Privacy Policy

Effective date: August 14, 2026

1. Who we are

Ventura Labs LLC, a Texas limited liability company, operates the Allways websites, hosted API, and exchange application (the "Services", as defined in our Terms of Service).

This policy explains what we collect, why, and what you can do about it. It covers the Services only. It does not cover the Allways Protocol — the Solana smart contract, the Bittensor Subnet 7 network, and the independent miners and validators — which we do not operate or control, and which we cannot make privacy commitments about. See §9.

2. The short version

• We do not collect your name, email, phone number, postal address, government ID, or date of birth to use the core Services.
• Your identifier is a public blockchain address. That is what we store.
• We do not sell your personal information, and we do not share it for behavioural advertising.
• Everything you do on-chain is already public and permanently recorded on a public blockchain, by anyone's ability to read it, not by our choice.

3. What we collect

3.1 Information you provide

What	Where it comes from	Why
Bittensor coldkey address	Wallet connection	Your account identifier
Linked wallet addresses (Solana, Bitcoin, Bittensor)	You add them	Routing swaps to the right destination
Terms acceptance timestamp	Your signed acceptance	Proving you agreed, and to which version
API keys you generate	Your request	Programmatic access
Support correspondence	You contact us	Answering you

If subscription billing is introduced, billing details will be handled by a third-party payment processor and are subject to its privacy policy. We do not store full payment card numbers.

3.2 Information we collect automatically

• Blockchain data: swap records — source and destination chain, amounts, rate, status, miner hotkey, your on-chain taker address, and source transaction hash. Most of this exists publicly on-chain; we index it so the Services can show you your history.
• Stake data: your stake to the validator, sampled over time, used to determine service tiers and routing priority.
• Technical and log data: IP address, browser and device type, timestamps, pages and endpoints requested, referring URL, and error diagnostics. Used for security, abuse prevention, debugging, and — per §3.3 — geographic restriction.
• Cookies and local storage: session state and preferences. See §8.

3.3 Compliance screening

To meet legal obligations and the eligibility requirements in our Terms, we may screen your wallet addresses and IP address against sanctions and restricted-party lists and against blockchain-analytics risk signals, using third-party compliance-screening providers. We may record the fact, time, and outcome of a screening.

We may use your IP address to determine approximate location and restrict access from jurisdictions where we do not offer the Services.

3.4 What we do NOT collect

We do not collect or store private keys, seed phrases, or wallet passwords. We cannot access or move your assets. We do not collect biometric data, precise GPS location, or contents of communications outside support correspondence.

4. Why we use it

• To provide the Services — routing reservations, showing swap status and history, maintaining your account and linked wallets.
• To comply with law — sanctions screening, restricted-jurisdiction enforcement, responding to lawful requests, and maintaining records we are required or advised to keep.
• To secure the Services — detecting abuse, fraud, rate-limit evasion, and attacks.
• To improve the Services — aggregate usage analysis and debugging.
• To communicate — service notices, security alerts, and material changes to terms.

Legal bases (where GDPR or similar applies): performance of a contract (§4 first bullet); legal obligation (second); legitimate interests in security, abuse prevention, and service improvement (third and fourth); consent, where required, for non-essential cookies and marketing.

5. When we share it

We do not sell your personal information. We share it only:

• With service providers acting on our instructions — hosting, infrastructure, analytics, compliance screening, and payment processing — bound to use it only to provide those services.
• When legally required — in response to valid legal process, or where we reasonably believe disclosure is necessary to comply with law, protect rights or safety, or investigate suspected illegal activity.
• In a corporate transaction — a merger, acquisition, or asset sale, with notice.
• With your direction — where you ask us to.

Necessarily public: submitting a swap publishes transaction details to public blockchains. Anyone can read them, permanently. We cannot restrict, retract, or delete on-chain data.

6. International transfers

We are based in the United States and process data there. If you access the Services from elsewhere, your information is transferred to the U.S., which may not provide the same protections as your jurisdiction. Where required, we use appropriate safeguards for such transfers.

7. How long we keep it

Data	Retention
Account and linked wallets	Life of account + 5 years
Terms acceptance records	5 years after the account closes
Swap records	5 years
Screening records	5 years
Server and access logs	12 months
Support correspondence	5 years

We keep information as long as needed to provide the Services and for a reasonable period afterward to meet legal, regulatory, tax, audit, and dispute-resolution needs. On-chain data is permanent and outside our control.

8. Cookies

We use cookies and local storage for session management, preferences, and aggregate analytics. Essential cookies are required for the Services to function. You can block cookies in your browser, but parts of the Services may stop working. Where required by law, we request consent for non-essential cookies.

9. Third parties we do not control

The Protocol, independent miners, independent validators, blockchain networks, block explorers, and any third-party wallet you use are not operated by Ventura Labs LLC. Their handling of information is their own. Interacting with the Protocol directly — without the Services — involves no data collection by us at all.

10. Security

We use administrative, technical, and physical safeguards appropriate to the sensitivity of what we hold, including encryption in transit, access controls, and monitoring. No system is perfectly secure, and we cannot guarantee absolute security. You are responsible for your own wallet and key security; compromise of your wallet is outside our control and cannot be remedied by us.

11. Your rights

Depending on where you live, you may have the right to access, correct, delete, or receive a portable copy of your personal information; to object to or restrict certain processing; to withdraw consent; and to appeal a refusal.

Exercise these by contacting [email protected]. We will verify your request — typically by asking you to sign a message with the wallet in question — and respond within the time the applicable law requires.

Limits. We cannot delete on-chain data. We may retain information where we have a legal obligation to keep it, notably sanctions-screening records, and deleting your account does not remove your public blockchain history.

California. We do not sell or share personal information as those terms are defined by the CCPA/CPRA, and we do not discriminate against you for exercising your rights.

12. Children

The Services are not for anyone under 18. We do not knowingly collect information from children. If we learn we have, we will delete it.

13. Changes

We may update this policy. Material changes will be notified through the Services or by posting an updated version with a new effective date. Continued use after the effective date constitutes acceptance.

14. Contact

[email protected] · 1705 Guadalupe Street, Unit 300, Austin, TX 78701