# Privacy and cookie policy
#### Tlend Protocol
**Privacy Policy**
**International Compliance and EU GDPR**
PAMA LIMITED (the "Website"), incorporated in Seychelles, declares the following Privacy Policy for Tlend protocol, which includes a cookie policy (the "Policy"), in relation to its website and all digital software platforms and components, including but not limited to its web app and functions such as "borrow", "refund", and other features (collectively referred to as the "Platform") and any user and/or visitor of the Website (the "User" or "You"):
I. Information the Platform collects about the User when visiting the Website or interacting with the Platform;
II. How the Website and Platform use, share, store, and secure collected information;
III. The User’s rights to access and control their information.
This Policy is linked to the Website’s Terms of Use, accessible to all Users.
**1. User Information**
1.1. The Website may collect "Personal Information", defined as data or a combination of data provided by the User or generated through Platform use that relates to an identifiable individual.
1.2. Personal Information is collected when the User provides it or interacts with the Website/Platform
1.3. The Website does not collect sensitive data (e.g., race, religion, health, biometrics, or sexual orientation).
**2. Information Usage**
2.1. The Website uses Personal Information as permitted by law, including:
2.1.1. Providing customer support, personalized features, and ensuring security;
2.1.2. Fulfilling legitimate interests (e.g., R\&D, legal rights protection) that do not override User rights;
2.1.3. With User consent for specific purposes;
2.1.4. Complying with legal obligations across jurisdictions.
2.2. Users may withdraw consent at any time via the Platform’s Telegram support channel. Withdrawal does not affect prior data usage.
2.3. No Personal Information is shared for marketing without explicit consent, except as stated in Section 3.
2.4. For EU Users, legal bases for processing are outlined in the Legal Bases Table (Clause 9).
**3. Information Sharing**
3.1. Personal Information may be shared with third-party service providers (e.g., payment processors, AML/KYC providers, infrastructure hosts) to operate, improve, and market the Platform.
3.2. Third parties must process data confidentially and securely, adhering to applicable laws.
3.3. The Website ensures third parties meet equivalent data protection standards.
3.4. Aggregated or anonymized data may be shared for research, analytics, or service improvement.
3.5. Third-party software (e.g., wallets) may access User data; their policies are not governed by this Policy.
3.6. Links to third-party websites are not controlled by Tlend; Users should review external privacy policies.
3.7. Personal Information may be disclosed to authorities to comply with applicable laws.
**4. Information Storage**
4.1. Data is stored on secure servers (owned by the Website or third parties) under Seychelles laws.
4.2. Retention periods align with legal, accounting, or operational requirements.
**5. Cookies**
5.1. Cookies and tracking technologies are used to enhance User experience, analyze traffic, and personalize services.
5.2. Types of cookies:
● Strictly Necessary: Essential for Platform functionality (no consent required).
● Functionality: Remember preferences (e.g., language).
● Performance: Analyze usage patterns (anonymous aggregation).
● Targeting/Advertising: Deliver personalized ads (minimized; Users may disable these).
5.3. Disabling cookies may limit Platform functionality.
**6. International Data Transfers**
6.1. Data may be transferred globally, including to jurisdictions with weaker privacy laws.\
6.2. Safeguards (e.g., contractual clauses) ensure data protection during transfers.
**7. User Rights**
7.1. Users may:
● Access, correct, or delete Personal Information (exceptions apply for legal/operational needs);
● Object to processing or request data portability;
● Withdraw consent;
● Opt out of marketing.
7.2. Requests are addressed within 30 days (may extend for complexity).
7.3. Identity verification may be required for security.
**8. Policy Changes**
8.1. Updates will be posted on the Website. Continued use constitutes acceptance.
**9. Children’s Privacy**
9.1. The Platform is not intended for minors. Data from minors will be deleted if detected.
**10. EU Users – GDPR**
10.1. EU Users’ data transfers comply with GDPR safeguards.
10.2. Legal bases include contract performance, consent, and legitimate interests (see Legal Bases Table).
10.3. EU-specific rights (e.g., complaint to data authorities) apply.
Legal Bases Table
Processing Purpose
Data Types
Legal Basis
Enable Platform services
Account, Transaction, Technical
Contract Performance
Security maintenance
Technical Data
Legitimate Interest
Service improvement
Usage, Feedback
Legitimate Interest
**11. Law and Jurisdiction**
11.1. Disputes are governed by Seychelles law, with exclusive jurisdiction in Seychelles courts.
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