Privacy Policy

1. Data Controller

Wakanda Tech (CNPJ: [placeholder]) is the data controller responsible for processing your personal data through the AkinBank Hub platform.

2. Personal Data We Collect

We collect the following categories of personal data:

• Identification data: name, date of birth, nationality, tax ID, government-issued IDs
• Contact data: email, phone, physical address
• Financial data: account numbers, transaction history, source of funds/wealth
• Technical data: IP address, device information, login records
• KYC/KYB data: documents, beneficial ownership, corporate structure

3. Legal Bases and Purposes

We process your data based on the following legal grounds:

• Contract performance: to provide banking and payment services
• Legal obligation: AML/CFT compliance, KYC/KYB, tax reporting, sanctions screening
• Legitimate interest: fraud prevention, risk management, service improvement
• Consent: marketing communications (where required)

4. Data Sharing

We may share your data with:

• Banking correspondents and payment service providers
• KYC/AML verification services and screening providers
• Regulatory authorities and law enforcement (as required by law)
• Professional advisors (legal, audit, compliance)
• Cloud infrastructure and technology service providers

5. International Transfers

Your data may be transferred to and processed in countries outside your jurisdiction. We implement appropriate safeguards including standard contractual clauses and adequacy decisions.

6. Data Retention

We retain your data for as long as necessary to fulfill the purposes outlined in this policy and to comply with legal obligations:

• KYC/transaction data: minimum 5-10 years (regulatory requirement)
• Communication records: 5 years
• Marketing data: until consent is withdrawn

7. Your Rights (LGPD/GDPR)

You have the following rights regarding your personal data:

• Access: request a copy of your data
• Correction: update inaccurate data
• Deletion: request deletion (subject to legal retention requirements)
• Portability: receive your data in a structured format
• Objection: object to processing based on legitimate interest
• Restriction: request limited processing
• Withdraw consent: for consent-based processing

8. Security Measures

We implement technical and organizational security measures including encryption, access controls, regular audits, and security monitoring. See our Security page for details.

9. Cookies and Tracking

We use essential cookies for platform functionality and, with your consent, analytics cookies to improve our services. You can manage cookie preferences through our cookie banner.

10. Contact and DPO

To exercise your rights or contact our Data Protection Officer (DPO):

• Email: dpo@akinbank.app (placeholder)
• Contact form: /contact
• Address: [Placeholder address]

11. Updates

We may update this Privacy Policy periodically. Material changes will be communicated through the platform or via email.