Privacy Policy

Effective Date: January 1, 2026
Last Updated: January 10, 2026

Vircard Limited ("Vtron," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application ("App") and related services. Please read this Privacy Policy carefully. By using the App, you consent to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Information You Provide Directly

We may collect information that you provide directly to us, including:

• Account Information: Name, email address, phone number, date of birth, government-issued identification, and other information necessary for identity verification (KYC).
• Financial Information: Bank account details, payment card information, transaction history, and wallet addresses.
• Communication Data: Information you provide when you contact our customer support, including emails, chat logs, and feedback.
• Profile Information: Username, profile picture, and preferences you set within the App.

1.2 Information Collected Automatically

When you use our App, we automatically collect certain information, including:

• Device Information: Device type, operating system, unique device identifiers, IP address, browser type, and mobile network information.
• Usage Data: Information about how you use our App, including access times, pages viewed, app crashes, and other system activity.
• Location Data: With your consent, we may collect precise or approximate location data from your device.
• Cookies and Similar Technologies: We use cookies, web beacons, and similar tracking technologies to collect information about your interactions with our services.

1.3 Information from Third Parties

We may receive information about you from third parties, including:

• Identity verification services
• Financial institutions and payment processors
• Marketing partners and analytics providers
• Public databases and government authorities

2. How We Use Your Information

We use the information we collect for the following purposes:

• Provide Services: To create and manage your account, process transactions, and provide our card and wallet services.
• Identity Verification: To verify your identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
• Security and Fraud Prevention: To detect, prevent, and respond to fraud, unauthorized access, and other illegal activities.
• Communication: To send you service-related notifications, updates, security alerts, and customer support messages.
• Improvement: To analyze usage patterns, improve our App, and develop new features and services.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, and government requests.
• Marketing: With your consent, to send you promotional communications about our products and services.

3. How We Share Your Information

We may share your information in the following circumstances:

• Service Providers: We share information with third-party vendors who perform services on our behalf, such as payment processing, identity verification, cloud hosting, and customer support.
• Financial Partners: We share information with banks, card networks (e.g., Visa, Mastercard), and other financial institutions as necessary to provide our services.
• Legal Requirements: We may disclose information if required by law, court order, or government regulation, or if we believe disclosure is necessary to protect our rights or the safety of others.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
• With Your Consent: We may share your information with third parties when you have given us your explicit consent to do so.

We do not sell your personal information to third parties.

4. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to:

• Provide our services to you
• Comply with legal and regulatory requirements
• Resolve disputes and enforce our agreements
• Prevent fraud and abuse

When your information is no longer needed, we will securely delete or anonymize it in accordance with applicable laws.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure access controls and authentication
• Regular security assessments and audits
• Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request access to the personal information we hold about you.
• Correction: Request correction of inaccurate or incomplete information.
• Deletion: Request deletion of your personal information, subject to legal retention requirements.
• Portability: Request a copy of your data in a portable format.
• Opt-Out: Opt out of marketing communications at any time.
• Withdraw Consent: Withdraw consent for processing where consent is the legal basis.

To exercise these rights, please contact us using the information provided below.

7. Children's Privacy

Our App is not intended for use by children under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information promptly.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your jurisdiction. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy.

9. Third-Party Links and Services

Our App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party services you access.

10. App Tracking Transparency

In compliance with Apple's App Tracking Transparency framework, we will request your permission before tracking your activity across other companies' apps and websites. You can change your tracking preferences at any time in your device settings.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the App or by other means, such as email. Your continued use of the App after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

13. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal information we collect, use, and disclose
• The right to request deletion of your personal information
• The right to opt-out of the sale of personal information (we do not sell your data)
• The right to non-discrimination for exercising your privacy rights

14. International Users

Our services are primarily operated from and intended for users in the United States and other non-European Union jurisdictions. We do not specifically target or market our services to users in the European Economic Area (EEA), United Kingdom, or Switzerland.

If you access our services from outside our primary operating regions, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our servers are located. By using our services, you consent to the transfer of your information to these countries.

Regardless of your location, we are committed to protecting your privacy and handling your personal information responsibly in accordance with this Privacy Policy.