Lomalo Labs Digital Wallet
Privacy Policy

1. Information We Collect

We may collect the following types of information when you use Lomalo:
For Individual Users:

• Account Data: Information you provide when registering, including your name, country of origin, and contact information.
• ‍Usage Data: Information about your use of the App, including transaction history, dates, and amounts.
• ‍Device Data: Technical information about the device you use to access Lomalo, such as device type, operating system, and IP address.

For Enterprise Users (Lomalo Enterprise):

• Enterprise Account Data: Information provided during enterprise registration, including enterprise name, enterprise type, registration number, enterprise address, and authorized representative name and contact information.
• Enterprise Transfer Data: Records of transfers processed through Lomalo Enterprise, including transfer volumes, customer-facing transfer identifiers, and transfer settlement data.
• ‍Device Data: Technical information about the device used to access Lomalo Enterprise, such as device type, operating system, and IP address.

2. How We Use Information

We use collected information to:

• Operate and improve Lomalo's functionality and security
• Process and record transfers between users
• Monitor and prevent fraud, misuse, and unlawful activity
• Comply with legal obligations under the laws of the Republic of the Marshall Islands
• Communicate with you regarding your account, service updates, or changes to these policies
• Respond to your inquiries and support requests

3. Sharing of Information

We may share your information with the following parties:

• Government and Regulatory Authorities. We may share information with the Government of the Republic of the Marshall Islands and international enforcement agencies, as required by Marshall Islands law, including for anti-money laundering (AML), countering the financing of terrorism (CFT), and customer due diligence (CDD) purposes.
• Third-Party Identity Verification Providers. When you use features requiring identity verification, your personal information is shared with third-party KYC/AML service providers who perform verification on our behalf or on behalf of the applicable service provider. These providers are bound by their own privacy policies and contractual confidentiality obligations.
• Service Providers. We may share information with other service providers who help us operate Lomalo, including infrastructure, analytics, and security providers. These parties are bound by confidentiality obligations and may only use your information for the purposes of providing services to us.
• Enterprise Transfer Data. When an individual user transacts with a Lomalo Enterprise merchant, certain transaction data — including transfer amount, date, and transaction identifier — is shared with the merchant. Merchants do not receive individual user personal information beyond what is necessary to complete and reconcile the transfer.

Lomalo Labs does not sell your personal information to third parties.

4. Supported Assets and Securities Disclosures

Lomalo supports U.S. dollar-denominated digital assets, which may include USDM1 and third-party stablecoins such as USDC. Certain Supported Assets, including USDM1, may be classified as securities under applicable law. Transaction data associated with securities may be subject to additional regulatory reporting requirements, and we may be required to share such data with regulators or governmental authorities upon request.

Lomalo is not the issuer of USDM1 or any third-party stablecoin and is not affiliated with any third-party stablecoin issuer.

5. Data Security

We take reasonable technical and organizational measures to protect your information. However, no method of digital transmission or storage is fully secure. You acknowledge the inherent risks of using electronic communications and digital networks.

Because Lomalo is non-custodial, we do not store or have access to your private keys or recovery phrases. If you lose access to these, we cannot recover your account or funds.

6. Blockchain and Distributed Ledger Technology

Lomalo uses blockchain and distributed ledger technology to process transfers. Certain information associated with your transfers — including wallet addresses, transfer amounts, timestamps, and transaction identifiers — may be recorded on a public or semi-public distributed ledger. Once recorded on a blockchain, this data is permanent and cannot be modified or deleted by Lomalo or any single party.

While your personal identity is not published on-chain, on-chain transaction data may be visible to third parties and could, under certain circumstances, be linked to your identity through external analysis. Lomalo does not control access to or use of data recorded on public blockchains.

7. Your Choices

You may stop using Lomalo at any time by deleting the App. You may contact us to request access to, correction of, or - where required by applicable law - deletion of your personal information held by Lomalo Labs. Please note that we may be required to retain certain information to comply with legal obligations, and that data recorded on a blockchain or distributed ledger is not subject to deletion.

8. Retention

We retain your information as long as required by law and as necessary to operate Lomalo and comply with regulations under the Republic of the Marshall Islands law. When retention is no longer required, we will delete or anonymize your information in accordance with our data retention practices. Transaction data recorded on a blockchain or distributed ledger exists independently of Lomalo's systems and is not subject to deletion.

9. Children's Privacy

Lomalo is available to individuals aged 13 and older. Users between the ages of 13 and 18 must have consent from a parent or legal guardian. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have collected information from a child under 13, we will take steps to delete that information promptly.

10. Additional Terms for Enterprise

If you use Lomalo Enterprise, the following additional terms apply:

• Account Ownership: The enterprise entity is the account holder. Authorized representatives act on behalf of the enterprise. Lomalo is not responsible for managing internal access permissions within the enterprise.
• ‍Merchant Compliance: Enterprises using Lomalo Enterprise are responsible for their own compliance with applicable data protection, tax reporting, and record-keeping obligations. Lomalo is not responsible for how an enterprise handles data it receives through the platform.
• ‍Consumer Transaction Data: Merchants receive transaction data necessary to process and reconcile payments. Merchants must handle consumer transaction data in accordance with applicable law.

11. International Data Transfers

Lomalo Labs is operated by MIBOND Global LLC, a Delaware limited liability company. Your information may be processed and stored in the United States, the Republic of the Marshall Islands, or other jurisdictions where our service providers operate. By using Lomalo, you consent to the transfer and processing of your information in these jurisdictions, which may have data protection laws that differ from your jurisdiction.

12. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice in the App or by other appropriate means. Continued use of Lomalo after changes take effect constitutes acceptance of the revised Privacy Policy.

13. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact: compliance@lomalo.app.

Entity: MIBOND Global LLC (d/b/a Lomalo Labs), Delaware, United States of America