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Privacy Policy

Last updated October 12, 2026

1. Who we are

Zxee (“Zxee,” “we,” “us”) operates the Zxee mobile app and the website at https://zxen.app. Zxee is a payments app. The balance you see is USDC on the Base network, held at a wallet address that belongs to your account. We provide the app, the address book, and the connections to the partners who verify identity and move money. We do not hold your USDC in a company account.

This Privacy Policy explains how we collect, use, and share information when you use our services, including when we send SMS one-time verification codes.

Questions: contact@zxen.io.

2. Information we collect

We collect information you provide and information generated when you use Zxee:

  • Account details: mobile phone number, email address, name, and @handle.
  • Authentication data: one-time SMS verification codes, and records that you requested or confirmed those codes. An app PIN or biometric unlock, if you set one, stays on your device. We do not receive it.
  • Profile and discovery information you choose to add, such as an avatar, who can find you by phone, email, or @handle, and — if you grant contact access — phone numbers from your address book, used only to show which contacts already use Zxee.
  • Wallet metadata: your public Base address, saved external addresses, pay-link activity, transfer references, amounts, and timestamps. We do not store your private key or a copy of your USDC balance. The balance is read from the public network.
  • Identity information you submit to get verified: legal name, date of birth, address, place of birth, nationalities, a tax identification number, a photo of your ID, and a liveness check. For bank access we also ask how you earn and use money (source of funds, employment, account purpose, and expected volume).
  • Payment records: whether a purchase, bank deposit, or cash-out is pending or complete, the public transaction id, and a display label for a linked bank (bank name, account-holder name, and last four digits).
  • Device and usage information needed to operate the app and website (for example browser type, app version, push token, and crash diagnostics).

3. Information we do not keep

Some information passes through the app on its way to a partner and is not written to our database:

  • Your tax identification number, including a US Social Security number. It is sent to the verification partner. For a US card or bank purchase it is also sent once to the on-ramp partner. We keep only the fact that it was submitted, not the number.
  • ID photos, the liveness capture, and any proof-of-funds image. The verification and banking partners keep those.
  • Card numbers, Apple Pay credentials, and Google Pay credentials. Those are entered in the on-ramp partner’s own secure screen.
  • Full bank account and routing numbers. Those are sent to the banking partner, or collected by Plaid when you link a bank. We keep the bank name, the account-holder name, and the last four digits so you can recognize the account.

While you are filling out verification, the form stays in memory on your phone. If you leave before submitting, we do not keep a draft of your legal name, address, or tax ID.

4. How we use information

We use this information to:

  • Create and secure your account, including SMS verification.
  • Create your wallet, show your balance, and let you send, receive, and request money.
  • Verify your identity, and share that verification with the partners who buy USDC for you or pay your bank.
  • Link a bank account, accept a bank deposit, and cash out to a bank.
  • Operate public pay links and referral invites you choose to share.
  • Send the notifications you have turned on, and provide support.
  • Protect against fraud, abuse, and unauthorized access.
  • Comply with law and enforce our Terms of Service.

5. SMS and mobile phone numbers

If you opt in, we use your mobile number only to send Zxee Account Verification messages: automated one-time passwords so you can create an account or sign in. Message frequency varies. You typically receive one message each time you create an account or sign in. Message and data rates may apply. Reply HELP for help. Reply STOP to cancel.

You can review the full SMS program terms at our SMS Terms page and opt in at zxen.app/sms.

We do not sell, rent, or share your mobile phone number or SMS opt-in consent with third parties or affiliates for their marketing or promotional use. SMS consent is not shared with anyone except the service providers that deliver the verification messages you requested, and then only to send those messages.

6. Your wallet

After you verify your phone, Privy creates one wallet for your account on Base. The private key is generated and used only inside Privy’s secure key infrastructure (trusted execution environments). It is never sent to your device, to our servers, or to our database. A transfer from your wallet is signed only when it is authorized with your signed-in Zxee session, after you confirm it in the app. Zxee does not hold a signing key for your wallet. Network fees for your sends are paid in USDC from your wallet. Exporting the private key is not available in the app yet.

If you pay or get paid in an asset other than USDC on Base, Fireblocks Flow (provided through Dynamic) routes the conversion through independent swap and bridge providers. Those providers see the transaction they need to complete the route. We record the result. We do not hold the assets while they are in transit.

7. Identity verification

You complete one identity form in the app. Three partners then make their own decisions. We store the outcome (approved, in review, or rejected) and, for bank access, the compliance answers described above. We do not store the documents.

  • Sumsub reviews your ID and liveness check. Sumsub is where the tax ID, ID photos, and liveness capture are kept. Sumsub approval is what lets you use verified features in the app.
  • Transak buys USDC for you with a bank transfer, card, Apple Pay, or Google Pay. Transak relies on the Sumsub check through a short-lived share token. Transak does not receive a copy of your documents from us. A US Social Security number, when required, is sent directly to Transak and is not saved by Zxee.
  • Bridge reviews the same identity on its own before you can link a bank or cash out. We send Bridge the identity fields, the ID photos, and the compliance answers. Bridge’s approval is separate from Sumsub’s. Being verified in the app does not by itself mean Bridge has approved a bank withdrawal.

8. Banks, cards, and cash

Buying USDC and cashing out are done by partners. Zxee shows the status. We do not take the fiat, and we do not hold the USDC during a purchase or a cash-out.

  • Card, Apple Pay, and Google Pay purchases are handled by Transak inside their own payment screen. Transak takes the payment and sends USDC to your wallet address.
  • Bank deposits in USD or EUR are handled by Bridge. We show you Bridge’s deposit details (for example a routing number and account number, or an IBAN) so you can pay them. Those details belong to Bridge, not to your personal bank login.
  • Linking a US bank uses Plaid, or a form you fill in by hand. Plaid collects the bank login. We receive a linked-account reference and the display label (bank name and last four). Cash-out sends USDC from your wallet to a Bridge-controlled address, and Bridge pays your bank. From the moment that USDC arrives until the bank payment settles, Bridge holds it.
  • In the EEA, a one-time euro payment can be confirmed in your bank app through Plaid. If that cannot start, we show Bridge’s IBAN and reference instead.

9. Service providers

We use vendors to operate Zxee. They receive only what their part of the service requires. They may not use your SMS opt-in to market their own products to you.

  • Supabase — account login, database, and file storage for avatars.
  • Privy — your wallet: key management and transaction signing, and notices of funds moving in or out of it.
  • Dynamic — cross-chain payments and conversions (Fireblocks Flow).
  • Sumsub — identity documents and the liveness check.
  • Transak — card, Apple Pay, Google Pay, and bank-transfer purchases of USDC.
  • Bridge — bank deposits, bank linking, and cash-out to your bank.
  • Plaid — connecting a US bank, or starting a euro payment in the EEA.
  • Our SMS delivery provider — the verification texts you requested.

A public pay link can be paid by someone who does not have a Zxee account. In that case we receive the payment details needed to deliver USDC to the address on the link. We do not create a wallet for that payer.

10. Blockchain data

Transfers you make on public networks, including Base, are recorded on a public ledger. Wallet addresses, amounts, and transaction details on those networks are visible to anyone. Zxee does not control that record once a transaction is broadcast, and it cannot be deleted from the network.

11. Retention

We keep account, verification-status, and payment records for as long as your account is active and as needed to provide the service, resolve disputes, and meet legal obligations. Identity documents stay with Sumsub and Bridge under their own retention rules. If you reply STOP, we retain enough information to honor that opt-out and to show that we received your request.

12. Your choices

You may update profile details in the app, choose whether people can find you by phone, email, or @handle. You may request deletion of your account by emailing contact@zxen.io. Deleting the account removes our records of it. It does not remove transactions already written to a public blockchain, or documents a verification partner is required to keep. You can stop SMS messages by replying STOP. Opting out of SMS may prevent you from signing in until you opt in again or use another supported verification method.

13. Children

Zxee is not directed to children under 18, and we do not knowingly collect personal information from them. Identity verification also requires you to be at least 18.

14. Changes

We may update this policy from time to time. The “Last updated” date at the top of this page will change when we do. Continued use of Zxee after an update means you acknowledge the revised policy.