Privacy Policy

2.1 Information You Provide

Account Registration

• Identity Information: Full legal name, date of birth, nationality, Social Security number (or last four digits)
• Contact Information: Email address, phone number, residential address
• Identity Documents: Government-issued photo identification (passport, driver's license, state ID), proof of address documents
• Selfie/Photo: Facial photograph for identity verification purposes

Recipient Information

• Recipient Identity: Full name, relationship to you
• Recipient Financial Details: Bank name, account number, routing number, mobile money number, mobile wallet details
• Recipient Contact Information: Phone number, email address (where applicable)
• Personal Notes: Birthday dates, nicknames, and other information you choose to associate with Recipients for use with the AI Assistant's reminder features

Transaction Information

• Transfer Details: Amount, currency, destination country, exchange rate, transfer status
• Funding Information: Stablecoin type (USDC/USDT), blockchain network used, wallet address, transaction hash
• Payment History: Complete record of all transfers sent through the Service

Communications

• Support Requests: Messages, emails, and other communications with our support team
• Feedback: Surveys, reviews, and feedback you provide

2.2 Information from the AI Assistant (Kora)

When you interact with the Kora AI Assistant, we collect:

• Text Commands: Written instructions and queries you submit to the AI Assistant (e.g., “Send $200 to Mom”)
• Voice Commands: Audio recordings of voice commands, which are processed to extract transfer instructions
• Conversation History: Your interaction history with the AI Assistant, including questions asked and responses provided
• Behavioral Patterns: Transfer frequency, preferred Recipients, typical transfer amounts, and timing patterns identified by the AI to provide personalized recommendations and reminders

2.3 Information Collected Automatically

Device and Technical Data

• Device Information: Device type, model, operating system version, unique device identifiers, mobile network information
• App Usage Data: Features used, screens viewed, session duration, timestamps, in-app actions
• Log Data: IP address, access times, error logs, crash reports

Location Data

• Approximate Location: Based on IP address (we do not collect precise GPS location)

Blockchain Data

• Wallet Addresses: Your stablecoin wallet addresses used to fund your Stratum Remit Wallet
• Transaction Hashes: Blockchain transaction identifiers for incoming deposits
• Network Data: Blockchain network used, confirmation status, network fees

2.4 Information from Third Parties

• Identity Verification Services: Results from third-party identity verification providers used to confirm your identity
• Sanctions and Watchlist Databases: Screening results from OFAC, FinCEN, and other regulatory databases
• Blockchain Analytics: Data from blockchain analytics providers used for compliance and fraud prevention
• Public Records: Information from public databases used to verify your identity or comply with regulatory requirements

3.1 Providing the Service

• Process and complete money transfers
• Fund and manage your Stratum Remit Wallet
• Deliver funds to Recipients via bank accounts and mobile wallets
• Display exchange rates and transaction details
• Send transaction confirmations and delivery notifications
• Process refunds and handle failed transfers

3.2 AI Assistant Features

• Process text and voice commands to initiate and manage transfers
• Learn your transfer patterns to provide personalized suggestions
• Send automated reminders (e.g., birthday reminders for Recipients)
• Provide exchange rate alerts based on your preferences
• Improve the accuracy and relevance of AI responses over time

3.3 Identity Verification and Compliance

• Verify your identity as required by federal and state law
• Screen transactions against sanctions lists and watchlist databases
• Monitor for suspicious, fraudulent, or illegal activity
• File regulatory reports (SARs, CTRs) as required by law
• Comply with the Bank Secrecy Act, USA PATRIOT Act, and state money transmitter regulations

3.4 Security and Fraud Prevention

• Detect and prevent unauthorized access to your account
• Identify and investigate potentially fraudulent transactions
• Protect against abuse, spam, and other harmful activities
• Maintain the integrity and security of the Service

3.5 Communication

• Send service-related notifications (transaction updates, security alerts, account changes)
• Respond to your support requests and inquiries
• Send product updates and new feature announcements (with your consent)
• Send marketing communications (with your consent, and with the ability to opt out)

3.6 Improvement and Analytics

• Analyze usage patterns to improve the Service
• Develop new features and functionality
• Conduct internal research and analytics
• Generate aggregated, de-identified statistics about Service usage

4.1 With Recipients

When you initiate a transfer, the Recipient may receive your name and a notification that funds have been sent. We share only the minimum information necessary to complete the transfer.

4.2 Service Providers

We share information with trusted third-party service providers who assist us in operating the Service, including:

All service providers are bound by contractual obligations to protect your information and use it only for the purposes we specify.

4.3 Regulatory and Legal Disclosure

We may disclose your information:

• To comply with applicable federal, state, or local law or regulation
• In response to valid legal process (subpoenas, court orders, search warrants)
• To regulatory agencies, including FinCEN, OFAC, state regulators, and the NMLS
• To law enforcement when we believe disclosure is necessary to prevent physical harm, financial loss, or illegal activity
• To report suspicious transactions as required by the Bank Secrecy Act

4.4 Business Transfers

If Orokii Inc. is involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

4.6 No Sale of Personal Information

Stratum Remit does not sell your personal information to third parties. We do not share your personal information with third parties for their direct marketing purposes.

5.1 Account Data

We retain your account and identity verification data for the duration of your account and for a minimum of five (5) years following account closure, as required by the Bank Secrecy Act and applicable state money transmitter regulations.

5.2 Transaction Records

We retain transaction records for a minimum of five (5) years from the date of the transaction, as required by federal and state recordkeeping requirements for money transmitters.

5.3 AI Assistant Data

• Voice Recordings: Processed in real time and not stored in raw audio form after processing. Transcribed text is retained as part of your conversation history.
• Conversation History: Retained for the duration of your account to enable personalized AI features. You may request deletion of your conversation history (see Section 8).
• Behavioral Patterns: Retained for the duration of your account. Patterns are deleted when your account is closed.

5.4 Technical Data

Log data, device information, and analytics data is retained for up to twenty-four (24) months for operational and security purposes.

5.5 Post-Closure

When you close your account, we will delete or de-identify your personal information within ninety (90) days, except for data we are legally required to retain (identity verification records, transaction records, and compliance records) for the periods described above.

6.1 Security Measures

We implement and maintain comprehensive security measures to protect your personal information, including:

• Encryption: 256-bit SSL encryption for data in transit; AES-256 encryption for data at rest
• Access Controls: Role-based access controls and multi-factor authentication for internal systems
• Network Security: Firewalls, intrusion detection, and continuous security monitoring
• Compliance Standards: SOC 2 and PCI-DSS compliant infrastructure
• Employee Security: Background checks, security training, and confidentiality agreements for personnel with access to personal information
• Incident Response: Documented breach response procedures with defined notification timelines

6.2 Your Security Responsibilities

You are responsible for:

• Keeping your account credentials confidential
• Using a strong, unique password for your Stratum Remit account
• Logging out of the App when not in use
• Keeping your device secure and its operating system updated
• Reporting any suspected unauthorized access immediately

6.3 Breach Notification

In the event of a data breach affecting your personal information, we will notify you in accordance with applicable federal and state breach notification laws. Notification will be provided via email and/or in-app notification and will include a description of the breach, the types of information affected, and the steps we are taking in response.

8.1 Access and Correction

You may access and update your account information at any time through the App settings. For information not accessible through the App, contact us at privacy@stratumremit.com.

8.2 Data Export

You may request a copy of your personal information in a portable, machine-readable format by contacting privacy@stratumremit.com.

8.3 Deletion

You may request deletion of your personal information by contacting privacy@stratumremit.com. Please note that we are legally required to retain certain records (identity verification, transaction records, compliance records) for the periods described in Section 5, even after account closure.

8.4 AI Assistant Preferences

You may:

• Delete your AI conversation history through the App settings
• Disable personalized recommendations and behavioral pattern analysis
• Choose not to use voice commands (text-only mode is always available)
• Disable birthday and other reminders

8.5 Marketing Communications

You may opt out of marketing communications at any time by:

• Using the unsubscribe link in marketing emails
• Adjusting notification preferences in the App settings
• Contacting us at privacy@stratumremit.com

Opting out of marketing communications will not affect service-related notifications (transaction confirmations, security alerts, regulatory notices).

8.6 Push Notifications

You may disable push notifications through your device settings. Note that disabling push notifications may affect your ability to receive important transaction and security alerts.

9.1 Right to Know

You have the right to request information about:

• The categories of personal information we have collected about you
• The specific pieces of personal information we have collected
• The categories of sources from which we collected your information
• The business purposes for collecting your information
• The categories of third parties with whom we share your information

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions (including legal retention requirements for money transmitters).

9.3 Right to Correct

You have the right to request correction of inaccurate personal information.

9.4 Right to Opt-Out of Sale/Sharing

Stratum Remit does not sell personal information and does not share personal information for cross-context behavioral advertising.

9.5 Right to Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

9.6 How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@stratumremit.com. We will verify your identity before processing your request. You may also designate an authorized agent to make requests on your behalf.

Categories of Personal Information Collected: Identifiers (name, email, phone, SSN), financial information (account numbers, transaction records), internet/electronic activity (device data, app usage), geolocation (approximate), biometric information (facial photograph for verification), and audio information (voice commands).

12.1 Website Cookies

Our website (stratumremit.com) uses the following categories of cookies:

12.2 Mobile App Tracking

The Stratum Remit App may use:

• Analytics SDKs: To measure App performance, feature usage, and crash reporting
• Device Identifiers: To identify your device for security and fraud prevention purposes

12.3 Managing Cookies

You can manage cookies through your browser settings. Blocking strictly necessary cookies may affect website functionality. The App's analytics tracking can be managed through your device's privacy settings.