Privacy

Privacy Policy

Last updated: November 28, 2025

This privacy notice explains how Oasis Digital Holdings Limited ("Oasis Digital", "Company", "we", "us" or "our") collects, uses, stores and shares information about you when you use our products and services.

Oasis Digital Holdings Limited is a company incorporated in the British Virgin Islands, and for the purposes of the British Virgin Islands Data Protection Act, 2021 ("DPA") we are the data controller of your personal information.

Please read this notice carefully to understand how we handle your information and the rights you may have.

If you do not agree with any part of this privacy notice, you should not use our services.

1. Who we are and how to contact us

This privacy notice applies to:

  • Our website at https://suiet.app and any subdomains that link to this notice

  • Our browser extensions, mobile or desktop applications and related tools and features (together, the "Services")

  • Any other interactions you have with us, for example by email, social media or support channels

The controller of your personal information is:

Oasis Digital Holdings Limited
A company incorporated in the British Virgin Islands
Email: contact@suiet.app

2. Summary

  • We design Suiet so that, by default, most wallet data stays locally on your device. We do not transmit your private keys or seed phrases to our servers.

  • We may process limited personal information about you, for example if you contact us, sign up for updates or interact with our website or support channels.

  • As a BVI company, we are subject to the BVI Data Protection Act, 2021, which sets out principles for lawful, fair and secure processing of personal data.

  • Depending on where you live, you may also have additional rights under other data protection laws, such as the EU or UK GDPR or similar regimes.

  • We use reasonable technical and organisational measures to protect your information, but no system can be guaranteed to be completely secure.

3. What information we collect

3.1 Information you provide to us

We may collect information that you choose to provide directly, for example:

  • Contact details such as name, email address and any other information you include when you:

    • Request information about Suiet or our Services

    • Subscribe to newsletters or marketing communications

    • Participate in surveys, beta programs or community campaigns

    • Contact us for support

  • Support communications including the content of messages, screenshots and any other information you provide when you request help.

We do not ask you to provide and we do not want you to send us:

  • Your seed phrase, private keys, full wallet backup or similar highly sensitive secrets

  • Highly sensitive personal information such as health information, biometric data or government identifiers

If you choose to provide such information anyway, you do so at your own risk.

3.2 Information collected automatically

When you visit our website or use Services that connect to the internet, we may automatically collect limited information that your browser or device sends, such as:

  • Device information such as device type, operating system and version, browser type and settings

  • Log information such as the date and time of access, pages viewed, basic diagnostic information and error logs

  • General location information derived from your IP address, at a city or region level, where needed for security or analytics

We use this information mainly to operate and secure the Services, to understand how they are used and to improve them.

Where possible, we either do not collect IP addresses at a level that identifies you personally or we collect and store them only in an aggregated or truncated form.

3.3 Wallet data and blockchain information

Suiet is a non custodial wallet. In general:

  • Your private keys, seed phrase and transaction signing happen locally on your device. We do not have access to them.

  • Information about your blockchain transactions and balances is publicly available on the relevant blockchain and may be associated with your wallet addresses. This information is not created by us, but we may display it in the wallet interface or use it to provide the Services.

Because public blockchains are transparent by design, anyone can view transaction data associated with your wallet addresses. Take this into account when you use the Services.

3.4 Third party integrations and ZK Login

If you use features that rely on third parties (for example, ZK Login or other authentication providers):

  • We may receive limited tokens or identifiers that allow the feature to function.

  • According to our current design, we do not persist your third party login credentials or passwords on our servers. They are stored locally on your device or managed by the third party.

The exact data processed will depend on how each integration is implemented and on the settings you configure. You should also review the privacy policies of the relevant third party providers.

4. Why we use your information and legal bases

We process personal information only where there is a legal basis to do so under applicable law. Under the BVI DPA and other similar laws, this includes:

  • To provide and operate the Services

    • To allow you to install and use the wallet and related features

    • To provide support, respond to your inquiries and handle bug reports

  • To maintain security and prevent abuse

    • To monitor for suspicious or malicious activity and protect against fraud, spam and misuse

    • To enforce our terms of use and other policies

  • To improve and develop the Services

    • To analyse aggregated or de identified usage patterns

    • To test and roll out new features and UX improvements

  • To communicate with you

    • To send service announcements, security alerts and administrative messages

    • To send marketing communications where you have opted in, and to allow you to manage your preferences

  • To comply with legal obligations and protect our legitimate interests

    • To comply with laws in the BVI and other jurisdictions where required

    • To protect our rights, property and safety and that of our users and third parties

Where we rely on consent, you have the right to withdraw that consent at any time, but this will not affect processing that has already taken place.

5. How we share information

We do not sell your personal information.

We may share your information in the following limited situations:

  • Service providers
    We use third party vendors to help us operate and improve the Services, such as hosting providers, analytics tools, customer support platforms, email service providers and security services. These vendors may process your information on our behalf and only according to our instructions and applicable data protection laws.

  • Business transfers
    If we are involved in a merger, acquisition, financing or sale of all or a portion of our business, your information may be disclosed to advisers and other participants in the transaction and may be transferred to a successor entity, subject to appropriate safeguards.

  • Legal and regulatory requirements
    We may disclose information where we believe it is necessary to:

    • Comply with a legal or regulatory obligation or request

    • Protect the rights, property or safety of the Company, our users or others

    • Detect, prevent or address fraud, security or technical issues

  • With your consent
    We may share your information with other third parties when you explicitly give us permission to do so.

6. International transfers

Because we are a BVI company and use service providers located in different countries, your information may be processed in jurisdictions outside of the British Virgin Islands and outside of your country of residence.

Where required by law, we take steps to ensure that such cross border transfers are subject to appropriate safeguards, for example by:

  • Entering into contractual terms that require service providers to protect personal data in line with applicable standards

  • Limiting access to personal data on a need to know basis

  • Using providers in jurisdictions that have comparable data protection regimes where possible

7. Data retention

We keep personal information only for as long as reasonably necessary for the purposes described in this notice or as required by law, including for:

  • Providing and maintaining the Services

  • Resolving disputes and handling support issues

  • Meeting our legal and regulatory obligations

When we no longer need personal information, we will either delete or anonymise it. If deletion is not possible immediately, we will securely store the information and isolate it from further use until deletion is possible.

8. How we protect your information

We use appropriate technical and organisational measures designed to protect the personal information we process, including:

  • Limiting the personal information we collect and store

  • Using encryption, access controls and logging where appropriate

  • Restricting access to personal information to staff and service providers on a need to know basis

However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security of your information.

You are responsible for maintaining the security of your devices and your wallet secrets, including your seed phrase and private keys. We will never ask you to send us your seed phrase or private keys.

9. Your rights

Your rights depend on the laws that apply where you live. Under the BVI Data Protection Act, 2021, individuals generally have rights that are similar to those under EU and UK style data protection regimes, including the right to:

  • Access the personal information we hold about you

  • Rectify inaccurate or incomplete personal information

  • Erase personal information in certain circumstances

  • Restrict or object to certain processing

  • Withdraw consent where processing is based on consent

  • Lodge a complaint with the relevant supervisory authority

If you are located in the European Economic Area (EEA) or the United Kingdom, you may also have rights under the EU or UK GDPR.

If you live in another jurisdiction that provides additional privacy rights, we will respect those rights where the law requires us to do so.

How to exercise your rights

You can exercise your rights or ask questions about this notice by contacting us at:

Email: contact@suiet.app

We may need to verify your identity before responding to certain requests. We will respond within the time limits required by applicable law.

10. Children

Our Services are not intended for and should not be used by children under 18 years of age.

We do not knowingly collect personal information from children. If you believe that a child under 18 has provided us with personal information, please contact us and we will take steps to delete the information as required by law.

11. Third party services and links

The Services may contain links to third party websites, services or content that are not operated by us, including:

  • External websites and documentation

  • Blockchain explorers and network infrastructure managed by third parties

  • Analytics providers, authentication providers and other integrations

We are not responsible for the privacy practices of these third parties. Their handling of your information is governed by their own privacy policies, which you should review.

12. Changes to this privacy notice

We may update this privacy notice from time to time, for example to comply with changes in law or to reflect changes in our Services.

When we do so, we will update the "Last updated" date at the top of this notice, and the revised version will be effective as soon as it is posted. Where required by law, we will provide additional notice of material changes.

We encourage you to review this notice regularly so that you stay informed about our information practices.

13. How to contact us or make a complaint

If you have any questions, concerns or complaints about this privacy notice or how we handle your information, you can contact us at:

Oasis Digital Holdings Limited
Email: contact@suiet.app

If you are located in a jurisdiction where you have the right to lodge a complaint with a data protection authority, you may also contact the relevant supervisory authority. In the British Virgin Islands, oversight of the Data Protection Act, 2021 is carried out by the competent public authority designated under that law.