Privacy Policy

This Privacy Policy describes how Anzo Labs, Inc. (“Avvio,” “we,” “us”) collects, uses, discloses, and protects information when you access or use the Avvio application, website, wallet software, card services, virtual accounts, trading, yield features, and related services (collectively, the “Service”). By using Avvio, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We collect information that you provide directly when creating an account, communicating with support, or using regulated financial features. This may include identifiers such as your name, email address, phone number, and information required to satisfy identity verification and compliance obligations imposed by our financial partners. We also automatically collect limited technical information such as device identifiers, IP addresses, app usage data, and log information in order to operate, secure, and improve the Service. Transaction-related metadata, including wallet addresses and transaction hashes, may be processed to display activity and status within the app.

2. Non-Custodial Wallet Data

Avvio is a non-custodial application. We do not collect, store, or have access to your private keys, seed phrases, or signing credentials. Wallets for Bitcoin, Ethereum/EVM chains, and Solana are created and secured using Turnkey’s MPC infrastructure. Avvio cannot initiate transactions, sign messages, or access funds on your behalf.

3. Information From Third Parties

We receive information from the service providers that make the Service work. This includes wallet and authentication data from Turnkey; identity verification results and document review outcomes from our identity verification partners, including Sumsub and Persona; account, payout and virtual account data from our payments partners, including Seismic, Lightspark and Bridge; transaction routing and execution data from OneBalance, LI.FI, Jupiter and Relay; pricing, balance and asset data from market data providers including Zerion and CoinGecko; yield-related data from providers such as Blend and yo.xyz; tokenized stock and real-world asset data from partners such as XStocks; and on-ramp and off-ramp data from providers including MoonPay, Swapped and PayTrie. Section 15 lists our service providers and what each one processes. Additional providers may be integrated from time to time, and each processes data in accordance with its own privacy policy.

4. How We Use Information

Information is used to create and maintain accounts, enable wallet functionality, process swaps and transfers, facilitate card and fiat services, provide customer support, comply with legal obligations, detect fraud, and improve the performance and security of the Service. Avvio does not sell personal information or use it for advertising unrelated to the Service.

5. Blockchain Transparency

Blockchain transactions are inherently public. When you use Avvio to broadcast transactions, the associated wallet addresses and transaction details become permanently visible on public blockchains. Avvio cannot modify, delete, or obscure this information once it is recorded on-chain.

6. Data Sharing

We share information only as necessary with service providers, financial partners, infrastructure vendors, and legal authorities where required by law. Such sharing is limited to what is reasonably necessary to provide the Service, meet regulatory obligations, or protect Avvio, our users, and partners from fraud or security risks.

7. International Data Transfers

Avvio operates globally. Your information may be processed in the United States or other jurisdictions where our service providers operate. We take reasonable measures to ensure appropriate safeguards are in place for cross-border data transfers in accordance with applicable data protection laws.

8. Data Retention

We retain personal information only for as long as necessary to provide the Service, comply with legal and regulatory requirements, resolve disputes, and enforce our agreements. Identity verification records and transaction records support anti-money-laundering obligations that our licensed financial partners and applicable law impose on us, so those records are kept for the period the law requires, measured from the end of your relationship with us and not from the date we collected them. Technical logs and analytics data are kept for shorter periods set by the providers described in Section 15. Upon account deletion we remove personal data from our systems where it is lawful to do so, and keep only what we are required to keep. Public blockchain data such as wallet addresses and transactions remains permanently available and cannot be deleted by us or by anyone else.

9. Security

Avvio implements administrative, technical, and organizational measures designed to protect information against unauthorized access, loss, or misuse. Traffic between you and the Service is encrypted in transit using TLS. Data is encrypted at rest, and sensitive identity fields, such as your tax identification number, phone number and address, are additionally encrypted at the field level under keys held in a managed key service. Access to production systems is limited to personnel with a business need and is reviewed periodically. We are undergoing a SOC 2 audit and maintain a published set of information security policies. Despite these measures, no system is completely secure, and we cannot guarantee absolute security of information transmitted or stored. If you believe you have found a security vulnerability, write to security@avvio.xyz.

10. Your Rights

Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict the processing of your personal information. You may also have the right to object to certain processing activities or request data portability. Requests may be submitted using the contact details below.

11. Age restrictions

Avvio is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal information from individuals under age 18.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page and reflected in the “Last Updated” date above. Continued use of the Service constitutes acceptance of the revised policy.

13. Contact

Anzo Labs, Inc.

General and privacy requests: support@avvio.xyz

Security reports: security@avvio.xyz

https://avvio.xyz

To exercise the rights described in Section 10, write to support@avvio.xyz. We will verify your identity before acting on a request, and we respond within the time limits applicable to your jurisdiction.

14. Lightspark Grid Transaction Services

Certain payout, on-ramp, off-ramp, and related money transmission features in Avvio ("Grid Transaction Services") are provided by Lightspark Payments, LLC ("Lightspark"), a licensed money transmitter, rather than by Anzo Labs, Inc. When you use these features, Lightspark collects, processes, and shares information about you as described in Lightspark's Privacy Policy and End User Terms, which are incorporated into our Terms of Service. Lightspark may share your information with its own service providers and financial partners as reasonably necessary to execute transactions, verify your identity, and comply with applicable law. See our Terms of Service for the full text of Lightspark's End User Terms.

Anzo Labs, Inc. is a financial technology company and not a bank. Fiat services, virtual accounts and card programs are provided by third-party financial institutions and program managers, including Lightspark Payments, LLC, Seismic and Bridge, together with the banks those partners work with. Each is subject to its own privacy policy. Our partners and their banks may change over time, and the current list is in Section 15.

15. Service Providers and Subprocessors

The providers below process personal information on our behalf so that we can operate the Service. We assess each one before we integrate it and review them on a recurring basis. This list is current as of the “Last Updated” date at the top of this page, and we update it when a provider is added or removed.

Most of these providers process information in the United States. Where a provider processes information outside your jurisdiction, the safeguards described in Section 7 apply. Business customers who need a signed data processing agreement or a list scoped to a specific product can request one at support@avvio.xyz.

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