Privacy Policy

Effective Date: April 7, 2026 · Last Updated: April 7, 2026

1. Overview

This Privacy Policy describes how TPWR Holdings ("Company", "we", "us") collects, uses, and protects information when you use the TrueAsset platform ("Platform"). We are committed to protecting your privacy and handling your data with transparency.

2. Information We Collect

Information you provide:

• Name, email address, and company affiliation (via access request forms)
• Role and intended use case descriptions
• Communications you send to us

Information collected automatically:

• IP address, browser type, and device information
• Pages visited and time spent on the Platform
• API usage patterns (for authorized users)

Information we do NOT collect:

• Exchange credentials or private keys
• Personal financial data or portfolio holdings
• Social media accounts or contacts

3. How We Use Information

We use collected information to:

• Process and evaluate access requests
• Communicate with you regarding the Platform
• Improve Platform performance and user experience
• Ensure security and prevent abuse
• Comply with legal obligations

4. Data Sharing

We do not sell, rent, or trade your personal information. We may share information only in the following limited circumstances:

• Service providers: Trusted third parties that assist with peripheral services (e.g., web delivery, DNS). Core computation and decision processing runs exclusively on dedicated, privately-operated infrastructure. Third-party providers are bound by confidentiality agreements and do not process market data or decision logic.
• Legal compliance: When required by law, regulation, legal process, or government request
• Business transfers: In connection with a merger, acquisition, or sale of assets, with appropriate notice

5. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encrypted connections (TLS) for all data in transit
• Access controls and authentication for internal systems
• Regular security monitoring and incident response procedures
• Sovereign infrastructure — data processed on dedicated hardware, not shared cloud environments

6. Data Retention

We retain personal information only as long as necessary for the purposes described in this policy, or as required by law. Access request data is retained for up to 24 months. You may request deletion of your data at any time by contacting us.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your personal information
• Object to or restrict certain processing activities
• Data portability (receive your data in a structured format)

To exercise these rights, contact us at access@trueasset.ai.

8. Cookies and Tracking

The Platform may use essential cookies for functionality. We do not use third-party advertising trackers or share browsing data with advertisers.

9. International Users

The Platform is operated from Mexico. If you access the Platform from outside Mexico, your information may be transferred to and processed in Mexico. By using the Platform, you consent to this transfer.

10. Children's Privacy

The Platform is not intended for individuals under the age of 18. We do not knowingly collect information from minors.

11. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated effective date. Continued use of the Platform constitutes acceptance of the revised policy.

12. Contact

For privacy-related inquiries, contact us at access@trueasset.ai.