Privacy Policy

Bit1 Ventures Inc. · Effective: March 25, 2026

1. Introduction

Bit1 Ventures Inc. ("Company," "we," "us," or "our") operates the BIX mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App, including our embedded non-custodial cryptocurrency wallet, in-app swap functionality, and Visa card program powered by Rain.

By downloading, accessing, or using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the App.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account, verify your identity, or use our services, we may collect the following categories of personal information:

Account Registration Information: Name, email address, phone number, date of birth, and account credentials necessary to create and maintain your BIX account.

Identity Verification (KYC) Information: Government-issued identification documents (passport, driver's license, national ID), selfie or biometric facial data for liveness verification, residential address proof, Social Security Number or Tax Identification Number (where required by law), and any additional documentation required by our KYC provider, Persona, Inc., or by applicable Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) regulations.

Financial Information: Cryptocurrency wallet addresses, transaction history, card funding amounts, and spending activity related to the BIX Visa card program.

2.2 Information Collected Automatically

When you use the App, we automatically collect certain information, including:

Device Information: Device type, operating system version, unique device identifiers (IDFA/GAID, where permitted), device model, and hardware specifications.

Usage Data: App interaction logs, feature usage patterns, session duration, crash reports, and performance data.

Network Information: IP address, approximate geolocation (derived from IP), mobile carrier, and connection type.

Wallet Interaction Data: On-chain transaction hashes (public blockchain data), swap activity metadata (not private keys), and card loading events. We do not collect or store your private keys or seed phrases at any time.

2.3 Information from Third-Party Providers

We receive information from the following external service providers that are integral to the App's functionality:

3. How We Use Your Information

We use the information we collect for the following purposes:

Service Delivery: To create and manage your account, provide the embedded wallet, facilitate cryptocurrency swaps, process card transactions, and deliver the core functionality of the App.

Identity Verification and Compliance: To verify your identity through our KYC process (via Persona), comply with AML/CFT regulations, sanctions screening, and other applicable financial regulations.

Transaction Processing: To authorize and settle Visa card transactions through Rain, execute in-app cryptocurrency swaps, and maintain accurate records of your financial activity.

Authorized Signer Operations: When you accept our Terms of Service, you authorize designated smart contract signers operated by Bit1 Ventures Inc. to execute specific blockchain transactions on your behalf (see Section 9 — Authorized Signers for details). This authorization is limited to transaction execution and does not grant Bit1 Ventures Inc. access to your private keys or custody of your funds.

Security and Fraud Prevention: To detect and prevent fraud, unauthorized access, and other illegal activities; to monitor for suspicious transactions in compliance with financial regulations.

App Improvement: To analyze usage patterns, diagnose technical issues, improve features, and enhance the overall user experience.

Communications: To send you service-related notifications, security alerts, transaction confirmations, and (with your consent) promotional communications.

Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.

4. Disclosure of Your Information

We may share your information in the following circumstances:

With Service Providers: We share information with Privy.io (wallet infrastructure), Persona, Inc. (KYC verification), Rain (card issuance and settlement), and other service providers who assist in operating the App. These providers are contractually bound to use your information only for the purposes we specify and in accordance with this Privacy Policy.

For Legal and Regulatory Compliance: We may disclose information to comply with applicable laws, regulations, legal processes, or governmental requests, including responding to subpoenas, court orders, or law enforcement requests. This includes sharing information with financial regulators as required under AML/CFT and sanctions compliance programs.

With Your Consent: We may share your information with third parties when you provide explicit consent.

Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of such transaction, subject to applicable privacy laws.

Blockchain Data: Transactions executed on public blockchains are inherently public. Wallet addresses and transaction data recorded on-chain are visible to anyone and cannot be deleted or modified by Bit1 Ventures Inc..

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. We also retain and use your information as necessary to comply with our legal obligations (including AML/CFT record-keeping requirements, which may require retention for a minimum of five years after account closure), resolve disputes, and enforce our agreements.

KYC verification data collected by Persona, Inc. is retained according to Persona's data retention policies and applicable regulatory requirements. Card transaction data processed by Rain is retained according to Rain's policies and Visa network requirements.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including encryption in transit (TLS 1.2+) and at rest, access controls, regular security assessments, and incident response procedures.

Non-Custodial Architecture: The BIX wallet is non-custodial, powered by Privy.io. Your private keys are never transmitted to, stored on, or accessible by Bit1 Ventures Inc.'s servers. Key management is handled entirely through Privy's secure infrastructure, with the user retaining ultimate control. This architecture significantly reduces the risk of centralized key compromise.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

Access and Portability: You may request a copy of the personal information we hold about you.

Correction: You may request correction of inaccurate or incomplete personal information.

Deletion: You may request deletion of your personal information, subject to our legal retention obligations (including AML/CFT requirements).

Opt-Out: You may opt out of promotional communications at any time. Note that you cannot opt out of service-related communications (transaction confirmations, security alerts).

California Residents (CCPA/CPRA): California residents have additional rights, including the right to know what personal information is collected and sold, the right to delete, and the right to opt out of the sale of personal information. Bit1 Ventures Inc. does not sell personal information.

EU/EEA Residents (GDPR): If applicable, you have rights under the General Data Protection Regulation, including the right to access, rectify, erase, restrict processing, data portability, and object to processing. Our legal basis for processing includes contract performance, legal obligation, and legitimate interests.

To exercise any of these rights, please contact us at legal@bixpay.io.

8. Children's Privacy

The App is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will take steps to delete such information promptly. If you believe a minor has provided us with personal information, please contact us at support@bixpay.io.

9. Authorized Signers and Transaction Delegation

By accepting our Terms of Service, you authorize Bit1 Ventures Inc. to operate designated blockchain transaction signers ("Authorized Signers") on your behalf. These Authorized Signers are smart contract-level signers that facilitate specific operations necessary for the App's functionality, including:

In-App Swaps: Executing cryptocurrency-to-stablecoin conversions through the integrated swap engine within the App.

Card Funding: Transferring stablecoins (USDC/USDT) from your embedded wallet to the Rain smart contract for card loading.

Transaction Settlement: Facilitating the on-chain components of Visa card transaction settlement through Rain's infrastructure.

Important: Authorized Signers operate under a limited delegation model. They can only execute pre-defined transaction types that you have explicitly authorized. Bit1 Ventures Inc. does not have access to your private keys, cannot move your funds to unauthorized destinations, and cannot modify the scope of signer permissions without your explicit consent through the App. As the Authorized Signer system is essential for the App’s core functionality, if you wish to revoke signer authorization, you must request the closure of your account (see Terms of Service, Section 4.4).

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses (where applicable) and compliance with local data protection laws.

11. Third-Party Links and Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of Privy.io, Persona, Inc., and Rain, as their services are integral to the App's functionality.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes through the App or by email. Your continued use of the App after such changes constitutes acceptance of the revised Privacy Policy. The date of the last revision is indicated at the top of this document.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Bit1 Ventures Inc.

Email: legal@bixpay.io