Privacy Notice – Wavy Node

Effective Date: July 25, 2025

Wavy Node, committed to the responsible use of technology and regulatory compliance, places the highest priority on the protection and confidentiality of your personal data. This Privacy Notice is issued in accordance with the Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP) in Mexico and outlines how we collect, use, store, and protect your data as part of our Anti-Money Laundering (AML) services for web3 ecosystems.

1. Identity and Address of the Data Controller

Wavy Node

4061, 1007 N Orange St. 4th Floor

Wilmington, DE, New Castle, US, 19801

For any questions regarding your personal data, you may contact our Data Protection Officer at: fridaruh@wavynode.com

2. Personal Data Collected

We collect the following categories of personal data, either directly from you or through your interaction with our platform and blockchain infrastructure:

  • Identification data: Full name, email address, country of residence
  • Contact data: Email address, other optional communication channels
  • Blockchain and wallet data: Wallet address(es), transaction history, token movement, smart contract interactions
  • Usage data: Logs, activity timestamps, IP address (for fraud prevention), access patterns
  • Compliance-related data: Risk scores, origin of funds indicators, KYC/AML results (if applicable)

We do not collect sensitive personal data (e.g., racial/ethnic origin, biometric data) unless required under exceptional regulatory requests and with your explicit consent.

3. Purposes of Processing

Your data is processed for the following primary purposes, which are necessary to provide our services:

  • To enable you to access our AML compliance tools for web3
  • To conduct behavioral analysis of on-chain activity for anti-money laundering, fraud detection, and compliance monitoring
  • To assess wallet risk scores and provide security alerts and reports
  • To comply with Mexican, international, and cross-border regulatory frameworks and legal obligations (e.g. FATF, OFAC, FinCEN guidelines)
  • To respond to lawful requests from regulators or enforcement bodies

Secondary purposes (optional, with opt-out option):

  • To improve our product through analytics
  • To communicate platform updates, surveys, or educational content related to compliance and blockchain security

4. Legal Basis for Processing

The processing of your personal data is carried out based on the following legal grounds:

  • Performance of a contract: For registered users accessing our services
  • Compliance with legal obligations: For AML, fraud, and transaction monitoring
  • Legitimate interest: To maintain security and operational integrity
  • Consent: For any secondary or marketing use, where required

5. Sharing of Personal Data

In strict accordance with applicable data protection regulations, Wavy Node may share your personal data with third parties only in the following cases:

  • Regulatory Compliance: We may disclose data to governmental authorities or regulators when required by law or supervisory obligations.
  • AML and Compliance Partners: For the sole purpose of facilitating compliance operations (e.g., monitoring, alerts, reporting), your information may be shared with authorized third-party compliance providers. These parties are contractually obligated to maintain the confidentiality and security of your information.
  • Technology and Hosting Providers: Cloud and infrastructure vendors under strict data processing agreements

No data is sold or used for advertising purposes.

6. Cross-Border Data Transfers

Wavy Node may process or store data on servers located outside Mexico (e.g. in the United States or Europe), always ensuring that such jurisdictions offer adequate levels of protection or through binding contractual clauses in accordance with Mexican regulations.

7. Data Retention Period

In compliance with AML and financial regulations, your personal data will be retained for a period of 10 years after your last interaction with Wavy Node, even if you are no longer an active user. After this period, your data will be securely deleted, unless an additional legal requirement mandates its conservation.

8. Data Security Measures

We have implemented industry-standard administrative, physical, and technical safeguards to protect your personal data. These include:

  • End-to-end encryption of critical data
  • Role-based access control
  • Regular audits and penetration testing
  • Data minimization and anonymization strategies

In the event of a data breach, we will notify affected parties and the applicable authority in accordance with legal requirements.

9. ARCO Rights (Access, Rectification, Cancellation, Opposition)

As the owner of your personal data, you may exercise your rights under the Mexican data protection law, including:

  • Access: Know what data we hold and how we use it
  • Rectification: Request correction of incomplete or inaccurate data
  • Cancellation: Request deletion of data when appropriate
  • Opposition: Object to specific uses of your data
  • Data Portability & Revocation of Consent (if applicable)

To exercise your rights, send an email to:

fridaruh@wavynode.com

Including:

  • • Your full name and contact details
  • • A description of your request
  • • Proof of identity or representation (INE, passport, or similar)

We will respond within the timeframe established by law (maximum 20 business days).

10. Changes to the Privacy Notice

Wavy Node reserves the right to amend this Privacy Notice at any time. Updates will be communicated through our official website https://wavynode.com and, if significant, through direct notification.

The most recent version will always be accessible at the link above, and continued use of our services implies acceptance of any changes.

11. Consent

By using our services, registering on our platform, or interacting with Wavy Node systems, you acknowledge that you have read and understood this Privacy Notice and consent to the processing of your data as described herein, subject to your rights.