Privacy Policy

Effective Date: February 28, 2026

This Privacy Policy ("Policy") describes how Bemo Labs Ltd., a business company incorporated in the British Virgin Islands with company number 2125224, doing business as Kotei ("Company," "Kotei," "we," "us," or "our"), collects, uses, stores, and discloses information in connection with the Kotei platform, including our website at kotei.co, APIs, SDKs, payment widgets, merchant dashboard, and related services (collectively, the "Service").

By using the Service, you agree to the collection and use of information as described in this Policy. This Policy should be read in conjunction with our Terms of Service.

1. Information We Collect

1.1 Information Provided by Merchants

Wallet Addresses: Public cryptocurrency wallet addresses you connect or provide when creating your account. These are public blockchain identifiers and are not considered private information.

Product Information: Product names, descriptions, pricing, and other details you configure in the dashboard.

Webhook URLs: Endpoint URLs you configure for receiving payment notifications.

Communication Data: Information you provide when contacting us for support, including email addresses and message content.

Subscription Data: Information related to your subscription plan, billing history, and payment records for Kotei subscription fees.

1.2 Information Collected Automatically

Usage Data: Information about how you interact with the Service, including pages visited, features used, actions taken in the dashboard, and timestamps.

Device and Browser Information: IP address, browser type and version, operating system, device type, screen resolution, and language preferences.

Transaction Monitoring Data: Public blockchain transaction data that we monitor to provide payment confirmation services, including transaction hashes, wallet addresses, amounts, network fees, block confirmations, and timestamps. This data is publicly available on blockchain explorers and is not private.

Cookies and Similar Technologies: We use essential cookies to maintain session state and provide core functionality. We may use analytics cookies to understand usage patterns. See Section 6 for more details.

1.3 Information We Do NOT Collect

Kotei is designed with a privacy-first, minimal data collection approach. We do NOT collect:

  • Private keys, seed phrases, or wallet passwords
  • Personal identity documents (we do not perform KYC)
  • Social security numbers, national identification numbers, or equivalent
  • Bank account numbers or credit card numbers
  • Biometric data
  • Precise geolocation data
  • Personal information of Buyers (Merchants' customers)

Kotei does not have access to or collect any information about the specific goods or services that Merchants sell to their Buyers.

2. How We Use Information

We use the information we collect for the following purposes:

Service Provision: To operate and maintain the Service, including processing Merchant account creation, monitoring blockchain transactions, delivering webhook notifications, and providing the merchant dashboard.

Service Improvement: To analyze usage patterns and improve the functionality, reliability, and user experience of the Service.

Security: To detect, prevent, and respond to fraud, abuse, security incidents, and technical issues.

Communications: To respond to support requests, send service-related notices (e.g., maintenance updates, security alerts), and communicate changes to our Terms or this Policy.

Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

Subscription Management: To manage your subscription, process payments for Kotei services, and communicate billing-related information.

3. Data Sharing and Disclosure

Kotei does not sell, rent, or trade your personal information to third parties. We may share information in the following limited circumstances:

Service Providers

We may share information with trusted third-party service providers who assist in operating the Service, such as cloud hosting providers, analytics services, and communication platforms. These providers are contractually obligated to use the information solely for the purposes of providing services to Kotei and to maintain appropriate security measures.

Legal Requirements

We may disclose information if required to do so by law, subpoena, court order, or governmental request, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Kotei, our users, or the public.

Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.

Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify you for any purpose, including business analytics, industry research, and marketing.

Blockchain Data

Transaction data that is recorded on public blockchain networks is inherently public. Kotei has no control over the accessibility or use of data recorded on public blockchains. Wallet addresses and transaction details are visible to anyone with access to blockchain explorers.

4. Data Retention

Account Data: We retain Merchant account information for as long as your account is active. Upon account deletion or termination, we will delete or anonymize your account data within ninety (90) days, except as required by law.

Transaction Monitoring Data: Transaction monitoring records are retained for a period of twenty-four (24) months for service quality, dispute support, and compliance purposes. After this period, data is anonymized or deleted.

Usage and Analytics Data: Anonymized usage and analytics data may be retained indefinitely for service improvement purposes.

Legal Obligations: We may retain certain information for longer periods as required by applicable law, regulation, or legitimate business interest (e.g., tax records, legal dispute evidence).

5. Data Security

Kotei implements commercially reasonable administrative, technical, and physical security measures to protect information against unauthorized access, loss, destruction, or alteration. These measures include, but are not limited to:

  • Encryption of data in transit using TLS/SSL
  • Encryption of sensitive data at rest
  • Regular security assessments and vulnerability testing
  • Access controls and authentication mechanisms
  • Secure development practices

However, no method of electronic transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You acknowledge and accept this inherent risk.

6. Cookies and Tracking Technologies

Essential Cookies

We use essential cookies that are strictly necessary for the operation of the Service, including session management and authentication. These cookies cannot be disabled.

Analytics Cookies

We may use analytics cookies (such as those provided by privacy-focused analytics platforms) to understand how the Service is used. These cookies collect anonymized usage data only.

No Advertising Cookies

Kotei does not use advertising cookies, tracking pixels, or third-party advertising networks. We do not track users across websites or build advertising profiles.

You can manage cookie preferences through your browser settings. Disabling essential cookies may impair the functionality of the Service.

7. International Data Transfers

Kotei is operated from the United States. If you access the Service from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. By using the Service, you consent to the transfer of your information to these countries, which may have different data protection laws than your country of residence.

8. Third-Party Services

The Service may integrate with or contain links to third-party services, including blockchain networks, wallet providers (via WalletConnect), and blockchain explorers. This Policy does not apply to any third-party services. We encourage you to review the privacy policies of any third-party services you interact with. Kotei is not responsible for the privacy practices or content of third-party services.

9. Children's Privacy

The Service is not directed to individuals under the age of 18 (or the age of legal majority in the applicable jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information promptly.

10. Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

  • Access: The right to request a copy of the personal information we hold about you.
  • Correction: The right to request correction of inaccurate personal information.
  • Deletion: The right to request deletion of your personal information, subject to legal retention requirements.
  • Data Portability: The right to receive your personal information in a structured, machine-readable format.
  • Objection: The right to object to certain processing of your personal information.

To exercise any of these rights, please contact us at privacy@kotei.co. We will respond to valid requests within thirty (30) days or as required by applicable law.

11. California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). Kotei does not sell personal information as defined under these laws. California residents may contact us at privacy@kotei.co to exercise their rights under applicable California privacy law.

12. European Data Subjects

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you may have rights under the General Data Protection Regulation (GDPR) or equivalent legislation. Our legal bases for processing your information include: performance of a contract (providing the Service), legitimate interests (security, fraud prevention, service improvement), compliance with legal obligations, and your consent (where applicable). You may contact us at privacy@kotei.co to exercise your rights or lodge a complaint with your local supervisory authority.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or via email at least thirty (30) days before they take effect. Your continued use of the Service after the effective date of a revised Policy constitutes acceptance of the changes. We encourage you to review this Policy periodically.

14. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: Bemo Labs Ltd. Company No. 2125224 c/o Hermes Corporate Service (BVI) Ltd. 6th Floor, Waters Edge, Building 1 Wickham's Cay 2, Road Town, Tortola British Virgin Islands Website: kotei.co Privacy inquiries: privacy@kotei.co General inquiries: legal@kotei.co