USD Hawaiʻi (“USD Hawaiʻi,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website, join a waitlist, or use our services (collectively, the “Services”).

By accessing or using the Services, you agree to this Privacy Policy.

1. Information We Collect

We collect only the information necessary to operate a secure, compliant payments platform.

a. Information You Provide

You may provide information such as:

• Name

• Email address

• Business name and role (for merchants)

• Contact information

• Information submitted through waitlists, forms, or inquiries

For certain services, we may also collect:

• Identity verification information (KYC)

• Business verification details

• Compliance-related documentation required by law

b. Automatically Collected Information

When you visit our website, we may collect limited technical data, including:

• IP address

• Device type and browser

• Pages visited and usage patterns

• Referring URLs

This information is used for security, performance, and analytics purposes only.

2. How We Use Information

We use information to:

• Provide and operate the Services

• Manage waitlists and early access programs

• Communicate with merchants, residents, policymakers, or media

• Conduct onboarding, verification, and compliance checks

• Improve platform functionality and reliability

• Comply with legal and regulatory obligations

• Prevent fraud, misuse, or security threats

We do not use your information for speculative, advertising-heavy, or unrelated purposes.

3. Payments, Compliance & Verification

USD Hawaiʻi may be required to collect and process certain information to comply with:

• Know Your Customer (KYC) requirements

• Anti–Money Laundering (AML) laws

• Sanctions screening obligations

• Other applicable state or federal regulations

This information is used strictly for compliance, security, and lawful operation.

4. How We Share Information

We do not sell personal information.

We may share information only when necessary:

• With regulated service providers (e.g., identity verification, hosting, analytics)

• With banking or custody partners where required

• To comply with legal obligations, court orders, or regulatory requests

• To protect the rights, safety, or security of users or the platform

All partners are expected to meet appropriate confidentiality and security standards.

5. Data Retention

We retain information only as long as necessary to:

• Provide the Services

• Meet legal, regulatory, or compliance requirements

• Resolve disputes or enforce agreements

Retention periods may vary depending on the nature of the information and applicable law.

6. Data Security

USD Hawaiʻi uses administrative, technical, and organizational safeguards designed to protect information against unauthorized access, misuse, or disclosure.

While no system can guarantee absolute security, we design our platform with security and resilience as core principles.

7. Your Choices & Rights

Depending on your location and applicable law, you may have rights to:

• Access information we hold about you

• Request correction of inaccurate information

• Request deletion of certain information (subject to legal requirements)

• Opt out of non-essential communications

Requests can be made using the contact information below.

8. Cookies & Analytics

We may use limited cookies or similar technologies to:

• Ensure website functionality

• Understand site usage

• Improve performance

We do not use cookies for aggressive tracking or behavioral advertising.

9. Children’s Privacy

The Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children.

10. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted with a revised “Last updated” date.

Continued use of the Services constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, contact:

USD Hawaiʻi

Email: privacy@usdhawaii.com

Website: www.usdhawaii.com