This document is published in English. The English version is the legally binding text.

PRIVACY POLICY OF MOVITON LTD.

Last Updated: October 21, 2026

This Privacy Policy (“Policy”) explains how MovitOn Ltd., a company incorporated under the laws of the British Virgin Islands (the “Company”, “we”, “us”, or “our”), collects, uses, discloses, and safeguards personal data when you access, interact with, or participate in the MVON token sale, connect a cryptographic wallet, or use our website and associated applications (collectively, the “Platform”).

We respect your privacy and are committed to protecting your personal data in compliance with applicable international data protection laws, including the BVI Data Protection Act, 2021 (DPA), the General Data Protection Regulation (EU 2016/679) (GDPR), and the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection, where applicable.

1. DATA CONTROLLER & CONTACT DETAILS

1.1. Data Controller: For the purpose of applicable data protection legislation, the data controller is:

Entity: MovitOn Ltd.
Jurisdiction: British Virgin Islands
Contact Email for Data Protection Requests: info@moviton.com

2. TYPES OF DATA WE COLLECT

We collect information directly from you, automatically through your interactions with the Platform, and from third-party Web3/compliance providers.

2.1. Blockchain & Technical Data (Automatically Collected)

Public Wallet Addresses: Your public cryptographic wallet address (e.g., Ethereum/EVM-compatible address) connected to the Platform.
On-Chain Transaction Data: Transaction hashes, timestamps, gas fees, token purchase amounts, and smart contract interaction logs.
Device & Network Data: IP address, browser type and version, operating system, device identifiers, time zone setting, and Web3 provider details (e.g., MetaMask, WalletConnect).

2.2. KYC / AML Compliance Data (Collected via Verified Service Providers)

If required for regulatory compliance or token claim verification, our third-party identity verification partners may collect:

Identity Documents: Government-issued ID, passport, or national identity card.
Proof of Address: Utility bills, bank statements, or official correspondence.
Biometric Data: Facial verification scans/liveness checks for identity authentication.
Compliance Screening Results: Politically Exposed Person (PEP) status, sanctions screening against OFAC, UN, UK, and EU lists, and Source of Funds (SoF) declarations.

2.3. Communication & User Support Data

Email address, Telegram/Discord handle, or other contact details provided voluntarily when submitting support tickets or subscribing to official updates.

3. LEGAL BASES & PURPOSES OF DATA PROCESSING

We process your personal data based on the following legal grounds:

Purpose of Processing	Legal Basis
Executing Token Sale & Claim Mechanics: Processing purchases, calculating token entitlements, and enabling Web3 wallet interactions.	Performance of a Contract: Necessary to fulfill our obligations under the Terms & Conditions.
Regulatory & AML Compliance: Conducting identity checks, sanctions screening, and reporting under BVI DPA, FATF, CARF, and CRS requirements.	Legal Obligation: Necessary to comply with statutory legal and regulatory mandates.
Platform Security & Fraud Prevention: Monitoring suspicious transactions, preventing bot attacks, MEV exploits, or unauthorized access.	Legitimate Interests: Protecting the integrity and operational security of the MovitOn infrastructure.
Communication & Platform Updates: Sending transaction confirmations, TGE announcements, and responding to support requests.	Legitimate Interests & Consent: Maintaining communication with users regarding platform developments.

4. SPECIAL DISCLAIMER: BLOCKCHAIN IMMUTABILITY

4.1. Public Ledger Nature: Blockchain technology is inherently decentralized and transparent. When you connect a wallet or execute a smart contract transaction, your public wallet address and transaction history are permanently recorded on the public blockchain ledger (e.g., Ethereum, Base, OP Mainnet, Polygon or BNB Chain).

4.2. No Alteration or Erasure On-Chain: The Company does not own, control, or operate the underlying public blockchain networks. Data written to a public blockchain cannot be modified, updated, or deleted by the Company.

4.3. Exclusion of Erasure Rights On-Chain: Your statutory rights to request deletion or rectification of data under GDPR, BVI DPA, or UAE Data Protection Law do not apply to data recorded directly on public blockchains.

We do not sell, rent, or trade your personal data to third parties for marketing purposes. We may share your data under the following circumstances:

5.1. Service Providers & Web3 Infrastructure:

Third-party identity verification and KYC/AML providers (e.g., Sumsub, Onfido, or equivalent);
Web3 infrastructure and RPC node providers (e.g., Infura, Alchemy, WalletConnect);
Cloud hosting, analytical, and cybersecurity providers (e.g., AWS, Cloudflare).

5.2. Regulatory & Legal Authorities:

BVI Financial Services Commission (FSC), BVI International Tax Authority (ITA) for CARF/CRS tax reporting, law enforcement agencies, or courts when required by law, subpoena, or official judicial order.

5.3. Corporate Reorganization:

In connection with any merger, acquisition, sale of company assets, or restructuring of MovitOn Ltd., subject to standard confidentiality agreements.

6. INTERNATIONAL DATA TRANSFERS

6.1. Your personal data may be transferred to, processed, and stored in jurisdictions outside the British Virgin Islands or the European Economic Area (EEA), including servers located in the UAE, the United States, or other global cloud data centers.

6.2. Whenever we transfer personal data internationally, we ensure appropriate safeguards are implemented, such as Standard Contractual Clauses (SCCs), adequacy decisions, or binding regulatory compliance frameworks.

7. DATA RETENTION

7.1. Off-Chain Compliance Data: KYC/AML records and transaction verification logs are retained for a minimum period of five (5) years following the completion of the Token Sale or termination of the business relationship, as mandated by BVI Anti-Money Laundering Regulations.

7.2. Technical & Support Data: Retained only for as long as necessary to fulfill the purposes outlined in this Policy or until you request its deletion (subject to statutory record-keeping exceptions).

7.3. On-Chain Data: Persists indefinitely on the public blockchain network.

8. YOUR DATA PROTECTION RIGHTS

Depending on your jurisdiction, you may hold the following statutory rights regarding off-chain personal data held by the Company:

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure (Right to be Forgotten): Request deletion of your off-chain personal data, subject to statutory retention obligations (e.g., 5-year AML record retention).
Right to Restriction & Objection: Object to or request restriction of processing based on legitimate interests.
Right to Data Portability: Request transfer of your data in a structured, machine-readable format.

To exercise any of these rights, please submit a written request to info@moviton.com. We will respond within thirty (30) days.

9. COOKIES & ANALYTICAL TECHNOLOGIES

9.1. We may use essential cookies and local storage tokens to maintain your wallet session and ensure site functionality.

9.2. You can manage or disable non-essential analytics cookies through your browser settings.

10. AMENDMENTS TO THIS PRIVACY POLICY

10.1. We reserve the right to update or modify this Privacy Policy at any time to reflect changes in legal, technical, or business developments.

10.2. The updated version will be indicated by the “Last Updated” date at the top of this page. Continued use of the Platform after any modifications constitutes acceptance of the revised Policy.