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Introduction
Conduit Zero Technologies Inc. (“Calm,” the “Company,” “we,” “us,” or “our”) is committed to protecting and respecting your privacy. This Privacy Policy (the “Policy”) explains how Calm collects, uses, and shares data in connection with the Calm web application, websites, deposit and payment orchestration technology, and related software, products, and services (collectively, the “Services”), including where the Services are embedded as a deposit interface within third-party applications and platforms (each, a “Platform”). Your use of the Services is subject to this Policy as well as our Terms of Service. This Policy describes why and how we may collect and use personal information (“Personal Information”) and provides information about individuals’ rights in relation to Personal Information.Personal Information We May Collect
Identity Verification Information
Certain funding methods require identity verification (“KYC”) before you can transact. In connection with verification, we and our Regulated Partners (defined below) may collect your name, date of birth, residential address, phone number, email address, government-issued identification documents, photographs and liveness data, and for certain U.S. flows tax identification information. This information is collected and processed to meet legal and regulatory obligations, including anti-money-laundering and sanctions requirements.Financial and Transaction Information
When you initiate a deposit, we and our Regulated Partners may collect information about your funding source (such as bank account details, card details, or connected exchange account identifiers), deposit amounts, currencies, timestamps, destination addresses, and transaction status. Card details are collected and processed by our payment partners, not stored by Calm.Public Blockchain Data
When you connect a non-custodial blockchain wallet to the Services (including via Privy, Wagmi-compatible wallets, or Dynamic), we may collect and log your publicly available blockchain address to operate the Services and to screen addresses for illicit activity using third-party blockchain analytics providers. Blockchain addresses are publicly available data that are not created or assigned by us and, by themselves, are not personally identifying.Device and Usage Information
We and our third-party service providers may collect information through local storage, cookies, mobile device identifiers, web beacons, and similar technologies to operate, personalize, secure, and improve the Services across sessions.Direct Communications
If you contact us via email, social media, support channels, or community platforms (such as Discord or Telegram), we receive the information you provide. We do not attempt to associate this information with your wallet address unless necessary to respond to your request.Information from Platforms and Business Customers
Where you access the Services through a Platform, we may receive information from that Platform necessary to provide the Services, and business contact information such as name, email, company affiliation, and role.Information from Job Applicants
If you apply for a role with us, we collect the information you provide, including contact details, employment history, immigration status, and any materials submitted with your application.Blockchain Processing Disclaimer
Due to the nature of blockchain networks, certain transaction-related data may be processed and stored on public blockchains outside our control. Calm does not operate or control these blockchains and is not responsible for any Personal Information that may be recorded on them.How We Use Personal Information
We use the information we collect in accordance with our Terms of Service and applicable law, including for the following purposes:- Providing the Services: To operate, maintain, customize, and improve Calm products and features, including initiating, routing, and completing deposits.
- Identity Verification and Compliance: To verify your identity, screen against sanctions and other watchlists, monitor transactions, and meet anti-money-laundering, counter-terrorist-financing, and other legal obligations, together with our Regulated Partners.
- Payment and Settlement Operations: To facilitate deposits through regulated payment, conversion, and settlement providers and to deliver funds to the destination designated in your deposit flow.
- User Support: To respond to inquiries and provide assistance.
- Security and Risk Management: To detect, prevent, and investigate fraud, unauthorized activity, chargebacks, or security incidents.
- Legal and Regulatory Compliance: To comply with applicable laws, regulations, and legal processes.
- Recruitment: To evaluate and communicate with job applicants.
Who We Share Personal Information With
We do not sell your Personal Information and do not share it for marketing purposes. We may share information in the following circumstances:- With Regulated Partners. Payment processing, currency conversion, custody of funds in transit, settlement, and identity verification are performed by regulated third-party providers integrated with the Services (“Regulated Partners”), currently including Bridge (a Stripe company) and Circle. We share Personal Information with Regulated Partners as necessary to verify your identity, complete your deposits, and meet compliance obligations. Regulated Partners process your information under their own privacy policies, which we encourage you to review.
- With employees, contractors, and affiliates of the Company.
- With infrastructure providers, vendors, and service partners that support the Services (such as hosting providers, analytics providers, compliance and identity-verification providers, or communication tools).
- With blockchain analytics and risk intelligence providers to support safety and compliance.
- With the Platform through which you access the Services, as necessary to provide the Services (for example, deposit status).
- With regulators, law enforcement, or governmental authorities where required by law.
- In connection with corporate transactions such as mergers, acquisitions, or asset transfers.
- With third parties where you provide consent.
Bank Transfers
Calm uses financial institutions to process ACH, SEPA, and Faster Payments transfers from your funding source bank account to our Regulated Partners for use of the Services. Information you provide in connection with bank transfers is processed by those institutions under their own terms and privacy policies.Your Rights Regarding Personal Information
Depending on your jurisdiction, you may have the following rights regarding your personal data:- Right to be informed
- Right of access
- Right to rectification
- Right to restriction of processing
- Right to erasure (“right to be forgotten”)
- Right to data portability
- Right to object to processing
- Right to withdraw consent at any time
- Right to lodge a complaint with a supervisory authority