Privacy Policy

Effective Date: June 10, 2025

1. Introduction

Toggle AI LTD is committed to protecting your privacy. This Privacy Policy explains how we handle information in accordance with the British Virgin Islands' Data Protection Act, 2021 (the "DPA").

This policy applies when you use our website, kops.ai (the "Site"), and the KOPS protocol (collectively, the "Service"). By using the Service and expressly consenting where required, you agree to the collection and use of information in accordance with this policy.

2. Our Role under the BVI DPA

Under the DPA, Toggle AI LTD is the "data controller" for the limited information we process.

3. Information We Collect

We collect the following types of information:

  • Public On-Chain Data: This includes your public wallet address and transaction history, which is inherent to blockchain technology and publicly accessible.

  • Non-Personal Technical Data (with your consent): When you use our Site, we may, with your consent provided via our cookie banner, collect limited technical information such as device and browser type. This data is used solely to improve our Service.

  • Information You Voluntarily Provide: If you contact us at [email protected], we will collect your email address and message content to respond to your inquiry. Your submission of this request is considered your consent to this processing.

4. Lawful Basis for Processing

Under the BVI DPA, our processing of any personal data is justified by your express consent. Unlike regulations like the GDPR, the BVI DPA does not allow for a "legitimate interests" basis for processing. Therefore, we will only process your data when you have given clear, affirmative consent for a specific purpose.

5. How We Use Information

We use the limited information we collect strictly to:

  • Provide, maintain, and improve the Service.

  • Respond to your support requests.

  • Monitor and analyze usage to enhance the user experience.

  • Comply with our legal obligations under BVI law.

6. Your Rights Under BVI Law

The BVI DPA provides you with specific rights regarding your personal data. You have the right to:

  • Request Access: You can ask for a copy of the personal data we hold about you.

  • Request Rectification: You can ask us to correct any information you believe is inaccurate or incomplete.

  • Withdraw Consent: You can withdraw your consent to our processing of your data at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

  • Prevent Processing for Direct Marketing: You have the right to request that we stop processing your data for direct marketing purposes.

  • Lodge a Complaint: You have the right to lodge a complaint with the Office of the Information Commissioner of the Virgin Islands if you believe we have infringed upon your rights under the DPA.

To exercise these rights, please contact us at [email protected].

7. International Data Transfers

We will not transfer your personal data outside of the British Virgin Islands unless we have ensured that there are adequate data protection safeguards in place or we have obtained your explicit consent for such a transfer.

8. Data Security and Retention

We implement appropriate technical measures to protect your data. We retain data only for as long as is necessary to fulfill the purpose for which it was collected or to comply with our legal obligations.

9. Children's Privacy

Our Service is not intended for use by individuals under the age of 18. We do not knowingly collect any personal information from children.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Effective Date."

11. Contact Us

If you have any questions about this Privacy Policy or our compliance with the BVI DPA, please contact us at: [email protected]

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