Privacy Policy

TEA Software Inc. · Effective: August 17, 2026 · Last updated: August 17, 2026

1. Overview

TEA Software Inc. ("TEA," "we," "us," or "our") is a Delaware corporation providing enterprise software for digital asset operations, including mining pool and mining operations management, node-as-a-service, MPC wallet software, digital asset treasury management, and banking, payment, and card features made available through licensed third-party partners (collectively, the "Services"). This Privacy Policy explains how we collect, use, share, and protect personal information when you visit teasoftware.io (the "Site"), use the TEA platform, request a demo, or otherwise interact with us.

TEA's Services are built for businesses. The personal information we handle is primarily about business representatives — the people who evaluate, administer, and use the Services on behalf of their organizations.

Plain-English summary (the detailed sections below control):

We do not sell personal information, and we do not use advertising trackers on the Site.
Our wallet technology is self-custodial by design — TEA does not hold your complete private keys.
Activity on public blockchains is public and permanent, and outside any company's control.
If you use the Services through your employer, your employer controls that data — contact them first.

2. Information we collect

Information you provide to us

Contact and demo requests: name, job title, email address, company website address, the platform module you are interested in, and the use-case description you provide. The demo form is protected by Google reCAPTCHA to prevent spam and abuse; the Google Privacy Policy and Google Terms of Service apply to reCAPTCHA.
Account information: name, email, organization, role, and login credentials when an account is created for you on the TEA platform.
Billing information: billing contacts and invoicing details. Where card payments apply, they are handled by payment providers; TEA does not store full card numbers.
Communications: the contents of emails, support requests, and calls or meetings with our team.

Information collected automatically

Usage and log data: IP address, browser and device type, operating system, pages viewed, referring URLs, and timestamps.
Approximate location inferred from IP address (country/region level).
Security data collected by our infrastructure providers (for example, bot-detection signals) to protect the Site and platform.
Cookies and similar technologies, described in our Cookie Policy. Our website analytics are privacy-focused and do not use cookies or track individuals across sites.

Blockchain and mining data

Public wallet addresses, transaction identifiers, and transaction details recorded on public blockchain networks.
Miner, worker, and fleet identifiers, hashrate, uptime, and related operational telemetry submitted to the platform.

Wallet addresses and on-chain activity may constitute personal information where they can be linked to an identifiable person.

Information from other sources

From your organization, when it purchases the Services and provisions accounts for its personnel.
From business partners and service providers that support the Services.
From publicly available sources, including public blockchain networks.
Where you enroll in banking, card, exchange, or on/off-ramp features, the relevant licensed partner may share your enrollment status and information needed to operate those features. Identity verification (KYC) for those features is performed by the partner, not by TEA.

3. How we use information

We use personal information to:

Provide, operate, secure, and maintain the Site and Services (performance of a contract; legitimate interests).
Respond to demo requests and inquiries and manage our business relationships (legitimate interests; steps taken prior to entering a contract).
Protect against fraud, abuse, and security threats (legitimate interests; legal obligation).
Comply with law, including accounting, tax, sanctions, and anti-money-laundering obligations that apply to us or that our financial-services partners are required to satisfy (legal obligation; legitimate interests).
Improve and develop the Services, including analytics and troubleshooting (legitimate interests).
Send service communications and, with your consent or as otherwise permitted, marketing communications that you can opt out of at any time (consent; legitimate interests).
Enforce our agreements and establish or defend legal claims (legitimate interests).

Where the GDPR or UK GDPR applies, the legal bases we rely on are noted in parentheses above.

4. When TEA acts as a processor

When your organization is our customer, TEA processes the data your organization submits to the platform ("Customer Data") on that organization's behalf and under its instructions, acting as a processor (GDPR/UK GDPR) or service provider (CCPA/CPRA). Your organization is responsible for its own privacy practices, and requests concerning Customer Data should be directed to it first. Our processing of Customer Data is governed by our agreement with the customer, including our Data Processing Addendum, and the third parties we use to process Customer Data are listed on our Sub-processor List.

Service providers and sub-processors that help us run the Site and Services — hosting and content delivery, security, email and SMS delivery, and business tools. Those that process Customer Data appear on our Sub-processor List.
Financial services, exchange, and card partners. Stablecoin accounts, payments, cards, on/off-ramps, and trading features are provided by licensed third parties. When you enroll in those features, your information is shared with the relevant partner, which acts as an independent controller under its own terms and privacy notice, including for the identity verification it performs. TEA is a software company; it is not a bank, money transmitter, or card issuer.
Professional advisors, such as lawyers, accountants, auditors, and insurers.
Legal, safety, and compliance purposes: to comply with law or legal process, respond to lawful requests from authorities, or protect the rights, safety, and property of TEA, our customers, or others.
Corporate transactions. In connection with a merger, acquisition, financing, reorganization, or sale of assets, personal information may be disclosed to the parties involved and transferred to a successor, subject to this Policy.
With your direction or consent.
Aggregated or de-identified information that does not identify you.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

6. Self-custody and private keys

The TEA platform's wallet features use multi-party computation (MPC) and are designed to be self-custodial: TEA does not hold customers' complete private keys and cannot unilaterally move customer funds. Customers are responsible for safeguarding their key shares, devices, and account credentials.

7. Public blockchains

Transactions on public blockchain networks are, by design, public, permanent, and replicated across systems that no single party — including TEA — controls. We cannot modify or delete information recorded on a public blockchain, and rights such as erasure may not be technically possible for on-chain data. Third parties may be able to associate public wallet addresses with individuals or organizations using information outside our control.

8. International transfers

TEA is based in the United States, and information we collect is processed in the United States and in other countries where our service providers operate. Where the GDPR or UK GDPR applies to a transfer, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, supplemented by the UK Addendum or International Data Transfer Agreement where required. You may request more information about these safeguards using the contact details below.

9. Retention

We keep personal information for as long as needed for the purposes described in this Policy, and then delete or de-identify it. Retention periods depend on the nature of the data, our legal and contractual obligations (including tax, accounting, and audit requirements), the need to resolve disputes and enforce agreements, and legitimate business needs such as security. Customer Data is retained as instructed by the relevant customer under our agreement with it.

10. Security

We maintain administrative, technical, and organizational safeguards designed to protect personal information, including encryption in transit, multi-factor authentication, role-based access controls, logging and monitoring, and security review of vendors. No system is completely secure, and we cannot guarantee absolute security. If you believe your account has been compromised, contact us immediately at legal@teasoftware.io.

11. Your rights and choices

European Economic Area, United Kingdom, and Switzerland. You may have the right to request access to, correction of, or deletion of your personal information; to restrict or object to our processing; to data portability; and to withdraw consent where processing is based on consent. You may also lodge a complaint with your supervisory authority (in the UK, the Information Commissioner's Office).

California. Subject to the CCPA/CPRA, California residents may have the right to know and access the personal information we collect, to correct or delete it, to opt out of "sales" or "sharing" of personal information, and not to be discriminated against for exercising these rights. We do not sell or share personal information as those terms are defined by California law; if that ever changes, we will update this Policy and honor recognized opt-out preference signals such as Global Privacy Control.

Other U.S. states. Residents of states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, and Texas) may have similar rights, including the right to appeal a decision on a request.

Exercising your rights. Email legal@teasoftware.io. We may need to verify your identity before acting on a request, and where the request concerns Customer Data controlled by your organization, we may refer the request to that organization. Authorized agents may submit requests where the law allows, with proof of authorization. We will respond within the timeframes required by applicable law.

Marketing choices. You can opt out of marketing emails using the unsubscribe link in each message or by contacting us. We will continue to send administrative and service messages.

12. Children

The Site and Services are intended for business users and are not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, contact us and we will delete it.

13. Third-party sites and services

The Site and Services may link to or interoperate with third-party websites, wallets, exchanges, and tools. Their practices are governed by their own privacy notices, which we encourage you to read.

14. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date above shows when it was most recently revised, and we will communicate material changes through the Site or by other appropriate means. Continued use of the Site or Services after an update means the updated Policy applies.

15. Contact us

TEA Software Inc.
Office: 300 Delaware Ave., Suite 210, Wilmington, DE 19801, USA
Mailing: 600 N Broad Street, Suite 5 #4138, Middletown, DE 19709, USA
Phone: +1 (302) 294-7070
Email: legal@teasoftware.io