Privacy Policy

1. Introduction

Polarbit Solutions Limited ("Company", "we", "us", or "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, process, and protect your personal data when you use the TOLO Exchange platform.

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and all applicable Canadian data protection laws.

2. Data Controller

The data controller is Polarbit Solutions Limited, registered at 700-838 W Hastings Street, Vancouver, BC V6C 0A6, Canada, FINTRAC MSB: C10001398, Incorporation No: BC1547199.

3. Data We Collect

We collect the following categories of personal data:

• Identity Data: Full name, date of birth, nationality, government-issued ID documents
• Contact Data: Email address, phone number, residential address
• Financial Data: Bank account details, transaction history, wallet addresses
• Technical Data: IP address, browser type, device information, login data
• Usage Data: Trading activity, platform interaction, feature usage

4. How We Use Your Data

We use your personal data for:

• Account registration and management
• KYC/AML compliance and identity verification
• Processing transactions and providing services
• Fraud prevention and security monitoring
• Customer support and communication
• Legal and regulatory compliance
• Platform improvement and analytics

5. Legal Basis for Processing

We process your data based on:

• Performance of a contract (providing our services)
• Legal obligations (AML/KYC compliance)
• Legitimate interests (fraud prevention, platform security)
• Your consent (marketing communications)

6. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements. AML/KYC records are retained for a minimum of 5 years after the end of the business relationship.

7. Your Rights

Under applicable privacy law, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Request data erasure ("right to be forgotten")
• Restrict processing of your data
• Data portability
• Object to processing
• Lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC)

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including encryption, access controls, regular security audits, and employee training.

9. International Transfers

Your data may be transferred to and processed in countries outside of Canada. We ensure adequate protection through contractual safeguards or other approved transfer mechanisms.

10. Cookies

We use cookies and similar technologies as described in our Cookie Policy. You can manage cookie preferences through your browser settings.

11. Contact Us

For any questions about this Privacy Policy or to exercise your data rights, contact our Data Protection Officer:

Email: support@toloexchange.biz
Address: 700-838 W Hastings Street, Vancouver, BC V6C 0A6, Canada