# STORE PRIVACY POLICY

**Version 3.0 · Effective September 28, 2026 · Published at storecloud.org/privacy**

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## THE SHORT VERSION (not part of the policy)

- We collect what we need to run STORE, verify identity where the law
  requires, and keep honest records.
- We never sell your personal information, and never use it for advertising
  that follows you across other sites.
- Your identity documents never go on a blockchain. What goes on chain is
  fingerprints: proof something happened, not who you are or what it says.
- Receipts are public so anyone can audit STORE: they show amounts and
  country, never your name or contact details.
- Member votes are private. Governor votes are public.
- You can see, correct, download, and delete your data, except records the law
  or a blockchain makes permanent.

---

## 1. WHO IS RESPONSIBLE

1.1 **STORE Research Inc.**, a Delaware corporation, 440 N Barranca Ave #9117,
Covina, CA 91723, is responsible for your personal information (the
"controller"). Contact: privacy@storecloud.org.

1.2 If the planned STORE Association in Switzerland takes over some Services,
it will become responsible for the related data. We will tell you before that
happens.

## 2. WHAT THIS POLICY COVERS

storecloud.org, the STORE Protocol, and the STORE apps (STORE Pay, STORE Send,
Account, Govern, Holdings, Jobs, Activity), plus our emails and support.

## 3. WHAT WE COLLECT

| Category | Examples | Source |
|---|---|---|
| **Account** | Display name, email, username, account type, organization name | You |
| **Identity (MID1)** | Legal name, date of birth, country, verification result and reference. Your ID document images and selfie are collected and held by Persona, our identity provider; we receive the result | You, via Persona |
| **Eligibility** | Reg D or Reg S status, evidence reference, who approved it, when | You, our review |
| **Organizations** | Organization details and its owners of 10% or more | You |
| **Signing records** | Agreement version and fingerprint, typed name, consent to sign electronically, email-code confirmation, time, device, network (IP) address | You, our systems |
| **Payments** | Amounts, payment method, wallet addresses, wire sender name and reference; for cards, only what the processor returns (for example the last four digits) | You, Circle, card processor, banks |
| **Holdings and ledger** | Credits, tokens, grants, rewards, receipts, statements | Our systems |
| **Wallets** | Saved wallet addresses and their verification | You |
| **Governance** | Ballots you took part in; for governor votes, your choice; for member votes, only that you voted (your choice is stored privately and never made public) | You |
| **Other people's emails you give us** | Recipients of email Drops, requests, invoices, invited accountants | You |
| **Support and feedback** | Messages, tester reports | You |
| **Device and usage** | Browser, device, IP address, pages used, errors, security events | Our systems |
| **Cookies** | See section 12 | Our systems |

We do not knowingly collect special categories of data (such as health or
religion) and ask you not to send them.

## 4. HOW WE USE IT, AND WHY WE ARE ALLOWED TO

| Use | Legal basis |
|---|---|
| Create and run your account; provide the Services you ask for | Contract |
| Verify identity and eligibility; screen against sanctions; prevent fraud and money laundering | Legal obligation; legitimate interests |
| Record and prove signatures and transactions (Trust Receipts, Signature Receipts) | Contract; legal obligation |
| Approve purchases, including automatic approval (section 11) | Contract; legal obligation |
| Process payments and automatic returns of failed payments | Contract |
| Deliver email Drops, requests, and invitations to the people you name | Contract (with you); legitimate interests |
| Run governance ballots | Contract; legitimate interests |
| Statements, tax summaries, and records the law requires | Legal obligation |
| Security, reliability, and fixing problems | Legitimate interests |
| Improving STORE from usage (measured in aggregate where possible) | Legitimate interests; consent where required |
| Service emails (receipts, reminders, notices) | Contract |
| News and updates | Consent (you can opt out any time) |

## 5. WHAT GOES ON A PUBLIC BLOCKCHAIN

5.1 STORE records **fingerprints** on a public blockchain: signatures on
agreements, governor votes, and receipts you choose to anchor. A fingerprint
proves that a record existed unchanged; it does not reveal the record.

5.2 **Never on chain:** your ID documents, your legal name, your email, your
member vote choice, or your card details.

5.3 After launch, STORE token transfers to and from wallets are recorded on a
public blockchain, as with any token.

5.4 Anything on a public blockchain is permanent. We cannot delete it, even if
you ask. That is why we keep personal details off it.

5.5 **Public receipts.** STORE is publicly auditable. Every transaction has a
public Trust Receipt that anyone can open and verify. It shows the transaction
type, time, status, **amounts**, and the **country** of the account, along with
the checks passed and the on-chain proof. It never shows your name, email,
address, identity documents, wallet details beyond what is on chain, or
anything you wrote in a survey or form.

## 6. WHO WE SHARE IT WITH

6.1 **We never sell your personal information** and never share it for
cross-site advertising.

6.2 **Service providers,** only as needed, under contract: Persona (identity),
Circle (USDC), our card processor, BitGo (custody), our banks (wires), email
delivery (for example Postmark), hosting and security providers. A current
list is available on request at privacy@storecloud.org.

6.3 **Other users, as you direct:** for example a person you send a Drop to sees
your display name; a payer sees a "recently changed" notice on a username.

6.4 **The law:** when required by valid legal process, or to protect people from
harm, we disclose what is required and, where allowed, tell you.

6.5 **The STORE Association:** if it takes over Services (section 1.2).

6.6 **A business transfer:** if STORE is merged or sold, under this policy.

## 7. INTERNATIONAL TRANSFERS

We process data in the United States and may in Switzerland and the EU. For
transfers from the EU, UK, or Switzerland we use recognized safeguards such as
standard contractual clauses.

## 8. HOW LONG WE KEEP IT

| Data | Kept for |
|---|---|
| Account data (not on chain) | Until you close your account, then deleted within 90 days, except as below |
| Identity and eligibility records | As long as the law requires after the relationship ends (typically 5 to 10 years) |
| Signed agreements and signing records | For the life of the agreement plus the legal retention period |
| Transaction and tax records | As long as tax and financial law requires (typically 7 to 10 years) |
| Recipient emails for unclaimed Drops | Until the Drop is claimed, cancelled, or returned, plus 90 days |
| Device and security logs | Up to 12 months, longer if needed for an investigation |
| Blockchain records | Permanent (section 5) |

## 9. SECURITY

We protect data with encryption in transit and at rest, access controls,
separation of identity data, audit logs, and email-code confirmation for
signatures. No system is perfectly secure. If a breach affects your data, we
will tell you and the authorities as the law requires.

## 10. YOUR RIGHTS

10.1 Depending on where you live, you can ask to: see your data; correct it;
delete it; receive a copy you can take elsewhere; restrict or object to some
uses; withdraw consent; and not be subject to certain automated decisions.

10.2 **Limits:** we cannot delete blockchain records, and we must keep some
records the law requires. We will tell you when a limit applies.

10.3 **How:** in the Account area, or email privacy@storecloud.org. We will
confirm your identity first and answer within the time the law sets (for
example 30 days in Switzerland and the EU, 45 days in California). You may use
an authorized agent. If we say no, you can appeal by replying to our answer.

10.4 **California:** you have the right to know, delete, and correct, and to opt
out of sale or sharing. We do not sell or share personal information as those
words are defined, and we do not use sensitive personal information beyond what
the law permits. We will not treat you differently for using your rights.

10.5 **EU, UK, Switzerland:** you may complain to your data protection
authority, including Switzerland's Federal Data Protection and Information
Commissioner.

## 11. AUTOMATED DECISIONS

11.1 Some decisions are automatic: approving later SAFT purchases once your
eligibility is recorded, sanctions re-checks, fraud signals, and holds for
review. They are checks, not profiling for marketing.

11.2 You can ask for a person to review any automated decision that
significantly affects you, and to explain it, at support@storecloud.org.

## 12. COOKIES

12.1 **Essential cookies** keep you signed in and secure. They are always on.

12.2 **Analytics cookies** help us improve STORE. Where the law requires
consent (for example in the EU, UK, and Switzerland), we ask first, and you can
withdraw consent at any time by emailing privacy@storecloud.org.

12.3 We do not use advertising cookies.

## 13. CHILDREN

STORE is for people 18 and older. We do not knowingly collect data from anyone
under 18, and we delete it if we learn we have.

## 14. EMAILS

Service emails (receipts, reminders, security, agreement notices) are part of
the Services. News and updates are optional; unsubscribe in any email.

## 15. CHANGES

We will give notice of material changes by email and in the Services before
they take effect. Each version is published with its own number and
fingerprint; past versions stay available.

## 16. CONTACT

privacy@storecloud.org · STORE Research Inc., Attention: Privacy, 440 N
Barranca Ave #9117, Covina, CA 91723. English controls over any translation.