KAIT Privacy Policy

01Introduction

KAIT Coin (“KAIT”, “we”, “us”, or “our”) respects your privacy and is committed to protecting the personal information and digital information entrusted to us.

This Privacy Policy explains how we collect, use, process, store, disclose, protect, and otherwise handle information when you access or use the KAIT website, applications, wallets, staking services, rewards programs, referral programs, exchange-related services, and other products or services made available through the KAIT ecosystem (collectively, the “Services”).

The Services may involve cryptocurrency, digital assets, blockchain networks, wallet services, staking, rewards, referrals, airdrops, educational resources, and related ecosystem activities.

By using the Services, you acknowledge that you have reviewed this Privacy Policy. Where applicable law requires consent for a particular processing activity, we will obtain consent through an appropriate mechanism.

This Privacy Policy should be read together with our Terms and Conditions, Risk Disclosure, Cookie Policy, KYC/AML requirements, and any other applicable policies or notices.

02About KAIT

KAIT is a digital asset and utility token associated with the Kairaa ecosystem and related services. The KAIT ecosystem may provide or facilitate access to services relating to:

• KAIT digital assets
• Cryptocurrency-related transactions
• Wallet services
• Staking
• Staking rewards
• Referral programs
• Community or promotional programs
• Airdrops
• Educational and informational resources
• Exchange-related services
• Other services introduced from time to time

The specific Services available to you may depend on your jurisdiction, eligibility, account status, applicable law, and the availability of particular products or services.

Where a particular Service is provided by an independent third party, that third party may process your information under its own privacy policy and terms.

03Scope of This Privacy Policy

This Privacy Policy applies to personal information processed in connection with the Services, including information collected through:

• The KAIT website
• KAIT applications or platforms
• Account registration
• KYC and verification processes
• Staking and rewards services
• Referral programs
• Customer support
• Contact forms
• Promotional activities
• Blockchain transactions
• Wallet-related services
• Communications with us
• Other KAIT-controlled digital interfaces

04Information We Collect

Depending on how you use our Services, we may collect different categories of information.

4.1 Personal and Identification Information

We may collect:

• Full name
• Email address
• Mobile telephone number
• Date of birth
• Country of residence
• Residential or correspondence address
• Government-issued identification documents
• KYC information
• Tax-related information where legally required
• Account and profile information
• Verification information
• Photographs or verification images
• Information required to establish eligibility for particular Services
• Other information you voluntarily provide or that is required by applicable law

The information required may vary depending on the Service you use and the applicable legal or regulatory requirements.

4.2 Contact Information

When you contact us, we may collect:

• Name
• Email address
• Telephone number where provided
• Message or inquiry
• Attachments or supporting information
• Other information voluntarily provided by you

The KAIT website may provide contact forms requiring information such as name and email address.

4.3 KYC, AML and Compliance Information

Where required for compliance purposes, we may collect:

• Government-issued identification
• Proof of address
• Date of birth
• Photographs or selfies
• Identity-verification information
• Source-of-funds information
• Source-of-wealth information where required
• Tax information
• Transaction information
• Sanctions-screening information
• Politically exposed person screening data where legally required
• Information relating to fraud or financial-crime investigations
• Other information required under applicable laws and regulations

4.4 Cryptocurrency, Wallet and Transaction Information

When you use cryptocurrency or blockchain-related Services, we may process:

• Wallet addresses
• Blockchain addresses
• Transaction hashes
• Deposits
• Withdrawals
• Transaction amounts
• Transaction dates and times
• Blockchain network information
• Token balances
• Transaction history
• Trading activity
• Staking activity
• Staking amounts and periods
• Reward information
• Referral information
• Airdrop participation
• Transfer information
• Other transaction-related information

4.5 Account and Platform Information

We may collect information relating to your account, including:

• Username or account identifier
• Account status
• Login information
• Security settings
• Authentication information
• Transaction history
• Staking status
• Reward status
• Referral status
• Account preferences
• Communications preferences
• Records of interactions with our Services

4.6 Device and Technical Information

When you access our website or Services, we may automatically collect:

• IP address
• Browser type and version
• Operating system
• Device type
• Device identifiers
• Language settings
• Regional settings
• Website access times
• Pages viewed
• Referring URLs
• Approximate location derived from technical information where permitted
• Session information
• Usage information
• Error information
• Diagnostic information
• Security and performance information

4.7 Cookies and Similar Technologies

We may use cookies, pixels, local storage, analytics technologies, SDKs, and similar technologies to operate, secure, analyze, and improve our Services. These technologies may be used for:

• Website functionality
• Authentication
• Session management
• Security
• Fraud prevention
• Analytics
• Performance monitoring
• Remembering preferences
• Improving user experience
• Understanding how users interact with our Services

Where required by applicable law, we will obtain consent before using non-essential cookies or similar technologies. You may control cookies through your browser settings and, where available, our cookie-consent mechanism.

05How We Use Personal Information

We may process personal information for the following purposes.

5.1 Providing and Operating Services

We may use information to:

• Create and manage accounts
• Provide access to our Services
• Process transactions
• Provide wallet-related services
• Support staking
• Calculate and administer rewards
• Administer referral programs
• Administer airdrops
• Provide customer support
• Provide educational resources
• Maintain account records
• Communicate with users
• Operate and improve the KAIT ecosystem

5.2 KYC, AML and Regulatory Compliance

We may process information to:

• Verify identity
• Perform KYC procedures
• Conduct AML checks
• Conduct counter-terrorist financing checks
• Conduct sanctions screening
• Detect and prevent financial crime
• Identify suspicious activity
• Meet tax and reporting obligations
• Comply with applicable laws and regulations
• Respond to lawful requests from authorities
• Satisfy regulatory and compliance requirements

5.3 Security and Fraud Prevention

We may use information to:

• Protect accounts
• Detect unauthorized access
• Prevent fraud
• Detect suspicious transactions
• Investigate security incidents
• Prevent abuse
• Identify manipulation
• Monitor unusual activity
• Protect our systems and infrastructure
• Protect users
• Maintain the integrity and security of the Services

5.4 Communications

We may use contact information to:

• Respond to inquiries
• Provide account notifications
• Send security alerts
• Communicate transaction information
• Notify users about changes to Services
• Provide important legal or regulatory notices
• Communicate about maintenance or service interruptions
• Provide other service-related communications

Where required by law, marketing communications will be sent only through an appropriate consent or lawful communication mechanism.

5.5 Website and Service Improvement

We may analyze usage and technical information to:

• Improve website functionality
• Improve Services
• Develop new features
• Monitor performance
• Troubleshoot technical problems
• Improve security
• Understand user interactions
• Identify errors
• Improve reliability

06Legal Grounds for Processing

Depending on the applicable law and the circumstances, we may process personal information based on:

• Your consent
• Performance of a contract or provision of requested Services
• Compliance with a legal or regulatory obligation
• Prevention, detection, and investigation of fraud or financial crime
• Protection of our systems and Services
• Protection of users and other persons
• Legitimate interests where legally recognized
• Establishment, exercise, or defense of legal claims
• Another lawful basis permitted by applicable law

The applicable legal basis may differ depending on the jurisdiction, type of information, and purpose of processing.

Where processing is based on consent, you may withdraw consent through the mechanism made available for that processing, subject to applicable legal limitations. Withdrawal of consent does not affect processing lawfully carried out before withdrawal.

07KYC, AML and Financial-Crime Compliance

Certain Services may require identity verification before you can access or continue using them.

We may use internal systems or authorized third-party verification providers to conduct KYC, AML, sanctions screening, fraud prevention, and related compliance procedures.

We may retain compliance information for the period required by applicable law, regulatory requirements, legitimate business requirements, dispute resolution, fraud prevention, or enforcement of legal obligations.

Where required, we may refuse, restrict, suspend, or terminate access to Services based on legal or compliance requirements.

08KAIT Staking, Rewards and Referral Information

Where KAIT provides staking, rewards, referral, community, promotional, or related programs, we may process information necessary to administer those programs. This may include:

• Wallet address
• Staking amount
• Staking date
• Staking duration
• Staking status
• Reward amounts
• Reward history
• Referral identifiers
• Referral activity
• Eligibility information
• Program level or status
• Promotional participation
• Related blockchain transaction information

Information may be processed to determine eligibility, calculate rewards, prevent abuse or manipulation, maintain records, and comply with applicable requirements.

Participation in a staking, rewards, referral, or promotional program may be subject to separate terms and eligibility requirements.

09Blockchain and Public Ledger Privacy

Blockchain networks are generally decentralized and transparent. Depending on the blockchain used, information such as:

• Wallet addresses
• Transaction hashes
• Transaction amounts
• Timestamps
• Token movements
• Other transaction information

may be publicly accessible.

Information recorded on a public blockchain may be replicated across multiple systems and may be technically difficult or impossible to modify or delete.

Accordingly, privacy rights that apply to information stored in our systems may not be technically exercisable in the same manner with respect to information permanently recorded on a blockchain.

10Wallet and Account Security

Users are responsible for taking reasonable steps to protect their accounts and authentication credentials. Depending on the Services available, you may be responsible for protecting:

• Passwords
• PINs
• OTPs
• Two-factor authentication credentials
• Recovery credentials
• Private keys
• Seed phrases
• Wallet credentials
• Other security information

If you believe your account or credentials have been compromised, you should contact us promptly through an official KAIT support channel.

11Information Sharing and Disclosure

We do not sell personal information for monetary consideration.

We may disclose or provide access to personal information where reasonably necessary to operate the Services, comply with law, protect users, prevent fraud, or perform other lawful activities. Information may be shared with:

11.1 Service Providers

Service providers may assist us with:

• KYC and identity verification
• Cloud hosting
• Data storage
• Cybersecurity
• Analytics
• Customer support
• Email and communications
• Payment processing
• Technical infrastructure
• Fraud detection
• Security monitoring
• Other operational functions

Service providers may process information only as permitted by applicable law and the relevant contractual or legal arrangements.

11.2 Exchanges, Wallet and Ecosystem Partners

Where necessary to provide KAIT-related Services, relevant information may be shared with or processed by exchanges, wallet providers, custodial service providers, blockchain service providers, or other ecosystem partners.

The KAIT website may identify Koinnation Exchange as an exchange or service provider associated with KAIT-related services.

Where a third party independently determines how personal information is processed, its own privacy policy and terms may apply.

11.3 Legal and Regulatory Authorities

We may disclose information where required or permitted by law to:

• Government authorities
• Courts
• Regulators
• Law-enforcement agencies
• Tax authorities
• Financial intelligence authorities
• Courts and tribunals
• Other authorized public bodies

11.4 Corporate Transactions

If KAIT or the relevant operating entity is involved in a merger, acquisition, restructuring, financing, sale of assets, investment, reorganization, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

12International Data Transfers

Depending on your location and the location of our service providers, your information may be processed or stored outside your country of residence.

Where applicable law requires safeguards for international transfers, we will implement appropriate legal, contractual, organizational, or technical measures.

By using the Services, you acknowledge that international processing may occur where permitted by applicable law.

13Data Security

We use reasonable technical, organizational, and administrative measures designed to protect personal information against:

• Unauthorized access
• Unauthorized disclosure
• Loss
• Misuse
• Alteration
• Destruction
• Cybersecurity threats
• Other unlawful or unauthorized processing

Security measures may include:

• Access controls
• Encryption where appropriate
• Authentication mechanisms
• Monitoring
• Logging
• Security procedures
• Vulnerability management
• Other reasonable security measures

14Data Breach and Security Incidents

If we become aware of a personal-data breach or security incident affecting personal information, we will assess and respond to the incident in accordance with applicable law and our internal security procedures.

Depending on the nature and legal requirements applicable to the incident, we may:

• Investigate the incident
• Contain and mitigate the incident
• Take steps to prevent recurrence
• Notify relevant authorities where required
• Notify affected individuals where required
• Cooperate with regulators and law-enforcement authorities
• Maintain appropriate records of the incident

Users should promptly notify us if they suspect unauthorized access to their account or personal information.

15Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law. Retention may be necessary for:

• Providing Services
• Maintaining accounts
• Maintaining transaction records
• KYC and AML compliance
• Legal and regulatory obligations
• Tax requirements
• Fraud prevention
• Dispute resolution
• Enforcing agreements
• Cybersecurity
• Accounting and business records
• Establishing, exercising, or defending legal claims

Retention periods may vary depending on the category of information and applicable legal requirements. Certain blockchain transaction information may remain permanently recorded on the relevant blockchain.

When information is no longer required, we may delete, anonymize, or securely dispose of it, subject to technical and legal limitations.

16Your Privacy Rights

Depending on the law applicable to you, you may have rights relating to your personal information. These may include:

• The right to access information about your personal data
• The right to request correction of inaccurate information
• The right to request deletion where legally available
• The right to withdraw consent where processing is based on consent
• The right to request information regarding processing
• The right to restrict or object to certain processing where applicable
• The right to data portability where applicable
• The right to nominate or exercise other rights recognized by applicable law
• The right to raise a grievance
• The right to approach the applicable data-protection authority or regulatory body

These rights are subject to applicable legal limitations and exceptions. We may need to verify your identity before processing a privacy request. We may also refuse or limit a request where permitted or required by applicable law.

17India – Digital Personal Data Protection Framework

Where applicable, KAIT will process digital personal data in accordance with applicable Indian data-protection laws, including the Digital Personal Data Protection Act, 2023 and the Digital Personal Data Protection Rules, 2025, as and when the relevant provisions apply to the Services and processing activities.

The Indian framework establishes obligations relating to the processing and protection of digital personal data and provides rights and mechanisms for individuals in accordance with the applicable provisions.

The notified DPDP Rules, 2025 provide requirements concerning matters including clear notices, consent-related mechanisms, rights exercise, complaints, security safeguards, and other compliance obligations.

The precise rights, obligations, implementation dates, notices, retention requirements, and compliance mechanisms applicable to a particular processing activity may depend on the applicable law and the relevant commencement provisions.

Where required, KAIT will provide appropriate notices and mechanisms for:

• Obtaining consent
• Withdrawing consent
• Exercising applicable rights
• Raising grievances
• Managing personal data
• Receiving legally required information

18European Economic Area and United Kingdom Users

Where the GDPR, UK GDPR, or another applicable data-protection law applies to you, you may have additional rights. These may include:

• Access
• Correction
• Erasure
• Restriction of processing
• Objection to processing
• Data portability
• Withdrawal of consent
• Rights relating to automated decision-making
• The right to lodge a complaint with a competent supervisory authority

Where applicable, we will identify the relevant legal basis for processing and provide additional information required by applicable law.

19Automated Decision-Making, Monitoring and Risk Assessment

We may use automated tools or systems for purposes including:

• Fraud detection
• Security monitoring
• Transaction monitoring
• Risk assessment
• Account protection
• Sanctions screening
• KYC/AML screening
• Suspicious-activity detection
• Prevention of abuse or manipulation

Where applicable law provides rights concerning automated decision-making or profiling, you may contact us regarding those rights.

Certain automated or semi-automated controls may result in a transaction, account, or Service being temporarily restricted or subject to additional review where permitted by applicable law.

20Marketing Communications

Where permitted by law, we may send promotional communications regarding:

• KAIT products
• Services
• Staking programs
• Ecosystem developments
• Campaigns
• Educational activities
• Events
• Announcements
• Other promotional activities

You may unsubscribe from marketing communications by using the unsubscribe mechanism provided in the communication or by contacting us.

21Children's Privacy

The Services are not intended for individuals who are below the minimum legal age required to use the relevant Service.

We do not knowingly collect personal information from children where such collection is prohibited by applicable law.

If you believe that a child has provided personal information to us in violation of applicable requirements, please contact us. If we become aware that personal information has been collected contrary to applicable children's privacy requirements, we may take appropriate steps to delete or otherwise address the information, subject to legal requirements.

22Third-Party Websites and Services

Our website and Services may contain links to third-party:

• Exchanges
• Wallets
• Blockchain explorers
• Websites
• Payment providers
• Social-media platforms
• Applications
• Service providers
• Other external services

We do not control the privacy practices, security, terms, or content of third-party services. Your use of third-party services is subject to the terms and privacy policies of those third parties.

You should review the relevant privacy policy before providing personal information to a third-party service.

23Social Media

KAIT may maintain or link to social-media accounts or community platforms.

If you interact with KAIT through a social-media platform, that platform may collect and process information under its own privacy policy.

We are not responsible for the privacy practices, security, or policies of third-party social-media platforms.

24User-Generated Information and Public Communications

If you voluntarily post information in a public community, forum, social-media channel, blockchain transaction, or other publicly accessible environment associated with the KAIT ecosystem, that information may become accessible to other users or the public.

25Privacy Requests and Identity Verification

To exercise an applicable privacy right or submit a privacy-related request, you may contact us using the details provided in the “Contact Us” section.

To protect users and prevent unauthorized disclosure, we may request reasonable information to verify your identity before processing a request.

We may retain records relating to privacy requests where necessary to demonstrate compliance, resolve disputes, prevent fraud, or meet legal requirements.

26Grievance and Data Protection Contact

Where required by applicable law, KAIT will maintain an appropriate privacy or data-protection contact and/or grievance mechanism.

Privacy-related requests should contain sufficient information to enable us to understand and process the request. Where applicable, we will respond within the period required by law.

27No Sale of Personal Information

KAIT does not sell personal information for monetary consideration.

We may nevertheless process or disclose information to service providers, partners, authorities, and other recipients where permitted or required by law and as described in this Privacy Policy.

Nothing in this section prevents lawful processing, disclosure, transfer, or sharing that is necessary to provide Services or comply with legal obligations.

28Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes may be made due to:

• Changes to our Services
• New products or features
• Changes in technology
• Changes in data-processing practices
• Changes in applicable laws
• Regulatory requirements
• Cybersecurity developments
• Changes in business operations

When we update this Privacy Policy, we will publish the revised version on the applicable website or platform and update the “Last Updated” date.

Where required by law, we may provide additional notice or obtain consent before implementing material changes.

Your continued use of the Services after the effective date of an updated Privacy Policy constitutes acknowledgment of the updated policy to the extent permitted by applicable law.

29Governing Law and Jurisdiction

This Privacy Policy will be interpreted and applied in accordance with applicable law.

Where legally permissible, matters relating to this Privacy Policy and the processing of personal information will be subject to the laws and jurisdiction applicable to the entity responsible for operating the relevant Service.

Nothing in this section limits any mandatory rights or protections available to you under the laws of your jurisdiction.

The final governing-law and jurisdiction clause should be aligned with the legal entity operating KAIT and the applicable Terms and Conditions.

30Contact Us

If you have questions regarding this Privacy Policy, your personal information, KYC information, privacy rights, or our data-processing practices, please contact us.

For privacy-related requests, please provide sufficient information for us to identify the relevant account or request and verify your identity where required.

31Important Security Notice

KAIT will not ordinarily request your:

• Private key
• Seed phrase
• Wallet recovery phrase
• Account password
• OTP
• Two-factor authentication code
• Other confidential authentication information

through unsolicited communications.

32Acknowledgment

By accessing or using the KAIT website or Services, you acknowledge that you have had an opportunity to review this Privacy Policy.

Where applicable law requires consent, consent will be obtained through the relevant consent mechanism and may be withdrawn as permitted by law.

If you do not agree with the applicable privacy practices or cannot comply with the applicable requirements, you should discontinue use of the relevant Services.

Legal and Regulatory Note

This Privacy Policy is intended to describe KAIT's privacy and personal-data processing practices. It is not a substitute for legal advice.

The applicability of data-protection, cryptocurrency, virtual-digital-asset, AML/KYC, tax, consumer-protection, financial-services, securities, licensing, sanctions, and other laws may vary depending on the KAIT operating entity, the Services offered, and the jurisdiction of the user.

KAIT should obtain a jurisdiction-specific legal review before publishing this Privacy Policy or relying on it as evidence of regulatory compliance.