Privacy Policy

Introduction

Last Updated: April 1, 2026

This Privacy Policy describes how Web3 Stable Company, a Delaware corporation (“Stable Clerk,” “we,” “our,” or “us”), collects, uses, and shares information about you when you visit stableclerk.com (the “Website”), register for an account, or use our software platform and APIs (collectively, the “Services”).

Our Services are designed for businesses — payment service providers, marketplaces, contractor networks, and other developers — and our direct counterparties are typically companies, not individual consumers. If you are an end user of one of our clients' products, your relationship is with that client, and we encourage you to review their privacy policy. We handle personal data relating to our clients' end users only as a data processor acting on behalf of our clients, as described below.

Please read this Privacy Policy carefully. We may update it from time to time. If we make material changes, we will notify you by posting the revised policy on our Website and updating the “Last Updated” date. Your continued use of the Website or Services after any change constitutes acceptance of the revised policy.

1. Information We Collect

1.1 Information You Provide Directly

When you interact with us — by filling out a contact form, signing up for early access, registering for an account, or communicating with our team — we may collect:

• Contact and identity information: name, email address, phone number, job title, and company name.
• Business information: company registration details, business description, and intended use case, which we collect as part of our onboarding and compliance process.
• Communications: messages, emails, and other content you send to us, including customer support inquiries.

1.2 Information Collected Automatically

When you visit our Website or use our Services, we automatically collect certain technical information, including:

• Log data: IP address, browser type and version, operating system, referring URL, pages visited, and timestamps.
• Device identifiers: device type and unique device identifiers.
• Usage data: API call patterns, feature usage, error logs, and performance data.
• Cookies and similar technologies: as described in Section 5 below.

1.3 Information From Third Parties

We may receive information about you or your company from third parties, including:

• Identity and compliance verification services: we use third-party providers to verify identity and business information as part of our onboarding process.
• Business data providers: publicly available business registration data, sanctions screening databases, and similar sources used for compliance purposes.
• Partners and referrals: if you are referred to us by a partner or integration partner, they may provide us with your contact information.

1.4 Client and End User Data

When our clients use the Services to build their products, they may transmit data relating to their own end users through our APIs. We process such data only on behalf of and at the direction of our clients, as their data processor, in accordance with our Data Processing Agreement. We do not use client end user data for our own purposes other than to provide the Services.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing and improving the Services: to operate, maintain, and improve our platform and APIs; to process transactions; to respond to technical issues; and to develop new features.
• Account management: to create and manage your account; to authenticate you; and to administer your relationship with us.
• Onboarding and compliance: to verify your identity and the identity of your business; to conduct required compliance reviews; to screen against applicable sanctions and prohibited party lists; and to fulfill our legal and regulatory obligations.
• Communications: to respond to your inquiries and support requests; to send you service-related notices (such as updates to these Terms or the Services); and, with your consent or as otherwise permitted by law, to send you marketing communications about Stable Clerk products and updates.
• Security and fraud prevention: to detect, investigate, and prevent fraudulent or unauthorized activity; to protect the integrity of our platform; and to enforce our Terms of Service.
• Analytics: to understand how the Services are used; to measure performance; and to generate aggregated, anonymized insights that we may use to improve our products.
• Legal compliance: to comply with applicable laws, regulations, court orders, and lawful requests from government authorities.

3. How We Share Your Information

We do not sell your personal information. We share your information only as described in this Section.

• Service providers: We share information with third-party vendors and service providers that perform services on our behalf, such as cloud infrastructure, data analytics, identity verification, sanctions screening, customer support software, and email delivery. These providers are contractually bound to use your information only as necessary to provide services to us and in accordance with applicable law.
• Compliance and legal requirements: We may disclose information when required by law, regulation, legal process, or governmental request; to enforce our Terms of Service; to protect the rights, property, or safety of Stable Clerk, our clients, or others; or to investigate potential violations.
• Business transfers: If Stable Clerk is involved in a merger, acquisition, asset sale, financing, or other business combination, your information may be transferred as part of that transaction. We will provide notice of any such transfer and any material changes to how your information is handled.
• With your consent: We may share your information with third parties when you direct us to do so or otherwise consent.
• Aggregated or anonymized data: We may share aggregated or anonymized information that does not reasonably identify you for analytics, research, or marketing purposes.

4. Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to maintain your account, comply with our legal obligations (including AML record-keeping requirements), resolve disputes, and enforce our agreements. When we no longer have a lawful basis for retaining your information, we delete or anonymize it.

Specific retention periods:

• Account and business information: retained for the duration of your account, and for up to 7 years following account closure to comply with applicable legal and regulatory requirements.
• Transaction and API logs: retained for up to 5 years.
• Communications and support records: retained for up to 3 years after your last interaction with us.
• Website analytics data: retained for up to 2 years.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Website to operate and improve it. Here is how we use them:

• Strictly necessary cookies: These are required for the Website to function and cannot be disabled. They include session cookies that authenticate logged-in users and maintain security.
• Analytics cookies: We use analytics tools to understand traffic patterns, page performance, and how visitors use the Website. This may include tools such as Google Analytics or similar services. You can opt out of analytics tracking by using browser settings, opt-out browser add-ons provided by the applicable service, or our cookie consent mechanism.
• Preference cookies: These remember your preferences (such as language or display settings) to improve your experience.

You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Website or Services.

6. Your Privacy Rights

Depending on where you are located, you may have rights under applicable data protection law regarding your personal information, including:

• Access: the right to request a copy of the personal information we hold about you.
• Correction: the right to request that we correct inaccurate or incomplete information.
• Deletion: the right to request that we delete your personal information, subject to our legal and regulatory obligations to retain certain records.
• Portability: the right to receive your information in a structured, machine-readable format.
• Objection and restriction: the right to object to or request restriction of certain processing activities.
• Withdrawal of consent: where we rely on your consent as the legal basis for processing, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us at info@stableclerk.com. We will respond within the timeframe required by applicable law (generally within 30 days). We may need to verify your identity before processing certain requests.

California residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know about the categories of personal information we collect, use, and disclose; the right to delete personal information; and the right to opt out of the sale of personal information. We do not sell personal information. For more information or to submit a request, contact us at info@stableclerk.com.

EEA, UK, and Swiss residents: If you are located in the European Economic Area, the United Kingdom, or Switzerland, please see Section 9 below.

7. Data Security

We implement and maintain commercially reasonable technical and organizational security measures designed to protect your information from unauthorized access, disclosure, alteration, or destruction. These include encryption of data in transit and at rest, access controls, and security monitoring.

However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at info@stableclerk.com.

8. Links to Third-Party Sites and Services

The Website and Services may contain links to or integrations with third-party websites, services, and infrastructure, including public blockchain networks, stablecoin issuers (such as Circle), and wallet infrastructure providers. This Privacy Policy does not govern the data practices of those third parties. We encourage you to review the privacy policies of any third-party service before interacting with it.

9. International Data Transfers

Stable Clerk is based in the United States. If you are located outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. Data protection laws in those countries may differ from those in your jurisdiction.

For transfers of personal data from the EEA, UK, or Switzerland to countries that have not been found to provide an adequate level of data protection, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission or UK Information Commissioner's Office, or other legally recognized transfer mechanisms.

For questions about our international transfer practices, contact info@stableclerk.com.

10. Children

The Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have inadvertently collected personal information from a child under 13, we will delete it promptly. If you believe we have collected such information, please contact us at info@stableclerk.com.

11. Marketing Communications

If you have provided us with your contact information and expressed interest in our products, we may send you marketing communications. You can opt out of receiving marketing emails at any time by clicking “unsubscribe” in any such email or by contacting us at info@stableclerk.com with the subject line “Unsubscribe.” Opting out of marketing communications does not affect our ability to send you service-related notices.

12. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or our privacy practices, please contact us:

Stable Clerk Inc.
info@stableclerk.com

We will respond to all requests within the timeframe required by applicable law.

Web3 Stable Company is a Delaware corporation. These documents do not constitute legal or regulatory advice. Stable Clerk is not a bank, money services business, or financial institution.