🔐Privacy Policy

Last modified: 16 March 2026

1. Overview

This Privacy Policy describes how H Lab Limited (“H Lab”, “we”, “us”, or “our”) handles information in connection with the TWIFT decentralized application (“TWIFT”, “the Platform”).

TWIFT is designed to operate as a non-custodial, privacy-preserving technology interface.

We do not collect, store, or process any personally identifiable information (PII) such as names, addresses, emails, wallet private keys, or identification documents.

By accessing or using TWIFT, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. This Policy applies only to TWIFT and not to any third-party websites or services

2. Data We Do Not Collect

We do not:

• Require registration, login, or account creation.

• Request or store names, email addresses, or any contact information.

• Access, store, or recover wallet private keys, seed phrases, or recovery phrases.

• Track individual users across wallets, sessions, or devices.

• Store any transaction data linked to personal identity.

All interactions with TWIFT occur directly between your self-custodial wallet and the blockchain network. We cannot identify individual users or associate wallet activity with any personal identity except standard server logs for security.

3. Information Automatically Processed

When you access the Platform, limited technical data may be automatically processed to maintain functionality and ensure security.

Such data may include:

• Browser type and version

• Device type and operating system

• Network or region information

• Timestamp and general usage logs

• Aggregated interaction metrics (e.g., page views or clicks)

This data is non-identifiable and used solely for operational monitoring, debugging, and performance optimization. Such information may include an anonymized or truncated IP address, but is never stored in full or linked to a user identity. It cannot be used by H Lab to identify individual users or link blockchain addresses to personal data.

4. Cookies and Analytics

4.1 Cookies

TWIFT uses a small number of functional cookies to remember user interface preferences such as language, network selection, or display mode.

These cookies do not contain personal information and automatically expire after a limited period. You can manage or delete cookies through your browser settings without affecting your ability to use the Platform. TWIFT may display a notice or banner seeking your consent to enable analytics cookies where required by law.

4.2 Analytics

We may use Google Analytics or similar third-party analytics tools to understand overall platform usage patterns.These tools collect aggregated and anonymized information such as page views, browser version, referral links, and session duration. This information is used solely to improve product performance and user experience.

You can opt out of Google Analytics by installing the official browser add-on available at:

https://tools.google.com/dlpage/gaoptout

5. Data Storage and Retention

TWIFT does not maintain any centralized database containing user information.

Temporary system logs such as error traces, network requests, or connection events may be retained for up to seven (7) days (may retain longer if required by law) solely for security monitoring and technical troubleshooting.

After this period, they are automatically deleted.

Because TWIFT operates as a decentralized interface, transaction data is stored permanently on public blockchains, outside H Lab’s control. H Lab cannot alter, delete, or obscure on-chain data once a transaction is confirmed.

6. Third-Party Services

When using TWIFT, you may interact with or rely on third-party services, including but not limited to:

• Wallet connectors (e.g., MetaMask, WalletConnect, etc.)

• RPC providers or blockchain nodes

• Analytics and content delivery networks

Each third-party service operates under its own terms of service and privacy policy.

H Lab has no control over how these external providers collect, use, or process your information. We do not endorse or verify any third-party software. By using TWIFT, you acknowledge that interactions with such third-party systems are entirely at your own discretion and risk.

7. International Data Processing

Because TWIFT is a globally accessible decentralized platform, limited technical data (such as analytics or hosting metadata) may be processed or transmitted across international borders through third-party service providers. Data may be processed outside ADGM, including in the United States or European Union.

H Lab ensures that all external service partners maintain industry-standard security and confidentiality measures, and that any data processing is consistent with the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021.

By using the Platform, you acknowledge that such cross-border processing may occur solely for technical and operational purposes, and that no personal data is transferred or stored by H Lab.

8. Data Security

H Lab implements reasonable administrative, technical, and organizational safeguards to maintain the integrity and availability of the Platform. These include access controls, encryption in transit, and secure hosting environments for infrastructure components.

However, due to the open and decentralized nature of blockchain networks, H Lab cannot guarantee the complete security or privacy of on-chain transactions. All transactions executed through TWIFT are publicly recorded on blockchain networks and may be viewed by third parties through blockchain explorers.

Users are responsible for ensuring the safety of their wallet credentials, device security, and browser extensions used to connect to the Platform.

9. Your Rights

Since TWIFT does not collect or store personal data, most individual data protection rights, such as access, rectification, deletion, or portability, are not applicable. If you have questions regarding temporary technical data (for example, cached logs or anonymized analytics), you may contact H Lab at [e-mail], and we will respond in accordance with the ADGM Data Protection Regulations 2021. Users may also disable cookies or opt out of analytics tools at any time through their browser settings without affecting access to the Platform.

9.1 Rights for European Economic Area (EEA) and UK Residents (GDPR)

If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), you may have certain data protection rights under the General Data Protection Regulation (GDPR) and UK GDPR. However, because TWIFT is designed to operate strictly without collecting, storing, or processing Personally Identifiable Information (PII) such as names, email addresses, or wallet private keys, our ability to fulfill standard data subject requests is inherently limited by our privacy-preserving architecture.

Data Minimization & Identification: We do not track individual users or link wallet activity to any personal identity. Because we cannot identify you, requests to access, rectify, restrict, or delete personal data cannot be processed unless you provide additional identifying information—which we actively refuse to collect by design.

Immutable On-Chain Data: Please note that all transactions executed through TWIFT are permanently recorded on public blockchains, which are strictly outside of H Lab's control. We do not have the technical ability to alter, delete, or obscure any on-chain data once a transaction is broadcasted and confirmed.

Legal Basis for Processing: Any temporary technical data processed for security and operational purposes (such as truncated IP addresses, browser types, or general usage logs) is handled solely based on our legitimate interest in maintaining the stability, functionality, and security of the Platform.

10. Updates to this Policy

H Lab may amend or update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, or the functionality of the Platform. Any updates will be posted on the official TWIFT website (www.twift.xyz) or documentation portal (docs.twift.xyz) with a revised “Last Modified” date at the top of the page. Your continued access or use of TWIFT after publication of an updated Privacy Policy constitutes your acknowledgment and acceptance of the revised version.

11. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or TWIFT’s data handling practices, please contact us at: H Lab Limited, Abu Dhabi Global Market (ADGM), United Arab Emirates. (Email: [e-mail])

H Lab will review and respond to all legitimate inquiries within a reasonable time frame, in accordance with the ADGM Data Protection Regulations 2021.