Privacy Policy
EFFECTIVE_DATE: MARCH 18, 2026
Welcome to the privacy policy for The Real Deal (TRD)protocol and platform (the "Website"). This Privacy Policy explains how TRD, Jiwambe Mobility Ltd, and the associated Security Agent SPV ("we," "our," or "us") collect, use, and share information in connection with your use of our services, including the Jiwambe Kenya Debt Facility.
1. Information We Collect
[CATEGORY // USER_INPUT]
A. Information You Provide to Us
- Identity Information (KYC): To participate in the facility, you must verify your identity. Please note that TRD does not collect or store your personal identification information (PII). All KYC verification is handled exclusively by a third-party regulated service provider (the "Identity Provider"). We only receive cryptographic proof or a status flag (e.g., "Verification Successful") from the Identity Provider.
- Communications: If you contact us directly, we may retain a record of your communication and the information you provide.
[CATEGORY // SENSOR_LOGS]
B. Information We Collect Automatically
- Wallet and Blockchain Data: We collect your public wallet address and transaction history associated with the TRD smart contracts. Due to the public nature of the blockchain, your wallet address and transactional activity on the Sui network are publicly visible and cannot be deleted.
- Log Data & Device Information: We automatically collect standard internet log data, including your IP address, browser type, operating system, pages viewed, and access times.
2. How We Use Your Information
We use the collected information for the following purposes:
- Providing the Services: To facilitate your deposits, withdrawals, and participation in the debt facility.
- Compliance & Security: To comply with legal and regulatory obligations, including Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations (such as the Kenyan POCAMLA 2009).
- Communication: To send you updates, security alerts, and administrative messages.
- Improvement: To monitor performance and optimize the user experience of the TRD platform.
3. How We Share Your Information
We do not sell your personal information. We may share it under the following circumstances:
- Service Providers: We share information with third-party vendors, most importantly our Identity Verification Providers. These providers are the sole custodians of your PII. We also use hosting and analytics providers who handle non-PII log data.
- Legal and Regulatory Authorities: We may disclose your information if required to do so by law, or in the good faith belief that such action is necessary to comply with legal processes, respond to claims, or protect the rights, property, or safety of TRD, our users, or the public.
- Business Transfers: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.
4. Public Nature of the Blockchain
Please note that blockchain networks (such as Sui) are decentralized and public. By design, records on these networks are permanent and immutable. We do not control these networks, and any transaction data (including your wallet address and transfer amounts) will remain publicly accessible regardless of your interactions with our Website.
5. Your Rights
Depending on your jurisdiction (e.g., under the Kenya Data Protection Act, 2019 or the GDPR), you may have the right to access, correct, delete, or restrict the processing of your personal data. Please note that these rights do not extend to immutable data recorded on the public blockchain.
6. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by updating the "Effective Date" at the top of this policy and posting the amended policy on the Website.
7. Contact Us
If you have any questions about this Privacy Policy, please contact us at legal@therealdeal.fi.