Privacy Policy

Effective Date: Dec 1,2025 
*Operated by Chu Ventures, LLC (Texas, USA)

1. Our Commitment to Privacy

Chu Ventures, LLC (“VEX Wallet,” “VEX,” “we,” “us,” or “our”) respects your privacy and is committed to safeguarding your personal information. This Privacy Policy explains how we collect, use, store, and disclose information when you use VEX Wallet, our mobile applications, websites, and related services (“Services”).

By creating a VEX Wallet account or using our Services, you consent to the practices described in this Privacy Policy.

For privacy-related questions, you may contact us at:
📩 hi@vexwallet.co

2. Applicability

This Privacy Policy applies to:

All information collected from individuals who use VEX Wallet Services.

Former users (we continue to protect information after an account is closed).

This policy does not apply to services operated by third parties that VEX Wallet may link to.

VEX Wallet may update this policy periodically. If changes materially affect your rights, we will notify you at least 30 days before they become effective.

3. Information We Collect

We collect only the minimum information necessary to operate a secure payment and conversion platform.
We do not collect:
❌ GPS location
❌ Contacts / phonebook
❌ Selfies
❌ Biometric data
❌ Residential addresses

A. Information You Provide

• Phone number
• Name
• Email address
• Date of birth
• Venezuelan ID (Cédula) or other government ID number
• Bank account information required for transfers
• Crypto wallet addresses, but only for enabling transfers or conversions

B. Information Collected Automatically

• Device information: IP address, OS version, device model, browser type
• Mobile device identifiers
• Push notification tokens (to send security alerts and transactional messages)

C. Analytics

We use PostHog to collect anonymized or pseudonymized analytics about app performance and usage.

D. Transaction Information

When you use VEX, we collect:

• Transfers, conversions, and payment activity
• Time, date, counterparties, amounts
• Internal routing information
• Account activity logs

E. Information From Third Parties

To prevent fraud and comply with KYC/AML requirements, we may obtain data from:

• Banks or financial institutions connected to your transfers
• Public records or identity verification databases
• Payment processors and risk-scoring providers
• Law-enforcement or regulatory agencies, where legally required

4. No Teen Users

VEX Wallet is not intended for users under 18 years of age.
We do not knowingly collect personal information from minors.
If we learn that information from a minor has been collected, we will delete it.

5. How We Use Personal Information

We use your information to:

A. Operate and Improve the Services

• Create and maintain your VEX Wallet account
• Facilitate transfers, conversions, and payments
• Provide customer support
• Send receipts, confirmations, and security alerts
• Perform internal analytics to improve app performance

B. Risk & Compliance

• Verify identity (manual review only)
• Monitor fraud, money laundering, or suspicious activity
• Comply with U.S. federal, state, and international law, including OFAC sanctions rules
• Enforce our Terms of Service

C. Legal & Security

• Detect and prevent unauthorized use
• Investigate and resolve disputes
• Maintain system integrity and platform security

D. Communications

We may send:

• Account-related messages
• Transaction alerts
• Important updates
• Security notifications

We do not send your data to advertisers or marketing networks.

6. Digital Asset Information (Stablecoin-Related Data)

VEX Wallet may process information related to digital transfers or balances, including stablecoins (such as USDT), only to the extent necessary to:

• Enable transfers
• Facilitate conversions
• Prevent fraud
• Maintain compliance

We do not access your private keys and do not require custodial control of your external wallets unless explicitly part of the service flow.

7. How We Disclose Personal Information

We do not sell personal information.
We do not share your data with advertisers or marketing partners.

We may disclose personal information only with:

A. Service Providers

• Entities that help us operate the platform, such as:
• Risk and fraud prevention partners
• Cloud hosting providers
• Payment processors and financial institutions

These providers may access personal information only to perform services on our behalf.

B. Banks and Financial Institutions

When you initiate deposits, withdrawals, or conversions.

C. Legal Compliance

We may disclose information to:

• U.S. or international regulatory agencies
• Law enforcement
• Courts or legal processes
• Only if legally required, including under:
• Subpoenas
• Court orders
• Anti-money laundering regulations
• OFAC sanctions compliance

D. Corporate Transactions

If VEX Wallet is involved in a merger, acquisition, financing, or asset transfer, your data may be shared as part of due diligence, subject to confidentiality protections.

8. Public Information

VEX Wallet does not operate a public social feed.
No part of your profile or transactions is publicly visible.

Only you and the counterparties involved in a transaction may see transaction details.

9. Cookies & Tracking Technologies

If you use our website, we may use cookies to:

• Authenticate sessions
• Prevent fraud
• Measure site performance

We do not use cookies for advertising or tracking across third-party websites.

Your browser may allow you to disable cookies, but doing so may affect functionality.

10. How We Protect Your Data

We use industry-standard security measures, including:

• Encryption in transit (TLS)
• Encryption at rest
• Firewalls
• Access-controlled data systems
• Monitoring and intrusion detection
• Strict staff access controls

Despite our efforts, no system can guarantee absolute security.
If we detect a security breach, we may notify you electronically consistent with applicable law.

11. Data Storage Locations

Your data is stored in:

• Helsinki (European Union)
• United States (Texas or other data centers)

We use secure cloud infrastructure with strict physical and logical controls.

12. Data Retention

We retain personal information only as long as necessary for:

• Providing services
• Legal and regulatory obligations
• Anti-money laundering recordkeeping
• Tax and audit requirements
• Fraud prevention

Financial data is typically retained up to 10 years after account closure, unless law requires longer retention.

13. Your Privacy Rights

Depending on your jurisdiction, you may have rights such as:

• Access your information
• Correct inaccurate information
• Request deletion (subject to regulatory retention limits)
• Request a copy of your data

To exercise rights, contact:
📩 hi@vexwallet.co

14. Third-Party Links

Our Services may contain links to external sites or tools.
We are not responsible for the privacy practices of third-party services.

We encourage you to review their policies independently.

15. Contact Us

For privacy questions or requests:

📧 hi@vexwallet.co

📍 Chu Ventures, LLC
Texas, United States

16. U.S. Consumer Privacy Notice (GLBA-Style)

Why?
Financial companies choose how they share personal information. Federal law gives consumers the right to limit some but not all sharing.

What we collect:

• ID numbers
• Transaction data
• Account balances
• Payment history
• Device information

How we share:
We share information only for:

• Everyday business purposes
• Fraud prevention
• Compliance and risk management
• Processing transfers

We do not share for marketing or advertising.

Can you limit this sharing?
Federal law does not allow you to limit sharing necessary for:

• Everyday business operations
• Anti-fraud
• Compliance
• Transaction processing

We do not share in ways that federal law allows customers to restrict.