Legal

Privacy Policy

BCS Global Holdings, Inc. — Delaware C-CorpLast Updated: March 31, 2026

Introduction

BCS Global Holdings, Inc. ("BCS," "we," "us," or "our") is a technology company that provides a non-custodial software platform (the "Platform") enabling users to access and interact with services offered by independent third-party providers. BCS is fully non-custodial — we do not request, store, or have access to your private keys, seed phrases, or wallet balances beyond publicly available on-chain data. BCS acts solely as a technological conduit and does not offer, hold, or transmit funds, crypto-assets, or provide any financial, custodial, or regulated services.

This Privacy Policy describes how we collect, use, share, and protect your information when you use the Platform. By using the Platform, you agree to the collection, use, and sharing of your information as described in this Privacy Policy.

1. Information We Collect

1.1 Information You Provide

We collect the following categories of information that you provide directly:

• Identity Information: full legal name, date of birth, Social Security Number or ITIN, government-issued photo identification, and proof of address.

• Contact Information: email address, phone number, and mailing address.

• Card Usage Data: transaction history, card load and spend activity, and merchant information, as shared with us by our Card Partners.

• Communications: support tickets, feedback, and correspondence with BCS.

1.2 Information Collected Automatically

We automatically collect:

• Device Information: device type, operating system, browser type, and unique device identifiers.

• Usage Data: pages viewed, features used, interaction patterns, and time spent on the Platform.

• Location Data: IP address and approximate geographic location. We do not collect precise GPS location data.

• Blockchain Data: publicly available blockchain transaction data associated with wallet addresses you connect to the Platform. Blockchain transactions are recorded on public, decentralized ledgers and are inherently transparent. BCS does not control and cannot delete on-chain data.

1.3 Information We Do Not Collect

BCS does not collect, store, or have access to: your private keys or seed phrases; your wallet balances (except as visible on public blockchains); DeFi Protocol position details beyond what is publicly available on-chain; or card account numbers, which are held by the Card Partners.

1.4 Biometric Data

If you use our identity verification process, our third-party identity verification provider may collect biometric identifiers or biometric information (such as facial geometry derived from a selfie compared against your government-issued ID) solely for the purpose of verifying your identity. This biometric data is collected, used, and stored by our third-party verification provider in accordance with its own privacy policy and applicable law, including the Illinois Biometric Information Privacy Act (740 ILCS 14) where applicable. BCS does not directly collect, store, or possess biometric data. Our verification provider retains biometric data only for the period necessary to fulfill the verification purpose and in no event longer than three (3) years from your last interaction, or as required by applicable law, whichever is shorter.

1.5 Cookies and Tracking Technologies

We use cookies and similar technologies (pixels, web beacons, local storage) to: maintain your session and authentication; remember your preferences; analyze Platform usage and performance; and detect and prevent fraud. You can control cookies through your browser settings. Disabling certain cookies may limit your ability to use some Platform features. We do not respond to Do Not Track (DNT) browser signals at this time. We do not use third-party advertising cookies.

2. How We Use Your Information

We use your information to: provide, maintain, and improve the Platform; verify your identity and comply with KYC/AML requirements; process transactions and send related communications; detect and prevent fraud, money laundering, and other prohibited activities; comply with legal obligations, including applicable tax reporting requirements; respond to your requests and provide customer support; send you service updates and promotional communications (with opt-out option); and conduct analytics and improve user experience.

2.1 Automated Decision-Making

We use automated systems to make certain decisions about your account and transactions, including: transaction authorization and decline decisions based on risk parameters; fraud detection and suspicious activity monitoring; identity verification scoring; and eligibility determinations. These automated decisions may affect your ability to use certain Platform features or complete transactions. You may request human review of any automated decision that significantly affects you by contacting us.

3. How We Share Your Information

We do not sell, trade, or rent your personal information. We may share your information with the following categories of recipients:

• Card Partners: our card program manager and their issuing bank partners, to facilitate card issuance, transaction processing, and compliance with card network rules.

• Wallet Infrastructure Provider: our non-custodial wallet infrastructure provider, to facilitate wallet creation and management. The Wallet Provider does not have access to your private keys.

• Identity Verification Providers: third-party providers that perform KYC/AML verification on behalf of BCS or our Card Partners.

• Blockchain Analytics Providers: third-party providers that monitor for prohibited activities and compliance with applicable sanctions requirements.

• DeFi Protocols: when you interact with DeFi Protocols through the Platform, your wallet address and transaction data are transmitted to the Protocol's smart contracts on public blockchains. BCS does not control the data practices of autonomous smart contract protocols.

• Government Authorities: government agencies, law enforcement, or regulators when required by law, subpoena, or court order.

• Service Providers: cloud hosting, analytics, and customer support providers, under data processing agreements that restrict the use of your information to the services they provide to us.

• Corporate Transactions: in connection with a merger, acquisition, or sale of assets, with notice to you as required by applicable law.

4. Data Retention

We retain your personal information for as long as your account is active and for a minimum of five (5) years after account closure, as required by applicable anti-money laundering laws and regulations and our obligations to Card Partners subject to the Bank Secrecy Act. Transaction records are retained for a minimum of five (5) years. We may retain anonymized, de-identified data indefinitely for analytics purposes. You may request deletion of your personal information subject to our legal retention obligations.

5. Data Security

We implement industry-standard security measures including encryption in transit and at rest, access controls, regular security assessments, and employee security training. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

5.1 Data Breach Notification

In the event of a data breach that compromises your personal information, we will notify you and applicable regulatory authorities as required by applicable state and federal law, including but not limited to the notification requirements of your state of residence. Notifications will include the information required by applicable law.

6. Your Rights

6.1 All Users

You may request access to, correction of, or deletion of your personal information by contacting us at privacy@bitcoincredit.services. We will respond within thirty (30) days. We may be required to retain certain information for legal and compliance purposes, in which case we will inform you of the specific retention requirement.

6.2 State Privacy Rights

Depending on your state of residence, you may have additional rights under applicable state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA/CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), Texas Data Privacy and Security Act (TDPSA), and other state privacy laws. To the extent any such law applies to our processing of your personal information, you may have rights that include: the right to know what personal information we collect, use, and share; the right to request deletion of your personal data (subject to legal retention requirements); the right to correct inaccurate personal data; the right to opt out of the sale or sharing of personal data (we do not sell your data); the right to data portability; the right to appeal a denial of a privacy request; and the right not to be discriminated against for exercising your privacy rights. To exercise any of these rights, contact us at privacy@bitcoincredit.services.

7. International Data Transfers

Your information is processed and stored in the United States. If you access the Platform from outside the United States, your information will be transferred to and processed in the United States, which may have different data protection laws than your country of residence. By using the Platform, you consent to the transfer of your information to the United States.

8. Children

The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we learn that we have collected personal information from an individual under 18, we will take steps to delete the information as soon as possible.

9. Changes to This Policy

We may update this Privacy Policy from time to time. For material changes, we will provide advance notice as required by applicable law via email, in-app notification, or by posting the revised Privacy Policy on the Platform with a revised 'Last Updated' date. For changes required by law or regulation, we may make changes effective immediately. Your continued use of the Platform after the effective date constitutes acceptance of the revised Privacy Policy.

10. Contact Information

If you have questions about this Privacy Policy or wish to exercise your privacy rights, you may contact us at:

BCS Global Holdings, Inc.

Email: privacy@bitcoincredit.services

Website: https://bitcoincredit.services