Coinductor — Comprehensive Privacy Policy

Effective Date: June 2026

Techwhirl Information Technology CO LLC (hereinafter referred to as "Coinductor", "the Company", "we", "us", or "our"), a corporate entity registered and operating under the federal laws of mainland United Arab Emirates (UAE), welcomes you. Coinductor acts as a digital asset management interface and a specialized Blockchain Transaction Operating System (BTOS).

This Comprehensive Privacy Policy (hereinafter referred to as "the Policy") outlines our strict methodologies regarding the collection, usage, disclosure, and safeguarding of the limited data generated when you download, install, log into, or otherwise interact with our mobile application container (iOS and Android), desktop Web Interface dashboard, open API structures, or automated transaction orchestration services (collectively, "the Services").

1. The Non-Custodial Core (What We Never Collect)

Coinductor is modeled after premium decentralized paradigms to ensure total user sovereignty. Unlike traditional centralized financial institutions, Coinductor operates under a strict zero-custody data architecture.

⚠️ CRITICAL CRYPTOGRAPHIC ISOLATION DECLARATION

We do not collect, log, view, intercept, transmit, or store your private cryptographic keys, backup recovery seed phrases (mnemonics), local device PINs, passwords, or Keystore files.

All cryptographic keys and backup seed phrases are generated exclusively on your local device and remain isolated within your hardware's native secure architecture (leveraging the iOS Secure Enclave or Android Keystore) via local AES encryption loops. Techwhirl Information Technology CO LLC has no technical mechanism to access or recover this data. Consequently, we can never access your digital token balances, reverse your actions, or assist in credential recovery.

2. Information We Collect (Principle of Lawfulness and Necessity)

In strict compliance with the UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL) and international mobile marketplace criteria, Coinductor limits data processing to minimal technical data points. We collect and process data strictly under the principles of lawfulness, rightfulness, and operational necessity:

A. Technical and Device Information

Unique Device Indicators: Your mobile device’s unique serial number or hardware identifier (processed solely to map your local interface to our system configuration parameters).

Operating System Metrics: Information regarding your mobile device type, operating system version, local language configurations, and network status.

Application Container Action History: Logs of your operational events, feature selections, interface navigation paths, and tool-tip activations taking place entirely inside the native software container.

B. On-Chain and Blockchain Data

Public Wallet Addresses: The public cryptographic receiving and sending addresses generated by your local keys, which you explicitly surface to look up asset balances or compile transaction payloads.

Public Ledger History: Public blockchain transaction records (including metadata such as timestamps, token identifiers, and quantities) copied directly from the public distributed network.

C. Digital Marketplace Billing Telemetry

Handshake and Purchase Logs: In-app purchase verification parameters, receipt states, and cryptographic validation handshakes processed during native mobile marketplace billing checks (Apple App Store, Google Play Store, Apple Pay, Google Pay, or carrier mobile billing systems).

3. How We Use Your Information (Purposes of Processing)

Techwhirl Information Technology CO LLC never sells, rents, or licenses your device indicators or public wallet structures to third-party commercial brokers or advertisement networks. Your data is processed exclusively for the following operational workflows:

Software Configuration Matching: Utilizing your unique mobile device serial number to match your local app container setup with your custom, pay-as-you-go transaction orchestration choices.

Automated Geofencing and Compliance: Actively tracking incoming connection telemetry to enforce absolute jurisdictional barriers. This automated mechanism drops API connections and blocks access for Excluded Persons residing or operating within the United States of America (USA) or any region under international or UAE trade sanctions and constraints.

Preflight Warning Disclosures: Evaluating real-time data metrics to trigger native notification messages on your preflight confirmation screen, informing you of baseline network fees whenever external third-party optimization routing is down or unavailable.

SaaS Validation Execution: Processing in-app billing parameters to validate your single-use OTO Pass software transactions, allowing our discovery scripts to search the public network for underutilized parameters.

System Integrity Preservation: Monitoring operational event logs to maintain secure services, run internal audits, perform structural troubleshooting, and detect malicious code or high-frequency automated bots attempting to strain our open API nodes.

4. Feature-Specific Data Handling Frameworks

The core transaction orchestration features of Coinductor process technical parameters according to strict operational boundaries:

A. Smart Send Routing Data

The Smart Send engine operates as a pay-as-you-go automation utility. When a transaction is initiated, the engine reads your public wallet address to evaluate cost paths. If Route 1 (Free) is unavailable, it communicates with independent, third-party resource providers via open APIs to coordinate energy lease allocations. Coinductor does not pass personal identifiers to these external networks; only the raw public transaction payload is routed.

B. OTO Pass SaaS Utilities

The OTO Pass functions strictly as a Software-as-a-Service (SaaS) transaction automation utility tool. When your wallet flags a native fee deficit, your purchase funds the execution of our automated resource discovery script. This background script crawls public blockchain matrices to identify excessive amounts of unnecessary or unclaimed resources left idle across the ledger, programmatically linking them to clear your specific transaction payload. No identity information is tied to these discovered ledger parameters.

C. Dapp Pass Portal Redirection

The Dapp Pass interface functions purely as a secure container and navigation bridge. The system features no native subscription models.

Registry Navigation: The application does not contain an open-text URL bar. Instead, it displays an unpromoted registry list of verified third-party resource providers utilizing Coinductor's open API infrastructure.

The Data Firewall: When you click a provider, a secure JavaScript bridge redirects you to their external web domain. Coinductor does not share your internal device indicators, preferences, or app logs across this bridge. All subsequent data collections, cookies, or account sign-ups are governed entirely by the privacy policies of those independent web entities.

D. Cross-Platform Web Interface (QR Synchronization)

The desktop Web Interface provides an expanded analytics, viewing, and initiation layer.

Local Cryptographic Handshake: Scanning the web dashboard's dynamic QR code with your mobile app triggers a secure local handshake. This mirrors your wallet data and historical transaction metrics onto the external browser environment in a read-only state.

Key Protection: Private keys and seed phrases are never transmitted to or cached on the web interface.

Signing Boundary: The web browser environment is technically incapable of signing or broadcasting data to the ledger. Transactions initiated on the web remain dormant until you manually confirm and sign the transaction payload inside your native mobile application.

5. Blockchain Data and Public Ledger Transparency

Public distributed ledgers operate as open-source, permanent, and completely transparent data matrices.

By broadcasting a transaction via Coinductor, you explicitly recognize that all metadata linked to your public cryptographic wallet address becomes instantly, permanently, and irreversibly public across the global blockchain ledger. This public on-chain data can be tracked, logged, and mapped by external third parties via public block explorers. Techwhirl Information Technology CO LLC exercises no control or ownership over this decentralized ledger architecture, and we are technically incapable of deleting, altering, or obscuring data broadcast to a public blockchain.

6. How We Share and Disclose Information

We restrict external data sharing to a baseline of administrative and compliance handshakes:

7. Tracking Technologies and Analytics Tools

Coinductor does not deploy intrusive cross-site ad-tracking scripts or behavioral profiling cookies. On our desktop Web Interface, we use localized session cookies and basic technical telemetry to ensure session continuity during your secure QR synchronization events. Natively inside the mobile container, we track aggregate operational behaviors to refine our BTOS optimization paths and prevent system logic errors. You may disable analytical tracking within your device’s system privacy settings, though doing so may limit real-time preflight fee synchronization accuracy.

8. International Data Transfers and Infrastructure Security

Global Server Transfers

As an international application leveraging automated discovery scripts, the limited data we collect (such as device serial numbers and public wallet strings) may be transferred to and maintained on secure cloud storage nodes located outside your home country. By accessing our software utilities, you explicitly authorize this cross-border transfer, which is carried out via secure encryption pathways.

Technical Protection Controls

Techwhirl Information Technology CO LLC enforces layered data security shields to safeguard our backend validation paths and open API networks. We use transport layer security (TLS), tokenized access constraints, firewall rules, and regular code reviews. However, you remain the ultimate guardian of your funds; we are completely unindemnified against asset losses resulting from local device vulnerabilities or from leaving your synchronized desktop web sessions unattended.

9. Your Rights Under UAE Data Protection Law (PDPL)

In strict accordance with the UAE Personal Data Protection Law (PDPL), users are granted explicit statutory data rights regarding the processing of their personal indicators:

Right to Information and Access: The right to obtain a structured report of the limited technical data logs we maintain linked to your device identifier or public wallet path.

Right to Personal Data Portability: The right to request the transfer of your technical operational logs to another technological platform.

Right to Rectification: The right to demand the correction of inaccurate administrative logs or corrupted device settings within our database arrays.

Right to Erasure ("Right to be Forgotten"): The right to request the complete deletion of your device-level logs and connection metrics from Coinductor's backend servers.

Right to Restriction of Processing: The right to oppose or restrict the automated processing of your application container history for data analytics and system testing.

10. Submitting Privacy Requests & Verification Protocols

To submit a formal request to execute any of your data rights outlined in Section 9, you must adhere to our validated administrative verification channels:

A. Official Submission Paths

1. Native Support Console: Open an official, tracked privacy ticket directly within the help center console inside your Coinductor mobile app container.

2. Compliance Officer Email: Draft an explicit request to our dedicated data privacy desk at privacy@techwhirl.ae.

B. Identity Authentication and Protection

Because our application is completely non-custodial, we do not maintain email accounts, user profile cards, or real-world identity logs for our retail user base. Therefore, to protect your privacy and prevent malicious data scraping or unauthorized record access, you must cryptographically or structurally authenticate ownership of the public wallet address or device identifier in question before Coinductor can process your request.

C. Statutory Processing Timelines

In strict compliance with mainland UAE data criteria, our privacy desk will review, validate, and respond to your authenticated request within 30 calendar days of official receipt. For highly complex structural investigations, this period may be extended by an additional 15 days, and you will be updated via your chosen submission path.

11. Minor Exclusion Standards (Under 16 Restriction)

Coinductor does not knowingly target, market to, or collect operational data from minors. Use of this application by any natural person under the age of 16 is strictly prohibited. If we discover that an incoming API connection or device identifier is controlled by an individual under the age of 16, our backend services will instantly disconnect and wipe all associated operational data logs from our server arrays.

12. Policy Governance, Venue, and Amendments

UAE Governing Law: This Privacy Policy, all automated data processing, and any regulatory disputes arising from your interaction with our services shall be exclusively governed by and interpreted under the federal laws of mainland United Arab Emirates (UAE).

Exclusive Jurisdiction: Any formal claims, complaints, or unresolved data disputes shall be submitted exclusively to the competent local courts of mainland Dubai, United Arab Emirates.

Amendments Clause: Techwhirl Information Technology CO LLC reserves the absolute right to amend this Policy at any time at its sole discretion. Revised editions take effect immediately upon their publication within the app interface or on our website. Your ongoing interaction with our services following an update indicates your explicit acceptance of the revised terms. Any matters or privacy variables not explicitly detailed herein shall be governed directly by automated system notices updated within our official help center repository.