Privacy Policy

Version 1.0.0  |  Effective: February 4, 2026

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Fluxa (hereinafter referred to as "we" or "us") values your privacy and data protection. This Privacy Policy explains how we collect, use, disclose, and protect your personal data, as well as the rights you have under applicable laws.

1. Scope

This Privacy Policy applies to:

• Accessing or using the Fluxa platform website, APIs, and services
• Registering as a developer or using AI Agents as an end user

This Policy does not apply to the processing of your data by AI Agents independently provided by third-party developers.

2. Data Roles

2.1 Fluxa's Role

In most cases, Fluxa acts as:

• Data Controller: For platform account, billing, compliance, and website operation data
• Data Processor: When processing end user data on behalf of developers (e.g., API transmission, compute operations)

2.2 Developer's Role

Developers are independent data controllers for end user data collected and processed by their AI Agents.

Developers must provide their own privacy policies to end users and fulfill legal obligations.

3. Personal Data We Collect

3.1 Data You Provide

• Name, email, contact information
• Account registration information
• Identity verification materials (KYC / KYB)
• Wallet addresses, transaction identifiers

3.2 Automatically Collected Data

• IP address, device information, logs
• API call records, usage data
• Cookies and similar technologies

3.3 Blockchain Data

• Public chain addresses
• Transaction hashes (Tx Hash)
• On-chain timestamps

Blockchain data is public and immutable; Fluxa cannot delete or modify on-chain data.

4. Purposes of Processing

We may process personal data for the following purposes:

• Providing and maintaining platform services
• Identity verification and compliance checks (AML / CTF)
• Billing, settlement, and risk control
• Security, fraud prevention, and abuse detection
• Legal obligations and regulatory requirements
• Product improvement and operational analysis

5. Legal Basis (GDPR)

Under GDPR, we process data based on the following legal grounds:

• Contract performance (Article 6(1)(b))
• Legal obligation (Article 6(1)(c))
• Legitimate interests (Article 6(1)(f))
• User consent (Article 6(1)(a), where applicable)

6. Data Sharing

We may share data in the following circumstances:

• With cloud services, compliance, payment, and audit service providers
• To comply with legal, court, or regulatory requirements
• To prevent fraud, security issues, or abuse
• With your explicit consent in other circumstances

We do not sell your personal data.

7. International Transfers

Your data may be transferred and stored in jurisdictions outside your country or region.

We will take reasonable measures (such as Standard Contractual Clauses - SCCs) to ensure adequate data protection.

8. Data Retention

We retain personal data only for the period necessary to achieve processing purposes or fulfill legal obligations.

To the extent permitted by law, data will be deleted or anonymized.

9. Data Security

We implement reasonable technical and organizational measures to protect personal data, including:

• Access controls
• Encryption
• Audit and monitoring

However, please understand that no system is absolutely secure.

10. Your Rights

10.1 GDPR User Rights

If you are located in the EU/EEA, you have the right to:

• Access, correct, or delete personal data
• Restrict or object to processing
• Data portability
• Withdraw consent
• Lodge a complaint with a supervisory authority

10.2 CCPA / CPRA User Rights (California)

If you are a California resident, you have the right to:

• Know
• Delete
• Correct
• Limit use of sensitive personal information
• Non-discrimination

Fluxa does not sell or share personal data for advertising purposes.

11. Cookies

We may use Cookies and similar technologies for:

• Website functionality
• Security
• Analytics and experience improvement

You can manage Cookies through your browser settings.

12. Children's Privacy

Fluxa does not provide services to users under 18 years of age.

If we discover that children's data has been mistakenly collected, we will delete it promptly.

13. Third-Party Links and Services

The platform may contain third-party links.

We are not responsible for the privacy practices of third parties.

14. Updates

We may update this Privacy Policy from time to time.

Updates become effective upon posting on the platform.

15. Contact

If you have any questions about this Privacy Policy or data processing, please contact us through the contact information published on the platform.