Last Updated: [28 April 2026]

1. INTRODUCTION

This Privacy Policy explains how personal data is processed in connection with your use of the CheckD mobile application, website, and related services (the “CheckD Application”).

The CheckD Application enables users to access content, services, and interactions and may integrate with the Dataswyft Wallet to support authentication and data-enabled functionality.

This Privacy Policy applies solely to personal data processed through the CheckD Application and does not govern the processing of personal data within the Dataswyft Wallet, which is subject to a separate privacy framework.

2. DATA CONTROLLER

The CheckD Application is operated by:

Dataswyft Sdn Bhd BO1-A-9, Menara 2 (9th Floor) KL Eco City, 3 Jalan Bangsar 59200 Kuala Lumpur Malaysia

(“Dataswyft”, “we”, “us”, or “our”).

For the purposes of applicable data protection laws, Dataswyft acts as a data controller in respect of personal data processed in connection with the operation of the CheckD Application.

3. DATA GOVERNANCE MODEL

The CheckD Application operates within a user-directed and instruction-based data architecture.

3.1 User as Controller of Wallet Data

Where personal data is stored within your Dataswyft Wallet, including your Wallet Account and any Personal Data Accounts, you act as the data controller in respect of that data.

Such data is:

• created, managed, and shared under your control;
• processed only in response to your actions or instructions; and
• not independently accessed, extracted, or repurposed by Dataswyft.

3.2 Dataswyft as Processor (User-Directed Data Flows)

Where personal data is collected through the CheckD Application and transmitted into your Wallet Account at your direction, Dataswyft processes that data as a data processor acting on your behalf.