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Legal document

Privacy Policy

Version 2.0 · Last updated: August 17, 2026

1. Introduction

Dinaria LLC (“Dinaria”, “we”, “us”, or “our”) is committed to protecting your personal data and ensuring transparency in how information is collected, used, and shared in connection with our financial services.

This Privacy Policy applies to all users of Dinaria’s services, platforms, and systems.

2. Who We Are

Dinaria LLC is a U.S.-based financial technology company registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) under Registration No. 31000321315533, with registered address at 1001 S Main St, Ste 600, Kalispell, Montana 59901, United States.

Dinaria operates as a group. Personal data may be processed by Dinaria LLC or by an affiliated entity of the group that provides the relevant service in your jurisdiction. The entities of the group are Dinaria LLC (United States), Dynaria S.R.L. (Argentina), Dinaria Perú S.A.C. (Peru), Dinaria México S.A. de C.V. (Mexico) and Dinaria Latam S.A. (Uruguay). Where an affiliate provides the service, that entity acts as controller for the data it processes in connection with it.

Depending on the context, Dinaria may act as:

  • Data Controller (when determining purposes of processing)
  • Data Processor (when acting on behalf of clients or partners)

3. Information We Collect

We collect the following categories of data:

  • Identity Data: name, date of birth, nationality, ID documents
  • Biometric Data: facial image, selfie and liveness capture, and the facial comparison performed between them and your identity document, collected for the sole purpose of verifying that you are who you claim to be
  • Contact Data: email, phone, address
  • Financial Data: bank accounts, transaction history, wallet addresses
  • Technical Data: IP address, device identifiers, logs
  • Compliance Data: KYC/KYB, beneficial ownership of legal entities, sanctions and PEP screening, source of funds and source of wealth documentation
  • Behavioral Data: transaction patterns, usage activity, risk indicators
  • Communications: emails, support interactions

Data may be collected:

  • Directly from you
  • From your use of services
  • From third-party providers

4. Purpose of Processing

We process your data to:

  • Provide and operate financial services
  • Perform identity verification (KYC/KYB)
  • Conduct transaction monitoring and risk analysis
  • Detect fraud and suspicious activity
  • Comply with legal and regulatory obligations
  • Communicate with you
  • Improve and secure our platform

5. Legal Basis

We process data under:

  • Legal obligations (AML/CFT, BSA, FinCEN, IRS)
  • Contractual necessity
  • Legitimate interests (fraud prevention, security, analytics)
  • Consent where required

Biometric data is processed on the basis of your explicit consent, which is requested separately at the time of verification, together with the legal obligation to verify the identity of our clients. You may withdraw that consent, but we will not be able to complete or maintain your verification without it, and consequently will not be able to provide the services.

6. Monitoring, Profiling and Automated Decisions

Dinaria may:

  • Monitor transactions and behavior in real time
  • Apply automated risk scoring models
  • Use artificial intelligence services to read, extract and analyse the documentation and case files you submit, in order to assist our compliance team
  • Flag, restrict, or block transactions based on risk indicators

These processes are necessary for compliance and fraud prevention. Automated analysis assists our compliance team but does not by itself determine the outcome of your case: decisions to approve, restrict or reject are taken by a person.

7. Sharing of Information

We may share data with:

  • Regulators and authorities
  • Financial institutions and banking partners
  • Identity verification providers
  • Sanctions, PEP and adverse media screening providers
  • Blockchain analytics providers, which receive wallet addresses but not your personal details
  • Payment processors and infrastructure providers
  • Providers of artificial intelligence services used to analyse documentation, under contractual terms that prohibit using your data to train their models
  • Affiliates of the Dinaria group: Dynaria S.R.L. (Argentina), Dinaria Perú S.A.C. (Peru), Dinaria México S.A. de C.V. (Mexico) and Dinaria Latam S.A. (Uruguay)

We share only the data each provider needs for the purpose for which it is engaged. The current list of the providers that process personal data on our behalf, and the countries in which they do so, is available on request at support@dinaria.com.

Third parties may process data under their own legal obligations.

We do not sell personal data.

8. International Transfers

Your data may be transferred to and processed in jurisdictions outside your country.

We implement safeguards such as:

  • Standard Contractual Clauses (SCCs)
  • Data processing agreements
  • Equivalent legal protections where applicable

In practice, your data may be processed in the United States, in the European Union, and in the Latin American countries where entities of the Dinaria group or our providers operate.

9. Data Retention

We retain personal data:

  • For a minimum of 5 years where required by AML/CFT laws
  • Longer where required by legal, regulatory, or audit obligations

Biometric data is subject to a shorter and separate rule: it is retained only for as long as necessary to complete and maintain your identity verification, and is deleted once that purpose has been fulfilled or when you withdraw your consent, unless a specific legal obligation requires us to retain it for longer. The record that the verification took place, and its outcome, is retained under the general rule above.

10. Data Security

We implement:

  • Encryption
  • Access controls
  • Monitoring systems
  • Security audits

However, no system is completely secure.

11. Cookies and Tracking Technologies

We may use:

  • Cookies
  • Analytics tools
  • Session tracking

These are used for:

  • Security
  • Performance
  • User experience

You may control cookies through your browser settings.

12. Data Breach and Incident Response

In the event of a data breach:

  • We will take immediate mitigation actions
  • Notify affected users where required by law
  • Report incidents to regulators where applicable

13. Your Rights

Depending on your jurisdiction, you may:

  • Access your data
  • Correct inaccuracies
  • Request deletion (subject to legal limits)
  • Object to processing
  • Withdraw consent

Requests may be submitted to: support@dinaria.com

We may require identity verification before processing requests.

If you are located in Argentina, your personal data may be processed by Dynaria S.R.L. under Argentine data protection law. You may exercise the rights of access, rectification and deletion recognised by that law through the same channel, and you may also lodge a claim with the Agencia de Acceso a la Información Pública.

14. Independent Third Parties

This section concerns parties that act independently of Dinaria and not on our behalf, such as:

  • A bank or financial institution you choose and instruct yourself
  • Blockchain networks
  • External platforms and websites we may link to

Dinaria is not responsible for the privacy practices of those parties, and you should review their policies separately.

This does not apply to the providers we engage to process personal data on our behalf, which are described in section 7. In respect of those, Dinaria remains responsible as controller and requires them by contract to protect your data.

15. Updates to this Policy

We may update this policy at any time.

Where an update materially changes how we process your personal data, we will present the updated policy for your acceptance. For all other updates, continued use of services constitutes acceptance.

16. Contact

Dinaria LLC — 1001 S Main St, Ste 600, Kalispell, Montana 59901, United States

General enquiries: info@dinaria.com

Privacy enquiries and rights requests: support@dinaria.com