keyx — PRIVACY POLICY

1. Who we are

This Privacy Policy explains how Neptune Venture Studio Ltd, a company registered in the United Kingdom under company number 17413672, with registered office at:

128 City Road
London EC1V 2NX
United Kingdom

("keyx", "we", "us" or "our"), collects, uses, stores and otherwise processes personal data when you use the keyx website and services available at https://keyx.pro (the "Service").

Neptune Venture Studio Ltd is the data controller responsible for personal data processed in connection with the keyx Service, except where a third-party provider acts as an independent controller for particular processing activities.

keyx provides a digital interface that allows users to create and access a personal keyx wallet and to send and receive USDC on supported blockchain networks, currently including Arbitrum.

For privacy-related questions or to exercise your data protection rights, you can contact us at:

Privacy: support [ at ] keyx [ dot ] pro

If a Data Protection Officer is legally required for a particular processing activity, the relevant contact details will be made available through this Privacy Policy or other appropriate privacy information.

Where the EU General Data Protection Regulation (EU GDPR) applies to our processing activities, additional requirements applicable to organisations established outside the European Economic Area may also apply.

2. What information we collect

Depending on how you use keyx, we may process the following categories of information.

Account information

When you create or access a keyx account, we may process:

• your email address
• account identifier
• authentication information
• information associated with your keyx account

keyx uses third-party wallet and authentication infrastructure providers, such as Privy, to provide certain wallet and authentication functionality.

Wallet and transaction information

When you use keyx to send or receive USDC, we may process:

• blockchain wallet addresses
• transaction hashes
• transaction dates and times
• transaction amounts
• blockchain and network information
• transaction status
• information necessary to determine whether a recipient is a keyx user

Blockchain transaction information may also be publicly visible on the relevant blockchain network.

Recipient information

When you enter an email address in the Send function, keyx may process that email address to determine whether it is associated with an existing keyx account.

If the email address belongs to a keyx user, keyx may display the relevant keyx recipient information so that you can send USDC without manually entering the recipient's blockchain address.

Technical information

When you access the Service, we may automatically collect certain technical information, such as:

• IP address
• browser and device type
• operating system
• language and basic device information
• date and time of access
• pages or functions accessed
• technical logs
• security and error information

We use this information primarily to operate, secure and improve the Service.

Support information

If you contact keyx for support, we may process:

• your email address
• the content of your request
• information you voluntarily provide
• technical information necessary to investigate and resolve your request

3. How we use your information

We use personal data for the following purposes.

Providing the keyx Service

We process information necessary to:

• create and maintain your keyx account
• authenticate you
• provide your keyx wallet
• enable you to send and receive USDC
• display your balance and transaction information
• identify keyx users when an email address is entered as a recipient
• maintain transaction records
• provide customer support

The primary lawful basis for these activities is performance of our contract with you, where the processing is necessary to provide the Service you have requested.

Security and prevention of abuse

We may process information to:

• protect keyx and its users
• detect and prevent abuse
• investigate suspicious activity
• maintain the security of accounts and infrastructure
• prevent unauthorised access
• detect and investigate technical incidents

The lawful basis may be our legitimate interests in operating a secure and reliable service, provided that such interests are not overridden by your rights and interests.

Legal and regulatory obligations

We may process and retain information where necessary to comply with applicable laws, regulations, court orders, governmental requests or other legal obligations.

The applicable lawful basis will generally be compliance with a legal obligation.

Service improvement

We may use technical and usage information to:

• understand how the Service is used
• identify errors
• improve functionality and performance
• improve security and reliability

Where consent is required by applicable law, we will obtain consent before carrying out the relevant processing.

4. Blockchain information

keyx uses blockchain technology to facilitate USDC transactions.

Blockchain networks are decentralised networks and may be publicly accessible. Information recorded on a blockchain may be difficult or impossible to modify or delete.

For example, the following information may remain publicly available:

• wallet addresses
• transaction hashes
• transaction amounts
• transaction timestamps
• blockchain and network information

Once a transaction has been recorded on a public blockchain, keyx generally cannot modify or delete that information.

keyx cannot guarantee the deletion, alteration or removal of information that has already been recorded on a public blockchain.

Users should therefore consider carefully the information they choose to associate with a blockchain address.

5. Third-party service providers

keyx relies on specialised third-party providers to operate certain parts of the Service.

These may include providers of:

• wallet infrastructure
• authentication
• blockchain infrastructure
• hosting
• technical analytics
• security
• customer support
• communications

For example, keyx may use Privy for wallet and authentication infrastructure.

Depending on the service and contractual relationship involved, a provider may process personal data on our behalf as a processor, or may act as an independent controller for certain processing activities.

Where required by applicable data protection law, we enter into appropriate contractual arrangements with processors and require appropriate security measures.

6. When we share information

keyx does not sell your personal information.

We may disclose personal data to:

• service providers supporting the keyx Service
• blockchain and infrastructure providers
• professional advisers
• auditors
• legal or regulatory authorities where required
• courts, law enforcement or governmental authorities where legally required
• parties involved in a merger, acquisition, restructuring or sale of assets

We only disclose personal information where there is an appropriate legal basis for doing so.

Information recorded directly on a public blockchain may also be accessible to participants and other users of that blockchain independently of keyx.

7. International data transfers

Some of our service providers may process personal data outside the United Kingdom or outside the European Economic Area.

Where applicable data protection law requires safeguards for an international transfer, we will use an appropriate legally recognised mechanism.

Depending on the circumstances, this may include:

• an adequacy decision
• the UK International Data Transfer Agreement (IDTA)
• the UK Addendum to the EU Standard Contractual Clauses
• EU Standard Contractual Clauses
• another legally recognised transfer mechanism

Additional information about relevant international transfers and safeguards may be requested by contacting us at:

support [ at ] keyx [ dot ] pro

The specific mechanism used may depend on the location of the relevant service provider and the applicable data protection legislation.

8. How long we keep your information

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Retention periods may depend on:

• the type of information
• the purpose for which it was collected
• whether you maintain an active keyx account
• legal, regulatory or accounting requirements
• the need to establish, exercise or defend legal claims
• security and fraud-prevention requirements

Where appropriate, information may be deleted, anonymised or otherwise securely disposed of when it is no longer required.

Blockchain information is different. Once a transaction has been recorded on a public blockchain, the relevant information may remain publicly available indefinitely and may not be removable by keyx.

9. Your rights

Depending on the applicable data protection legislation and circumstances, you may have the right to:

• request access to your personal data
• request correction of inaccurate or incomplete data
• request deletion of personal data
• request restriction of processing
• object to certain processing
• request data portability
• withdraw consent where processing is based on consent
• lodge a complaint with a competent data protection authority

These rights are subject to applicable legal limitations and exceptions.

To exercise your rights, contact:

support [ at ] keyx [ dot ] pro

We may need to verify your identity before fulfilling certain requests.

If you are located in the European Economic Area and the EU GDPR applies to our processing of your personal data, you may also have rights under the EU GDPR and may contact the relevant supervisory authority in your country of residence or place of work.

If you are located in the United Kingdom, you may contact the Information Commissioner's Office (ICO) regarding data protection matters.

10. Cookies and similar technologies

keyx may use cookies and similar technologies that are necessary for:

• authentication
• security
• session management
• essential functionality

If keyx uses analytics, advertising or other non-essential technologies that require consent under applicable law, we will request consent where required.

You can manage cookies through your browser settings and, where applicable, through cookie preference tools made available by keyx.

11. Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

However, no internet-based service, digital wallet infrastructure or blockchain system can be guaranteed to be completely secure.

You are responsible for maintaining the security of your account and authentication methods and should contact keyx if you believe your account or access credentials have been compromised.

12. Children

keyx is not intended for children under the minimum age required to use the Service under applicable law.

We do not knowingly collect personal information from children where such collection is prohibited by law.

If you believe that a child has provided personal information to keyx, please contact us at:

support [ at ] keyx [ dot ] pro

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

• the keyx Service
• applicable law
• our processing activities
• our service providers
• our security or privacy practices

When we make material changes, we will provide appropriate notice where required by applicable law.

The latest version will always be made available on the keyx website.

14. Contact

For privacy questions or to exercise your data protection rights:

Neptune Venture Studio Ltd
Company No. 17413672
128 City Road
London EC1V 2NX
United Kingdom

Privacy: support [ at ] keyx [ dot ] pro

keyx: https://keyx.pro