Privacy Policy
USX Privacy Policy
(the “Privacy Policy”)
Last updated: Oct. 6th, 2025
ZK (BVI) Limited is an entity incorporated in the British Virgin Islands. Together with all its affiliates and subsidiaries (collectively referred to as the “Company”, “we”, “us” or “our”), it provides access to a set of decentralized smart contracts available through https://usx.capital (the “Website”). Through the Website, it provides users access to a set of decentralized smart contracts available on the Scroll blockchain that, amongst other functionalities (the “Protocol”), allow users to, via a third-party wallet application (e.g., Metamask) (i) mint USX, a USD pegged stablecoin at a 1:1 ratio per USD deposited (“USX”), (ii) mint sUSX, a staked version of USX that accrues benefits, and (iii) burn any of these tokens in order to regain an equivalent amount of USDC. Documentation relevant to the Website and the Protocol are available at https://docs.usx.capital (the “Documentation”).
This Privacy Policy should be read in conjunction with the USX Terms of Use, available https://docs.usx.capital.
This Privacy Policy outlines how the Company intends to collect, use and disclose personal information concerning you, when you:
Access the Website and Protocol;
Create an account to access the Website and/or Protocol; and
Engage with us in any other way in relation to the use of and access to the Website and/or Protocol.
Please ensure that you have read this page carefully. By continuing to access and use the Website and the Protocol, you agree and acknowledge that you shall be bound by this Privacy Policy. Please cease your use of the Website and the Protocol if you do not agree with this Privacy Policy, whether in part or in whole.
If you have any questions, please contact us at legal@usx.capital.
1. What is Personal Information?
Personal Information refers to any information that relates to an individual that can be used to identify them or contact them. This may include, but is not limited to a person’s:
Email address;
Phone number;
Address, state, province, ZIP/Postal code, city, country;
Usage data such as their IP address and device you use to access the Websites.
2. What kind of personal information does the Company collect?
The categories of personal information we collect depend on how you interact with us, our Website and Protocol, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Website and/or the Protocol and information from other sources such as third-party services and organizations, as described below.
Below, we present a table that outlines the personal information the application uses and the purposes for processing that information.
Account Information
Your selected username, display name and profile image (if you choose to upload one)
We process this information in order to identify your account, and to facilitate, execute, and manage the transactions you request. We also process this information in order to allow other users to search for your profile by your username, to perform functions such as sending you tokens.
Wallet Information
Wallet private key and public wallet address.
Please note that wallet information is stored locally on your device under your custody.
We process your Wallet Information and Transaction Information to facilitate, execute, and manage the transactions you request.
Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party.
Transaction Information
Historical information about the transactions you have made on the public blockchain.
This includes but is not limited to timestamps, public wallet address, transaction amounts, balances and transaction history.
We process this in order to improve your user experience, by allowing you to keep track of your past transactions.
Our legal basis for this processing is that it is necessary to fulfill our legitimate interests in improving our services and enhancing user experience.
Device and Usage Information
Device model, operating system, app installation information, browser type and language setting.
We use your Device and Usage Information to deliver and enhance our services, ensuring you have a better user experience.
Our legal basis for this processing is that it is necessary to fulfill our legitimate interests in improving our services and enhancing user experience.
Contact Information
Information you choose to provide during your interaction with us on our website such as email address.
We process your contact information in order to communicate with you, only when necessary, in relation to customer support and assistance matters.
Our legal basis for this processing is that it is essential for the performance of a contract of which you are a party.
Device Usage Information
Device model, operating system, internet connectivity data such as browser type, application version, time zone and language setting.
* Please note that the IP address is used only on a transient basis, cannot be linked to any user’s personal data, and is not retained.
The IP address’s sole purpose is to facilitate traffic and service redirection in compliance with regulatory requirements based on the visitor’s country. We neither store nor access the IP address
We use your Device and Usage Information to deliver and enhance our services, ensuring you have a better user experience.
Our legal basis for this processing is that it is necessary to fulfill our legitimate interests in improving our services and enhancing user experience.
3. Do you use Cookies?
Yes, we use cookies and pixel tags. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Site that collects information about engagement on our Site. We, as well as third parties that provide content, advertising, or other functionality on our Site, may use cookies, pixel tags, and other technologies to automatically collect information through your use of our Website.
4. Do you share user data with third parties, and if so, how?
We share user data with third parties, but only for a limited set of purposes. This includes key business purposes, including to provide our services and Website to you, to protect ourselves or others under law, or in the event of a major business transaction. Personal data will only be disclosed when we have a legal basis to do so. Please also note that third-parties may collect your data, in accordance with their own terms of service, for the purpose of providing their services.
4.1 Disclosures to Provide our Products and Services
Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of products and services. This includes service providers and vendors that provide us with IT support, hosting, and related services.
KYC/AML and other Legal Obligations. Additionally, a Service Provider may use your personal data where it is necessary for compliance with a legal obligation to which it is directly subject. The Service Provider, in respect of this specific use of personal data acts as a data controller.
Affiliates. We may share your personal information with our affiliates.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Site to collect information regarding your activities and your device (for example, your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising”, “targeted advertising,” “personalized advertising, or cross-context behavioral advertising.”
Security and Performance Service Providers. We collect performance and crash metrics, as well as logs relating to performance issues. We may also collect data relating to in-app user behavior leading up to such performance issues.
4.2 Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal, tax or regulatory process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
4.3 Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law.
5. How are international data transfers handled?
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may not offer equivalent protection of personal data under the applicable laws. We will ensure that your personal data is processed in accordance with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us at legal@usx.capital.
6. How long do we retain your personal data for?
We store the personal information we collect as described in this Privacy Policy for as long as you use our Website or Protocol (as applicable), or as necessary to fulfil the purpose(s) for which it was collected, provide the products and services on our Website or Protocol, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
7. What rights do I have in relation to my personal data?
You have certain rights regarding how we use personal information, include the right to:
Be informed about the purposes for which your Personal Information are processed;
Access Personal Information we hold about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
Request correction of your personal information where it is inaccurate or incomplete;
Request deletion of your personal information in certain circumstances;
Request to opt out of certain processing activities, including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
Request reconsideration where decisions producing legal effects concerning you, or otherwise affect you are based solely on automated processing (i.e. without human involvement);
Request to be informed in the event of a personal data breach, unless the breach is unlikely to be prejudicial to you;
Request certain restrictions or object to our processing of your information; and
Withdraw your consent to our processing of your personal information. (However, please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal).
8. Do we collect personal information from minors?
We do not knowingly solicit data from or market to children under 18 years of age. By using the Website and the Protocol, you represent that you are at least 18 years of age. If we learn that you are less than 18 years of age and that we have collected your personal information, we will deactivate your account and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from children under age 18, please contact us at legal@usx.capital.
9. What if changes are made to this Privacy Policy?
We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Site after the new Privacy Policy takes effect.
10. Do citizens of certain countries have certain additional rights?
Yes - please see below for a non-exhaustive list of certain jurisdictions.
IF YOU ARE RESIDENT IN CALIFORNIA:
You have a right to knowledge, access, correction, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale or sharing of their personal information by a business, and a right not to be discriminated against for exercising their California privacy rights. We do not sell or share the personal information of California consumers, as those terms are defined under California law, and do not discriminate in response to privacy rights requests. We also do not use or disclose sensitive personal information for any purposes that would require a user to exercise a right to limit according to California law.
IF YOU ARE A DATA SUBJECT IN THE UK OR EU:
We process your data in relation for the purposes highlighted in Parts 2, 3 and 4 of this Privacy Policy.
We process your data in reliance on the following legal bases under Article 6 of the GDPR:
If you have given your consent for one or more specific purposes which we process your data for;
If the provision of your personal data is necessary for the performance of an agreement with us and/or for any pre-contractual obligations;
If the processing is necessary for us to comply with any legal obligations to which we are subject to;
If the processing is necessary in order to protect your vital interests;
If the processing if related to a task that is carried out in the interests of the public; or in the exercise of any official authority vested in us;
If the processing is necessary for any legitimate interest pursued by us with any other third party.
You are entitled to the following rights. You may:
Withdraw your consent to your personal data being processed at any time.
Object to your data being processed, if the processing is being carried out on a legal basis other than consent.
Access your data and request a portable copy of it.
Verify and seek to correct the accuracy of your data.
Restrict the processing of your data.
Ask for your personal data to be deleted or removed.
Lodge a complaint to the competent data protection authority in your jurisdiction, in the event that you feel any of your data protection rights have been breached.
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