Privacy Policy

1. Introduction

AvtaMata Assets ("we", "our", or "us") operates the AvtaMata Assets mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

2. Information We Collect

2.1 Personal Information

When you register and use our App, we may collect:

• Full name and contact information (email, phone number)
• National identification number (for KYC verification)
• Date of birth
• Bank account details
• Identity documents (passport, national ID card)
• Selfie photos for identity verification

2.2 Financial Information

• Investment transaction history
• Portfolio holdings and balances
• Payment and withdrawal records

2.3 Device and Usage Information

• Device type, operating system, and version
• App usage analytics
• Push notification tokens
• Camera access (for document scanning and selfie verification)

3. How We Use Your Information

We use the collected information to:

• Create and manage your investment account
• Verify your identity (KYC) in compliance with regulatory requirements
• Process investment purchases and redemptions
• Calculate and display your portfolio value and returns
• Send transaction confirmations and important notifications
• Provide customer support
• Improve our services and user experience
• Comply with legal and regulatory obligations

4. Camera Permission

Our App requests camera access solely for the purpose of KYC (Know Your Customer) identity verification. This includes scanning identity documents and taking selfie photos for face matching. We do not access your camera for any other purpose. Camera images are securely transmitted and stored for verification purposes only.

5. Data Sharing and Disclosure

We may share your information with the following parties:

• Regulatory authorities — as required by Mongolian financial regulations
• Custodian bank (Golomt Bank) — for asset custody and settlement processing
• Identity verification services (E-Mongolia) — for KYC verification
• Cloud service providers — for secure data storage and processing

We do not sell your personal information to third parties.

6. Data Security

We implement industry-standard security measures to protect your data, including encryption in transit (TLS/SSL) and at rest, secure authentication with JWT tokens, and access controls. While we strive to protect your information, no method of electronic transmission or storage is 100% secure.

7. Data Retention

We retain your personal and financial data for as long as your account is active and as required by Mongolian financial regulations. After account closure, we may retain certain data for regulatory compliance purposes for a minimum of 5 years.

8. Your Rights

You have the right to:

• Access and review your personal data
• Request correction of inaccurate data
• Request deletion of your data (subject to regulatory requirements)
• Withdraw consent for data processing
• Request a copy of your data in a portable format

9. Children's Privacy

Our App is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes through the App or via email. Continued use of the App after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us at: