Last Updated: Mar 10, 2026

This Privacy Notice explains how ANDX USA LLC and its affiliates collect, use, disclose, and otherwise process information in connection with your access to and use of ANDX Pay and any related website, mobile application, interface, content, features, tools, and functionality made available in connection with ANDX Pay.

ANDX Pay is a digital wallet product made available by ANDX USA LLC. As of the date of this Privacy Notice, ANDX Pay supports only USDC on the Base network.

This Privacy Notice is intended to describe our data practices in a clear and transparent manner. By accessing or using ANDX Pay, you acknowledge that your information may be processed as described in this Privacy Notice, subject in each case to applicable law.

1. Scope of this Privacy Notice

This Privacy Notice applies to information we collect or process in connection with ANDX Pay, including when you access or use the ANDX Pay application, website, interfaces, or related services, communicate with us regarding ANDX Pay, or otherwise interact with us in connection with the product.

This Privacy Notice does not govern the privacy practices of third parties that are not owned or controlled by ANDX USA LLC. Where ANDX Pay enables access to or interaction with third-party services, websites, applications, infrastructure providers, payment providers, merchants, analytics providers, or blockchain protocols, those third parties may apply their own terms and privacy notices to your information and activities.

2. Categories of Information We May Collect

We may collect or process information that you provide directly, information generated through your use of ANDX Pay, information obtained from your device or browser, information derived from blockchain activity, and information received from service providers, business partners, or other third parties where permitted by law.

The categories of information we may collect or process include identification and contact information, such as your name, email address, phone number, username, or similar account-related details where applicable.

We may collect transactional and wallet-related information, including wallet addresses, transaction hashes, blockchain network information, asset type, transaction status, timestamps, recipient and sender address information, and other information associated with blockchain activity relating to your use of ANDX Pay.

We may collect device, usage, and technical information, including IP address, device identifiers, browser type, operating system, app version, language settings, time zone, access dates and times, crash data, diagnostic information, and information regarding how you interact with ANDX Pay.

We may collect communications information, including records of correspondence, support requests, inquiries, complaints, and other communications you send to us or that we send to you in connection with ANDX Pay.

We may collect compliance and risk-related information where necessary or appropriate, including information used to investigate fraud, abuse, suspicious activity, sanctions concerns, security incidents, misuse of the service, or other legal, regulatory, or operational risks.

We may also collect information from cookies, software development kits, log files, pixels, or similar technologies used for security, authentication, analytics, functionality, and service improvement, subject to applicable law.

3. Public Blockchain Data

You acknowledge that blockchain networks are public or otherwise transparent by design. Transactions carried out using USDC on the Base network may be recorded on a public blockchain and may be visible to others.

As a result, wallet addresses, transaction history, recipient and sender addresses, timestamps, transaction amounts, and related blockchain metadata may be accessible to third parties and may be linked, analyzed, or attributed by others, including through blockchain analytics tools.

ANDX USA LLC does not control how third parties may use publicly available blockchain data and cannot delete or alter information recorded on a blockchain.

4. How We Use Information

We may use information we collect or process in order to provide, operate, maintain, support, secure, and improve ANDX Pay and related functionality.

We may use information to authenticate users, enable access to the service, maintain product functionality, troubleshoot issues, monitor performance, detect bugs, conduct internal analytics, and improve the usability, reliability, and security of ANDX Pay.

We may use information to communicate with you regarding ANDX Pay, including to respond to inquiries, provide customer support, send service-related notices, deliver product updates, and provide legal, technical, administrative, or operational communications.

We may use information to protect ANDX Pay, our users, our business, and third parties, including by detecting, preventing, investigating, and responding to fraud, abuse, suspicious activity, sanctions concerns, cyber incidents, unauthorized access, technical misuse, and other conduct that may violate applicable law or our terms.

We may use information to comply with applicable law, regulation, legal process, court order, governmental request, audit requirement, reporting obligation, or internal compliance and risk management procedures.

We may use information to enforce our Terms of Use, establish or exercise legal rights, defend claims, resolve disputes, and otherwise protect the rights, safety, property, and legitimate interests of ANDX USA LLC, its affiliates, users, and others.

We may also use information for any other purpose disclosed to you at the time of collection or otherwise permitted by applicable law.

5. Legal Bases for Processing

Where applicable law requires a legal basis for processing personal data, we may process such data where necessary to provide ANDX Pay and perform our contractual relationship with you, where necessary to comply with legal obligations, where necessary for our legitimate interests or the legitimate interests of others, provided such interests are not overridden by applicable legal requirements, or where you have provided consent to the extent consent is required under applicable law.

Our legitimate interests may include operating and improving ANDX Pay, maintaining platform integrity, securing our systems, communicating with users, preventing fraud and abuse, conducting analytics, enforcing our terms, and managing legal, compliance, and business risks.

6. How We Disclose Information

We may disclose information to our affiliates and corporate group members where reasonably necessary for the operation, support, administration, security, compliance, or improvement of ANDX Pay.

We may disclose information to vendors, contractors, cloud providers, analytics providers, communications providers, customer support providers, security providers, compliance providers, and other service providers that process information on our behalf and subject to appropriate contractual or legal safeguards.

We may disclose information where necessary or appropriate to comply with applicable law, regulation, subpoena, court order, governmental request, law enforcement request, regulatory inquiry, audit, or legal process.

We may disclose information where we believe in good faith that such disclosure is necessary to detect, investigate, prevent, or respond to fraud, security incidents, sanctions concerns, unlawful conduct, technical abuse, violations of our Terms of Use, or threats to the rights, property, or safety of any person or entity.

We may disclose information in connection with an actual or proposed merger, acquisition, financing, asset sale, corporate reorganization, bankruptcy, dissolution, or similar business transaction, subject to applicable legal requirements.

We may also disclose information with your direction or consent, or as otherwise permitted by applicable law.

7. Cookies and Similar Technologies

We and our service providers may use cookies, local storage, pixels, software development kits, log files, and similar technologies in connection with ANDX Pay for purposes such as authentication, security, fraud prevention, performance monitoring, analytics, remembering preferences, maintaining session integrity, and improving product functionality.

Depending on applicable law and your location, you may have choices regarding certain cookies or similar technologies. Certain technologies may, however, be necessary for ANDX Pay to function properly and cannot be disabled without impairing the service.

8. Data Retention

We retain information for as long as reasonably necessary for the purposes described in this Privacy Notice, including to provide ANDX Pay, comply with legal and regulatory obligations, maintain security, resolve disputes, enforce our agreements, prevent fraud and abuse, and protect our legitimate business interests.

Retention periods may vary depending on the nature of the information, the context in which it was collected, the sensitivity of the information, the risk associated with deletion, and applicable legal, regulatory, accounting, tax, audit, or recordkeeping requirements.

Because blockchain data may be public and immutable, certain information relating to on-chain activity may remain publicly accessible indefinitely.

9. Data Security

We implement reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no system, network, device, or method of transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security, and you acknowledge that you provide information and use ANDX Pay at your own risk.

You are also responsible for maintaining the security of your own devices, credentials, authentication methods, wallet access methods, and related materials.

10. International Data Transfers

Your information may be processed, stored, or accessed in jurisdictions other than the jurisdiction in which you reside. Those jurisdictions may have data protection laws that differ from the laws of your jurisdiction.

Where required by applicable law, ANDX USA LLC will take appropriate measures designed to provide an adequate level of protection for personal data transferred across borders.

11. Children’s Privacy

ANDX Pay is not directed to children, and we do not knowingly collect personal information directly from children where doing so is prohibited by applicable law.

If we become aware that we have collected personal information from a child in violation of applicable law, we may take steps to delete such information or otherwise address the matter in accordance with applicable legal requirements.

12. Your Rights and Choices

Depending on your jurisdiction and subject to applicable law, you may have the right to request access to personal data we hold about you, request correction of inaccurate personal data, request deletion of personal data, request restriction of processing, object to certain processing, request portability of personal data, or withdraw consent where processing is based on consent.

You may also have the right to appeal a decision relating to your privacy request or to lodge a complaint with a competent data protection authority, depending on your jurisdiction.

These rights are not absolute and may be limited by applicable law, including where retention or processing is necessary to comply with legal obligations, complete a transaction, detect or prevent fraud, protect security, exercise or defend legal claims, or otherwise maintain lawful operations.

To exercise any applicable rights, you may contact us using the contact details provided below. We may request information necessary to verify your identity and process your request.

13. Third-Party Links and Services

ANDX Pay may contain links to, integrations with, or functionality involving third-party websites, applications, merchants, payment providers, smart contracts, protocols, infrastructure services, or other external services.

We are not responsible for the privacy, security, content, or practices of such third parties. Your interactions with such third parties are governed by their own terms, notices, and practices, not this Privacy Notice.

14. Changes to this Privacy Notice

We may amend this Privacy Notice from time to time. The updated version will become effective when made available, unless a different effective date is stated.

Your continued access to or use of ANDX Pay after an updated Privacy Notice becomes effective constitutes your acknowledgment of the revised Privacy Notice to the extent permitted by applicable law.