Privacy Policy

1. Introduction

Dinario is a remittance application built exclusively for the Solana Seeker mobile phone ecosystem. This Privacy Policy describes how Dinario collects, uses, discloses, and protects your information when you use our mobile app, website, or related services (the "Services"). It also explains your privacy rights and how you can exercise them.

Your use of Dinario indicates your acceptance of this Privacy Policy.

2. Scope

This Privacy Policy applies to your use of the Dinario mobile application, website, and any associated features or services.

It does not apply to third-party services (such as Bridge.xyz, or external payment providers), whose privacy practices are governed by their respective policies.

3. Data Controller

Dinario is operated by DINARIO TECHNOLOGIES INC, 2125 Biscayne Blvd, Ste 204 #21062, Miami, Florida 33137, USA. For privacy inquiries, you may contact us at support@dinario.app.

4. What Personal Information We Collect

4.1 Blockchain and Wallet Data (On-chain)

• Wallet Address: Your public Solana wallet address (Seed Vault, non-custodial, device-generated).
• Transaction Data: Transaction hashes, accounts involved, amounts, timestamps, and on-chain metadata (publicly accessible per Solana protocol).

4.2 Off-chain and Device Data

Limited Personal Data for Remittance and Compliance:

• Name, email address, country of residence, and KYC documentation, but only during fiat on/off-ramp operations per Bridge.xyz and requirements.

Device and Security Data:

• Device type, model, operating system.
• Biometric authentication status (confirmation only, never storing the biometric data itself).

Usage Data:

• App interaction events (e.g., UI navigation, transaction initiation, completion status), error logs, anonymized crash reports.

Analytics:

• Aggregated usage analytics via Google Firebase Analytics (opt-out available via device settings).

Cookies/Identifiers:

• Device identifiers or analytics tags (no browser cookies used in the mobile app).

4.3 Data from Third Parties

• Compliance Data: Identity verification results, AML checks, and compliance flags, received only from Bridge.xyz as required.

4.4 No Custodial Storage by Dinario

Dinario does not store or have access to your private keys, seed phrases, or full identity information. Wallets are generated and secured locally on your device through Solana's Seed Vault. Identity and compliance data for fiat operations are collected and stored only by Bridge.xyz or other licensed partners. Dinario does not retain this data.

5. Bridge.xyz as Our KYC Provider

Dinario partners with Bridge.xyz as our licensed Know Your Customer (KYC) and identity verification provider for all fiat on-ramp and off-ramp operations.

5.1 What Bridge.xyz Collects

When you use fiat remittance services, Bridge.xyz collects and processes:

• Personal Information: Full legal name, date of birth, residential address, email address, phone number
• Identity Documents: Government-issued ID (passport, driver's license, national ID), selfie photos for identity verification
• Financial Information: Bank account details, payment card information, transaction history, source of funds documentation
• Compliance Data: Risk assessments, sanctions screening results, AML flags, transaction monitoring data

5.2 How Bridge.xyz Handles Your Data

Bridge.xyz processes your data in accordance with their Privacy Policy and under strict regulatory requirements:

• Secure Storage: All personal and financial data is encrypted at rest and in transit using bank-grade encryption (AES-256, TLS 1.3+)
• Data Retention: KYC records are retained for a minimum of 5 years as required by U.S. federal law (Bank Secrecy Act, FinCEN regulations)
• Access Controls: Data is accessible only to authorized Bridge.xyz personnel on a need-to-know basis
• Regulatory Sharing: Bridge.xyz may share data with financial regulators, law enforcement, and compliance authorities as required by law
• No Sale: Bridge.xyz does not sell your personal information to third parties

5.3 Dinario's Limited Access

Important: Dinario does NOT have access to your full KYC documents, identity images, or banking details stored by Bridge.xyz. We only receive:

• KYC verification status (approved/pending/rejected)
• Basic user identifier to link your wallet to your KYC record
• Transaction status updates for fiat operations

All sensitive personal and financial data remains solely with Bridge.xyz and is never transmitted to or stored by Dinario.

5.4 Why We Use Bridge.xyz

Bridge.xyz is a licensed and regulated financial services provider with:

• Money Transmitter Licenses: Licensed in multiple U.S. states and compliant with federal regulations
• Banking Partnerships: Partnerships with FDIC-insured banks and regulated financial institutions
• Compliance Infrastructure: Robust AML/KYC systems, sanctions screening, and fraud detection
• Data Security: SOC 2 Type II certified, regular security audits, and enterprise-grade infrastructure

For more details on how Bridge.xyz handles your data, please review their Privacy Policy and Terms of Service.

6. How We Collect Data

• Directly from you: via MWA authentication, KYC/AML flows during fiat on/off-ramps, and Seeker device interactions.
• Automatically: via app usage, transaction execution, and performance monitoring instruments.
• From third parties: through Bridge.xyz, or other licensed providers for AML/KYC/compliance requirements.

7. Purposes of Data Use

We do not use personal information for advertising or unrelated marketing without your explicit consent.

8. Data Storage and Retention

• On-Chain Data: Immutable and permanent—publicly available on the Solana blockchain.
• App Data/Analytics: Aggregated and anonymized where possible. Retention policies conform to product improvement needs and legal requirements.

9. How We Share or Disclose Information

• Blockchain Network: Transaction data is inherently public.
• RPC Infrastructure: Solana network interactions are facilitated through Helius RPC services for improved performance and reliability. Transaction data passed to RPC providers is necessary for blockchain operations.
• Compliance Partners: KYC/AML data is securely transmitted to Bridge.xyz, only when required for fiat-related services.
• Analytics Providers: Aggregated, anonymized data to analytics platforms (Google Firebase).
• Legal/Regulatory Disclosure: To authorities or as legally compelled to meet AML, KYC, FATF, or other compliance obligations.
• Service Providers: Limited only to what is necessary for app functionality, infrastructure, and support.

No Sale of Data: Dinario does not sell your personal information to third parties.

10. International Data Transfers

As a global remittance platform, data (including compliance data) may be processed in or transferred to jurisdictions outside your home country, subject to strict contractual safeguards and encryption measures.

EU/UK users: When data is processed outside the EEA/UK, standard contractual clauses or equivalent measures will be in place (where required by law).

11. Security

• MWA/Seed Vault Security: All wallet private keys are generated and stored locally on the device in the Seed Vault, secured with hardware-level biometric authentication. Dinario cannot access or recover your private key.
• Data Transmission: All data to Bridge.xyz, and other partners is sent over secure, encrypted channels (HTTPS/TLS).
• App Security: Device-level security features, code obfuscation, anti-tampering, and root/jailbreak detection are implemented.
• Access Controls: Only authorized Dinario team members with a need-to-know basis may access relevant off-chain data.
• Incident Response: In case of a breach, users and authorities will be notified per applicable law.

12. Your Privacy Rights

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

• Access: Request information about your processed data.
• Rectification: Request correction of inaccurate off-chain data.
• Erasure ("Right to be Forgotten"): Request deletion of your personal data when feasible (note: on-chain data cannot be deleted).
• Restriction/Objection: Restrict or object to specific processing purposes.
• Data Portability: Request a copy of your off-chain data.
• Withdraw Consent: Withdraw consent for processing where you previously provided it (does not retroactively affect lawful processing).
• Lodge a Complaint: EU/UK users may complain to their data protection authority.

To exercise these rights, contact us at support@dinario.app. Some requests may require verification or be restricted by legal/regulatory requirements.

13. Data Related to Minors

Dinario does not knowingly provide services to or knowingly collect personal data from children under 18 years of age. If you believe a child's data has been collected, contact us for prompt deletion.

14. Cookies, Analytics, and Tracking

• No web cookies apply to the mobile app.
• Google Firebase Analytics: Used for usage monitoring and improvement; users may opt-out in device settings.
• Do Not Track: Dinario does not respond to DNT browser signals due to the mobile-only nature of the service.

15. Third-Party Links and Partners

The Dinario app may provide links or interfaces to third-party sites (such as Bridge.xyz or payment processors). Your interaction with those services is governed by their own privacy policies. Dinario is not responsible for content or data handling outside its direct ecosystem.

16. Changes to This Policy

We may update this Privacy Policy as technology, law, or service scope evolves.

• Material changes will be communicated via in-app message or email (if provided).
• Continued use after updates constitutes acceptance.

17. Contact Us

For privacy and data-related questions, rights requests, or complaints, reach us at: