Privacy Policy

Privacy Policy Purpose

The purpose of this Privacy Policy is to describe how Independent Well USA Corp., doing business as Bitcoin Well ("Independent Well USA Corp.," "the Company," "we," "us," or "our") collects, uses, discloses, and protects personal information obtained through its operations in the United States. This Policy supports Independent Well USA Corp.'s obligations under applicable U.S. federal and state privacy and consumer protection laws, including the Gramm-Leach-Bliley Act (GLBA), and the Federal Trade Commission Act (FTC Act).

Independent Well USA Corp. is committed to maintaining transparency in its data practices and ensuring that personal information is collected and handled lawfully, fairly, and securely. This Policy provides users with a clear understanding of:

• The categories of information we collect;
• How that information is used to provide our products and services;
• The circumstances under which it may be shared;
• The rights and choices available to users; and
• The safeguards applied to protect personal information in our possession.

Independent Well USA Corp. does not sell or share personal information and does not engage in targeted or cross-context behavioral advertising. Sensitive personal information is collected only when necessary to verify identity, comply with the Bank Secrecy Act (BSA), Anti-Money Laundering (AML) requirements, and to meet other regulatory obligations.

1.1 Scope and Applicability

This Privacy Policy applies to individuals located in the United States who use the products and services of Independent Well USA Corp. It governs the collection, use, disclosure, and protection of personal information obtained through the Company's operations, digital platforms, communication channels, and customer interactions.

This Policy applies to all personal information collected directly from clients, prospective clients, business partners, and other individuals who engage with the Company. It also applies to information received indirectly through authorized third-party service providers that support the Company's operations.

Independent Well USA Corp. operates as a Money Services Business (MSB) registered with the Financial Crimes Enforcement Network (FinCEN) under registration number 31000308454032. As a registered MSB, the Company is subject to the Bank Secrecy Act (BSA), the Anti-Money Laundering Act of 2020, and related Financial Crimes Enforcement Network (FinCEN) regulations. These laws require the Company to collect, verify, and retain certain identifying information to meet its regulatory obligations.

This Policy applies only to information collected and controlled by Independent Well USA Corp. Information collected or processed by third-party service providers acting independently under their own privacy policies is outside the scope of this Policy.

2. Information We Collect

Independent Well USA Corp. collects personal information that is necessary to establish and maintain business relationships, comply with regulatory obligations, and deliver secure financial services. The categories of information collected depend on the nature of the user's interactions with the Company and the products or services requested.

2.1 Information Provided Directly by Users

The Company may collect personal information that users provide directly through account creation, identity verification, transaction requests, or other communications. This information may include:

• Full legal name, date of birth, residential address, and contact information such as telephone number and email address;
• Government-issued identification numbers, such as a driver's license, state identification card, passport, Social Security number, or tax identification number;
• Bank account or payment information necessary to complete authorized transactions;
• Photographs or scanned images of identification documents and supporting records used to verify identity;
• Biometric identifiers or verification data, such as facial images or liveness detection information, collected solely for identity verification and fraud prevention purposes; and
• Any other information voluntarily provided to support customer service or compliance review.

2.2 Information Collected Automatically

When users interact with the Company's websites or digital applications, limited technical and usage data may be automatically collected. This information helps maintain platform security, monitor for suspicious activity, and ensure reliable service delivery. It may include:

• Device identifiers, browser type, operating system, and access times;
• Internet Protocol (IP) address and general location derived from network routing information; and
• Logs of user activity within Company-controlled systems, including date, time, and session details.

The Company does not use cookies or tracking technologies for advertising purposes and does not engage in cross-context behavioral advertising.

2.3 Information Obtained from Third Parties

The Company may obtain additional information from verified third-party sources to meet its due diligence and regulatory requirements. These sources may include:

• Financial institutions and service providers used to facilitate payments or verify account ownership;
• Identity verification vendors, sanctions screening systems, and blockchain analytics providers; and
• Publicly available sources and regulatory databases used for compliance screening and risk assessment.

3. How We Use Information

Independent Well USA Corp. uses personal information to operate its business, deliver services, and meet legal and regulatory requirements. All use of information is consistent with applicable federal and state privacy and consumer-protection laws.

Personal information may be used to:

• Provide, maintain, and improve the Company's products and services;
• Verify identity and process authorized transactions;
• Communicate with clients about account activity, verification requests, or operational updates;
• Detect, prevent, and investigate fraud, security incidents, or other prohibited activities;
• Comply with applicable laws and regulations; and
• Protect the rights, property, and safety of clients, the Company, and others.

Independent Well USA Corp. does not use personal information for marketing, profiling, or targeted advertising. The Company does not share mobile numbers or related contact information with third parties or affiliates for marketing or promotional purposes. Text message opt in data and consent information is used only to provide the services you request and is not shared with any third party.

4. How We Share Information

Independent Well USA Corp. shares personal information only when necessary to conduct lawful business activities, meet regulatory requirements, or legal obligations.

Personal information may be shared in the following circumstances:

• Service Providers: With vendors and contractors that perform operational, technological, or administrative functions on behalf of the Company.
• Regulatory and Legal Obligations: With government agencies, law enforcement, or regulatory authorities as required by law, regulation, subpoena, court order, or other legal process.
• Corporate Administration: Within Independent Well USA Corp. for purposes of risk management, compliance oversight, or recordkeeping.
• Corporate Restructuring: In the event of a merger, acquisition, or other corporate restructuring, personal information may be transferred as part of the transaction, subject to continued protection consistent with this Policy.
• Affiliated Entities: Independent Well USA Corp. may share limited personal information with its parent company, Bitcoin Well Canada Ltd., for purposes of compliance oversight, internal reporting, and operational support. All information shared with affiliated entities is handled in accordance with this Privacy Policy and applicable data protection laws.

Independent Well USA Corp. takes reasonable steps to ensure that any third party receiving personal information provides safeguards consistent with applicable privacy and data protection laws.

4.1 Information Shared with Plaid Inc.

Independent Well USA Corp. uses Plaid Inc. ("Plaid") to securely collect and share information from users' financial institutions. When you choose to link a financial account, Plaid accesses and transmits the relevant account data to Independent Well USA Corp. to support account verification and authorized transactions.

By connecting a financial account, you consent to Plaid's access, use, and transmission of your information as described in the Plaid End User Privacy Policy, available at https://plaid.com/legal.

5. Data Retention and Security

Independent Well USA Corp. retains personal information for as long as necessary to meet operational needs, fulfill legal and regulatory obligations, and maintain accurate business and financial records. The Company follows the recordkeeping standards established under the Bank Secrecy Act (BSA) and the Anti-Money Laundering (AML) Act of 2020.

Records may be retained for longer periods when required by law, to support investigations, audits, or regulatory reviews, or when necessary to protect the Company's legal interests. When personal information is no longer required for these purposes, it is securely deleted, anonymized, or otherwise disposed of in accordance with the Company's Data Retention & Disposal Policy.

Independent Well USA Corp. maintains administrative, technical, and physical safeguards to protect personal information against unauthorized access, use, disclosure, or destruction. These safeguards include, but are not limited to:

• Protection of data in transit and at rest;
• Access controls and authentication requirements for employees and authorized contractors;
• Network monitoring and secure storage practices; and
• Regular reviews of systems, processes, and security measures to ensure continued effectiveness.

6. Your Privacy Rights

Independent Well USA Corp. respects the privacy and rights of individuals whose information it collects and maintains. In accordance with applicable U.S. federal and state privacy laws, users may have certain rights related to the personal information collected by the Company.

Subject to verification and applicable law, users may have the right to:

• Request access to the personal information maintained by the Company;
• Request correction of inaccurate or incomplete information;
• Request deletion of personal information when it is no longer required for legal, regulatory, or operational purposes;
• Request information about how personal information has been collected, used, and shared; and
• Opt out of the disclosure of personal information where permitted by law.

7. Contact Information

Independent Well USA Corp. will respond to verified privacy-related requests and other inquiries regarding this Privacy Policy.

Independent Well USA Corp.
Attn: Privacy Office
30 N Gould St Ste 100
Sheridan, WY 82801
Email: privacy@bitcoinwell.com