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Privacy Policy

Effective date: October 21, 2026

1. About this policy

1.1 Who we are. This Privacy Policy explains how Zxee, LLC (formerly Zxen LLC), 1076 Washington Rd., Rye, NH 03870 ("Zxee," "we," "us"), collects, uses, shares, and protects personal information. It applies to the Zxee mobile app, our websites at zxee.app and zxen.app, our pay-link and request-link pages, and related services (the "Zxee Services"). It also applies to people who are not Zxee users but pay through a pay link or receive an invitation from a user.

1.2 Third-party services. Some features are provided by independent third parties, such as wallet infrastructure, identity verification, payment and on-ramp and off-ramp services, bank account linking, exchanges, and conversion services. When you use a third-party service directly, that provider may also collect and use your information under its own privacy policy, which it will show you.

1.3 Your wallet. Your Zxee wallet is self-custodial. You approve every transfer with a passkey on your device, and you can add an optional recovery phrase. Our wallet infrastructure provider helps secure the wallet, but Zxee cannot move your funds on its own. Zxee never collects or stores your private key, seed phrase, passkey, or recovery phrase. We never receive your bank or exchange login credentials.

1.4 Public blockchain. Your wallet address and transactions are recorded on the Base blockchain, which is public. Anyone can view them, and no one, including Zxee, can change or delete blockchain records. Information that links you to your wallet address is kept private as described in this policy.

2. Information we collect and how we collect it

For each category, we say how we collect it: from you (you enter it), automatically (the app or website collects it as you use it), or from third parties.

  • Contact and account details

    Phone number, name, email address, @handle, profile photo

    From: you

  • Identity verification information

    Name, date of birth, address, government ID images and details, a selfie and liveness check, and the verification result

    From: you, through an identity verification provider acting on our behalf

  • Wallet and transaction details

    Wallet address, recipients, amounts, fees, notes, transfer status, pay-link and request-link activity

    From: you, automatically, and from the public blockchain

  • Recipient and invitee details

    Phone number, handle, or wallet address of people you pay, request from, or invite

    From: you

  • Pay-link payer details

    Payer's wallet address, amount, and any name or note the payer enters

    From: payers using a pay link

  • Contacts

    Contacts you choose to pay or invite, and, only if you allow access, contacts on your device used to help you pick recipients

    From: you and, with your permission, your device

  • Linked account details

    Bank name, account type, masked account number, account status; exchange deposit addresses

    From: third-party bank-linking services and exchanges you connect

  • Third-party transaction status

    Status, amount, and reference of a purchase, sale, conversion, or transfer

    From: third-party providers

  • Support communications

    Messages you send us and our replies

    From: you

  • Device and usage information

    IP address, device type and identifiers, operating system, app version, crash logs, features used

    From: automatically

  • Approximate location

    General location (such as country or state) derived from your IP address or the address you give us. We do not collect precise GPS location. During identity verification, our verification provider may ask your permission to check your device location to confirm your country.

    From: automatically, from you, and with your permission, from your device

  • Referral information

    Who invited you, who you invited, and fee credits earned

    From: you and automatically

Biometrics. If you use Face ID, Touch ID, or similar features, your device checks your biometrics and Zxee never receives that data. The selfie used for identity verification is processed by our identity verification provider, on our behalf, to confirm it matches your ID.

Camera. If you allow camera access, we use it to scan QR codes and to take photos of your ID and selfie for identity verification. We do not access your camera without your permission.

Cookies. Our websites use cookies and similar technologies to operate the site, remember preferences, keep it secure, and understand how it is used. You can control cookies in your browser settings.

3. How we use and share information

3.1 How we use it. We use personal information to:

  • create and secure your account and verify your phone number;
  • verify your identity, as required by law and by our partners;
  • set up your wallet through our wallet infrastructure provider;
  • show your balance and activity and prepare the transactions you confirm;
  • connect you with third-party services you choose and show their transaction status;
  • run pay links, request links, invitations, and referrals;
  • calculate and show fees and fee credits;
  • detect and prevent fraud and prohibited use, and enforce our Terms;
  • provide support and send account, security, and transaction messages;
  • improve, test, and fix the Zxee Services; and
  • meet legal, tax, and regulatory obligations.

We use information only for the purpose we collected it for, or a compatible purpose. We will ask for your consent before using it for a new purpose.

3.2 We do not sell or track. Zxee does not sell personal information. We do not share it for advertising, and we do not track you across other companies' apps or websites.

3.3 Who we share it with. We share personal information only as follows:

  • Service providers that help us run Zxee, such as hosting, databases, authentication, identity verification, text-message delivery, analytics, crash reporting, and customer support. They may use it only to provide services to us.
  • Our wallet infrastructure provider, which receives your phone number and account identifier to verify your sign-in, your wallet address, and device and network information such as IP address and device identifiers.
  • Third-party services you choose, such as payment, on-ramp and off-ramp providers, bank-linking services, exchanges, and conversion services. We share what they need to provide the service you requested, such as your wallet address, contact details, and transaction amount. With your permission, which we ask for in the app before you use the provider, we may also share your identity verification results and related information so the provider can rely on them instead of asking you to verify again. These providers may still run their own checks.
  • Other people you transact with. Recipients and payers can see your name, @handle, profile photo, and payment details for transactions with them. Your pay link shows your name and @handle to anyone who opens it.
  • Legal and safety. To comply with law, legal process, or government requests; to protect the rights, safety, or property of Zxee, our users, or others; or to detect and prevent fraud, sanctions violations, or security threats.
  • Business transfers. If Zxee is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this policy.
  • With your consent or at your direction.

We require every service provider and third party we share information with to protect it with safeguards at least as protective as those in this policy.

3.4 Financial privacy. To the extent federal financial privacy law applies to Zxee, we do not share nonpublic personal information with non-affiliated third parties except as that law permits, such as to process transactions you request or to comply with law.

3.5 Invitations. We use invitee phone numbers only to deliver that invitation and complete the payment, and never for marketing.

4. Retention, security, and your choices

4.1 How long we keep information. We keep personal information while your account is open and as long as needed to provide the Zxee Services. After you close your account, we keep transaction, identity verification, and compliance records for as long as the law requires, generally five years, and as needed to resolve disputes and prevent fraud. We then delete or de-identify it.

4.2 Deleting your account and data. You can delete your account in the app under Settings > Delete account, or request deletion at zxee.app/delete-account without the app. We may ask you to confirm your identity. We complete deletion within 30 days and confirm when it is done, and we ask our service providers to delete it too. Before you delete your account, you must move all funds out of your wallet. You cannot delete your account while your wallet holds funds. Some information cannot be deleted: records we must keep by law (Section 4.1), information held by third-party services under their own policies, and your wallet address and transactions on the public blockchain.

4.3 Security. We use administrative, technical, and physical safeguards to protect personal information, including encryption of all data in transit (HTTPS/TLS), access controls, and monitoring. No system is completely secure. Protect your device and passkey, and tell us at support@zxee.app if you suspect unauthorized access.

4.4 Your choices and how to withdraw consent.

  • Access and correction. View and update your profile in the app, or ask us for a copy of your information or to correct it.
  • Device permissions. Turn off contacts, notifications, camera, and other permissions in your device settings at any time. The app still works without contacts access; you can enter recipients manually.
  • Sharing with providers. You can withdraw permission to share your verification results with a provider by contacting support@zxee.app. You may then be unable to use that provider through Zxee.
  • Marketing. Opt out of marketing emails with the unsubscribe link, and out of non-essential texts by replying STOP. We will still send account, security, and transaction messages.
  • Delete everything. Delete your account as described in Section 4.2.

4.5 State privacy rights. Depending on where you live, you may have the right to know what personal information we hold about you, to access, correct, or delete it, to get a portable copy, and to opt out of the sale of personal information, targeted advertising, and certain profiling. We do not sell personal information or use it for targeted advertising. To exercise your rights, contact support@zxee.app. You may use an authorized agent. We will verify your request, respond within the time the law requires, and not discriminate against you. If we deny your request, you may appeal by replying to our decision, and we will respond in writing.

4.6 Children. The Zxee Services are for people 18 and older. We do not knowingly collect information from anyone under 18. If you believe a minor has given us information, contact us and we will delete it.

4.7 Where we process information. The Zxee Services are offered only in the United States, and we store and process information in the United States.

4.8 App store disclosures. The practices described here match our disclosures in the Google Play Data safety section and the Apple App Store privacy labels.

4.9 Changes. We may update this policy. We will post the updated version with a new effective date and, for material changes, notify you in the app or by email before they take effect.

4.10 Contact us. Zxee, LLC, 1076 Washington Rd., Rye, NH 03870. Email: support@zxee.app. Phone: (603) 957-7775.