Vayana Digital Assets Platform

This privacy policy will explain how our organisation, Hylobiz Technologies LLC, (referred to here as  “Hylobiz”), uses the personal data we collect from you when you use our services. Please note that  Hylobiz provides several products and services, each with their own personal data processing needs,  some of which are more extensive than others. The personal data we collect from you is limited to the  specific products and services you have signed up for, and therefore, some clauses in this privacy policy  may not be applicable to you.

Topics:

  1. What data do we collect? 
  2. How do we collect your data? 
  3. How will we use your data? 
  4. How do we store your data? 
  5. Marketing 
  6. What are your data protection rights? 
  7. What are cookies? 
  8. How do we use cookies? 
  9. What types of cookies do we use? 
  10. How to manage your cookies 
  11. Privacy policies of other websites 
  12. Changes to our privacy policy 
  13. How to contact us 

What data do we collect?

 

It is important to note that this privacy policy covers the processing of personal data only, and not  business data. Personal data refers to information that is related to an identifiable individual. This may  include information such as name, address, contact details, and other identifying information. Personal  data is typically used to identify, contact, or locate an individual, or to provide personalized services to  that individual. Business data, on the other hand, refers to information that is related to a business or  organization. This may include information such as financial data, sales data, customer data, inventory  data, and other information related to the operations of the business. Business data is typically used to  understand the performance of the business, make informed decisions, and improve operations.

 

The main difference between personal data and business data is that personal data is related to  individuals, while business data is related to the operations of a business. Personal data is typically  subject to more stringent privacy regulations, as it is often sensitive and can be used for malicious  purposes if mishandled. Business data may be subject to different regulations and standards.

To provide our services, Hylobiz collects the following personal data: 

 

Information you provide:

  • Personal information (name, email address, physical address, phone number, date of birth etc.) 
  • Unique identification number, which includes a permanent account number (PAN), Goods and  Services Tax Identification Number (VAT), or Taxpayer Identification Number (TIN). Note that  unique identification numbers related to business entities are not personal data. 
  • Sensitive personal information (your password, financial information that includes account  details, credentials, payment instructions and transaction data) 

Your usage: 

  • Information on how you use our products and services, such as pages visited and average time  spent on Hylobiz’s platform. 
  • Information from and about the computers, phones, or other devices you use to access our  products and services, and we combine this information across different devices you use. This  information includes device attributes (such as the operating system, hardware and software  versions, and browser type), device identifiers (such as unique identifiers and device IDs),  network and connections (such as your mobile phone number and IP address) and cookie data  (such as information on your preferences and cookie ID). 

If you interact with blockchain networks through our platform, we may process blockchain-related data  such as your public wallet addresses, public keys, transaction hashes, timestamps, token or digital asset  identifiers, smart-contract interaction data, and any other on-chain information associated with your use  of our services.

 

Transaction information:

  • To provide our products and services, Hylobiz accesses and collects information on the status  of the fulfilment of transactions, including your payment history information.

Information from partners: 

  • Trading partners, banks and other financial institutions can send us your information, allowing  Hylobiz to provide its products and services to you. 

How do we collect your data? 

 

You directly provide Hylobiz with most of the data we collect. We collect data and process data when  you: 

  • Register online or sign up for any of our products or services 
  • Voluntarily complete a customer survey or provide feedback by contacting us via email or  phone. 
  • Use or view our platform via your browser’s cookies or web beacons. 

Hylobiz may also receive your data indirectly from the following

sources:

  • Our trading partners with whom Hylobiz is doing business 
  • Partners such as banks and financial institutions that provide a range of financing services to  corporates and enterprises in the area of domestic trade finance. 
  • Third-party service providers that help us analyse certain online activities, such as measuring  the performance of Hylobiz’s online campaigns or visitor activity.

How will we use your data?

 

Hylobiz will not sell or rent your data to any other party, for any reason, at any time. Hylobiz collects  your data so that it can: 

    • Provide you with our products or services and manage your account. 
    • Share marketing communications and newsletters, contact you with special offers on other  products and services we think you might like and let you know about our policies and terms.  We also use your information to respond to you when you contact us. 
    • Provide you with the following products and services: 
      • digital asset and tokenization services through our Vayana Digital Assets Platform  (VADP), including creation, issuance, management, and lifecycle tracking of tokenized  financial instruments; execution of on-chain transactions; operation of smart contracts;  support for digital negotiable instruments; and secure processing of data required for  digital asset transactions and blockchain-based record-keeping. 
      • international trade finance services platform that includes a transparent bidding  mechanism using know your customer (KYC), due diligence and anti-money  laundering (AML) checks;t 
    • Analyse your usage of Hylobiz’s products and services 
    • Deliver any administrative notices, alerts and communications to you that are relevant to your  use of our products or services 
    • Fulfil your requests for certain products and services. 
    • Enforce Hylobiz’s terms of use. 
    • Use the information we have to develop, test and improve our products and services, including  by conducting surveys and research and testing and troubleshooting new products and services
 
  • Your information is shared with others in the following ways: 

    • To operate our products and services, we work with trading partners, banking partners, financial  institutions and a Credit Bureau established under the rules and regulations of the relevant  country, and therefore share your personal information with these entities to the extent  necessary. 
    • We also work with third-party contractors providing Hylobiz services to operate our products  and services. We share your personal information with these third-party contractors to operate  our products and services and require them to be bound by the same privacy restrictions  described in this privacy policy. 
    • We may use third-party service providers to provide advertising, measurement, marketing and  analytics services to Hylobiz, and these providers may use cookies to provide those services to  us. We do not share any personal information about our customers with these third-party service  providers, and these service providers do not collect any personal information on Hylobiz’s behalf.
     

    Information sharing required by law: 

    • Hylobiz reserves the right to disclose your personal information when: it is necessary and  appropriate to enforce our rights against you or in connection with a breach of this privacy  policy or with Hylobiz’s terms of use; to prevent prohibited or illegal activities; or when  required by any applicable law, rule, regulation, subpoena, or any other legal process or request.  Hylobiz retains sole discretion in determining whether such disclosure is necessary or  appropriate. 
     

    Transfer of ownership:

    • If the ownership or control of all or parts of our products and services or their assets changes,  we may transfer your information to the new owner. 
    • In case of a sale, acquisition, merger, re-organisation or other transfer involving Hylobiz, your  information may be transferred to a third party upon your authorisation which will not be  unreasonably withheld. This is to ensure the continuation of the processing of transactions. 
    • Should such a transfer occur, Hylobiz will use its best efforts to require that the new combined  entity will follow this privacy policy with respect to your personal information, as and to the  extent required by applicable law, and to require that you receive prior notice if your data could  be used in a manner that is contrary to this privacy policy. 
     
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How do we store your data?

 

Hylobiz stores your data in a secure third-party facility. Our databases are protected from general  employee access, both physically and logically. We store a salted digest for your password so that it  cannot be recovered even by Hylobiz. All backup storage devices are encrypted.

 

Hylobiz uses a combination of firewall barriers, encryption techniques and authentication procedures,  among others, to maintain your online session’s security and protect accounts and systems from  unauthorised access. When you register for our products and services, Hylobiz requires you to set a  password for your privacy and security. To access your account, we also generate a pseudonymous  username to protect your privacy. 

 

From the time you submit your login information, including your username and password, the  communication between your device and Hylobiz is encrypted using secure socket layer (SSL)  technology. SSL enables you and our systems to communicate in a way that is designed to prevent  eavesdropping, tampering and message forgery. In addition, SSL encryption protects data transmissions  between your browser and Vayana’s servers, such as your registration information for our products and  services and your account credentials.

 

Hylobiz will keep your personal information and transaction data until it is no longer necessary to  provide our products and services. This is a case-by-case determination that depends on the nature of  the data, why it is collected and processed, and relevant legal or operational retention needs. Hylobiz stores all transaction data and identifiable information related to those transactions separately. Once the  case-by-case determination has been made, or upon your request to delete your data, whichever is  earlier, we will delete your data by permanently expunging all identifiable information from Hylobiz’s primary production servers, and further access to your account will not be possible. As part of Hylobiz’s “privacy by design” strategy, we will also promptly disconnect any connection Hylobiz had established to your account information and delete all account credentials. Once this process is complete,  anonymised data, consisting of aggregated data and any remaining transactional or other data that has  been stripped of any identifiable information, may remain on Hylobiz’s production servers indefinitely. 

 

Separately, in order to improve our products and services, Hylobiz also stores pseudonymised and  anonymised data derived from the data we collect from you. Data pseudonymisation is the process of  replacing personal information with a pseudonym or code. This makes it much harder for anyone who  may see the data to identify the actual person behind the data. Pseudonymisation helps to protect privacy  while still allowing the data to be used for research or analysis purposes.

 

Data anonymisation is the process of removing or obscuring personally identifiable information from a  dataset so that the individuals represented in the data cannot be identified. This is typically done by  replacing or removing any direct identifiers, such as names, addresses, or social security numbers, and  aggregating or generalizing the remaining data so that it cannot be linked back to any specific individual.  The purpose of data anonymisation is to protect the privacy and confidentiality of individuals while still  allowing the data to be used for research, analysis, or other purposes. Anonymised data can be used to  identify trends or patterns in a population without revealing any personal information about the  individuals in that population. 

 

Hylobiz takes specific technological measures, such as salting and data masking, and organisational  measures, such as restricting general employee access, to ensure that any anonymised or pseudonymised  data cannot be attributed to a particular individual or business entity without requiring additional  information. 

 

Your data may also remain on a backup server or other storage media. We keep these backups to ensure  Hylobiz’s continued ability to provide our products and services in the event of malfunction or damage  to Hylobiz’s primary production servers. Hylobiz will also keep audit data on its servers to comply with  our legal obligations. 

 

However, it is important to understand that these precautions apply only to Hylobiz’s products, services,  websites and systems. While Hylobiz will have contractual agreements with third parties around data  security, we do not exercise any control over how your information is stored, maintained or displayed  by third parties or on third-party sites.

 

Marketing Hylobiz would like to send you information about our products and services that we think you might  like. 

 

If you have agreed to receive marketing, you may always opt-out at a later date. 

 

You have the right at any time to stop Hylobiz from contacting you for marketing purposes. If you no  longer wish to be contacted for marketing purposes, please click here.

 

What are your data protection rights?

 

Hylobiz would like to make sure you are fully aware of all of your data protection rights. Every user is  entitled to the following:

 

The right to access – You have the right to request Hylobiz for copies of your personal data. We may  charge you a small fee for this request.

 

The right to rectification – You have the right to request that Hylobiz correct any information you  believe is inaccurate. You also have the right to request Hylobiz to complete the information you believe  is incomplete. Hylobiz shall not be responsible for the authenticity of the personal information or  sensitive personal data or information supplied by you. 

 

The right to not provide information – You have the option not to provide data or information that  Hylobiz seeks to collect. In such a situation, Hylobiz shall have the option not to provide products or  services for which we sought to collect your information.

 

The right to withdraw consent for processing – You have the right to request that Hylobiz restrict the  processing of your personal data by withdrawing your consent given earlier to us, with certain  conditions. You must send such a withdrawal of consent to Hylobiz in writing. In case of your  withdrawal of consent, Hylobiz shall have the option not to provide products or services for which your  consent was sought. 

 

The right to data portability – You have the right to request that Hylobiz transfer the data that we  have collected to another organisation or directly to you under certain conditions. 

 

The right to erasure – You have the right to request that Hylobiz erases your personal data under  certain conditions.

 

If you make a request, we have one month to respond to you. If you would like to exercise any of these  rights, please contact us at our email: etp-enquiries@vayana.com 

 

Cookies

 

Cookies are text files placed on your computer to collect standard Internet log information and visitor  behaviour information. When you visit our websites, we may collect information from you  automatically through cookies or similar technology. Our cookies are encrypted so that only Hylobiz can interpret the information stored in them.

 

For more general information on how cookies work, visit allaboutcookies.org. Our websites do not allow cookies of third parties. 

 

How do we use cookies and web beacons? 

 

Hylobiz uses cookies and web beacons in a range of ways to improve your experience on our websites,  including: 

    • Keeping you signed in. 
    • Understanding how you use our website. 
    • Track and store preferential information about you. 
    To personalise the content shown to you through our website, for example, by limiting the  number of times you see certain information or to help determine the information or preference  settings that help us serve you better.

What types of cookies do we use?

 

There are a number of different types of cookies; however, our website uses:

  • Functionality – Hylobiz uses these cookies so that we recognize you on our website and  remember your previously selected preferences. These could include what language you prefer  and the location you are in. Only first-party cookies are used. 

How to manage cookies 

 

You can set your browser not to accept cookies, and the above website (allaboutcookies.org) tells you  how to remove cookies from your browser. However, in a few cases, some of our website features may  not function as a result. 

 

Privacy policies of other websites

 

Hylobiz’s websites and platforms may contain links to other websites. Our privacy policy applies only  to our websites, products and services, so if you click on a link to another website, you should read their  privacy policy.

 

Changes to our privacy policy 

 

Hylobiz keeps its privacy policy under regular review and places any updates on this webpage. This  privacy policy was last updated on 09 December 2025. 

 

How to contact us 

 

If you have any questions about Hylobiz’s privacy policy or the data we hold on you, or you would like  to exercise one of your data protection rights, please do not hesitate to contact us. Email us at: etpenquiries@vayana.com.

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