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1.1. Quantum Works LLC, a Wyoming limited liability company with offices at 166 Geary Street, San Francisco, CA 94108 ("Quantum Works," "we," "us"), operates CentryOS, a payment infrastructure product for merchant platforms. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use centryos.xyz, merchants.centryos.xyz, the CentryOS dashboard, and our API, SDKs, widgets, and related services (the "Services").
1.2. It applies to merchants and their representatives, and to the end users of merchant platforms whose information we process in providing the Services. You should read it alongside our Merchant Terms and Conditions.
2.1. Merchants. Business and owner identity information, beneficial owner details, licenses, financial statements, bank account details, credit and background check results, contact details, and the documents we need to verify them.
2.2. End users of merchant platforms. Name, email address, phone number, date of birth, government-issued ID, liveness data, address, payment and account details, wallet addresses, and transaction history.
2.3. Technical information. Browser type, device type, IP address, approximate location, operating system, and usage data about how you interact with the Services.
2.4. Public blockchain data. Digital Asset transactions are recorded on public blockchain networks. That data (wallet addresses, amounts, and timestamps) is public and cannot be altered or deleted by us. Wallet addresses can be linked to a person through identity verification and blockchain analytics, which we apply for compliance.
3.1. We use information to:
3.2. We rely on our contract with you, our legal obligations, and, in limited cases, our legitimate interests, such as fraud prevention and product improvement.
4.1. Each of us is an independent controller of the personal information we collect. We and our Platform Partners retain and use transaction and account data for settlement, disputes, fraud prevention, tax, and regulatory purposes. Where we process data on a merchant's behalf, we do so under a data processing addendum.
4.2. Merchants own their customer relationship and end-user contact data. During the term of our agreement with a merchant and for 24 months after it, we do not use end-user data obtained through that merchant's platform to market to those end users or to offer them services that compete with the merchant's platform.
We do not sell personal information. We share it with:
We keep account, identity, transaction, and support records for at least 5 years, or longer where law requires. After a merchant relationship ends, we keep merchant data available for 60 days and may then delete it, except what we must keep for disputes, taxes, Network Rules, or law.
We maintain a security program appropriate to our role, including encryption of personal information in transit and at rest, need-to-know access controls, and regular security testing, and we comply with PCI DSS to the extent applicable. If we become aware of unauthorized access to personal information, we notify the affected merchant within 72 hours and cooperate on investigation and required notifications. No method of transmission or storage is completely secure. You are responsible for safeguarding your credentials and, for non-custodial wallets, your private keys, which we cannot recover.
Depending on where you live, you may have the right to access, correct, or delete your personal information, and to object to or restrict certain processing. End users may contact the merchant whose platform they use, or contact us. To exercise these rights, contact us using the details in Section 12. We may be unable to delete information we must keep for legal or regulatory reasons, or information recorded on a public blockchain.
We may transfer your information to, and process it in, countries other than your own. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses to protect your information in these transfers.
We use cookies and similar technologies to operate and secure our websites and to understand how they are used. You can control cookies through your browser settings.
The Services are not intended for anyone under 18. We may update this policy from time to time and will give notice of material changes by posting the updated policy on this page and updating the date above.
Quantum Works LLC, a Wyoming limited liability company
166 Geary Street, San Francisco, CA 94108
Quantum Works LLC, a Wyoming limited liability company with offices at 166 Geary Street, San Francisco, CA 94108 ("Quantum Works," "we," "us"), is committed to protecting your privacy. This policy explains how we collect, use, and share information when you use Poket, our digital wallet, whether accessed directly through our app or through a partner business's app that has embedded Poket (see Section 4). This policy applies to anyone interacting with Poket: registered users, prospective users, and merchant/partner contacts.
You should read this policy alongside our End User Terms of Use. We may update this policy from time to time; check back regularly.
Information you give us:
Information we collect automatically:
Information from third parties:
Public blockchain data: Digital Asset transfers are recorded on public blockchain networks. That data (wallet addresses, amounts, and timestamps) is public and cannot be altered or deleted by us or by you. We screen wallet addresses and transactions using blockchain analytics.
Information we do not collect: we do not track or collect sensitive categories such as race, religion, ethnicity, or political opinion.
We use your information to:
We rely on our contract with you, our legal obligations (e.g., AML/KYC law), and, in limited cases, our legitimate interests (e.g., fraud prevention, product improvement) as the basis for these uses. Where we rely on legitimate interests, you may object; contact us and we will consider your request, though there may be legal reasons we need to continue certain processing.
You may access Poket directly through our app, or through a third-party business's app that has integrated Poket as an embedded wallet. In the embedded case, the partner business may see information related to your activity within its own app, but we remain the sole operator of identity verification, screening, geolocation, and transaction monitoring, and independently collect and process the information in this policy regardless of which app you used. The partner business does not receive your verification documents or compliance screening results; those are handled solely by us and our verification providers. The partner business is responsible for its own use of information it collects, under its own privacy policy. We do not use information obtained through a partner's platform to market to you or to offer you services that compete with that partner's platform during our relationship with the partner and for 24 months after it ends.
We determine your location using IP geolocation, VPN/proxy/Tor detection, and device signals (OS location where permitted, timezone, language, carrier). We check your location at every login and at every transaction. If you're in a restricted jurisdiction, you'll be blocked from proceeding, and the attempt is logged.
Cookies are small files created in your browser when you visit our website. We use cookies to operate and personalize our website; we do not use cookies for advertising.
We publish content on social media platforms (e.g., LinkedIn, Twitter/X) through both organic and paid methods. We may place social media "tags" on our website to understand engagement and avoid showing you offers you've already acted on (e.g., removing a signup prompt if you're already a user). We do not have direct access to your personal data on social media platforms.
We and our banking partners retain and use transaction and account data for settlement, disputes, fraud prevention, tax, and regulatory purposes. Each of us acts as an independent controller of the information we collect.
We do not sell your personal information. Where we don't have a legitimate business or legal reason to share your information, we will ask for your consent first.
This policy applies only to our use of data. Our website, app, and Poket Widget may link to or appear within external sites and apps. We are not responsible for the privacy practices of those third parties, and we recommend reviewing their policies directly.
We retain account, transaction, and verification records for at least 5 years, consistent with Bank Secrecy Act recordkeeping requirements, longer than the general "as long as needed for the service" standard that applies to non-compliance data (e.g., customer support records). Logs are retained in an append-only, tamper-evident format and can be exported in response to a valid regulator, partner-bank, or law-enforcement request within 48 hours.
Depending on your jurisdiction (e.g., under GDPR or CCPA), you have the right to ask us for the information we hold about you, and to ask us to correct, delete, or stop processing it. To exercise these rights, contact us with the subject line "Information Access Request" (see Section 15).
Note that full erasure or cessation of processing may not always be possible, for example where we're required to retain records for regulatory compliance (Section 9) or where you remain an active user requiring ongoing service.
We use industry-standard safeguards to protect your information, including hash-chained, tamper-evident logging of account and transaction activity, and we limit access to your information to those bound by confidentiality obligations. If unauthorized access to your personal information affects you, we will notify you as the law requires. No system is completely secure, and we cannot guarantee absolute security.
Poket is not intended for anyone under 18. We verify age at registration (self-attestation), again at first deposit (against your verified government ID), and again at withdrawal. Accounts that fail age verification are blocked.
We may transfer your information to, and process it in, countries other than your own. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses to protect your information in these transfers.
We may update this policy from time to time, including in response to changes in law, regulatory guidance, or our services. Material changes will be communicated to you before they take effect.
Quantum Works LLC, a Wyoming limited liability company
166 Geary Street, San Francisco, CA 94108