Privacy Policy

Troopix - Privacy Policy

Last Updated: September 25, 2025

1. Introduction

1.1. Our Commitment. LIGIGA LLC. ("Troopix," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy ("Policy") is designed to help you understand what personal information we collect, why we collect it, and how we use, share, and protect it. Your trust is important to us, and we are dedicated to handling your information with care and respect.

1.2. Scope of this Policy. This Policy applies to the personal information we collect and process from: a) Merchants: The business entities that apply for, register for, or use our Service, including their directors, beneficial owners, employees, and authorized agents whose information is provided during the Onboarding Process or in the course of using the account. b) Website Visitors: Individuals who visit or interact with our public websites (e.g., www.troopixpay.com) and any other websites or online services that link to this Policy.

This Policy does not apply to the end-customers of our Merchants ("Buyers") who make payments using the PIX network. In the standard course of a transaction, we do not directly collect or solicit personal information from Buyers.

1.3. Relationship to Terms of Service. This Privacy Policy is incorporated by reference into our Terms of Service. By accessing our website or using our Service, you agree to the collection and use of information in accordance with this Policy and our Terms of Service. Capitalized terms used but not defined in this Policy shall have the meaning given to them in the Terms of Service.

2. Information We Collect

We collect information about you from different sources and in various ways to provide and improve our Service. The types of personal information we collect are detailed below.

2.1. Information You Provide to Us

We collect information that you directly provide to us when you register for an account, complete the Onboarding Process, or communicate with us. This includes:

• Business and Account Information: Your legal business name, trade names (DBA), physical address, email address, phone number, and tax identification numbers (e.g., Employer Identification Number - EIN).

• Personal Information of Owners and Representatives: To comply with legal and regulatory requirements (KYC/KYB), we collect personal information about the business's beneficial owners, directors, and account administrators. This may include full name, residential address, date of birth, government-issued identification documents (such as a passport or driver's license), and national identification numbers (such as a Social Security Number).

• Financial Information: Bank account details required to process Payouts, including the account holder's name, bank name, account number, and routing numbers.

• Communications: Any information you provide when you contact our support team, participate in a survey, or otherwise communicate with us.

• Biometric Information: To verify your identity and prevent fraud, we may ask you to provide a live selfie or facial scan. We use this biometric data solely for identity verification (liveness detection) and do not sell or share it for marketing purposes.

2.2. Information We Collect Automatically

When you access or use our Platform, we automatically collect certain technical information about your device and your usage. This includes:

• Log and Usage Data: Information such as your Internet Protocol (IP) address, browser type and settings, the date and time of your request, and your interactions with our Service.

• Device Information: Information about the computer or mobile device you use to access our Service, including the hardware model, operating system and version, and unique device identifiers.

• Location Information: We may derive your approximate geographic location from your IP address to enhance security, for fraud prevention, and for analytical purposes.

• Cookies and Similar Technologies: We use cookies and similar tracking technologies to operate the Service, personalize your experience, and analyze usage. For more information, please see our Cookie Policy.

2.3. Information We Receive from Third Parties

We may also receive information about you from third-party sources to supplement the information you provide. This includes:

• Identity and Business Verification Services: We receive information from third-party verification services to perform KYC and KYB checks as part of our compliance program. This may include reports confirming your identity, your business's legal standing, and checks against sanctions lists and lists of Politically Exposed Persons (PEPs).

• Financial Partners: We may receive information from our banking partners and other financial institutions regarding the status of your transactions and Payouts.

• Publicly Available Sources: We may collect information from public sources, such as government registries and public records, to verify and supplement your business information.

3. How We Use Your Information

We use the personal information we collect for legitimate business purposes, which are described in detail below. We do not use your personal information for purposes that are incompatible with those described in this Policy, unless required or authorized by law, or with your consent.

We use your information to:

a) Provide, Maintain, and Improve the Service. To create and manage your account, process your registration, provide you with customer support, and to operate, analyze, and improve our Service and develop new features and functionalities.

b) Verify Identity and Comply with Legal Obligations. To verify the identity of Merchants and their beneficial owners (KYC/KYB) and to comply with our legal and regulatory obligations, including but not limited to those under applicable Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT), and economic sanctions laws.

c) Manage Risk, Prevent Fraud, and Ensure Security. To protect the security and integrity of our Platform and our users by monitoring for, preventing, detecting, and mitigating fraud, security risks, and any other potentially prohibited or illegal activities.

d) Process Transactions and Send Payouts. To facilitate the core functionality of the Service, including processing PIX transactions initiated by Buyers and initiating Payouts of the corresponding funds to your verified bank account.

e) Communicate with You. To send you administrative communications regarding your account, such as security alerts, policy updates, and transaction notifications. We also use your contact information to respond to your support requests and to send you information about our services, subject to your communication preferences.

f) Create Anonymized and Aggregated Reports. As permitted under our Terms of Service, we may process your information to create anonymized and aggregated statistical data. We use this data for analytics, to produce market intelligence reports, and to provide industry benchmarks and insights to our Merchant community. This data will not personally identify you or your business.

4. How We Share Your Information

We do not sell your personal information to third parties. We only share your information with trusted third parties in the limited circumstances described below, as necessary to provide our Service and comply with our legal obligations.

a) With Our Service Providers and Vendors. We share information with third-party service providers who perform services on our behalf. These services are essential for our operations and include:

• Identity verification (KYC/KYB) and compliance monitoring services.

• Cloud hosting and infrastructure providers.

• Data analytics and performance monitoring tools.

• Customer support and communication platforms. These service providers are contractually obligated to use your information only to perform the services we have requested and to maintain the confidentiality and security of your data.

b) With Our Financial Partners. We share information with financial institutions and partners that are integral to our payment processing and settlement services. This includes:

• Banking partners who hold our operational accounts.

• Payment processors and networks required to facilitate PIX transactions.

• Virtual Asset Service Providers (VASPs): Partners who facilitate the conversion of funds (stablecoins) and settlement.

• Blockchain Analytics Providers: To screen transactions for compliance with anti-money laundering regulations.

c) For Legal Obligations and Safety. We may disclose your information to third parties, such as law enforcement, government authorities, and regulators, if we believe in good faith that it is necessary to:

• Comply with a law, regulation, subpoena, court order, or other valid legal process.

• Protect the rights, property, or safety of Troopix, our users, or the public.

• Enforce our Terms of Service or other agreements and policies.

• Detect, prevent, or otherwise address fraud, security, or technical issues.

d) In Connection with a Business Transaction. If Troopix is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be shared or transferred as part of that transaction. We will take steps to ensure that the receiving entity honors the promises made in this Privacy Policy.

5. International Data Transfers

5.1. Global Operations. Troopix operates as a global service. In order to provide the Service to you, your personal information will be transferred to, stored, and processed in countries other than the country in which you are resident. Specifically, you authorize us to transfer and process your information in the United States, where our primary servers and operations are located.

5.2. Data Protection and Safeguards. The data protection laws of the countries to which we transfer your information, such as the United States, may be different from, and potentially less protective than, the laws of your own country.

However, we will take all necessary steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We implement appropriate safeguards to protect your personal information when it is transferred. This includes, where applicable, entering into legally binding data processing agreements and standard contractual clauses (SCCs) with our service providers and partners to ensure that your data receives an adequate level of protection in the jurisdictions to which it is transferred.

6. Data Security

6.1. Our Commitment. We take the security of your information very seriously and have implemented a security program designed to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We are committed to employing a variety of security technologies and procedures to help protect your data.

6.2. Security Measures. We maintain a combination of technical, organizational, and administrative security measures to safeguard your information. These measures include, but are not limited to: a) Technical Measures: Encryption of data in transit (using Transport Layer Security - TLS) and at rest; network security measures such as firewalls; and systems for monitoring against unauthorized access. b) Organizational Measures: Strict access controls to ensure that only authorized personnel with a legitimate business need can access personal information; internal information security policies and procedures; and regular employee training on data protection and security best practices.

6.3. Security Disclaimer. You acknowledge and agree that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable and industry-standard means to protect your personal information, we cannot guarantee its absolute security. Therefore, we cannot be held liable for any unauthorized access or use of your information that is beyond our reasonable control.

7. Data Retention

7.1. General Principle. We will retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected, as described in this Policy, including for the duration of your business relationship with us.

7.2. Retention Periods. To determine the appropriate retention period for personal information, we consider several factors, including: a) The duration of your active account and the time needed to provide the Service to you. b) Our legal and regulatory obligations. As a financial technology service, we are subject to laws and regulations (such as Anti-Money Laundering - AML, tax, and accounting laws) that require us to retain certain transaction and account information for a specific number of years even after you have closed your account. This period is typically between five to seven years following the termination of the business relationship. c) The need to resolve disputes, enforce our agreements, or defend against potential legal claims.

7.3. Data Disposal. Once the retention period expires, we will either securely delete your personal information or anonymize it. Anonymized data, which can no longer be used to identify you, may be kept for statistical and analytical purposes to help us improve our services.

8. Your Data Rights and Choices

8.1. General. Subject to applicable local data protection laws, you (and your representatives whose personal information we process) have certain rights and choices regarding your personal information. To exercise any of the rights described below, please contact us using the contact details provided in the "How to Contact Us" section of this Policy.

8.2. Your Rights. Your rights may include:

a) Right of Access and Portability: You may have the right to request access to the personal information we hold about you and, in certain circumstances, to receive that information in a structured, commonly used, and machine-readable format for you to transmit to another service.

b) Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

c) Right to Erasure ("Right to be Forgotten"): You may have the right to request that we delete your personal information. Please note that this is not an absolute right, and we may have legal or legitimate grounds to retain your information, such as to comply with our legal and regulatory obligations (as detailed in our Data Retention policy), for the establishment or defense of legal claims, or for fraud prevention.

d) Right to Restrict or Object to Processing: You may have the right to object to or request that we restrict the processing of your personal information in certain circumstances, such as for direct marketing purposes.

8.3. Marketing Choices. You can opt out of receiving promotional or marketing communications from us at any time by following the "unsubscribe" link or instructions provided in any marketing email you receive, or by adjusting the communication preferences in your account settings. Please note that even if you opt out of marketing communications, we will still send you essential transactional and administrative messages related to your account and the Service, such as security alerts and Payout notifications.

8.4. Verification. For your protection, we may need to verify your identity before responding to your request to exercise your rights. We will only use the personal information provided in such a request to review and comply with your request.

9. Policy Towards Children

Our Service is a business-to-business service and is not intended for, nor directed at, individuals under the age of 18. We do not knowingly collect personal information from children under 18.

If we become aware that we have inadvertently collected personal information from an individual under the age of 18 without verification of parental consent, we will take commercially reasonable steps to delete that information from our records as soon as possible.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us using the contact details provided in the "How to Contact Us" section of this Policy, and we will work with you to address the issue.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies (such as web beacons and pixels) to operate and administer our website and Service, gather usage data, and improve your experience.

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site. We use these technologies to help us recognize you, remember your preferences, secure your account, and analyze how our Service is used.

For more detailed information about the cookies we use, the purposes for which we use them, and how you can manage your cookie preferences, please read our separate Cookie Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, the features of our Service, or applicable law. When we make changes, we will update the "Last Updated" date at the top of this Policy and post the revised version on our website.

For any material changes, we will provide you with reasonable prior notice by sending an email to the address associated with your account, by posting a prominent notice on our Platform, or through other appropriate communication channels.

We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. Your continued use of the Service after any changes to this Privacy Policy become effective will constitute your acceptance of the revised policy.

12. How to Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights as described in Section 8, or have any concerns about our privacy practices, please do not hesitate to contact us.

You can reach us via email at: compliance@troopixpay.com

Or by mail at: Ligiga LLC, 3 PARKLANE BLVD, SUITE 1005W, Dearborn, Michigan, ZIP 48126 Attn: Privacy Officer