Locus

The clause allows indefinite, perpetual, or necessity-based retention.

“We retain information as long as necessary to provide the Service, comply with our legal and regulatory obligations, resolve disputes, and enforce agreements. Specific retention practices include: (a) blockchain transaction data is immutable and permanently public on-chain; (b) wallets, agents, policy groups, and contacts are soft-deleted (data retained with deletion flag); (c) escrow wallets expire after a config...”

The clause provides a deletion or time-bounded retention path.

“We retain information as long as necessary to provide the Service, comply with our legal and regulatory obligations, resolve disputes, and enforce agreements. Specific retention practices include: (a) blockchain transaction data is immutable and permanently public on-chain; (b) wallets, agents, policy groups, and contacts are soft-deleted (data retained with deletion flag); (c) escrow wallets expire after a config...”

The clause permits sale of personal data or information.

“(not a substitute for the full policy) We collect information you provide, information collected automatically, and information from third parties (e.g., OFAC sanctions screening providers, transaction partners, blockchain infrastructure providers). We use data to operate the Service, enable payments through our partners, conduct OFAC sanctions screening, manage risk and fraud, comply with law, provide support, an...”

The clause permits sale of personal data or information.

“Embedded Wallet Platforms: Third-party platforms may embed Locus wallet infrastructure into their products. When you use Locus functionality through such platforms, we share transaction data, wallet information, and user identifiers with the embedding platform as necessary to provide the integrated service. Affiliates: Within our corporate group for operations and support consistent with this Policy. Legal, Safety...”

The clause permits sale of personal data or information.

“Categories Collected: Identifiers; commercial information; internet/network activity; geolocation (approximate, inferred from IP); inferences (e.g., risk scores). Sources & Uses: As described above. Disclosures for Business Purposes: To service providers, transaction counterparties and affiliates. Sale/Sharing: We do not sell personal information. We do not engage in "sharing" for cross-context behavioral advertis...”

Latest stance: third party or vendor sharing on privacy data use

“This Privacy Policy (the "Policy" ) explains how Locus Technologies Inc. , a Delaware corporation, and its affiliates (collectively, "Locus," "we," "us," or "our" ) collect, use, disclose, store, and otherwise process information when you ( "you" or "your" ) use our services, including our websites: https://paywithlocus.com , https://beta.paywithlocus.com , https://app.paywithlocus.com , and https://buildwithlocus.com as well as any other websites associated with Locus from time to time (collectively, the "Site" ), our applications, dashboards, software development kits, including the Locus Agent SDK ( "SDKs" ), and application programming interfaces ( "APIs" ) (together the "Platform" ), and related technologies (collectively, the "Service" ). By using the Service, you agree to the practices described here. If you do not agree, do not use the Service. The Service is intended for business and developer users only. You may not use the Service for personal, family, or household purposes.”

Latest stance: sale or sell on data retention

“(not a substitute for the full policy) We collect information you provide, information collected automatically, and information from third parties (e.g., OFAC sanctions screening providers, transaction partners, blockchain infrastructure providers). We use data to operate the Service, enable payments through our partners, conduct OFAC sanctions screening, manage risk and fraud, comply with law, provide support, and improve our products (including via deidentified/aggregated data). We share data with service providers (e.g., blockchain infrastructure providers, cloud hosting, communications providers), with your direction, to comply with law, and in business transfers. We do not sell personal information. You may have rights to access, correct, delete, or opt out of certain processing depending on where you live. See Your Rights & Choices .”

Latest stance: third party or vendor sharing on data retention

“(not a substitute for the full policy) We collect information you provide, information collected automatically, and information from third parties (e.g., OFAC sanctions screening providers, transaction partners, blockchain infrastructure providers). We use data to operate the Service, enable payments through our partners, conduct OFAC sanctions screening, manage risk and fraud, comply with law, provide support, and improve our products (including via deidentified/aggregated data). We share data with service providers (e.g., blockchain infrastructure providers, cloud hosting, communications providers), with your direction, to comply with law, and in business transfers. We do not sell personal information. You may have rights to access, correct, delete, or opt out of certain processing depending on where you live. See Your Rights & Choices .”

Latest stance: third party or vendor sharing on training use

“We may share information as follows: Service Providers / Sub-Processors: Vendors who host, process, or support the Service, including: AWS (cloud infrastructure, authentication via Cognito, key management via KMS, job scheduling), Cloudflare (CDN and file proxy), SendGrid (transactional email), Twilio (SMS notifications), Google Analytics (analytics), and Basis Theory (PCI-DSS Level 1 card tokenization vault). These parties are bound by contractual obligations to protect your data. Pay-Per-Use API Providers: When you use our Wrapped API proxy service, we forward your request data to third-party API providers and store both request and response payloads in our database. We provide access to over 40 third-party APIs across categories including providers such as OpenAI, Anthropic, Google Gemini, Mistral AI, Perplexity, Brave Search, Firecrawl, Deepgram, Stability AI, DeepL and others for AI, search, data enrichment, and productivity Services. The ownership of prompts you submit and outputs generated is governed by the applicable upstream provider's terms of service. Locus does not claim ownership of your prompts or AI-generated outputs. However, our storage of request and response payloads is subject to this Privacy Policy. Each upstream provider has its own privacy policy and terms governing how they process the data we send them on your behalf, intellectual property rights, training data usage and content policies.”

Latest stance: sale or sell on privacy data use

“Embedded Wallet Platforms: Third-party platforms may embed Locus wallet infrastructure into their products. When you use Locus functionality through such platforms, we share transaction data, wallet information, and user identifiers with the embedding platform as necessary to provide the integrated service. Affiliates: Within our corporate group for operations and support consistent with this Policy. Legal, Safety & Compliance: To comply with law, regulation, legal process, or governmental request; to enforce our terms; to protect the rights, property, or safety of Locus, our Users, or the public. Business Transfers: In connection with a merger, acquisition, financing, restructuring, or sale of assets; your data may be transferred as part of that transaction. With Your Direction or Consent. No Sale of Personal Information: We do not sell personal information. If we ever engage in activities that qualify as "sharing" for cross-context behavioral advertising under applicable law, we will provide a method to opt out (including honoring Global Privacy Control ( "GPC" ) signals where required).”

Latest stance: sale or sell on commercial use

“Categories Collected: Identifiers; commercial information; internet/network activity; geolocation (approximate, inferred from IP); inferences (e.g., risk scores). Sources & Uses: As described above. Disclosures for Business Purposes: To service providers, transaction counterparties and affiliates. Sale/Sharing: We do not sell personal information. We do not engage in "sharing" for cross-context behavioral advertising or "targeted advertising" unless expressly stated in the Service. If we introduce such activities, we will provide a clear in-product method to opt out (including GPC signal recognition). Retention: See Section 6. Non-Discrimination: We will not discriminate against you for exercising your rights.”

Latest stance: third party or vendor sharing on privacy data use

“We use or disclose sensitive personal information for the following statutorily approved reasons ( "Permitted SPI Purposes" ): Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect. Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information. Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at us. Ensuring physical safety. Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not disclose the sensitive personal information to another third party or use it to build a profile about you or otherwise alter your experience outside your current interaction with us. Services performed for us, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services. Activities required to verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled. Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer. We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.”

Latest stance: sale or sell on privacy data use

“We have not disclosed consumers' personal information to third parties for a business purpose in the preceding 12 months beyond what is described in Section 4 of this Policy. We may disclose the personal information we collect to service providers and contractors for the business purposes described in the "How We Use Information" section, such as to support our business functions. We do not sell your personal information to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.”