Privacy Policy — SCDO Wallet

Last updated: 27 September 2026

9Y9 Pty Ltd (APEC Capital), ACN 600 445 118, operates the SCDO Wallet application ("we", "us"). This policy explains what data we collect and how we use it.

1. Data we DO NOT collect

SCDO Wallet is a non-custodial wallet. Your private keys and mnemonic phrase are stored only on your device, encrypted with a password you choose. We do not have access to them, and we cannot recover them for you. We do not run or control the SCDO blockchain.

2. Data we DO collect

• On-chain data: your wallet address, transaction addresses, amounts, and timestamps are public on the SCDO blockchain by design. We read this to display your balance and history.
• KYC data (if you submit it): name, date of birth, country, ID type/number, and residential address. This is required by AUSTRAC for our Digital Currency Exchange registration (DCE100714503-001) and is stored encrypted on-device, with optional encrypted sharing only when you explicitly choose to share it.
• Crash/error logs: anonymous technical errors to help us fix bugs.

3. How we use KYC data

We collect KYC data to comply with Australia's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act 2006 and AUSTRAC rules. We may report suspicious transactions to AUSTRAC as legally required. We do not sell your KYC data to third parties.

4. Data retention

KYC records are retained for 7 years as required by AML/CTF law. You may request deletion of your data where we are not legally required to retain it.

5. Your rights

You may request access, correction, or deletion of your personal data by contacting us. To exercise these rights, email compliance@apeccapital.org.

6. Security

Private keys are encrypted with AES-256-GCM using a PBKDF2-derived key (100,000 iterations). No third party can move your funds without your password and device.

7. Contact

Compliance Officer, 9Y9 Pty Ltd
Email: compliance@apeccapital.org