Privacy Policy

This Policy applies to information collected:

• On this website and on other Company-controlled sites that link to this Policy.
• Through email, text, or other electronic communications between you and us.
• Through the merchant portal, hosted checkout, and related Services we provide to you.

It does not apply to information collected offline, on sites that do not link to this Policy, or by third parties accessible from our Services — including public blockchain networks, which are outside our control.

By accessing or using our website or Services, you agree to this Policy. If you do not agree, you should not use them.

Because the Services are non-custodial, there are categories of information we deliberately do not hold:

• We do not collect, store, or have access to your private keys, seed phrase, or wallet passcode. Key material is encrypted on your device under a passcode we never receive.
• We do not hold your Digital Assets and therefore hold no balance or custody record on your behalf.
• We cannot recover your wallet, and no request to us — however verified — can produce your keys.

Our Services are not directed to children under eighteen (18), and no one under that age may provide information through them. We do not knowingly collect personal information from children under 18, and will delete it if we learn we have. If you believe we may hold information about a child under 18, contact support@numerari.io.

• Identifiers: name, business name, address, email, phone number, and billing details.
• Commercial information: subscription and transaction records between you and the Company.
• Payment-related information: wallet addresses you add, contact records you create, payout metadata such as amounts, networks, timestamps, and transaction hashes.
• Technical information: IP address, browser type, operating system, device and connection data.
• Online activity: browsing behaviour and interactions with our website and Services.
• Information you voluntarily provide: through forms, support correspondence, and surveys.

We collect information directly from you, automatically as you use the Services, and from third parties such as business partners and service providers.

When you transact, information is written to a public blockchain by design. Wallet addresses, amounts, token types, timestamps, and transaction hashes are visible to anyone and are permanent.

• This data is not stored by us in the sense that we control it — it exists on a decentralised network we do not operate.
• We cannot edit, delete, anonymise, or retract it, and neither can you. A deletion request cannot reach it.
• Blockchain addresses can, in some circumstances, be linked to individuals through analysis performed by third parties. Consider this before publishing an address or associating it with your identity.

As you use our website we may use automatic collection technologies to gather details of visits, device and connection information, and usage patterns. Technologies used may include:

• Cookies: small files stored on your device. You may refuse cookies in your browser settings, though some parts of the site may not function properly.
• Web beacons and pixels: small files that record usage statistics, email interactions, and system integrity.

Some content or advertising may be served by third parties who use their own cookies or similar tools, including across other websites. We do not control third-party tracking technologies.

• To provide, maintain, secure, and improve the Services.
• To manage accounts, authenticate you, and provide support.
• To process subscriptions, billing, and fees.
• To operate address-confirmation features, including micro-deposits and signed challenges.
• To meet legal, regulatory, sanctions-screening, and record-keeping obligations.
• To detect, investigate, and prevent fraud, abuse, and security incidents.
• To notify you of updates or policy changes, and to deliver relevant communications.
• For any other purpose disclosed at collection or with your consent.

We may disclose aggregated, non-identifiable information without restriction. We may disclose personal information:

• To divisions, affiliates, and contractors who support our business, including payment, email, analytics, and infrastructure providers.
• To a buyer or successor in the event of a merger, divestiture, or sale of assets.
• To fulfil the purpose for which you provided it, or with your consent.
• To comply with legal obligations, court orders, or governmental requests.
• To enforce our rights and agreements, including billing and collection.
• To protect the Company, our customers, or others from fraud, security threats, or harm.

We do not sell your personal information.

• Marketing: you may opt out of promotional email by using the unsubscribe link or contacting support@numerari.io.
• Targeted advertising: you may opt out of behavioural advertising by contacting us or using the tools provided by the Network Advertising Initiative (NAI).
• Cookies: you may refuse or delete cookies through your browser settings.

You may request access to, correction of, or deletion of personal information by emailing support@numerari.io. We may be unable to delete certain information except by also closing your Account, and may deny a request where the law requires us to retain records. As set out in Section 5, information already written to a public blockchain cannot be deleted by us.

Residents of certain states — including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia — have rights such as confirming whether we process personal information; accessing, correcting, or deleting it; data portability; opting out of processing for targeted advertising, sale, or profiling with significant effects; and limiting the processing of sensitive personal data.

California residents have additional rights under the CCPA/CPRA, including disclosure, deletion, correction, and opt-out of data sales, and under California’s “Shine the Light” law. Nevada residents may submit opt-out requests under NRS Chapter 603A. We do not currently sell data in a way that triggers Nevada’s opt-out requirement.

We implement security measures including encryption, access controls, and monitoring. No method of transmission over the Internet is completely secure, and any transmission is at your own risk.

You are responsible for safeguarding your Account credentials and your wallet passcode. We cannot reset a wallet passcode, and losing it means losing access to that wallet permanently.

We may update this Policy to reflect changes in our practices or in applicable law. Updates will be posted with a revised Last Modified date, and significant changes may also be communicated by email or in-service notification. Continued use after an update constitutes acceptance.