Last Updated: [12 March 2026]

This Privacy Policy explains how personal data is processed in connection with the Dataswyft Wallet and the Dataswyft Network.

The Dataswyft Wallet enables individuals to acquire, manage, authenticate, and present data within the Dataswyft Network.

This Privacy Policy applies to personal data processed through Wallet Accounts.

1. Data Controller

The Dataswyft Wallet infrastructure is operated by the Country Network Licensee (“CNL”) responsible for the jurisdiction in which the wallet service is provided.

The CNL in Malaysia is Dataswyft Sdn Bhd

The CNL acts as the data controller for personal data processed within the Dataswyft Jurisdiction Wallet Database.

Wallet data is administered according to the Dataswyft Wallet Trust Deed, under which:

• the CNL acts as Trustee
• wallet users are Beneficiaries
• the HAT Community Foundation acts as Protector.

2. Wallet Architecture

A Wallet Account is the data environment associated with a Dataswyft Wallet.

Wallet Accounts may contain data stored in two environments:

Trustee-Custodied Wallet Storage

Data stored within the Dataswyft Jurisdiction Wallet Database.

This database forms part of the Trust Property governed by the Dataswyft Wallet Trust Deed.

Personal Data Accounts (HAT Microservers)

Wallet Accounts may also connect to Personal Data Accounts (“PDAs”) stored within HAT Microserver databases.