# Privacy Policy

This Privacy Policy explains how Castrum Labs d.o.o. (“Conectum”, “we”, “us”) processes information in connection with the use of the Conectum platform (“Platform”).

#### 1. No Traditional User Accounts

Conectum does not require users to create traditional user accounts and does not collect usernames, passwords, or email addresses as a condition for accessing the Platform.

No KYC (Know Your Customer) is performed on the Conectum platform. Access to the Platform is provided exclusively through the connection of a crypto wallet, which serves solely as a technical authentication mechanism.

#### 2. Wallet-Based Access and Pseudonymity

Conectum does not intentionally collect, process, or store personal data relating to identified or identifiable natural persons. Access to the Platform is based on wallet-derived technical identifiers that are cryptographically hashed and pseudonymized, and which do not enable Conectum to directly identify users.

Any technical or operational data processed in connection with the Platform is handled solely for security, functionality, and compliance purposes and in accordance with the principles of data minimization and purpose limitation under the General Data Protection Regulation (GDPR). Where applicable data may qualify as pseudonymous data within the meaning of the GDPR, and Conectum processes such data only to the extent strictly necessary.

The connected crypto wallet functions as a technical identifier and does not, by itself, constitute personal data identifying a natural person. Wallet identifiers are not stored in plain form and are processed only in hashed or pseudonymous form for technical and security purposes. Conectum does not know, verify, or attempt to determine the real-world identity of wallet holders.

#### 3. Technical and Operational Data

For the purposes of operating the Platform, ensuring security, preventing abuse, and complying with applicable legal and accounting obligations, Conectum may process limited technical and operational data, such as:

* technical usage signals;
* transaction references;
* system and error logs;
* pseudonymized internal account identifiers linked to wallet-based authentication;
* credit balance records and transaction history related to Conectum Credits;
* billing and invoice-related records required under applicable tax and accounting laws.

Such data is processed strictly for the following purposes:

* enabling platform functionality and account state management;
* maintaining accurate Conectum Credit balances and transaction integrity;
* preventing fraud, abuse, and technical misuse;
* ensuring system stability and security monitoring;
* complying with accounting, tax, and regulatory obligations (including invoice issuance where required by law).

Internal account records are created using pseudonymized identifiers derived from wallet authentication and are not directly linked to personal identity data such as name, address, or government identifiers.

Conectum does not use such data for behavioral profiling, advertising, or user tracking.

All operational and financial records are protected using appropriate technical and organizational security measures, including restricted access controls, encrypted storage where applicable, and server-side security monitoring.

Such data is not processed for the purpose of identifying users as natural or legal persons.

Where technical or operational data qualifies as personal data under applicable law, Conectum processes such data on the basis of legitimate interests (platform security, fraud prevention, service functionality), performance of a contract, and compliance with legal obligations, as applicable.

Conectum implements appropriate technical and organizational measures designed to protect data against unauthorized access, loss, alteration, or disclosure, including access controls, system monitoring, and security hardening practices.

#### 4. Payments and Third-Party Services

Payments are processed by independent third-party payment processors. Conectum does not process or store payment credentials.

VPN services, eSIM services, and other connectivity services are provided by independent third-party providers. Use of such services is subject to the privacy policies of the respective providers.

#### 5. Consumer Rights and Communications

If a user voluntarily contacts Conectum (e.g. to exercise legal rights or request support), Conectum may process the information provided by the user solely for the purpose of handling the request and in accordance with applicable data protection laws.

#### 6. Data Retention

Conectum retains only technical and operational data and only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable law.

#### 7. User Rights

Where applicable under data protection law, users may have rights relating to the processing of personal data. The scope and exercise of such rights may be affected by the pseudonymous and wallet-based nature of the Platform.

Due to the wallet-based and pseudonymous design of the Platform, Conectum may be unable to associate requests with a specific user unless sufficient technical information is provided.

#### 8. Changes to this Policy

This Privacy Policy may be updated from time to time. The current version is always available on the Platform.

#### 9. Contact

For privacy-related inquiries, please contact:

Castrum Labs d.o.o.

<info@castrumlabs.xyz>

Last updated: 19 February 2026

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