Privacy Policy

1. Who we are and what this policy covers

QUBE US INC (“Qube”, “we”, “us”) operates the Qube mobile application (the “App”) for residents of the United States. This Privacy Policy explains what personal information we collect through the App and our website at https://www.qubeus.com, why we collect it, who we share it with, and what choices you have.

Effective date: October 14, 2026

This policy applies only to information Qube itself controls. It does not cover:

• Information collected and controlled by Bridge Building Inc. (see Section 2)
• Information you provide directly to your bank, your wallet provider, or any third-party service you connect
• Public blockchain data, which no party controls (see Section 9)

Please read this policy alongside our End User License Agreement and Terms of Service.

2. The single most important thing to understand: Qube is not the money transmitter

Qube is a technology layer. Qube does not hold your money, does not transmit your money, and is not a bank.

Money transmission services for United States residents are provided by Bridge Building Inc., NMLS # 2450917 (“Bridge”), a licensed money transmitter. Qube acts as an authorized delegate or agent of Bridge. Bridge holds the licenses, holds customer funds, executes the transfer, and performs the regulatory compliance obligations attached to money transmission.

This matters for your privacy because it splits responsibility for your data:

Bridge’s United States privacy policy:** https://www.bridge.xyz/legal/us-privacy-policy/bridge-building-inc Bridge’s United States terms of service: https://www.bridge.xyz/legal/us-terms/bridge-building-inc Bridge’s state licensing disclosures: https://www.bridge.xyz/legal/licenses/us-licenses-and-registrations

Bridge processes your information as an independent controller for its own regulatory purposes. We cannot delete, correct, or export information that sits in Bridge’s systems on your behalf. Requests about that data go to Bridge at support@bridge.xyz or (888) 523-6133.

3. Information we collect

3.1 Information you give us

3.2 Information collected automatically

3.3 Information we receive from others

• From Bridge: your verification status (for example, approved, pending, or declined), your verification tier, transfer status, settlement confirmations, and limited identity attributes needed to display your account correctly. We receive outcomes and status, not the underlying documents.
• From Apple: aggregate app analytics and crash reports if you have enabled sharing with developers, and App Store transaction receipts where applicable.
• From fraud and risk vendors: device reputation and risk scores.

3.4 What we do not collect

We want to be precise here, because this is where most fintech privacy policies overclaim.

Qube does not receive, store, or have access to:

• Images or scans of your government-issued identification
• Your full Social Security Number or Taxpayer Identification Number
• Your selfie, liveness video, or facial geometry template
• Your online banking username or password
• Your full bank account number or routing number in cleartext
• Your card Primary Account Number (PAN), Card Verification Value (CVV), or expiry

Identity verification is arranged and controlled by Bridge. Bridge engages an identity verification provider (currently Persona Identities, Inc.) to capture and assess this information. Qube has no contractual relationship with that provider. Bridge creates the verification session, determines what is collected, receives the results, and sets the retention schedule. The verification runs on the provider’s own domain inside a frame that Qube’s application code cannot read, and the data is transmitted to the provider and to Bridge, not to Qube.

Qube receives only a verification status from Bridge.

Requests about your identity documents, including access, correction, deletion, and retention questions, must go to Bridge. Qube cannot action them and has no ability to instruct the verification provider. See Section 2 for Bridge’s contact details.

One remaining check before publishing. Two things must hold for the statements above to be accurate, and only the second is now materially at risk:

(a) No telemetry leakage. No Qube-controlled log, crash report, analytics event, screenshot capture, or session replay tool may capture a verification screen. Cross-origin isolation prevents Qube’s code from reading the frame, but it does not prevent the surrounding container from capturing the screen.

(b) No identity data returned through Bridge’s own API. The verification vendor no longer sends anything to Qube. Bridge, however, may return customer records containing legal name, date of birth, and residential address through its own interfaces. If Qube requests, receives, logs, or stores those fields, the first bullet list above is narrowed and Sections 3.1, 5, 10, and 12 must be revised. The data is the same; only the pipe has changed.

4. Biometrics and device keys

Face ID and Touch ID. If you enable biometric unlock, authentication happens entirely on your device through Apple’s Local Authentication framework. Qube receives a yes-or-no result. We never receive, store, or transmit your fingerprint, facial geometry, or any biometric template. Apple does not share it with us.

Device-bound keys. The App generates a cryptographic key pair inside your device’s Secure Enclave. The private key never leaves the Secure Enclave and cannot be extracted, including by us. We store only the corresponding public key, which we use to verify that requests genuinely originate from your device.

Identity verification is different, but it is not ours. The verification provider engaged by Bridge may capture a selfie or short liveness video and derive a facial geometry template from it in order to match your face against your identification document. That capture is arranged by Bridge, performed by Bridge’s provider, transmitted to Bridge’s provider, and retained under Bridge’s retention schedule. Qube does not receive it, does not store it, and cannot instruct anyone about it. It is separate from Face ID.

Residual position on biometric statutes.

The Illinois Biometric Information Privacy Act (BIPA) attaches duties to an entity that collects, captures, or otherwise obtains a biometric identifier, and separate duties to an entity in possession of one. Because Bridge holds the vendor relationship, defines the verification, and receives the output, Qube neither obtains nor possesses the biometric identifier. That is a materially stronger position than if Qube held the vendor contract, and it is the correct structure.

The residual argument against Qube is narrow but not zero: the capture occurs inside the Qube app, using a camera permission that Qube requests, on a screen Qube presents. Plaintiffs have named app operators on facts like these. The defence is that Qube exercised no control over purpose or means and never came into possession, which is a good defence rather than a certain one.

Texas (Capture or Use of Biometric Identifier Act, Attorney General enforcement at up to USD 25,000 per violation) and Washington are structured differently and should be assessed alongside.

Recommendation, revised. A written-release consent screen is no longer necessary to close a live exposure. It is now cheap insurance: one screen that converts a narrow residual argument into a very weak one, and that also improves the camera permission experience by explaining what is about to happen. Counsel’s call, and a defensible decision either way.

5. How we use your information

We use personal information to:

1. Create, authenticate, and secure your account
2. Hand off your identity verification to Bridge and display the status Bridge returns
3. Accept, validate, and submit your transfer instructions to Bridge
4. Display balances, history, receipts, and status updates
5. Detect, investigate, and prevent fraud, account takeover, and abuse
6. Support Bridge’s compliance obligations under the Bank Secrecy Act (BSA), including anti-money laundering (AML) and countering the financing of terrorism (CFT) programs, and sanctions screening administered by the Office of Foreign Assets Control (OFAC)
7. Confirm that you are located in a jurisdiction where the service is available
8. Provide customer support and respond to your requests
9. Send service communications (transaction confirmations, security alerts, policy changes)
10. Diagnose defects, monitor performance, and improve the App
11. Comply with law, respond to lawful requests, and establish or defend legal claims

We do not use your personal information to train machine learning models for any purpose unrelated to fraud detection and product security, and we do not sell it. See Section 9.

6. Why we cannot make some collection optional

Identity verification and transaction monitoring are legal requirements, not product choices. Bridge, as a money services business registered with the Financial Crimes Enforcement Network (FinCEN), is obligated to identify its customers and monitor activity. If you decline to provide the information required for verification, we cannot open your account or process transfers. There is no version of the service that operates without it.

7. Who we share information with

We require service providers to process personal information only on our instructions and to protect it. Bridge is an exception: it acts as an independent controller for its own regulatory purposes, and it engages the identity verification provider on its own account rather than ours.

A current itemized list of processors is maintained at https://www.qubeus.com/legal/subprocessors. (Decide whether to publish this. Recommended, but it creates an update obligation.)

8. Public blockchain data

Part of the service involves digital assets recorded on public blockchain networks.

Blockchain records are permanent, public, and outside anyone’s control. When a transaction is recorded on a public blockchain, it is visible to anyone, it is replicated across many independent computers worldwide, and it cannot be edited or deleted. Not by you, not by Qube, not by Bridge, not by a court order.

Blockchain addresses are pseudonymous, not anonymous. Anyone who links an address to your identity, through your own disclosure, through a service you use, or through blockchain analysis, can view your full transaction history at that address.

No right to erasure applies to on-chain data. Any request to delete personal information does not and cannot extend to data recorded on a public blockchain.

Open item. If the App issues, stores, or anchors verifiable credentials (for example via an iden3 or Polygon ID style scheme), state precisely what is written on-chain. Identity commitments, revocation registry entries, and Merkle roots are permanent even when they are hashed and non-reversible, and this section must describe them explicitly.

9. Advertising, tracking, and sale of information

• We do not sell your personal information for money.
• We do not share your personal information for cross-context behavioral advertising.
• We do not allow third-party advertising networks or advertising SDKs in the App.
• We do not use the Identifier for Advertisers (IDFA) and do not present the App Tracking Transparency prompt.
• We do not engage in “tracking” as Apple defines it, meaning we do not link your data with third-party data for advertising or share it with data brokers.

We honor Global Privacy Control (GPC) signals on https://www.qubeus.com as a valid opt-out request where applicable law recognizes it.

Verify before publishing. These are the strongest statements in this document and the easiest to falsify. If any embedded SDK (including an attribution or growth SDK) transmits data to a third party for its own purposes, several of these lines become false and expose Qube to unfair-practices liability. Audit the actual binary.

10. How long we keep information

Because of the Bank Secrecy Act, closing your account does not delete your records. We are legally required to retain them. This overrides deletion requests for those categories.

11. Security

We use encryption in transit (Transport Layer Security) and at rest, hardware-backed key storage on your device, App Attest and DeviceCheck attestation, least-privilege access controls, and logging and monitoring.

No system is perfectly secure. We do not guarantee that unauthorized parties will never defeat our safeguards. Protect your device passcode and your account credentials, and contact us immediately at support@qubeus.com if you believe your account has been compromised.

12. Your privacy rights

12.1 An important limitation

Qube is likely a “financial institution” under the Gramm-Leach-Bliley Act. Most state comprehensive privacy laws exempt either GLBA-regulated entities entirely or GLBA-regulated data specifically. The practical result is that many of the rights below may not apply to your financial account data, though they generally still apply to app usage data, marketing data, and website data.

We will not use this as a shield to refuse reasonable requests. Where an exemption applies but honoring the request causes no legal or regulatory problem, we will honor it anyway.

12.2 Rights you can exercise

Depending on where you live, you may have the right to:

• Know and access what personal information we hold about you
• Correct inaccurate personal information
• Delete personal information, subject to the retention obligations in Section 10 and the blockchain limitation in Section 8
• Port your information in a portable format
• Opt out of sale, sharing for cross-context behavioral advertising, and profiling with legal effects (we do none of these, so there is nothing to opt out of)
• Limit the use of sensitive personal information (we use it only for the purposes in Section 5, which are permitted purposes)
• Not be discriminated against for exercising your rights

12.3 How to exercise them

Email privacy@qubeus.com or use the in-app privacy request form. We will verify your identity before acting, typically by confirming control of the email address and phone number on your account. We respond within 45 days and may extend once by a further 45 days where permitted.

Authorized agents. You may use an authorized agent. We will require written authorization and may require you to verify your identity directly.

Appeals. If we deny your request, you may appeal by replying to our decision with the subject line “Privacy Appeal”. We will respond within 45 days with a written explanation. If we deny your appeal, you may contact your state Attorney General.

12.4 California residents

Under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA):

Sensitive personal information.** Qube collects account log-in credentials. Qube does not collect Social Security Numbers, biometric identifiers, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health data, or sex life or sexual orientation data. We use sensitive personal information only for purposes permitted under CCPA section 1798.121(a) and do not use it to infer characteristics about you.

We have not sold or shared personal information in the preceding twelve months.

Note: CCPA contains a data-level exemption for information collected, processed, sold, or disclosed subject to GLBA. Much of your financial account information falls within it.

12.5 Other states

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and other states with comprehensive privacy laws may have similar rights. Use the same contact method above. GLBA exemptions in these states are frequently entity-level, meaning the exemption may be broader than California’s.

13. Children

The App is for adults. You must be at least 18 years old to use Qube. We do not knowingly collect personal information from anyone under 18. If we learn we have, we will delete it and close the account, subject to Section 10 retention obligations. Contact privacy@qubeus.com if you believe a minor has provided us information.

14. Changes to this policy

We will post any changes here with a new effective date. For material changes, we will notify you in the App or by email at least 10 days before they take effect, and where required by law we will obtain your consent. Continued use after the effective date means you accept the updated policy.

15. Contact us

QUBE US INC 211 Justice Street, West Babylon, NY 11704 Privacy: privacy@qubeus.com Support: support@qubeus.com Phone: 631-693-9490

For questions about money transmission, custody of funds, or your verification records, contact Bridge Building Inc. at support@bridge.xyz, (888) 523-6133, or 2120 University Ave., Suite 213, Berkeley, CA 94704.