# Privacy Policy Last Updated Date: May 19, 2026 This Privacy Policy (“Policy”) describes how Venzo and its affiliates or related entities (“Venzo,” “we,” “us,” or “our”) may collect, use, disclose, and retain information when you access or use our Services. It also describes your choices and rights regarding this information. Please read this Policy carefully. ### Applicability of This Policy This Policy applies to the websites, web applications, interfaces, dashboards, APIs, documentation, and related online services owned or controlled by Venzo, including Venzo Earn, Venzo Swap, Venzo Pay, Venzo Rewards, vault discovery, transaction-routing interfaces, rewards interfaces, dashboards, documentation, and related services (collectively, the “Services”). This Policy does not apply to third-party websites, wallets, protocols, vaults, blockchains, decentralized applications, payment providers, card issuers, fiat on/off-ramp providers, identity verification providers, strategy managers, or other third-party services that may be linked to, integrated with, or accessible through the Services. Your use of those third-party services may be governed by separate terms and privacy policies. If you do not agree with this Policy, do not access or use the Services. ### Information We Collect When you interact with the Services, we may collect the following categories of information: * **Contact Information**, such as your name, email address, social handle, support information, or other information you provide when contacting us, joining a waitlist, registering for updates, participating in a campaign, or requesting support. * **Wallet and On-Chain Information**, such as your public wallet address, connected wallet provider, blockchain network, token balances, vault positions, receipt tokens, rewards, transaction hashes, smart contract interactions, gas fees, and other publicly available on-chain activity associated with your wallet. * **Transaction Interaction Information**, such as vaults or strategies you view, quotes or routes you request, transaction messages or instructions generated through the Services, transaction status, timestamps, transaction amounts, supported blockchain networks, and related interaction metadata. * **Account, Session, and Preference Information**, such as wallet connection status, interface preferences, notification settings, referral codes, campaign participation, rewards eligibility, and dashboard settings. * **Compliance and Eligibility Information**, such as jurisdiction information, sanctions screening results, anti-money laundering or fraud-prevention information, tax-related information, identity verification information, or other information required or requested for legal, regulatory, eligibility, security, or risk-management purposes. * **Correspondence and Support Information**, such as feedback, survey responses, customer support messages, complaints, bug reports, and other communications you provide to us. * **Device, Usage, and Online Identifier Information**, such as IP address, browser type, device type, operating system, referring and exit pages, pages viewed, clickstream data, timestamps, language settings, approximate location derived from IP address, browser fingerprint, and other information collected through cookies, pixels, SDKs, logs, or similar technologies. * **Information We Receive from Third Parties**, such as information from analytics providers, security providers, identity verification providers, sanctions screening vendors, wallet connection providers, payment providers, card providers, fiat on/off-ramp providers, blockchain data providers, public databases, partners, and other service providers. Public blockchain data may be permanently recorded on public blockchains and may be visible to anyone. Venzo does not control public blockchains and may not be able to modify, delete, or remove information that has been recorded on-chain. ### Information We Do Not Collect Venzo is non-custodial. We do not collect, store, or have access to your private keys, seed phrases, wallet passwords, recovery phrases, or other credentials required to control your digital assets. You should never provide this information to us. Connecting a digital wallet to the Services may allow us to view public information associated with that wallet, but it does not give Venzo custody or control over your assets. Venzo cannot initiate, authorize, sign, cancel, reverse, modify, or recover blockchain transactions or digital assets on your behalf. ### How We Use Information We may use the information we collect for the following purposes: ### Providing and Operating the Services We may use information to provide, operate, maintain, personalize, and improve the Services, including to: * enable wallet connection and user sessions; * display wallet-connected dashboards and on-chain information; * provide vault discovery, strategy information, rewards information, and analytics; * generate draft transaction messages, quotes, routes, or instructions that you may independently review and sign through your digital wallet; * support Venzo Earn, Venzo Swap, Venzo Pay, Venzo Rewards, and related features; * process support requests and respond to user inquiries; * provide service notices, security alerts, legal notices, confirmations, updates, and administrative messages; * create aggregated, anonymized, or de-identified data; and * improve the reliability, functionality, design, and performance of the Services. ### Safety, Security, Fraud Prevention, and Compliance We may use information to help maintain the safety, security, and integrity of the Services, including to: * detect, investigate, prevent, and deter fraud, unauthorized access, sanctions violations, money laundering, terrorist financing, market abuse, security incidents, spam, malware, or other unlawful or harmful activity; * conduct jurisdiction, sanctions, eligibility, fraud-prevention, tax, and compliance checks; * monitor and verify identity or service access where required or appropriate; * troubleshoot software bugs and operational issues; * enforce our Terms of Use, supplemental terms, and other agreements; * comply with applicable laws, regulations, legal processes, government requests, and regulatory inquiries; and * protect the rights, property, safety, and security of Venzo, users, partners, and the public. ### Research, Analytics, and Product Development We may use information for research, analytics, testing, and product development, including to understand usage trends, improve user experience, develop new features, measure performance, evaluate risk controls, and improve our ability to prevent unlawful or improper use of the Services. ### Communications and Marketing We may use information to send product updates, security notices, rewards communications, campaign information, educational content, event information, and marketing communications where permitted by law. You may opt out of marketing communications, but we may still send operational, legal, compliance, security, and transaction-related notices. ### How We Share and Disclose Information We may share information in the following circumstances: * **With Your Consent or Direction.** We may share information when you direct us to do so or otherwise consent, including when you connect a wallet, use a third-party integration, participate in a campaign, or request a service involving a third party. * **With Service Providers.** We may share information with service providers that support our Services, including cloud hosting providers, analytics providers, customer support vendors, email providers, security and fraud-prevention vendors, sanctions screening and identity verification providers, wallet connection providers, blockchain infrastructure providers, blockchain data providers, payment providers, card providers, fiat on/off-ramp providers, and other operational service providers. * **With Third-Party Services and Partners.** Certain features may involve third-party wallets, blockchains, protocols, vaults, strategy managers, payment providers, card issuers, fiat on/off-ramp providers, identity verification providers, rewards partners, analytics providers, or other third-party services. We may share information with these parties as needed to provide, secure, support, or make available the relevant feature, integration, campaign, reward, or service. * **For Legal, Regulatory, Compliance, and Safety Purposes.** We may share information to comply with applicable laws, regulations, legal processes, subpoenas, court orders, government requests, regulatory inquiries, sanctions rules, anti-money laundering obligations, tax obligations, or other legal requirements. We may also share information where we believe disclosure is necessary or appropriate to prevent harm, detect or prevent unlawful activity, investigate violations of our terms, protect rights or safety, or enforce agreements. * **During a Business Transaction.** If we engage in or consider a merger, acquisition, financing, reorganization, bankruptcy, dissolution, sale of assets, sale of equity, or similar transaction, information may be shared, transferred, or disclosed in connection with that transaction, subject to appropriate confidentiality arrangements where applicable. * **Aggregated, Anonymized, or De-identified Data.** We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. ### Third-Party Services and Public Blockchains The Services may link to, integrate with, or make available third-party wallets, blockchains, protocols, vaults, strategy managers, decentralized exchanges, bridges, oracles, payment providers, card issuers, fiat on/off-ramp providers, identity verification providers, analytics providers, and other third-party services. Venzo is not responsible for the privacy practices, security practices, content, or processing activities of third-party services. Your use of third-party services is subject to their own terms and privacy policies. Blockchain transactions are public by design. Information recorded on public blockchains may be immutable, permanent, and publicly accessible. Even if you request deletion of personal information from Venzo, we may not be able to delete or modify information recorded on public blockchains or maintained by third parties. ### Cookies and Online Tracking We and third parties we authorize may use cookies, pixels, SDKs, local storage, web beacons, and similar technologies to operate the Services, remember preferences, analyze usage, improve performance, prevent fraud, secure the Services, measure campaigns, and provide relevant communications. You may be able to adjust your browser or device settings to refuse or delete cookies. If you do so, some parts of the Services may not function properly. ### Online Tracking Opt-Out Guide There are a number of ways to opt out of certain online tracking activities: * **Blocking cookies in your browser.** Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit [www.allaboutcookies.org](http://www.allaboutcookies.org). * **Blocking advertising ID use in your mobile settings.** Your mobile device settings may allow you to limit use of the advertising ID associated with your device for interest-based advertising. * **Using privacy plug-ins or browsers.** You can use privacy-focused browsers or plug-ins to block certain tracking technologies. * **Platform opt-outs.** Google offers opt-out controls at . * **Advertising industry opt-out tools.** You can also use opt-out options from participating companies, including the Digital Advertising Alliance at and the Network Advertising Initiative at . Because these opt-out mechanisms are often specific to the device or browser on which they are exercised, you may need to opt out on each browser and device you use. ### Data Retention We retain personal information for as long as reasonably necessary to provide the Services, comply with legal, tax, accounting, sanctions, anti-money laundering, fraud-prevention, dispute-resolution, and regulatory obligations, enforce our agreements, resolve disputes, and protect our rights and users. Retention periods may vary depending on the type of information, the purposes for which it is used, and applicable legal requirements. Public blockchain data may remain available indefinitely on public blockchains and is not controlled by Venzo. ### Security We maintain administrative, technical, and organizational safeguards designed to protect the personal information we maintain against unauthorized access, loss, misuse, alteration, or disclosure. However, no system can be completely secure. We cannot guarantee that information transmitted to or through the Services will always remain secure. You are responsible for maintaining the security of your digital wallet, private keys, seed phrases, passwords, devices, and accounts. Venzo will never ask you to provide your private key or seed phrase. ### Your Rights and Choices Depending on your location and applicable law, you may have rights regarding the personal information we collect, use, disclose, and retain about you. These rights may include: * **Right of Access.** You may request information about the personal information we process about you and request a copy of that information. * **Right to Rectification.** You may request that we correct inaccurate or incomplete personal information. * **Right to Erasure or Deletion.** You may request deletion of personal information in certain circumstances. We may continue to retain or process information where permitted or required by law, including for compliance, security, fraud-prevention, dispute-resolution, or legal purposes. We may not be able to delete information recorded on public blockchains or maintained by third parties. * **Right to Restrict Processing.** You may request that we restrict processing of personal information in certain circumstances. * **Right to Data Portability.** You may request a copy of certain personal information in a machine-readable format where required by law. * **Right to Object.** You may object to certain processing of personal information where required by law. * **Right to Withdraw Consent.** Where processing is based on consent, you may withdraw that consent at any time, subject to applicable limitations. * **Right to Complain.** You may have the right to lodge a complaint with a local data protection authority or supervisory authority. To exercise rights available to you, please contact us at the contact email designated by Venzo for legal or support inquiries. We may require additional information from you to verify your identity and process your request. ### Age Limitations To the extent prohibited by applicable law, we do not allow use of the Services by anyone younger than the legal age in the jurisdiction in which the user resides. If you believe that someone younger than the applicable legal age has provided us with personal information, please contact us and we will take appropriate steps as required by applicable law. ### Additional Notice to California Residents The California Consumer Privacy Act, as amended, may require certain businesses to provide California residents with additional information about how they collect, use, disclose, share, or sell personal information and the rights and choices available to California residents. ### Categories of Personal Information Depending on how you use the Services, we may collect the categories of personal information described above, including identifiers, internet or electronic network activity information, commercial or transaction interaction information, geolocation information derived from IP address, professional or employment-related information if provided by you, inferences, and other information you choose to provide. ### Sources of Personal Information We may collect personal information directly from you, automatically through your use of the Services, from public blockchains, from service providers, from partners, from public sources, and from third-party services you use in connection with the Services. ### Business or Commercial Purposes We may use and disclose personal information for the purposes described in this Policy, including to provide and improve the Services, secure the Services, prevent fraud, comply with legal obligations, support users, communicate with users, analyze usage, and manage business operations. ### Sale or Sharing of Personal Information We do not sell personal information for money. Certain analytics or advertising activities may be considered “sharing” or “sale” under some privacy laws. Where required by law, you may opt out of such sharing or sale through available mechanisms that we provide. ### California Privacy Rights California residents may have the right to request access to personal information, request deletion of personal information, request correction of inaccurate personal information, request information about our data practices, opt out of certain sharing or sale of personal information, limit certain uses of sensitive personal information, and exercise these rights free from unlawful discrimination. To submit a request, please contact us at the contact email designated by Venzo for legal or support inquiries. We may need to verify your identity before responding to a request. California residents may designate an authorized agent to submit requests on their behalf, and we may require the authorized agent to provide written authorization confirming their authority. ### Disclosures for European Economic Area, United Kingdom, and Swiss Data Subjects If you are located in the European Economic Area, United Kingdom, or Switzerland, the following additional disclosures may apply. ### Legal Bases for Processing We may process personal information on the following legal bases: 1. you have given consent for one or more specific purposes; 2. processing is necessary to perform a contract with you or take steps at your request before entering into a contract; 3. processing is necessary to comply with a legal obligation; 4. processing is necessary to protect vital interests; 5. processing is necessary for the performance of a task carried out in the public interest, where applicable; and 6. processing is necessary for legitimate interests pursued by us or a third party, provided that your interests and fundamental rights and freedoms do not override those interests. ### European Privacy Rights Your rights may include the right to request access to and a copy of your personal data, request rectification or erasure, object to or restrict processing, request portability, and withdraw consent at any time where processing is based on consent. To exercise these rights, please contact us at the contact email designated by Venzo for legal or support inquiries. We may require additional information to verify your identity and process your request. Please note that we may retain information as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, prevent fraud, enforce agreements, and pursue legitimate interests. We cannot edit or delete information that is recorded on a public blockchain or maintained by third parties outside our control. ### International Transfers We may process and store information in jurisdictions outside your country of residence. These jurisdictions may have data protection laws that differ from those in your jurisdiction. Where required by applicable law, we will use appropriate safeguards for international transfers of personal information. ### Changes to This Policy We may update this Policy from time to time. When we make changes, we will update the “Last Updated” date above. If we make material changes, we may provide additional notice, such as through the Services, by email, through social media channels, or by other reasonable means. Your continued use of the Services after changes become effective constitutes your acceptance of the updated Policy to the extent permitted by applicable law. ### Contact Information If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact us at the contact email designated by Venzo for legal or support inquiries. --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. 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