PONTIFI
Privacy Policy
Version 1.0 · Last updated 15.09.2026 · Effective from 15.09.2026
This Policy explains how Pontifi Technologies Inc. handles personal data in connection with the Pontifi platform and website.
1. Introduction
1.1. This Privacy Policy describes how Pontifi Technologies Inc., a sociedad anónima incorporated in the Republic of Panama on 6 August 2026, registered with the Public Registry of Panama, Mercantile Section, Folio No. 155788271, with its registered office at Calle 55 Este, Edificio SL55, Piso 21, Oficina 3, Panama City, Republic of Panama (the "Company", "we", "us", or "our"), collects, uses, discloses, and protects personal data in connection with the Pontifi platform and the website available at https://www.pontifi.io (together, the "Platform"). Except as stated in Section 12, the Company is the controller of the personal data described in this Policy.
1.2. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Platform.
1.3. The Platform is a technology solution that enables users to connect with independent third-party service providers ("Partners"). Where Partners collect and process your personal data in connection with their own services — for example for their own onboarding, verification, or compliance purposes — they do so as independent controllers under their own privacy policies, which we encourage you to review. This Privacy Policy does not apply to processing carried out by Partners.
1.4. The Platform is not directed at, and is not intended for use by, persons located in the United States of America, the European Union, the European Economic Area, or the United Kingdom, or in any other restricted jurisdiction identified in our Terms of Service.
1.5. The Company is established in the Republic of Panama and processes personal data in accordance with Law 81 of 26 March 2019 on the Protection of Personal Data and Executive Decree No. 285 of 28 May 2021, under the supervision of the National Authority for Transparency and Access to Information (Autoridad Nacional de Transparencia y Acceso a la Información, ANTAI).
2. Personal data we collect
2.1. Data you provide to us, including: (a) account and registration data, such as name, email address, telephone number, company name, and job title; (b) profile and settings information; (c) communications you send to us, including support requests; and (d) any other information you choose to provide.
2.2. Verification and compliance data, which we are required to collect under our contractual obligations to our Partners, and which our Partners are required to collect under their own regulatory obligations, before you are permitted to transact: (a) identity data, including full name, date of birth, nationality, country of residence, residential address and the details and images of identity documents; (b) a photograph or short video recorded at the point of verification, used solely to confirm that the application is being submitted by a live person and not by means of a photograph, a recording or a forged document (a liveness check) — the Company does not carry out biometric matching, does not create a biometric template and does not use facial recognition; (c) for legal entities, corporate documents, details of directors and of beneficial owners holding 25 per cent or more, and evidence of the authority of the person acting; (d) information on the purpose of the relationship, expected activity, source of funds and, where relevant, source of wealth, together with any supporting documents; and (e) the results of sanctions, politically exposed person and adverse media screening.
2.3. Transaction and activity data, including instructions submitted through the Platform, amounts, currencies, counterparties, payment instruments, digital-asset addresses and transaction identifiers, and the results of blockchain analytics screening of those addresses.
2.4. Data collected automatically, including: (a) device and technical data, such as IP address, browser type, operating system, device identifiers, and language settings; (b) usage data, such as pages viewed, features used, access times, and referring pages; and (c) data collected through cookies and similar technologies, as described in Section 9.
2.5. Data from third parties, including Partners, identity verification providers, screening and analytics providers, commercial databases and public registers, to the extent necessary to operate the Platform, verify you, maintain security, or comply with our legal and contractual obligations.
2.6. We do not knowingly collect sensitive personal data as defined in Law 81 of 2019, including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual orientation, genetic data or biometric data, and we ask that you do not provide such data through the Platform. The image referred to in clause 2.2(b) is used only for the liveness check described there; no biometric template is created from it and it is not used to identify you by your physical characteristics.
3. How we use personal data
3.1. We use personal data to: (a) provide, operate, maintain, and improve the Platform; (b) create and manage your account and authenticate you; (c) verify your identity and that of your directors and beneficial owners, and assess and monitor the risk associated with the relationship; (d) screen you and your transactions against sanctions, politically exposed person and adverse media data, and screen digital-asset addresses using blockchain analytics; (e) facilitate integrations and the routing of your instructions to Partners at your request; (f) respond to your enquiries and provide support; (g) monitor and analyse usage, and develop new features; (h) maintain the safety, security, and integrity of the Platform, and prevent fraud, abuse, and unauthorised access; (i) comply with legal obligations applicable to us, and with the anti-money laundering, counter-terrorist financing and sanctions requirements our Partners are required to apply, and respond to lawful requests from competent authorities; (j) enforce our Terms of Service and other agreements, and establish, exercise or defend legal claims; and (k) send you service-related notices and, where permitted, information about the Platform and its features (you may opt out of marketing communications at any time).
3.2. We process personal data on the basis of your consent, and without consent where Law 81 of 2019 permits it — in particular where processing is necessary for the performance of our agreement with you (including the verification, screening and monitoring it requires), for compliance with a legal or contractual obligation, for compliance with an order of a competent authority, or to protect vital interests.
3.3. Some verification and screening steps are automated. An automated screening alert may result in the delay, refusal or blocking of a transaction, or in the refusal or suspension of an account. You may ask us to review such a decision by contacting us at compliance@pontifi.com, and the matter will be considered by a member of our compliance staff, save where we are prevented by applicable law from disclosing the reason for the measure.
4. How we share personal data
4.1. We may share personal data with: (a) Partners — including providers of custody, card issuing, payment processing and digital-asset services — to the extent necessary to onboard you and to enable the functions you request through the Platform, and to meet the compliance requirements those Partners apply; (b) identity verification, sanctions screening and blockchain analytics providers, who process the data on our behalf under written agreements; (c) service providers who perform services on our behalf, such as hosting, analytics, communications, and customer support, subject to appropriate confidentiality obligations; (d) professional advisers, such as lawyers, auditors, and insurers, where necessary; (e) competent authorities, courts, or other third parties, where we believe disclosure is required by applicable law or necessary to protect our rights, our users, or the public; and (f) a successor or acquirer in connection with a merger, acquisition, reorganisation, or sale of assets.
4.2. We do not sell personal data and do not share it for third-party advertising purposes.
4.3. Where we or a Partner are required by applicable law to report a suspicion to a financial intelligence unit or other authority, we may be prohibited from informing you that such a report has been made.
5. International transfers
5.1. Personal data is stored and processed in the Republic of Panama and in the countries in which our Partners and service providers operate. We transfer personal data outside Panama where the transfer is necessary to provide the Platform and the Partner services you request, or with your consent, as permitted by Law 81 of 2019 and Executive Decree No. 285 of 2021. Service providers acting on our behalf are bound by written agreements imposing confidentiality and security obligations; Partners process your data under their own privacy policies (clause 1.3). A list of the categories of recipients and the countries in which they process personal data is available on request from compliance@pontifi.com.
6. Data retention
6.1. We retain personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, including to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements.
6.2. Verification and compliance records — including identity documents, verification results, screening results, transaction records and the records of any internal report — are retained for at least five (5) years following the end of the relationship or the date of the transaction, whichever is later, and for longer where a competent authority, a Partner, or applicable law so requires. When personal data is no longer needed, we delete or anonymise it within a reasonable period.
7. Security
7.1. We implement reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration, including access controls, encryption in transit, and the restriction of access to compliance records to authorised personnel. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.
7.2. If a security incident affects your personal data, we will notify you and ANTAI within seventy-two (72) hours of becoming aware of it, as required by Law 81 of 2019 and Executive Decree No. 285 of 2021, describing the nature of the incident, the data affected, the likely consequences and the measures taken.
8. Your rights
8.1. Under Law 81 of 2019 you have the rights of access, rectification, cancellation, opposition and portability in respect of your personal data, and the right to withdraw consent where processing is based on consent.
8.2. These rights are limited where we are required to retain data to comply with anti-money laundering, contractual and other legal obligations. In particular, we cannot delete verification and transaction records before the retention period in clause 6.2 has expired.
8.3. To exercise any right, please contact us at compliance@pontifi.com. We will respond within ten (10) business days of your request, or within five (5) business days in the case of a request for rectification, as prescribed by Law 81 of 2019 and Executive Decree No. 285 of 2021. We may need to verify your identity before acting on your request, and we may decline a request where permitted or required by law, stating our reasons. If you are not satisfied with our response, you may lodge a complaint with ANTAI, Panama City, Republic of Panama.
9. Cookies and similar technologies
9.1. We use cookies and similar technologies to operate the Platform, remember your preferences, maintain sessions, provide security, and analyse usage. Cookies that are not strictly necessary are used only where you have accepted them. You can change your cookie choice at any time via the "Cookie settings" link in the footer of the website at https://www.pontifi.io, or through your browser settings; disabling certain cookies may affect the functionality of the Platform.
10. Children
10.1. The Platform is intended for persons who are at least 18 years old. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided us with personal data, please contact us and we will take appropriate steps to delete it.
11. Third-party links and services
11.1. The Platform may contain links to, or integrations with, websites and services operated by Partners and other third parties. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party websites or services you use.
12. Business Users and personal data of third parties
12.1. Where a business User (as defined in the Terms of Service) submits to the Platform personal data relating to its own customers, payers, employees, cardholders, contractors or vendors, that business User is the controller of such data and the Company processes it on that User's documented instructions, save where the Company processes it for its own compliance, security or legal purposes, in which case the Company acts as an independent controller.
12.2. Each business User warrants that it has a lawful basis for, and has given any notices required for, the disclosure of such data to the Company and to the Partners.
12.3. On request made to compliance@pontifi.com, the Company will enter into a Data Processing Addendum with a business User covering sub-processors, security measures, breach notification and the return or deletion of data.
13. Changes to this Privacy Policy
13.1. We may update this Privacy Policy from time to time by publishing an updated version in the Platform, with a revised "Last updated" date. Where a change materially affects how we process your personal data, we will notify you before it takes effect.
14. Contact us
Questions about this Privacy Policy, and requests concerning personal data, should be addressed to:
Pontifi Technologies Inc., a sociedad anónima incorporated in the Republic of Panama on 6 August 2026, registered with the Public Registry of Panama, Mercantile Section, Folio No. 155788271.
Registered office: Calle 55 Este, Edificio SL55, Piso 21, Oficina 3, Panama City, Republic of Panama
General and support: hello@pontifi.io
Compliance and data protection: compliance@pontifi.io
Website: https://www.pontifi.io