Legal documents

Effective date: [DD MONTH 2026] · Last updated: [DD MONTH 2026]

Privacy Policy

This Privacy Policy explains how [COMPANY NAME] ("Toka", "we", "us") collects, uses, shares and protects personal data when you visit our website, join our early access list or use the Toka virtual card (the "Services").

1. Who we are

The data controller is [COMPANY NAME], registered in [JURISDICTION] under number [NUMBER], with its registered address at [ADDRESS]. You can contact us at [privacy@yourdomain.com].

2. Data we collect

• Data you give us: email address, preferred coin and network, messages you send to support. • Account and card data: card balance, transaction history, top-up and wallet addresses, card status. • Technical data: IP address, device and browser type, language, time zone, approximate location derived from your IP address or browser settings, cookies and similar identifiers. • Where required by law or our issuing partner: additional identification information, which we only request when strictly necessary.

3. Why we use your data

• To create your account, issue and operate your virtual card (performance of a contract). • To manage the early access list and the welcome bonus program (performance of a contract and our legitimate interest). • To prevent fraud, abuse, money laundering and terrorist financing (legal obligation and legitimate interest). • To show the website in your language and improve our Services (legitimate interest). • To send you product news and offers, where you have agreed (consent, which you can withdraw at any time).

4. Language and location detection

Our website automatically selects English or Spanish based on your browser language and time zone. This happens in your browser. Your language choice may be stored locally on your device so the website remembers it. We do not use this to track your precise location.

5. Who we share data with

We share personal data only as needed with: our card issuing partner [ISSUER NAME] and the card network [VISA / MASTERCARD]; payment processors and blockchain service providers; hosting, email and analytics providers; professional advisers; and authorities where we are legally required to do so. We do not sell your personal data.

6. International transfers

Our service providers may process data outside your country. Where this happens, we use appropriate safeguards required by applicable law, such as standard contractual clauses.

7. How long we keep data

We keep personal data for as long as your account is active and afterwards for as long as needed to meet legal, accounting and anti-money laundering obligations, normally [5] years after the end of our relationship. Early access list data is deleted [12] months after the list closes if you do not open an account.

8. Your rights

Depending on your country, you may have the right to access, correct, delete or export your data, to object to or restrict processing, and to withdraw consent. To exercise your rights, write to [privacy@yourdomain.com]. You may also complain to your local data protection authority.

9. Cookies

We use essential cookies to make the website work and, with your consent where required, analytics cookies to understand how the website is used. You can control cookies in your browser settings.

10. Security

We use encryption, access controls and other technical and organisational measures to protect your data. No method of transmission over the internet is completely secure, but we work to protect your information.

11. Children

The Services are not intended for anyone under 18 years of age. We do not knowingly collect data from minors.

12. Changes

We may update this Privacy Policy. We will post the new version on this page and, for important changes, notify you by email.

These documents are a template prepared for the Toka website. Text in [BRACKETS] must be completed, and all documents must be reviewed by a qualified lawyer in your jurisdiction and approved by your card issuing partner before publication.