Privacy Policy.

Decrow ("Decrow", "we", "us") provides non-custodial private payroll software for teams that pay recipients in USDC on Solana. This Privacy Policy explains what personal data we collect when you use decrow.xyz and the Decrow application, why we collect it, and the choices you have.

Decrow does not custody customer funds. Your organization connects its own Solana treasury wallet, and that wallet signs and funds every payroll run. This policy covers the personal data we process to operate the product, not the funds themselves.

We process personal data in line with applicable data protection laws, including Brazil's Lei Geral de Proteção de Dados (LGPD, Law No. 13.709/2018) and, where it applies, the EU General Data Protection Regulation (GDPR).

We collect the following categories of information:

• Account information: your name, email address, and password (stored as a salted hash, never in plain text).
• Organization information: legal and display name, country, team size, and your treasury wallet address and network (e.g. Solana mainnet or devnet).
• Recipient information: contact details, payout method, and wallet addresses for the people or entities your organization pays through Decrow.
• Billing information: subscription tier, invoice and payment records, processed by our payment provider.
• Session and authentication data: tokens used to keep you securely signed in.
• Usage and analytics data: pages visited and basic interaction data collected through Google Analytics.
• Community and design-partner submissions: name, email, organization details, and optionally a wallet address, if you apply through our community or design-partner forms.

We use the information above to:

• Provide, operate, and secure the Decrow application, including recipient onboarding, approvals, payroll execution, retries, and audit history.
• Coordinate confidential payroll execution that your treasury wallet signs and funds — Decrow never holds your private keys or your organization's funds.
• Process billing and manage subscriptions.
• Respond to support requests and communicate with you about your account or community/design-partner applications.
• Understand product usage and improve Decrow through aggregated analytics.
• Comply with legal obligations and enforce our terms.

Where the LGPD or GDPR applies, we rely on the following legal bases to process personal data:

• Performance of a contract: to provide the Decrow application and process payroll runs for your organization.
• Legitimate interests: to secure, maintain, and improve the product, and to communicate about it, in a way balanced against your rights.
• Consent: for analytics cookies, which load only after you accept them; you can withdraw consent at any time.
• Legal obligation: to meet tax, accounting, audit, and other regulatory requirements.

Decrow is non-custodial: your organization's treasury wallet remains under your control and is the wallet that signs and funds payroll runs. We store the wallet addresses you connect or add for recipients so the application can prepare and track payroll execution.

Payroll amounts are settled confidentially on Solana using Cloak. Wallet addresses and the existence of on-chain transactions are inherently public on a blockchain and are not controlled by Decrow; the confidential settlement amounts are not exposed by Decrow's product, but Decrow does not control what third parties may independently observe on-chain.

We do not sell personal data. We share information only with service providers that help us operate Decrow, such as:

• Hosting and infrastructure providers.
• Payment and billing processors.
• Analytics providers (Google Analytics).
• Other professional advisors (e.g. legal, accounting) when necessary.

We may also disclose information if required by law, or in connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations.

We retain account, organization, recipient, and billing data for as long as your organization has an active workspace, and afterward for as long as needed to comply with legal, tax, audit, or accounting obligations, or to resolve disputes. You can request deletion of your account data as described in "Your rights" below, subject to these retention obligations.

We apply technical and organizational safeguards to protect personal data, including password hashing, encrypted storage of sensitive recovery material, and role-scoped access controls. No system is completely secure, and we cannot guarantee absolute security of information transmitted to or from Decrow.

Decrow uses Google Analytics to understand how visitors use our site, using cookies and similar technologies. Analytics cookies load only after you accept them through our cookie banner — if you decline, Google Analytics is not loaded. You can change your choice by clearing the site's stored preference in your browser, and you can further control cookies through your browser settings.

Depending on your location, you may have the right to access, correct, export, or delete the personal data we hold about you, to confirm whether we process it, to object to or restrict certain processing, to withdraw consent, and to information about how your data is shared. Under the LGPD you may also request anonymization or portability, and you may petition the Brazilian data protection authority (ANPD). Under the GDPR you may lodge a complaint with your local supervisory authority. To exercise any of these rights, contact us at the email below.

Decrow may process and store information in countries other than your own. Where required, we rely on appropriate safeguards for international transfers of personal data.

Decrow is intended for business use and is not directed to individuals under 18. We do not knowingly collect personal data from children.

We may update this Privacy Policy from time to time. We will update the "Last updated" date above and, for material changes, provide additional notice as appropriate.

If you have questions about this Privacy Policy or how we handle your data, contact us at hello@decrow.xyz.