Last Updated: 29 June 2026

This privacy notice explains how Zap Solutions, Inc. and its affiliates, including Zap Solutions Holdings, Inc., Zap Solutions Capital, Inc., Zap (Strike) Europe Limited, Zap Solutions Cayman Limited, and E4, S.A. de C.V., (“Strike,” “we,” or “us”) process information about you. This privacy notice applies when you use our websites, mobile applications, browser extension, payment processing services, application programming interfaces, and other online products and services that link to this privacy notice (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us or our Services.

If you are a resident of the United States and have a Strike consumer account or begin the process of creating a Strike consumer account, you can also review our U.S. Financial Privacy Notice here for a summary of our practices with respect to nonpublic personal information we collect about you. The U.S. Financial Privacy Notice is provided as an alternative way to read about our practices with respect to that information and does not supplement or supersede this privacy notice in any way.

We may change this privacy notice from time to time. If we make changes, we will notify you by revising the date at the top of this notice and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this privacy notice regularly to stay informed about our information handling practices and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, you can provide information directly to us when you create a Strike account, use our Services to send and receive money or cryptocurrency or to buy and sell cryptocurrency, request access to or use certain features, request customer support, or otherwise communicate with us. The types of information we may collect about you include your name and contact information (such as email address, postal address, and phone number), date of birth, username, profile image, photograph, payment and transaction hashes (including blockchain addresses), identity information you submit (such as government-issued identification numbers, photos of government-issued documents, and proof of address), passcode, payment and financial account information (including payment method information and bank account and routing numbers), transaction information (including information about other parties to the transaction), and any other information you choose to provide. Information we collect and process may be transferred between other Strike entities as a normal part of conducting business and offering our Services to you.

To open a business account with Strike, we may require you to provide additional information about you and the beneficial owners of the business. The types of additional information we may collect for business accounts includes business name, physical address, mailing address, proof of address, tax ID, name of beneficial owner(s), proof of legal formation (for example, a Certificate of Incorporation), bank statement, bank account information, and name and contact information of employees authorized to act on behalf of the business.

Information We Collect Automatically When You Interact with Us

When you use or interact with our Services, we may automatically collect certain information, including:

  • Transactional Information

    When you transfer, receive, purchase, or sell cryptocurrency or make or receive a payment, or take out any other service or product, we collect information about the transaction including from our third-party partners, such as the transaction amount, the date of the transaction, the transaction origination and destination (including any address information), and, in some cases, the identity and contact information of the other party to your transaction.

  • Device Information

    We collect information about your device when you interact with our Services, including hardware model, operating system version, mobile network, IP address, device identifier, browser type, and app version.

  • Location Information

    We infer your approximate geographic location (e.g. country or city-level location) based upon your IP address.

  • Information Collected by Cookies and Similar Tracking Technologies

    We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us provide and improve our Services and your experience, such as by allowing us to see which areas and features of our Services are popular, store preferences, and help protect our systems and users. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.

  • Do Not Track

    Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.

Information We Collect from Other Sources

We collect information about you (and the other party to a transaction) from third-party sources. For example, we may collect this information from identity verification and know-your-customer service providers, financial services providers, and financial institutions, including information such as name, username, phone number, postal address, transaction confirmations, age, government-issued identification numbers (such as Social Security number), and financial account information (including account balances and transaction history). In some circumstances, our know-your-customer service provider may perform a scan of face geometry from your government identification document or photographs you provide to us to verify your identity, and share information, which may be construed as biometric information under some state laws, from that process with us. In those circumstances, we store, transmit, and protect from disclosure the information shared with us in a manner that is the same as or more protective than the manner in which we store other confidential and sensitive information; and delete the information no later than when no longer required for the initial purpose of collection, or within three years from your last interaction with us, whichever occurs first. For more information about our know-your-customer service provider’s use of biometrics and its Privacy Policy, see https://withpersona.com/legal/privacy-policy. In addition, we receive information about you and your use and interactions with our Services, our marketing campaigns, and other third-party websites and services from third-party partners, such as advertising partners who provide us with information about your interest in and engagement with our Services and online advertisements. We may also receive information about you from other users, such as when they engage in transactions with you through our Services or invite you to use our Services. This information may include transaction descriptions that relate to you or your name or username.

Information We Derive

Finally, we may also derive information or draw inferences about you based on the information we collect. For example, as noted above, we may make inferences about your location based on your IP address, we may infer that certain products or services may be of interest to you based on your transaction history, and we may draw inferences about potential fraudulent activity.

Use of Information

We use the information we collect to provide, maintain, and improve our Services, including to process transactions, identify and repair errors in our Services, and analyze usage over time. We or our service providers also use the information we collect to:

  • Authenticate and help verify your identity;
  • Send you transactional or other account-related information, including confirmations, receipts, customer experience surveys, security alerts, transaction updates, and other customer support and administrative messages;
  • To notify you about changes to our Services;
  • Send you marketing communications that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
  • To measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;
  • Detect, investigate, and help prevent security incidents and other malicious, fraudulent, or illegal activity and help protect the rights and property of Strike and others. Some of this preventative action may prevent you from registering for an account, set deposit or withdrawal limits, or reject requested transactions on an automated basis. If you have questions about the validity of any automated rejection or limitation, please contact us;
  • To carry out our obligations, monitor your obligations, and enforce the terms of our Services;
  • To comply with agreements in place with you or third-party service providers;
  • De-identify, anonymize, or aggregate your information;
  • Determine your eligibility for any products or Services, and assess any applications you make for any accounts, products, or Services;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We share information about you in the following circumstances or as otherwise described in this notice:

  • With companies, professional advisors, and contractors that access and/or process your information to perform services for us, such as companies that assist us with web hosting, data storage, identity verification, fraud prevention, payment processing, tax reporting, financial services, customer service and support, legal and consulting services, customer communications, analytics, and marketing and advertising;
    • Depending on your location, we, or our financial institution partners may provide your personal information to vendors to help verify your identity and prevent fraud, including by determining whether a selfie you take matches the photo in your government-issued identity document.
  • With financial institutions that we partner with to receive and process payments and transactions you have authorized via the Services. Our financial institution partners may vary depending on your geographic location;
  • With business partners that provide products or services you request or that jointly offer products and services with us;
  • With other parties to transactions, including other people you are sending payments to or receive payment from, merchants when you use the Services to pay for goods and services, and their service providers;
  • With credit and debit card payment service providers (such as Checkout.com) to process credit and debit card transactions. When you choose to make a card transaction, you will provide your card information directly to such service provider, and their privacy policy will apply to the information you provide. Please refer to Checkout.com's privacy policy here for information about how they process your data;
  • With advertisers and advertising networks to facilitate more relevant and targeted advertising, track conversions and provide related services (please see the Analytics and Advertising section below for more details);
  • If we believe that disclosure is in accordance with, or required by, any applicable law or legal process. For example, we may disclose information about users or transactions in connection with tax filings, regulatory requests, court orders, or law enforcement requests;
  • If we believe that your actions are inconsistent with our user agreements or policies, that you have violated the law, or that it is necessary to protect the rights, property, and safety of Strike, our users, the public, or others;
  • In connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
  • Between and among Strike and its affiliates for use in connection with the purposes outlined above, or in connection with Services, or based on any request from you for additional services provided by different Strike affiliates; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

Analytics and Advertising

We allow others to provide analytics services, serve targeted advertising and provide related services for us. These entities may use cookies, web beacons, device identifiers, mobile app SDKs, and other technologies to collect information about your use of our Services and across other websites and online services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, transaction information and links clicked. This information may be used to, among other things, deliver ads targeted to your interests on other companies’ sites or online services, analyze and track data, determine the popularity of certain content, and better understand your online activity. Please see the “Targeted Ads Opt-Out” section below for details on how to opt out of the use of this information for targeted ads.

Transfer of Information to the United States and Other Countries

Strike has operations and service providers in the United States, El Salvador, Malta, Poland, Cayman Islands, and other countries. Therefore, we and our service providers may transfer information about you to jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. When that is the case, we will take steps designed to ensure that information about you receives an adequate level of protection in the jurisdictions in which we process it. By using the Services, you acknowledge that such transfers of information outside of your country of residence will occur.

Your Choices

Account Information

You may update and correct certain account information by logging into your account. If you wish to close your account, please use the tools made available via the settings feature to deactivate your account. Note that we may retain certain information as required by law or for our legitimate business purposes.

Targeted Ads Opt-Out

To opt out of us sharing information with third parties for targeted ads, you can opt out here. Please note that this opt-out is only relevant to your mobile device as the information shared for these purposes is currently only collected via our mobile app.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving marketing emails from Strike by following the instructions in those communications. If you opt out, we may still send you other non-marketing emails, such as those about your account and transactions or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Protection of Information

Strike implements security practices and policies designed to protect the confidentiality and security of your nonpublic personal information, which includes the information you provide to register for a consumer account (such as Social Security number and other identifying information) and other nonpublic personal information we collect about you. Strike implements measures designed to limit access to this information to personnel that have a business reason to know it and prohibits its personnel from unlawfully disclosing this information.

Children

To open a Strike Account and use the Services, you must be 18 years of age or older. We do not knowingly collect or solicit any information from any person under the age of 13 on our Services. If we have inadvertently collected personal information from anyone under age 13, we will make reasonable efforts to delete the information. If you believe that we may have collected any such information, please contact us at [email protected].

Other Important Information

Vermont: We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information to nonaffiliated third parties to market to you, other than as permitted by Vermont law.

Additional Disclosures for Users Outside the United States

Depending upon your jurisdiction, you may have certain additional rights and protections under the law regarding the processing of your personal data as further described below.

European and UK users

If you reside in an eligible country in Europe (EU) for the Services, Zap (Strike) Europe Limited and Zap Solutions Holdings, Inc. act as joint controllers in respect of your personal information. If you are eligible for certain additional services, Zap Solutions Cayman Ltd. may also act as a joint controller in respect of your personal information. Strike’s lead supervisory authority under the General Data Protection Regulation (GDPR) is Malta's Office of the Information and Data Protection Commissioner (IDPC) , located at Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, +356 2328 7100, [email protected], https://idpc.org.mt.

If you reside in the United Kingdom, Strike's designated Data Protection Representative under UK GDPR is Data Protection Representative (UK) Limited (trading as DataRep UK). If you have questions about how we process your personal data or wish to exercise any of your data protection rights, please contact our representative by sending an email to DataRep at [email protected] quoting Strike / strike.me in the subject line, or via DataRep's online webform at www.datarep.com/data-request. You may also mail your inquiry to DataRep, 107-111 Fleet Street, London EC4A 2AB, United Kingdom.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

  • To perform our responsibilities under our contract with you (e.g., providing the Services you requested).
  • When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).
  • To comply with our legal obligations (e.g., to comply with regulatory obligations, to maintain a record of any consents and track those who have opted out of marketing communications).
  • When we have your consent to do so. When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.

Data Subject Requests

Subject to certain limitations, and depending on your jurisdiction, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing.

If you would like to exercise any of these rights, please email us at [email protected]. When we receive a request, we may ask you for additional information in order to verify your identity and as a security measure to protect your personal information. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by applicable law.

Your Argentina Privacy Rights

The Agency of Access to Public Information, in its capacity as the Control Agency of Law No. 25.326, is responsible for dealing with complaints and claims filed by data subjects whose rights are affected by non-compliance with the regulations in force regarding the protection of personal data.

The data controller for Services provided in Argentina is:

E4, S.A. de C.V.
Avenida Las Magnolias, #206
Edificio Torre Insigne, Oficina 8-02 & 8-03
San Salvador, El Salvador

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside.

Texas consumers. If you have a complaint, first contact Zap Solutions, Inc. customer support at [email protected] or (800) 895-6045 (toll-free), if you still have an unresolved complaint regarding the company's money transmission activity, please direct your complaint to: Texas Department of Banking, 2601 North Lamar Boulevard, Austin, Texas 78705, 1-877-276-5554 (toll free), www.dob.texas.gov.

Contact Us

If you are in the United States and have any questions about this privacy notice, please contact us at:

Zap Solutions, Inc.
200 North LaSalle, Suite 2360
Chicago, IL 60601

[email protected]

(800) 895-6045

If you reside outside of the United States, please email us at [email protected].