Privacy Policy

1. Introduction

PONT Inc. ("PONT," "we," "us," or "our") operates Sampo (the "App"), a walk-to-earn mobile application. This Privacy Policy explains how we collect, use, share, and protect your information when you use the App.

2. Information We Collect

2.1 Information You Provide

• Account information (via Sign in with Apple / Google Sign-In)
• Identity verification information (KYC) when required for cashout
• Communications you send to our support team

2.2 Information Collected Automatically

• Step and Movement Data, via Apple HealthKit, Google Fit, or Health Connect
• Location data, used to determine market eligibility and for fraud prevention
• Device information (model, OS version, unique device identifiers)
• Advertising identifiers (IDFA / Advertising ID)
• Usage data (in-app actions, session length, feature usage)
• Wallet information — public wallet address and on-chain transaction history. WE DO NOT COLLECT OR STORE YOUR PRIVATE KEYS, SEED PHRASES, OR PASSCODES.

2.3 Information From Third Parties

We may receive information from advertising partners, offerwall providers, and analytics providers who help operate and improve the App.

3. How We Use Information

We use the information we collect to operate the App, calculate and grant rewards, prevent fraud and abuse, personalize content and ads, communicate with you, and comply with legal obligations. Where GDPR applies, our legal bases include contract performance, legitimate interests, consent, and legal obligation.

4. Sharing & Disclosure

We share information with service providers (advertising networks, offerwall partners, analytics providers, cloud hosting, cashout processors), as required by law, or in connection with a merger, acquisition, or sale of assets. We do not sell your personal information for money.

5. Wallet & Blockchain Data

The App uses a non-custodial wallet. Transactions on public blockchains are permanent, publicly visible, and cannot be reversed or deleted by us — this is a property of the blockchain, not a limitation of our systems.

6. Cookies & Tracking

We and our partners use cookies, SDKs, and similar technologies for analytics, attribution, and advertising. You can manage tracking permissions through your device's privacy settings (e.g. App Tracking Transparency on iOS).

7. Data Retention

• Account data: deleted within 30 days of account termination, subject to retention up to 7 years where required by law (e.g. tax, AML)
• Log data: retained 180 days
• Blockchain data: retained indefinitely, as it is part of the public blockchain record

8. Your Rights

8.1 General

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal information. Contact support@sampo.cash to exercise these rights.

8.2 California Residents (CCPA/CPRA)

California residents have the right to know, delete, correct, and opt out of the sale/sharing of personal information, and the right to non-discrimination for exercising these rights. We do not sell personal information for money.

8.3 EEA / UK Residents (GDPR)

EEA and UK residents have rights of access, rectification, erasure, restriction, portability, and objection, and the right to lodge a complaint with a supervisory authority.

9. Children's Privacy

The App is not directed at children under 13, and we do not knowingly collect personal information from children under 13 (COPPA). If we learn we have collected such information, we will delete it.

10. International Users

The App is operated from Japan. By using the App, you consent to the transfer and processing of your information in Japan and other countries where we or our service providers operate.

11. Security

We use reasonable administrative, technical, and physical safeguards to protect your information. No method of transmission or storage is 100% secure.

12. Changes to This Policy

We will provide at least 14 days' notice of material changes to this Policy before they take effect.

13. Contact Us

support@sampo.cash — Monday to Friday, 9:00–17:00 JST.