PayRam is a non-custodial wallet application. This means: You control your own private keys and digital assets; We do not have access to your wallet, funds, or transaction capabilities; We do not require account registration or personal identification to use the core wallet features. Our privacy practices reflect this design philosophy by minimizing the collection and retention of personal information.

PayRam does not collect, store, or have access to: Your name, email address, phone number, or physical address; Government-issued identification documents; Private keys, seed phrases, recovery phrases, or wallet passwords; The contents of your cryptocurrency wallet, including balances and holdings; Cryptocurrency transaction details, recipients, or amounts; Financial account information, banking details, or payment card numbers; Biometric data. Note: If you participate in the Rewards Program, certain additional data is collected as described in Section 13 below. This data relates to the Rewards Program only and does not include access to your cryptocurrency wallet or private keys.

3.1 Device and Technical Information To ensure the App functions properly, we may automatically collect limited technical information, which may include: Device region settings: Used for functional and compliance-related purposes (e.g., language display, regional feature availability); Device type and operating system: To ensure compatibility and optimize performance; App version: To provide updates and support; Crash logs and error reports: To identify and fix technical issues; General usage analytics: Aggregated, non-identifying data about how the App is used. This information is collected in a manner designed not to personally identify you. 3.2 Wallet Addresses When you use the App to conduct transactions on public blockchain networks, your wallet addresses are recorded on those public blockchains. While PayRam does not separately collect or store your wallet addresses, please be aware that blockchain transactions are publicly visible and permanently recorded. 3.3 Communications If you contact us via email or other support channels, we may collect the information you provide in your communications to respond to your inquiries.

4.1 Third-Party Integrations The App may integrate with or provide access to third-party services, including: Wallet infrastructure providers (e.g., Privy); Fiat on-ramp and off-ramp providers; Blockchain networks and decentralized applications (dApps); Analytics providers. 4.2 Third-Party Data Practices These third-party services may request or collect personal information directly from you. Such information is collected and stored by the third party, not by PayRam, and is governed by the third party's own privacy policy. PayRam does not collect, store, or have access to personal data you provide to third-party services, including KYC/AML verification data submitted to fiat service providers. 4.3 Your Responsibility Before using any third-party service, we encourage you to review their privacy policies and terms of service. PayRam is not responsible for the privacy practices of third parties.

To the extent we collect any information, we may use it for the following purposes: To provide, operate, and maintain the App; To improve, personalize, and optimize the App and user experience; To detect, prevent, and address technical issues, security incidents, or fraudulent activity; To comply with applicable legal obligations; To communicate with you regarding support inquiries or important updates; To enforce our Terms and Conditions and protect our legal rights.

6.1 General Policy PayRam does not sell, rent, lease, or monetize personal data. 6.2 Limited Disclosure We may share information in the following limited circumstances: Service Providers: With trusted third-party service providers who assist us in operating the App, subject to confidentiality obligations; Legal Requirements: If required by law, regulation, legal process, or governmental request; Protection of Rights: To protect the rights, property, or safety of PayRam, our users, or others; Business Transfers: In connection with a merger, acquisition, or sale of assets, where information may be transferred to the acquiring entity.

We implement reasonable technical and organizational measures designed to protect information against unauthorized access, alteration, disclosure, or destruction. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

We retain information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Given our non-custodial architecture, we retain minimal data. Technical logs and analytics data are typically retained for short periods and then deleted or anonymized. For Rewards Program data retention, please see Section 13.7 below.

The App is accessible globally. Information may be processed, stored, or transferred in jurisdictions outside your country of residence, including jurisdictions that may have different data protection laws. By using the App, you consent to the transfer of information to jurisdictions outside your country of residence.

The App is not intended for use by individuals under the age of 18 (or the age of majority in their jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete such information.

11.1 Access and Control Due to our non-custodial design and minimal data collection, there is limited personal information to access, correct, or delete. If you have questions about any information we may have, please contact us. 11.2 Communications If you have contacted us and wish to opt out of further communications, you may do so by contacting us at the email address below. 11.3 Region-Specific Rights Depending on your jurisdiction, you may have additional rights under applicable data protection laws. Please contact us to exercise any such rights.

Transactions conducted through the App are recorded on public blockchain networks. This data is: Publicly accessible to anyone; Immutable and cannot be modified or deleted; Not controlled by PayRam. PayRam cannot delete, modify, or retrieve blockchain data on your behalf.

13.1 Overview If you participate in the PayRam Rewards Program, we collect and process certain additional information to administer the Program, calculate Reward Coins, facilitate redemptions, and prevent fraud. Important Distinction: Rewards Program data is separate from your cryptocurrency wallet data. While PayRam does not collect or have access to your private keys, wallet balances, or on-chain transaction contents, participation in the Rewards Program involves off-chain data processing as described below. 13.2 Rewards Data We Collect When you participate in the Rewards Program, we may collect and process: Data Category / Examples / Purpose On-Ramp Transaction Data: Transaction amounts, fees incurred, timestamps, on-ramp provider identifiers – To calculate and credit Reward Coins earned Reward Coin Balance: Current balance, earning history, redemption history – To maintain accurate records and display your balance Redemption Data: Redemption amounts, Partner Merchant identifiers, transaction timestamps – To process redemptions and maintain transaction records Partner Merchant Interactions: Merchant identifiers, transaction references – To facilitate and verify redemptions Program Activity: Participation in promotions, bonus earning activities – To apply promotional multipliers and bonuses 13.3 How Rewards Data Differs from Wallet Data Aspect / Cryptocurrency Wallet / Rewards Program Data Location: On-chain (public blockchain) / Off-chain (PayRam systems) PayRam Access: No access to keys, balances, or transaction contents / Access to rewards data for Program administration Data Control: User-controlled via private keys / Tracked by PayRam; user controls usage decisions Data Permanence: Immutable on blockchain / Subject to PayRam data retention policies 13.4 How We Use Rewards Data We use Rewards Program data for the following purposes: Program Administration: To calculate, credit, and track Reward Coins earned through qualifying activities; Redemption Processing: To facilitate and verify redemptions with Partner Merchants; Balance Maintenance: To maintain accurate Reward Coin balance records and transaction history; Fraud Prevention: To detect, investigate, and prevent fraudulent or abusive activity in the Rewards Program; Program Improvement: To analyze Program usage patterns and improve the Rewards Program; Compliance: To comply with legal obligations and enforce our Rewards Program Terms; Dispute Resolution: To investigate and resolve disputes related to Reward Coins or redemptions; Communications: To send you Rewards Program-related notifications, updates, or promotional offers (where permitted). 13.5 Data Sharing with Partner Merchants When you redeem Reward Coins with a Partner Merchant, we may share limited information to facilitate the redemption: Transaction Reference: A unique identifier for the redemption transaction; Redemption Amount: The value of Reward Coins being redeemed; Wallet Address: Your public wallet address (which is already visible on-chain for the cryptocurrency transfer); Timestamp: The date and time of the redemption. We do not share: Your Reward Coin balance or earning history; Personal identification information (which we do not collect); Your transaction history with other merchants. Partner Merchants are contractually obligated to use this information solely for processing the redemption and are prohibited from using it for their own marketing purposes without your separate consent. 13.6 Data Sharing with On-Ramp Providers To calculate Reward Coins earned from on-ramp transactions, we may receive transaction confirmations and fee information from third-party on-ramp providers. This data sharing is necessary for Program operation and is governed by our agreements with these providers. 13.7 Rewards Data Retention We retain Rewards Program data as follows: Data Type / Retention Period Active Reward Coin Balances: For as long as your balance is active and you use the App Earning History: 3 years from the date of earning, or longer if required for legal or dispute resolution purposes Redemption Records: 3 years from the date of redemption, or longer if required for legal or dispute resolution purposes Fraud Investigation Data: As long as necessary for investigation and any subsequent legal proceedings Upon Program termination or your cessation of participation, we may retain certain data as required by law or for legitimate business purposes (such as dispute resolution). 13.8 Your Choices Regarding Rewards Data Participation: Participation in the Rewards Program is voluntary. If you do not wish for rewards data to be collected, you may choose not to participate in the Program. You may still use the PayRam Wallet for cryptocurrency management without participating in the Rewards Program. Access: You may request information about your Reward Coin balance and transaction history through the App or by contacting us. Deletion: Given that rewards data is necessary for Program administration, deletion requests may result in forfeiture of your Reward Coin balance. Please contact us to discuss your options. 13.9 Rewards Data Security Rewards Program data is protected by the same security measures described in Section 7 of this Privacy Policy. We implement technical and organizational measures to protect rewards data against unauthorized access, alteration, or disclosure.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through the App or by other reasonable means. Your continued use of the App after the effective date of any changes constitutes your acceptance of the updated Policy.

If you have questions, concerns, or requests regarding this Privacy Policy, please contact us: Email: support@payram.com Address: Mojo Nation Ltd 1st Floor, Ellen Skelton Building 3076 Sir Francis Drake's Highway Road Town, Tortola VG1110 British Virgin Islands