Privacy Policy – XDol Invest

Scope and controller

This Privacy Policy describes how XDol Invest handles personal data of invited users and of visitors to the public pages, under Brazilian Law 13,709/2018 (LGPD). Access to the platform is restricted to invited and authorized users, and registration is completed only through an invitation plus identity verification.

• Controller: XDOL DIGITAL LTDA, company registration (CNPJ) 65.919.249/0001-40.
• Role delimitation: The identification above applies to the processing described in this policy. Which entity acts as custodian of the assets and as counterparty to the financial contracts is a separate matter, is under validation (Terms of Use, section 14) and does not follow from the platform developer role.
• Registered office: Avenida Brigadeiro Faria Lima, 1811, Office 1119, Jardim Paulistano, São Paulo/SP, ZIP 01452-001, Brazil.
• Data protection officer: formal designation pending. Until one is appointed, requests are received through the account deletion page, and the applicability of ANPD rules for small agents is under assessment.
• Privacy channel: contact@xdol.com.br, verified and active official channel (send, receive and reply test completed on 07/11/2026). Erasure requests can also be made through the dedicated account deletion page.

Registration and access data

• Identity: Full name, email and, where applicable, the phone number used for two-step verification.
• Credentials: Passwords and verification codes are never stored in plain text — only hashes. The additional factor (authenticator app or SMS) is mandatory.
• Federated login: When you sign in with Google or Microsoft we receive only the basic provider data needed to authenticate the account.
• Technical records: Access date and time, IP address, browser and session identifiers, used for security and audit trail.

Financial information

• Contracts and contributions: Chosen plan, amount contributed in USDT and in XDOL, start date, lock-up, fees and contractual earnings.
• Balances and movements: Available balance, deposit and withdrawal requests, net amounts, fees, approved destinations, approval status and on-chain transaction identifiers (TXID).
• Reconciliation: Prices used in the operational conversion and calculation dates, to allow auditing and verification by the data subject.

Public wallet addresses

Wallet addresses are public by nature, as they are recorded on the blockchain. We record the address linked to the account, the destination address approved for withdrawals and the deposit sender address. We never ask for a seed phrase, private key or wallet password: proof of control is a signature verified on the server, and we keep only the signature hash, never the full signature.

Receipts and documents

Uploading a deposit receipt is optional. When uploaded, the file is kept in private storage, accessible only to the data subject and to authorized administrators, through a short-lived signed link. A deposit is confirmed by the on-chain record (TXID), not by the receipt.

Legal bases

• Contract performance: Registration, contributions, earnings and withdrawals depend on processing for contract performance and preliminary procedures.
• Legal and regulatory obligation: Maintaining tax, accounting, anti-money-laundering records and responding to competent authorities.
• Legitimate interest: Platform security, fraud prevention, verification of wallet ownership and improvement of internal controls.
• Consent: Optional communications and voluntary receipt uploads, which may be withdrawn at any time.
• Exercise of rights: Producing evidence in administrative, arbitration or court proceedings.

Providers and sharing

• Hosting and application: Hosting and database infrastructure contracted to run the application.
• Deposit ledger: PostgreSQL database dedicated to deposit records and to concurrency control of operations.
• Blockchain network: Ethereum RPC providers, used to verify on-chain transactions and balances.
• Wallets: WalletConnect/Reown and the wallet apps the data subject chooses, for connecting and signing messages.
• Login and email: Google and Microsoft login providers and the transactional email service used for codes and notices.
• Commitment: We do not sell personal data and do not use it for advertising. Sharing happens only with the operators above, for the purposes described, or as required by law.

International transfer

Providers may keep servers outside Brazil. In those cases, transfer occurs only to countries or organizations that offer an adequate level of protection or under specific contractual clauses and safeguards, pursuant to articles 33 to 36 of the LGPD.

Information security

• Access: Mandatory two-step verification and role-based access control (user and administrator).
• Isolation: Record-level isolation rules in the database: each user reaches only their own data.
• Transport: TLS-encrypted traffic between browser, application and database.
• Wallet proofs: Single-use nonce, short validity and cryptographic verification on the server.
• Audit: Trail of administrative and financial actions, recording who, when and what.
• Receipts: Access only through a temporary signed link, never a public URL.

Retention and deletion

No deletion is automatic. Every request goes through identity confirmation and human review before any removal. The periods below are provisional and depend on legal validation; the complete retention matrix, with category, purpose, legal basis, start of counting and deletion procedure, is part of the internal privacy documentation.

• Account and contact: Erased or anonymized after the request is confirmed and reviewed, subject to the periods below.
• Financial records: Deposits, contracts, earnings, redemptions, withdrawals and receipts are kept for up to 5 years after the relationship ends, to comply with tax, accounting and fraud-prevention obligations.
• Security and audit: Access and audit trails kept for up to 5 years, for the same reason.
• Registration data: Kept while the account is active and, afterwards, only for the period needed to meet the obligations listed above.
• Deletion requests: Kept for 12 months after closure, as proof that the data subject was served.
• No legal or operational need: Data with no legal, contractual or operational need is erased or anonymized as soon as the purpose that justified its collection ends.
• Current limit: Ledger records, contracts and receipts are not erased before the applicable retention rules are defined and approved. Meanwhile the request stays on record and account access may be suspended, with no irreversible deletion.

Your rights

To exercise these rights, use the account deletion page or the privacy channel contact@xdol.com.br. We reply within 15 days.

• Confirmation and access: Confirmation that processing exists and access to the data held.
• Correction: Correction of incomplete, inaccurate or outdated data.
• Erasure: Anonymization, blocking or erasure of unnecessary, excessive or unlawfully processed data.
• Portability: Portability of the data to another provider, upon express request.
• Information: Information about the entities with which data has been shared.
• Consent: Withdrawal of consent and objection to processing based on legitimate interest.
• Authority: Petition to the Brazilian Data Protection Authority (ANPD).

Cookies and local storage

We use only cookies and local storage that are essential to keep the session authenticated and protect the account. We do not use advertising cookies or third-party trackers for profiling.

Minors

The platform is intended for people aged 18 or over. We do not intentionally collect data from children or adolescents; if such a registration is identified, the account is suspended and the data handled under this policy.

Changes to this policy

This policy is versioned. Relevant changes are announced in the application, and the active version, with its date, appears at the top of this page. Using the platform after publication means you are aware of the current version.