merged into your DID-based profile.
• Because profiling happens at the DID level, your day-to-day activity on the Platform is pseudonymous within our own systems.
• We may internally link your DID to your verified identity where required by law, such as for sanctions screening, fraud prevention, or a valid legal request. That link is maintained separately and is not used to build your DID-based personalization profile.

4. How We Use Information

• To create and maintain your account and wallet.
• To process transactions, escrow, and Advocacy commissions.
• To verify identity and comply with KYC, KYB, and sanctions-screening obligations.
• To operate Newsline, Marketplace, and Senoa Studio features you use.
• To personalize your experience and profile activity against your DID as described in Section 3.
• To detect, investigate, and prevent fraud, abuse, and security incidents.
• To communicate with you about your account, transactions, and updates to our policies.
• To improve the Platform, including through aggregated or de-identified analytics.

5. How We Share Information

We do not sell your personal information. We share information only in the following circumstances:

• Service providers: vendors who help us operate the Platform, including our custodial wallet/custody partner, identity-verification vendors, payment processors, hosting, and analytics providers, under confidentiality and data-protection obligations.
• Other users: information you choose to make visible, such as your public profile, posts, listings, and messages sent to other users.
• Businesses you interact with: if you subscribe to, purchase from, or become an Advocate for a business on the Platform, relevant transaction information is shared with that business as needed to fulfill the transaction.
• Legal & compliance: where required to comply with law, respond to legal process, or protect the rights, safety, or property of Senoa, our users, or the public.
• Business transfers: in connection with a merger, acquisition, or sale of assets, subject to standard protections.

Our advertising placements are currently based on the placement and budget a business selects, not on targeting individual users by personal data. If this changes, we will update this Policy.

6. Cookies & Similar Technologies

We and our service providers use cookies and similar technologies to keep you signed in, remember your preferences, secure the Platform, and understand how the Platform is used so we can improve it. You can control cookies through your browser settings; disabling certain cookies may affect how the Platform functions.

7. Data Retention

We retain personal information for as long as your account is active and as needed to provide the Platform, comply with legal, tax, and recordkeeping obligations (including KYC/AML recordkeeping), resolve disputes, and enforce our agreements. Retention periods vary by data type and will be specified in more detail following legal review.

8. Your Rights & Choices

Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, and to object to or restrict certain processing. You can exercise many of these rights directly within your account settings, or by contacting us at privacy@senoaapp.com. Note that certain records, particularly those related to identity verification and financial transactions, may need to be retained even after a deletion request in order to meet legal and regulatory obligations.

9. Children's Privacy

Senoa is not directed to, and is not intended for use by, anyone under 18 years old. We do not knowingly collect personal information from children. If we learn that we have collected information from someone under 18, we will take steps to delete it.

10. Data Security

We use administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and access controls around wallet and verification data. No system is completely secure, and we cannot guarantee absolute security.

11. International Transfers

Senoa and its service providers may process and store information in countries other than the one in which you reside. Where required, we use appropriate safeguards for such transfers, to be detailed further following legal review.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version here with a new "Last updated" date, and where changes are material, provide additional notice.

13. Contact Us

Questions about this Privacy Policy can be sent to privacy@senoaapp.com.