Privacy Policy

Last updated: 7 June 2026

1. Data Controller

AXION SYSTEMS PTE. LTD.
110 Robinson Road, #08-00, ERH Building, Singapore 068901
Email: report@traccia.tech

2. Information We Collect

We collect information that you voluntarily provide when using our services:

Category	Data	Purpose
Identity	Name, date of birth, fiscal code, ID document number	Generate investigative report and complaint draft
Contact	Email address, phone number	Service delivery, support communications
Financial	Wallet addresses, IBAN, transaction hashes, amounts	On-chain tracing and fund flow analysis
Documents	Uploaded files (screenshots, receipts, chat logs)	Evidence analysis for report generation
Technical	IP address, browser type, device info	Security, fraud prevention, analytics
Payment	Payment method details (processed by third-party providers)	Transaction processing

3. Legal Basis for Processing

We process your personal data on the following legal bases:

Contract performance — to deliver the services you requested (Art. 6(1)(b) GDPR).
Legitimate interest — to improve our services, prevent fraud, and ensure security (Art. 6(1)(f) GDPR).
Consent — for marketing communications and non-essential cookies (Art. 6(1)(a) GDPR).
Legal obligation — to comply with applicable laws and regulations (Art. 6(1)(c) GDPR).

4. How We Use Your Information

To perform on-chain tracing and generate investigative reports.
To generate draft complaint documents (denuncia-querela).
To communicate with you regarding your case and our services.
To process payments and manage your account.
To improve and optimise our platform and AI models.
To comply with legal obligations and respond to lawful requests.

5. Data Sharing

We do not sell your personal data. We may share data with:

Service providers — hosting (cloud infrastructure), payment processors, AI model providers, blockchain data providers.
Law enforcement — when required by law or when you instruct us to share data as part of a complaint filing.
Professional advisors — legal counsel, auditors, as necessary.

6. International Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including Singapore and the United States. We ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission.

7. Data Retention

Case data — retained for 24 months after case completion, or longer if required by law.
Account data — retained for the duration of your account plus 12 months.
Payment records — retained for 7 years as required by accounting regulations.
Technical logs — retained for 90 days.

8. Your Rights

Under applicable data protection laws (including GDPR), you have the right to:

Access — request a copy of your personal data.
Rectification — correct inaccurate or incomplete data.
Erasure — request deletion of your data ("right to be forgotten").
Restriction — limit how we process your data.
Portability — receive your data in a structured, machine-readable format.
Object — object to processing based on legitimate interest.
Withdraw consent — at any time, without affecting prior processing.

To exercise your rights, contact us at report@traccia.tech. We will respond within 30 days.

9. Security

We implement appropriate technical and organisational measures to protect your data, including encryption in transit (TLS 1.3), encryption at rest, access controls, and regular security assessments. However, no system is 100% secure, and we cannot guarantee absolute security.

10. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page with a revised "Last updated" date. Your continued use of our services after changes constitutes acceptance.

12. Contact Us

For privacy-related inquiries or to exercise your rights:

AXION SYSTEMS PTE. LTD.
Email: report@traccia.tech
Website: www.traccia.tech