Privacy Policy

This privacy notice is effective as of May 22, 2025.

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At Byte Federal, LLC ("Byte Federal", "we" or "us" or "our"), we care about privacy, security and transparency; these are core tenets in our mission. Toward that, this privacy notice explains what to expect when Byte Federal collects, processes and shares your personal information; it also explains how we comply with laws and regulations, including compliance with and the protection of your non-public personal information (NPI) as defined under the Gramm-Leach-Bliley Act (GLBA), also known as the Financial Modernization Act of 1999, Pub. L. No. 106-102, 113 Stat. 1338 (1999) (codified at 15 U.S.C. §§ 6801-6809).

This privacy notice is structured to explain:

1. how we collect data;
2. who controls your data;
3. data we collect and the lawful basis for processing;
4. how we protect your data/NPI;
5. your data protection rights;
6. how to submit a data subject request;
7. how to limit data sharing and exercise opt-out choices;
8. how we manage data retention;
9. how we protect children's personal information;
10. supplemental information for residents of certain states;
11. changes to this privacy notice;
12. how to contact us.

Byte Federal has registered address at 795 Commerce Dr., Ste 5, Venice, FL 34292 and our legal identifiers include the following: FEI/EIN # 81-4487136; FinCEN BSA ID # 31000252496335; and NMLS # 2327474.

One of the purposes of this privacy notice is to explain how we collect and process personal data. The primary ways we collect information is by (a) visiting one of our websites; (b) using one of our ATMs; (c) employing a ByteWallet; and (d) using the ByteConnect Point of Sale (POS) payment platform. Please be informed that our websites and services are not intended for children, defined as age 17 and under; we do not knowingly collect data from children and will immediately delete it if discovered.

Byte Federal employs the use of Plaid Inc. ("Plaid") to gather your data from financial institutions. By using the Service, you grant Byte Federal and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy here.

Byte Federal recognizes the importance of defining the roles and responsibilities associated with personal data handling. We follow terminology consistent with leading U.S. state privacy laws—including the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), and similar statutes in Colorado, Connecticut, and Utah—which distinguish between "controllers" and "processors."

When you subscribe to any of our consumer services, Byte Federal acts as a data controller, meaning we determine the purposes for which and the means by which your personal information is collected and processed. As a controller, we are responsible for honoring your privacy rights under applicable state privacy laws.

When you share information with us directly by visiting our website, Byte Federal functions as a controller for any personal information you voluntarily submit or that is automatically collected through your interaction with our digital platforms. This includes, for example, contact information submitted via web forms or data collected through cookies or similar technologies.

When a business employs the ByteConnect Point of Sale payment platform, the business is the controller, and Byte Federal acts solely as a data processor on behalf of the business. We process information only under the business's documented instructions and in accordance with our contractual obligations. If an individual submits a data subject rights request concerning data collected through the use of the POS platform, it must be directed to the controller.

Byte Federal will only process your data according to the allowance permitted by law. In most instances, we will only use your data in the following situations:

1. when you provide us with your consent to process your personal data which may be revoked by you at any time and for any reason;
2. when it may be necessary for our legitimate interest;
3. when we may need to respond to a legal requirement or regulatory action;
4. where we need to fulfill our obligation to provide services when you subscribe to our services.

In the following table, we describe ways your personal information may be used; each of these uses are tied to a legal basis for processing. Further, we have also outlined wherever we have a legitimate interest to process your data where appropriate.

Under the GLBA, Byte Federal is permitted to collect, use, and disclose nonpublic personal information (NPI) in connection with providing financial services, subject to notice and opt-out rights for certain types of third-party sharing. U.S. state privacy laws similarly require us to state the purpose of processing, retain data for no longer than necessary, and provide rights such as access, correction, and deletion, where applicable.

Be aware that bitcoin, ether, and other Digital Assets are not necessarily truly anonymous. Generally, anyone can see the balance and transaction history of any public Digital Asset address. We, and any others who can match your public Digital Asset address to other information about you, may be able to identify you from a blockchain transaction. This is because, in some circumstances, information published on a block chain (such as your Digital Asset and IP address) can be correlated with information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to collect and process such information about you. By using our services, you acknowledge that certain blockchain-based transactions may be traceable and that Byte Federal may use blockchain analytics for security and compliance purposes.

We maintain administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of your NPI against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include but are not limited to:

1. encryption of sensitive data;
2. restricted access to NPI to authorized personnel only;
3. regular security assessments and updates to our security practices;
4. secure data storage and transmission protocols; and
5. conducting anti-fraud and identity verification checks.

The data protection and governance program at Byte Federal aligns with ISO/IEC 27001:2022.

Your privacy is important to us, and we are committed to upholding the data protection rights granted to individuals under applicable U.S. laws. These rights may vary depending on where you reside, the nature of your relationship with Byte Federal, and the services you use.

Rights Under State Privacy Laws

Several U.S. states—including California, Virginia, Colorado, Connecticut, and Utah—have enacted privacy laws that provide consumers with specific rights concerning their personal information. If you are a resident of a state with such legislation in force, you may have the right to:

1. Access: Request access to the personal information we maintain about you. This includes the categories of information collected, the purposes for which it is used, and with whom it has been shared.
2. Correction: Request correction of inaccurate personal information that we hold about you.
3. Deletion: Request deletion of certain personal information we have collected from or about you, subject to exceptions (e.g., legal obligations under financial services laws).
4. Data Portability: Request a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity.
5. Opt-Out of Certain Uses: Where applicable, opt out of (a) the sale of your personal information (Note: Byte Federal does not sell personal information); (b) targeted advertising based on your behavior across unaffiliated websites or applications; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects.

Please note that not all states have enacted privacy laws granting these rights. If your state does not currently provide statutory rights, Byte Federal may still, at its discretion, honor certain requests consistent with our internal privacy governance program.

Rights Under the GLBA

As a financial services company, Byte Federal is also governed by the Gramm-Leach-Bliley Act (GLBA). GLBA does not grant the same consumer-facing rights as some state privacy laws but does require:

1. that we notify you of our data collection and sharing practices;
2. that we give you the opportunity to opt out of certain disclosures to nonaffiliated third parties (except where exemptions apply); and
3. that we safeguard your nonpublic personal information (NPI) through administrative, technical, and physical controls.

Byte Federal adheres to these obligations through our privacy notices, security program, and vendor management practices.

You can typically review and update your account information by logging into your Byte Federal account through our mobile application or website. If you need assistance, Byte Federal has assigned a Privacy Officer to superintend all aspects of this privacy notice, ensuring your questions are answered and your rights are respected. Whenever you have questions, you should contact the Privacy Officer via one of the venues below:

We may request additional information to verify your identity and the legitimacy of your request. This is a necessary security measure to prevent unauthorized access to your data. We will not charge a fee to process your request unless it is manifestly unfounded, repetitive, or excessive. In such cases, we may charge a reasonable fee or decline to act on the request.

Remember: In some cases—such as when a merchant uses our ByteConnect Point of Sale system—Byte Federal acts only as a data processor on behalf of that business. In those instances, Byte Federal does not determine how personal data is used. Requests to exercise privacy rights relating to data collected through a business using ByteConnect should be directed to that business, as the data controller.

You have the right to limit our sharing of your NPI with non-affiliated third parties for their own marketing purposes. The table below summarizes what NPI we share and your choice to limit the sharing, based on the SEC's model privacy form under the GLBA.

Byte Federal retains your NPI and other personal data only for as long as necessary to provide our services, meet legal and regulatory obligations (such as those under AML, KYC, BSA, and IRS rules), resolve disputes, and enforce our agreements. In most cases, we are required to retain certain records—including identity documentation and transaction data—for a minimum of five to seven years after the end of your relationship with us. Retention periods may vary depending on the type of data and its purpose, and we periodically review our retention practices to ensure compliance with applicable laws, including the FTC's Safeguards Rule regarding secure disposal. If you submit a deletion request and we act as the data controller, we will evaluate it in light of these obligations and inform you if any legal requirements prevent full erasure. Where we act as a service provider on behalf of a business, we will refer your request to that business, which serves as the data controller. In some cases, we may anonymize personal data so it can no longer be associated with you, in which case it may be retained indefinitely for legitimate business purposes.

Our Services are not directed to individuals under the age of 18. We do not knowingly collect NPI from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take prompt steps to delete it in accordance with applicable laws.

If you are a resident of a state with comprehensive privacy laws, such as California, Colorado, and Virginia, by way of example, you may have additional rights regarding your personal information. Where there is a conflict between the GLBA-specific provisions of this notice and the state-specific provisions, the provision that affords greater protection or broader rights to you will govern, to the extent permitted by applicable law.

For the purposes of these state-specific provisions, "Personal Information" or "Personal Data" may include information beyond the "Nonpublic Personal Information" (NPI) covered by the GLBA and refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Please note that some state privacy laws include exemptions for information subject to the GLBA. To the extent that your NPI is collected, processed, sold, or disclosed pursuant to the GLBA, some of the state specific rights may not apply to that specific NPI, or we may be considered compliant with certain state law obligations through our compliance with GLBA.

We may amend this Privacy Notice from time to time. If we make material changes to how we collect, use, or share your NPI, we will notify you by posting the revised notice on our website and updating the "Effective Date" at the top of this notice. We may also notify you through our Services or by other means, such as email, or physical mail. We encourage you to review this Privacy Notice periodically to stay informed about our information practices.

If you have any questions or concerns about this Privacy Notice or our privacy practices, please contact us at: