Privacy Policy

Last updated: 2026-03-28

1. Introduction

This Privacy Notice (“Notice”) describes how Twilight OS Inc. and its affiliates (collectively "Twilight", "we", or "us") collect, use, and share your data. This Notice applies to processing activities where Twilight acts as a data controller for our digital asset clearing and settlement platform, including Twilight Shield, Twilight Clear, and Twilight Move.

2. Personal Data We Process

We collect information when you interact with our websites, functional prototypes, and settlement services:

  • Identification & Contact: Name, email, phone, date of birth, and government-issued ID (including biometric verification).
  • Financial & Transactional: Wallet addresses, bank details, asset pledge information, and transaction history.
  • Technical Data: IP address, device identifiers, browser type, and interaction data (via cookies).
  • Compliance Data: Information from AML/KYC checks, sanctions screening, and due diligence investigations.
  • Blockchain Data: Public ledger data, including transaction timestamps and digital signatures.

3. Purpose of Processing

We process your data to:

  • Facilitate Settlement: Provide 1:1 stable value clearing and T0 treasury operations.
  • Regulatory Compliance: Perform mandatory KYC, AML, and counter-terrorist financing checks.
  • Risk Management: Monitor for fraud, manage portfolio margin credit, and execute atomic liquidations.
  • Service Optimization: Maintain, secure, and improve our clearinghouse infrastructure.
  • Legal Obligations: Respond to subpoenas or requests from governmental authorities.

4. Blockchain Privacy & Transparency

Transactions processed via Twilight involve recording data on distributed ledgers.

  • Immutability: Data on a blockchain cannot be deleted or altered by Twilight.
  • Twilight Shield: While we use zero-knowledge proofs to keep settlement details private from external parties, transaction hashes remain on the ledger.
  • Publicity: Public addresses may become personally identifiable if linked to other data sets.

5. Data Sharing

We share information with:

  • Custodial & Banking Partners: To enable asset pledges and liquidity unification.
  • Service Providers: For identity verification, cloud hosting, and analytics.
  • Law Enforcement: When required by law or to prevent financial crime.
  • Corporate Transactions: In the event of a merger, sale, or asset transfer.

6. Your Rights and Choices

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal data. To opt out of marketing, use the "unsubscribe" link in our emails. Note that we must retain certain data for legal and audit purposes related to financial settlements.

7. Updates

We may update this Notice to reflect changes in our technology or regulatory requirements. Material changes will be posted on our website.

8. Contact Information

Twilight OS Inc. 124 East 14th Street, Zero Irving, 19th Floor,
New York, NY 10003
Email: legal@twilight.co