Privacy Policy

Last updated: April 24, 2026

This Privacy Policy explains how Zula LLC, operating as Zula LLC ("Zula", "we", "us", "our"), collects, uses, and shares personal information when you use our websites, applications, and services (the "Services"). It applies to information collected through our Services and through interactions with our team.

1. Information we collect

Information you provide

• Account information — name, email address, password, country of residence, and other account details.
• Identity verification (KYC) information — government-issued identification documents, date of birth, address, and similar information used to verify your identity.
• Transaction information — details of digital asset transfers you initiate, including amounts, counterparty addresses, and timestamps.
• Communications — content of messages you send to our support and compliance teams.

Information collected automatically

• Device and log data — IP address, browser type, operating system, referring URLs, and access times.
• Cookies and similar technologies — used to operate the Services, remember preferences, and analyze usage.

Information from third parties

• Identity-verification, sanctions, and fraud-prevention providers
• Public blockchain data related to wallet addresses associated with your account
• Banking partners, where applicable

2. How we use information

• To open, maintain, and service your account
• To verify your identity and screen for fraud, sanctions, and money-laundering risks
• To process digital asset transfers you instruct
• To comply with legal and regulatory obligations, including the Bank Secrecy Act
• To provide customer support and respond to inquiries
• To improve, secure, and develop the Services
• To send service-related notices and, where permitted, marketing communications you can opt out of

3. Legal bases for processing

Where applicable law requires, we process personal information based on (i) the performance of a contract with you, (ii) compliance with legal obligations, (iii) our legitimate interests in operating and protecting the Services, and (iv) your consent where required.

4. How we share information

• Service providers — identity-verification, fraud-prevention, hosting, analytics, and customer-support vendors that act on our behalf.
• Banking and blockchain partners — where required to execute transactions you have requested.
• Regulatory and law-enforcement authorities — where required by law, court order, or to protect our rights or others' safety.
• Corporate transactions — in connection with a merger, acquisition, financing, or sale of business assets.

We do not sell personal information.

5. Data retention

We retain personal information for as long as necessary to provide the Services and to meet our legal, accounting, and reporting obligations. KYC and transaction records are retained in accordance with applicable U.S. recordkeeping requirements (generally, at least five years after account closure).

6. Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. No method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

7. Your rights and choices

Depending on your jurisdiction, you may have rights to access, correct, delete, or restrict our processing of your personal information, to data portability, and to withdraw consent. To exercise these rights, contact admin@zulallc.com. We may need to verify your identity before completing your request and may decline requests where required or permitted by law (for example, where retention is required for AML compliance).

8. International transfers

We are based in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the United States, where data-protection laws may differ from those in your jurisdiction.

9. Children

The Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children.

10. Changes to this Policy

We may update this Privacy Policy from time to time. The "Last updated" date will reflect the most recent revision. We will notify you of material changes where required by law.

11. Contact us

For privacy questions or requests, contact admin@zulallc.com or write to Zula LLC, 15035 Military Rd S, SeaTac, WA 98188, United States.