Privacy Policy

NETWORK CLEARING LLC

1. Introduction

1.1 Our Commitment to Privacy

Network Clearing LLC ("Network Clearing," "we," "us," "our") respects your privacy and is committed to protecting your personal information.

This Privacy Policy describes:

What information we collect about you
How we use your information
When and with whom we share your information
How we protect your information
Your rights and choices regarding your information
How to contact us with privacy questions

1.2 Scope

This Privacy Policy applies to:

Our website and mobile applications
Money services provided by Network Clearing LLC
Virtual USD account services
Digital asset custody and conversion services
Payment card services
Foreign exchange services
Domestic and international funds transfer services
All related services and communications

1.3 Acceptance

By using our services, creating an account, or providing us with your information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

1.4 Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons. We will notify you of material changes by:

Posting the updated policy on our website with a new "Last Updated" date
Sending notice to your registered email address
Displaying a notice on our Platform

Your continued use of our services after changes become effective constitutes your acceptance of the updated Privacy Policy.

2. Information We Collect

2.1 Information You Provide to Us

We collect information you provide directly to us, including:

2.1.1 Account Registration Information

Full legal name
Date of birth
Gender
Nationality and citizenship
Country of residence
Email address
Phone number
Mailing address
Tax identification number or equivalent
Employment information (occupation, employer name)
For entities: legal name, registration number, formation documents, beneficial owners, authorized representatives

2.1.2 Identity Verification Information

Government-issued identification documents (passport, national ID, driver's license)
Proof of address documents (utility bills, bank statements)
Photographs or biometric information (facial recognition)
Video verification recordings

2.1.3 Financial Information

Bank account details (account numbers, routing numbers, IBAN, SWIFT/BIC codes)
Payment card information (card numbers, expiration dates, CVV)
Cryptocurrency wallet addresses
Source of funds and source of wealth information
Financial statements, tax returns, or other financial documentation
Income, net worth, assets, and liabilities

2.1.4 Transaction Information

Details of deposits, withdrawals, transfers, and conversions
Payment instructions and beneficiary information
Blockchain transaction hashes and addresses

2.1.5 Communication Information

Customer support inquiries and correspondence
Feedback, reviews, or survey responses
Messages sent through our Platform
Phone call recordings (with your consent where required)

2.1.6 Profile and Preference Information

Communication preferences
Language preferences
Profile settings and customizations

2.2 Information We Collect Automatically

When you use our services, we automatically collect certain information:

2.2.1 Device and Usage Information

Device type, model, and operating system
Browser type and version
IP address and geolocation data
Device identifiers (UDID, advertising ID)
Mobile network information
Time zone and language settings

2.2.2 Platform Usage Information

Pages viewed and features used
Time spent on pages or features
Click paths and navigation patterns
Search queries
Login dates and times
Session duration and frequency

2.2.3 Cookies and Tracking Technologies

Cookies (small text files stored on your device)
Web beacons and pixel tags
Local storage objects
Session replay data

For more information about cookies, please see our Cookies Policy.

2.3 Information from Third Parties

We may collect information about you from third parties, including:

2.3.1 Identity Verification Services

Background checks and identity verification services
Credit bureaus or credit reporting agencies
Sanctions lists and watchlists
Politically Exposed Person (PEP) databases
Adverse media screening services

2.3.2 Blockchain and Public Sources

Publicly available blockchain transaction data
Wallet address activity and balances
Public records and business registries
Social media profiles (if you link them)

2.3.3 Service Providers

Payment processors
Partner Financial Institutions
Market data providers
Analytics providers

2.3.4 Partners

Partner Financial Institutions with whom we provide integrated services
Business partners with whom we offer co-branded services

2.4 Inferences and Derived Information

We may create inferences or derived data based on the information we collect, including:

Risk profiles and scores
Behavior analysis and predictions
Suitability assessments

3. How We Use Your Information

3.1 Service Delivery

We use your information to provide, operate, and maintain our services, including:

Opening and managing your account
Verifying your identity and eligibility
Processing transactions and transfers
Providing custody and safekeeping of assets
Calculating and collecting fees
Providing customer support
Communicating with you about your account and transactions
Generating account statements and tax documents

3.2 Compliance and Legal Obligations

We use your information to comply with legal and regulatory requirements, including:

Anti-money laundering (AML) and know-your-customer (KYC) compliance
Sanctions screening and monitoring
Suspicious activity detection and reporting
Tax reporting and withholding
Responding to legal process (subpoenas, court orders)
Regulatory reporting and audits
Record-keeping requirements

3.3 Risk Management and Security

We use your information to protect our services and users, including:

Detecting and preventing fraud, money laundering, and illegal activity
Monitoring transactions for suspicious patterns
Verifying the authenticity of transactions
Preventing unauthorized access
Investigating security incidents
Enforcing our terms and conditions
Recovering debts or resolving disputes

3.4 Product Development and Improvement

We use your information to improve and develop our services, including:

Analyzing usage patterns and trends
Improving Platform features and functionality
Developing new products or services
Conducting research and data analysis
Testing and quality assurance

3.5 Marketing and Communications

With your consent where required, we use your information to:

Send promotional offers and product announcements
Provide personalized recommendations
Conduct market research and surveys
Inform you of events or educational content

You may opt out of marketing communications at any time by following the unsubscribe instructions in emails or updating your preferences in your account settings.

3.6 Corporate Transactions

We may use your information in connection with:

Mergers, acquisitions, or sales of assets
Financing or investment transactions
Corporate restructuring
Due diligence processes

3.7 Legal Purposes

We may use your information for legal purposes, including:

Establishing, exercising, or defending legal claims
Protecting our rights and property
Enforcing agreements
Complying with court orders or legal obligations

4. How We Share Your Information

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

Identity verification and KYC providers
Payment processors and correspondent banks
Partner Financial Institutions
Technology infrastructure providers (cloud hosting, data centers)
Customer support platforms
Analytics and data processing services
Marketing and communication platforms
Legal, accounting, and auditing services

Service providers are contractually required to protect your information and use it only for the purposes we specify.

4.2 Regulatory Authorities and Law Enforcement

We may disclose information to:

Regulatory authorities supervising our activities
Law enforcement agencies investigating crimes
Tax authorities for tax reporting and compliance
Government agencies pursuant to legal obligations
Courts or tribunals in response to legal process

We disclose only the information required by law or legal process.

4.3 Fraud Prevention and Security

We may share information with:

Fraud prevention services and databases
Cybersecurity providers
Other financial institutions to prevent and detect fraud

4.4 Blockchain Networks

When you conduct transactions involving Digital Assets:

Transaction details are publicly visible on the blockchain, including transaction amounts, sender and recipient addresses, and timestamps
While addresses are pseudonymous, it may be possible to link them to your identity
We have no control over blockchain transparency or data visibility

4.5 Business Transfers

If we are involved in a merger, acquisition, sale of assets, bankruptcy, or other corporate transaction:

We may transfer your information to the successor entity
Your information may be disclosed during due diligence
The successor entity will be bound by this Privacy Policy (or will notify you of changes)

4.6 With Your Consent

We may share your information with third parties when you provide express consent, such as:

Linking your account to third-party services
Participating in co-branded offers or partnerships
Authorizing specific disclosures

4.7 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that does not identify you personally, including:

Statistical information about Platform usage
Market research data
Industry reports and analysis

4.8 No Sale of Personal Information

We do not sell your personal information to third parties for their marketing purposes.

5. International Data Transfers

5.1 Global Operations

Our operations may involve international data transfers, and your information may be transferred to, stored in, and processed in countries other than your country of residence, including:

The United States
Countries where our service providers are located
Countries where our servers or data centers are located
Countries where our partners operate

5.2 Data Protection Standards

We implement appropriate safeguards to protect your information during international transfers, including:

Standard contractual clauses
Data processing agreements with service providers
Security measures and encryption
Compliance with applicable data protection laws

5.3 Consent to Transfer

By using our services, you consent to the transfer of your information to countries that may have different data protection laws than your country of residence. Some countries may not provide the same level of data protection as your home country. We take reasonable steps to ensure your information receives adequate protection wherever it is processed.

6. Data Security

6.1 Security Measures

We implement industry-standard security measures to protect your information, including:

Encryption: Data is encrypted in transit (TLS/SSL) and at rest
Access Controls: Restricted access to information on a need-to-know basis
Multi-Factor Authentication: Required for account access and sensitive operations
Firewalls and Network Security: Protection against unauthorized access
Monitoring and Logging: Continuous monitoring for security incidents
Regular Security Audits: Periodic assessments and penetration testing
Employee Training: Security awareness and data protection training
Incident Response Plan: Procedures for detecting and responding to breaches

6.2 Your Responsibilities

You play a critical role in protecting your information:

Use strong, unique passwords for your account
Enable multi-factor authentication when available
Keep your login credentials confidential and do not share them
Be vigilant against phishing and social engineering attacks
Monitor your account regularly for unauthorized activity
Report suspicious activity to us immediately

6.3 No Absolute Security

No security system is impenetrable. Despite our efforts, we cannot guarantee absolute security of your information. You acknowledge and accept the risk of unauthorized access, data breaches, or other security incidents.

6.4 Data Breach Notification

In the event of a data breach that compromises your information, we will:

Investigate the breach and take remedial action
Notify affected individuals as required by applicable law
Notify relevant regulatory authorities if required
Provide information about the breach and steps you can take to protect yourself

7. Data Retention

7.1 Retention Period

We retain your information for as long as:

Your account is active
Necessary to provide services to you
Required by law or regulation (typically 7+ years for financial records)
Necessary for legitimate business purposes (compliance, dispute resolution, enforcement)

7.2 Deletion After Retention Period

After the retention period expires, we will:

Securely delete or anonymize your information
Destroy physical records
Remove your information from active systems

Some information may be retained in backup systems for a limited period before permanent deletion.

7.3 Legal Holds

If your information is subject to legal proceedings, investigations, or disputes, we may retain it beyond the standard retention period until the matter is resolved.

8. Your Rights and Choices

8.1 Access to Your Information

You have the right to:

Access your personal information we hold
Request a copy of your information in a portable format
Verify the accuracy of your information

To request access, contact us at privacy@networkclearing.us.

8.2 Correction and Updates

You have the right to:

Correct inaccurate information
Update outdated information
Complete incomplete information

You can update most information directly in your account settings. For other changes, contact us at privacy@networkclearing.us.

8.3 Deletion Requests

You may request deletion of your information, subject to:

Legal retention requirements: We cannot delete information we are required to retain by law
Ongoing obligations: We cannot delete information necessary for open transactions or obligations
Legitimate business purposes: We may retain information for fraud prevention, dispute resolution, or legal compliance

To request deletion, close your account and contact us at privacy@networkclearing.us.

8.4 Objection and Restriction

You may object to or request restriction of certain processing activities, such as:

Marketing communications (you may opt out at any time)
Automated decision-making (if applicable and to the extent permitted by law)
Certain data processing activities (subject to legal or contractual requirements)

To exercise these rights, contact us at privacy@networkclearing.us.

8.5 Marketing Opt-Out

You may opt out of marketing communications by:

Clicking "unsubscribe" in marketing emails
Updating your communication preferences in your account settings
Contacting us at privacy@networkclearing.us

Note: Even if you opt out of marketing, we will still send transactional and account-related communications.

8.6 Cookie Choices

You can control cookies through your browser settings. See our Cookies Policy for details.

8.7 Limitations on Your Rights

Your rights may be limited by:

Legal or regulatory obligations that require us to retain or process information
Overriding legitimate business interests
The rights and freedoms of others
Technical feasibility

8.8 Response Timeframe

We will respond to your requests within a reasonable timeframe, typically within 30 days. If we need more time, we will notify you of the delay.

8.9 Verification

To protect your privacy, we will verify your identity before fulfilling requests. We may request additional information or documentation to confirm your identity.

8.10 No Fee

We do not charge a fee for processing requests, except in cases of excessive or repetitive requests, in which case we may charge a reasonable administrative fee.

9. Children's Privacy

9.1 Age Restrictions

Our services are not directed to individuals under the age of 18 (or the age of majority in their jurisdiction). We do not knowingly collect information from minors. If you are under 18, do not use our services or provide any information to us.

9.2 Parental Notice

If we become aware that we have collected information from a minor without proper consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@networkclearing.us.

10. Third-Party Links and Services

10.1 External Websites

Our Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party sites. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party sites you visit.

10.2 Third-Party Services

If you link your account to third-party services (e.g., social media, external wallets, analytics tools), those third parties may collect information about you. Review the privacy policies of third-party services to understand their data practices.

11. Do Not Track Signals

11.1 DNT Disclosure

Some browsers support "Do Not Track" (DNT) signals. Our Platform does not currently respond to DNT signals, as there is no industry consensus on how to handle them.

11.2 Cookie Controls

You can control cookies through your browser settings or by using cookie management tools. See our Cookies Policy for more information.

12. Automated Decision-Making

12.1 Use of Automated Systems

We may use automated systems and algorithms to:

Assess your risk profile
Detect fraud or suspicious activity
Determine suitability for certain products
Personalize your experience
Make account decisions

12.2 Human Review

Significant decisions (such as account closure or denial of services) involving automated processing may be subject to human review.

12.3 Right to Object

If you are subject to automated decision-making with significant effects, you may have the right to:

Request human intervention
Express your point of view
Contest the decision

Contact us at privacy@networkclearing.us to exercise this right.

13. US-Specific Provisions

13.1 US Money Services

For money services provided by Network Clearing LLC:

Your payment information is protected in accordance with US federal and state law
We comply with the Gramm-Leach-Bliley Act (GLBA) privacy requirements
We share information as necessary for payment processing and compliance
Payment records are retained for at least 7 years

13.2 State Privacy Rights

Residents of certain US states (California, Virginia, Colorado, Connecticut, Utah) may have additional privacy rights under state law. Please see our State-Specific Privacy Notice for details.

14. Complaints and Dispute Resolution

14.1 Privacy Concerns

If you have concerns about our privacy practices, please contact us at privacy@networkclearing.us. We will investigate and respond promptly.

14.2 Regulatory Authority

If you are not satisfied with our response, you may have the right to lodge a complaint with:

The Consumer Financial Protection Bureau (CFPB): www.consumerfinance.gov
Your state attorney general's office
The data protection authority in your jurisdiction (if applicable)

14.3 Dispute Resolution

Privacy disputes are subject to the dispute resolution provisions in our Terms and Conditions.

15. Contact Us

15.1 Privacy Officer

For privacy-related questions, requests, or concerns, contact our Privacy Officer:

Network Clearing LLC
Attn: Privacy Officer
1001 S Main St Suite 600
Kalispell, MT 59901
Email: privacy@networkclearing.us

15.2 Response Time

We will respond to privacy inquiries within 30 days. If we need additional time, we will notify you.

16. Changes to This Privacy Policy

16.1 Updates

We may update this Privacy Policy from time to time. We will notify you of material changes by:

Posting the updated policy with a new "Last Updated" date
Sending email notification
Displaying a notice on our Platform

16.2 Review

We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.

16.3 Continued Use

Your continued use of our services after changes become effective constitutes your acceptance of the updated Privacy Policy.

17. Additional Information

17.1 Language

This Privacy Policy is written in English. Translations are provided for convenience only. In case of inconsistency, the English version prevails.

17.2 Entire Agreement

This Privacy Policy, together with our Terms and Conditions and other applicable policies, constitutes the complete agreement regarding privacy.

17.3 Jurisdiction-Specific Provisions

Depending on your location, additional privacy rights or disclosures may apply. We will provide supplemental information as required by local law.

Acknowledgment

By using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

Last Updated: February 20, 2026
Version: 2.0