Privacy Policy

Last updated: 13 September 2026 — VirtexPay ("we", "our", or "us") is committed to protecting your personal information and your right to privacy. This Privacy Policy applies to our website, our crypto payment gateway, payouts & off-ramp, debit card services, and the Virtex Wallet mobile application for Android and iOS (collectively, the "Services").

1. Information We Collect

We collect information you provide directly to us when you create an account, use our Services, or contact us for support. This may include:

• Name, email address, and contact information
• Cryptocurrency wallet addresses and public transaction data
• Transaction history and payment data
• Identity verification (KYC) documents, where required by law
• Device and mobile app data — device model, operating system (Android/iOS) and version, app version, language, unique device identifiers, IP address, and crash/diagnostic logs
• Usage data — features used, in-app actions, and performance analytics

We collect only the data needed to operate the Services. Data collected through the Virtex Wallet app is disclosed in the Google Play Data Safety section and the Apple App Store privacy details for the app.

2. The Virtex Wallet Mobile App & Permissions

The Virtex Wallet app for Android and iOS may request the following device permissions. Each is optional where possible, used only for the stated purpose, and you may revoke them at any time in your device settings:

• Camera — to scan QR codes for wallet addresses and payments. Camera images are processed on-device and are not stored or transmitted by us.
• Biometrics / Face ID / Fingerprint — to unlock the app and authorize actions. Biometric data never leaves your device; it is handled by your operating system, and we do not receive or store it.
• Push notifications — to alert you to transactions, security events, and important updates. You can disable these in your device settings.
• Network access — to broadcast transactions, fetch balances, prices, and swap quotes from blockchain networks and our servers.
• Storage / Photos (optional) — only if you choose to save or upload an image (for example, a QR code or a KYC document).
• Clipboard — used only when you explicitly copy or paste a wallet address or seed phrase. We do not monitor your clipboard in the background.

3. Wallet Custody, Private Keys & Seed Phrases

Virtex Wallet offers both custodial and non-custodial modes, and how we handle key material differs between them:

• Non-custodial wallets: your private keys and recovery (seed) phrase are generated and stored locally on your device only. They are never transmitted to, accessible by, or stored on VirtexPay's servers. You are solely responsible for safeguarding and backing up your seed phrase.
• Custodial wallets: we securely manage the associated keys on your behalf using encryption and industry-standard safeguards.

VirtexPay will never ask you for your seed phrase or private keys. Anyone who does is attempting to defraud you. If you lose your seed phrase for a non-custodial wallet, we cannot recover it or your funds.

What we collect in non-custodial mode. Using a non-custodial wallet does not require you to create an account or provide your name or identity verification, and we never receive your keys or recovery phrase. However, to make the wallet work — showing balances and prices, fetching swap quotes, and broadcasting transactions — your device communicates with our servers, which receive technical data such as your IP address, the public wallet address(es) you query, and your transaction and swap requests. We use this data to operate and secure the app, prevent fraud, and for analytics to understand usage and improve the product; your IP address is processed and retained for these analytics and security purposes. In addition, some features are optional and are only processed if you choose to use them: if you link an email address, we process it to contact you; if you enable push notifications, we process a device push token to deliver alerts. We do not sell your data or use it for third-party advertising. Where required by law (for example in the EEA/UK), we will ask for your consent before using analytics, and you can withdraw it or opt out at any time in the app's settings. Note that activity recorded on a public blockchain is, by nature, public and outside our control.

4. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the Services and the Virtex Wallet app
• Process transactions, swaps, and payouts and send related notifications
• Verify your identity and prevent fraud, abuse, and illegal activity
• Comply with legal, regulatory, and anti-money-laundering requirements
• Diagnose crashes, monitor performance, and improve the app experience
• Communicate updates, security alerts, and support messages

We do not use your personal data for advertising profiling, and we do not sell your personal information.

5. Sharing Your Information

We do not sell your personal information. We may share limited data with:

• Third-party service providers that help us operate the platform (e.g., cloud hosting, KYC verification, customer support)
• Analytics and crash-reporting providers used in the mobile app, and push-notification delivery services (e.g., Apple Push Notification service and Firebase Cloud Messaging)
• Payment processors, banking/off-ramp partners, and public blockchain networks necessary to complete your transactions
• Regulatory or law enforcement authorities when legally required

6. Data Security

We implement industry-standard security measures to protect your personal information, including encryption in transit and at rest, secure servers, on-device encryption of sensitive app data, and multilayer authentication. However, no method of transmission or storage is 100% secure and we cannot guarantee absolute security.

7. Data Retention

We retain personal data only for as long as necessary to provide the Services and to meet legal, tax, accounting, and regulatory obligations (for example, KYC and transaction records may be retained for the period required by applicable law). When data is no longer required, we delete or anonymize it.

8. Account & Data Deletion

You can request deletion of your account and associated personal data at any time:

• In the app: open Virtex Wallet and go to Settings → Account → Delete Account.
• On the web (without the app): follow the steps at virtexpay.com/delete-account.
• By email: send a request to [email protected] from your registered email address.

On a verified request we will delete your personal data, except information we are legally required to retain (such as transaction and KYC records held for regulatory compliance), which we will securely retain only for the required period and then delete. For non-custodial wallets, removing the app or deleting your account does not delete funds on the blockchain — assets remain accessible with your seed phrase.

9. Cookies & Analytics

Our website uses cookies and similar technologies to enhance your experience, analyze usage, and serve relevant content; you may control these through your browser. The mobile app does not use website cookies but may use mobile analytics and diagnostic tools to understand usage and improve reliability, as described above.

10. Your Rights

Depending on your jurisdiction, you may have rights including:

• Access to the personal data we hold about you
• Correction of inaccurate data
• Deletion of your personal information (see Section 8)
• Objection to, or restriction of, certain processing activities
• Data portability

To exercise these rights, contact us at [email protected]

11. Age Requirement (18+) & Children's Privacy

The Services, including the Virtex Wallet app, are only for adults aged 18 and over and are not directed to children or minors. This applies to both custodial and non-custodial wallets. By downloading or using the app, you confirm that you are at least 18 years old (or the age of majority in your jurisdiction, if higher). Anyone under 18 must not download, register for, or use Virtex Wallet.

We enforce this requirement as follows:

• App store restrictions: Virtex Wallet's target audience on Google Play is 18 and over, and we have asked Google Play to block users it determines to be minors from finding or downloading the app. On the Apple App Store, the app carries an adult age rating.
• Identity verification: custodial accounts and fiat payouts require identity verification (KYC), which confirms that you are 18 or older.
• Non-custodial wallets: we do not collect your date of birth; access is restricted through the app store age controls above and this policy.

We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal information, please contact us at [email protected] and we will promptly delete it.

12. International Data Transfers

Your information may be processed and stored in countries other than your own. Where we transfer personal data internationally, we take appropriate steps to ensure it is protected in accordance with this policy and applicable law.

13. Third-Party Links & Stores

Our platform may contain links to third-party websites, including subdomain products (virtexgate.virtexpay.com) and payout/banking partners that process crypto-to-fiat off-ramp transactions. The Virtex Wallet app is distributed through the Google Play Store and the Apple App Store, whose own privacy policies and terms apply to your download and use of the app. These third parties have their own privacy practices and we are not responsible for them.

14. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of any significant changes by email, through the app, or via a notice on our platform. Continued use of the Services after changes constitutes your acceptance of the updated policy.

15. Contact

For privacy-related inquiries, or to exercise your data rights, please contact us:
[email protected]