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Cloak Privacy Corp.

Legal · Privacy

Privacy Policy.

Last updated · April 1, 2026
Effective immediately upon access

Data controller: Cloak Privacy Corp. · PH The Century Tower, Office 317, Vía Ricardo J. Alfaro, Betania, District of Panama, Republic of Panama · legal@cloak.ag

Privacy by design. Cloak is architected to minimize data collection. We do not collect, store, or process personal data of Protocol users in the ordinary course of service delivery. This policy describes what limited data we may encounter, how we handle it, and the rights users have.

01 · Data Controller

The data controller responsible for this Privacy Policy is Cloak Privacy Corp., a corporation incorporated under the laws of the Republic of Panama, with registered office at PH The Century Tower, Office 317, Vía Ricardo J. Alfaro, Betania, District of Panama, Republic of Panama. Registration number: 155781318.

For all privacy-related inquiries, contact: legal@cloak.ag.

02 · Scope

This Privacy Policy applies to:

  • The Cloak website (cloak.ag and subdomains)
  • The Cloak web interface and application
  • The Cloak SDK when used in connection with Cloak's hosted relay infrastructure
  • Any other services or communications provided by Cloak Privacy Corp.

This Policy does not apply to third-party services, wallets, or blockchain explorers that you may interact with in connection with the Protocol. Those services have their own privacy policies.

03 · Information We Do Not Collect

By design, Cloak does not collect or store:

  • Names, email addresses, phone numbers, or other contact information
  • Government-issued identification or KYC data
  • IP addresses, device identifiers, browser fingerprints, or location data
  • Private keys, seed phrases, wallet balances, or cryptographic secrets
  • Transaction details at the protocol level—Cloak cannot link deposits to withdrawals, identify counterparties, or reconstruct user transaction histories
  • Behavioral analytics, advertising identifiers, or cross-site tracking data

No account registration is required to use the Protocol.

04 · Information We May Encounter

4.1 Operational Logs

Cloak's relay infrastructure may generate limited technical logs for the purpose of maintaining service availability, diagnosing errors, and detecting abuse. These logs are designed to avoid personal identifiers. To the extent any logs temporarily capture data that could be associated with a user, such data is retained only for the period necessary for the operational purpose and is not shared with third parties except as required by law.

4.2 Wallet Blocklist

Cloak maintains a wallet address blocklist applied at the interface and relay level for the purpose of sanctions compliance and abuse prevention. This blocklist contains blockchain addresses only. No personal data is associated with blocked addresses. The basis for blocklisting is the appearance of an address on government-maintained sanctions lists (including the OFAC SDN List) or evidence of Protocol abuse.

4.3 Communications

If you contact Cloak directly (e.g., by email to legal@cloak.ag), we will receive and retain the content of that communication and any personal information you include therein, solely for the purpose of responding to your inquiry and maintaining records of that interaction.

05 · Cookies and Tracking

Cloak does not use cookies, local storage tracking, analytics trackers, advertising technology, or cross-site identifiers on its website or interface. No third-party tracking scripts are embedded in the Cloak interface.

06 · Blockchain Data

The Cloak Protocol operates on the Solana public blockchain. Interactions with the on-chain smart contract program are recorded on the public blockchain and are not controlled by Cloak. Public blockchain data is governed by the properties of that network. Cloak does not index, aggregate, or analyze on-chain data beyond what is necessary to operate the relay.

The zero-knowledge architecture of the Protocol means that the on-chain record of a transaction does not reveal the sender, recipient, or value to any observer, including Cloak.

07 · Enterprise Compliance Layer

For enterprise clients who elect to enable the optional compliance layer, the Protocol supports hierarchical viewing keys. These keys are generated and managed by the enterprise client, not by Cloak. The enterprise client determines who has access to transaction data and under what conditions. Cloak does not hold or have access to enterprise client viewing keys unless explicitly granted by the client for support purposes under a separate written agreement.

Enterprise clients are responsible for their own data protection obligations with respect to the data they access via viewing keys, including obligations under applicable data protection laws.

08 · Third-Party Services

The Protocol may interact with third-party services including wallet providers, RPC node providers, and decentralized exchanges. Cloak does not control the privacy practices of these services. Information you provide to or that is collected by third-party services is governed by their respective privacy policies. We encourage you to review the privacy policies of any third-party services you use in connection with the Protocol.

09 · Legal Disclosures

Cloak may disclose information—including any information in its possession arising from relay or interface operations—to the extent required by applicable law, valid legal process, or order of a competent court or regulatory authority. Cloak will seek to notify affected users of such disclosures where legally permitted to do so.

10 · International Access

The Protocol is accessible globally to non-Restricted Persons (as defined in the Terms of Use). Because Cloak does not collect personal data in the ordinary course of providing the Protocol, cross-border data transfer obligations under data protection frameworks such as the GDPR or LGPD are generally not applicable to Protocol-level interactions.

To the extent any personal data is processed (e.g., in connection with direct communications with Cloak), such processing is subject to applicable data protection law. Users are independently responsible for ensuring their use of the Protocol complies with the data protection laws of their jurisdiction.

11 · Children

The Protocol is not intended for individuals under 18 years of age. Cloak does not knowingly collect personal data from minors. If you become aware that a minor has provided personal data to Cloak, please contact us at legal@cloak.ag and we will take steps to delete such information.

12 · Blocklist Contestation

If you believe your wallet address has been incorrectly added to the Cloak interface blocklist, you may submit a request for review to legal@cloak.ag with the subject line "Blocklist Review Request" and provide the wallet address in question and any supporting information. Cloak will review the request and respond within a reasonable time. Cloak is under no obligation to remove addresses from the blocklist if their inclusion is based on a government-maintained sanctions list.

13 · Data Security

Because Cloak does not collect personal data in the ordinary course of Protocol operations, the risk profile of a data breach is materially minimized. For any limited operational data that Cloak does retain, we implement appropriate technical and organizational measures to protect it against unauthorized access, disclosure, or loss.

14 · Updates to This Policy

This Privacy Policy may be updated from time to time to reflect changes in the Protocol, applicable law, or Cloak's practices. The "Last Updated" date at the top of this document will reflect the date of the most recent revision. Your continued use of the Protocol following a posted update constitutes your acceptance of the revised Policy.

15 · Contact

For all privacy-related inquiries, requests, or notices:

Cloak Privacy Corp.
PH The Century Tower, Office 317
Vía Ricardo J. Alfaro, Betania, District of Panama
Republic of Panama
legal@cloak.ag

Contact

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