Privacy Policy

Last Updated: August 5, 2026

This Privacy Policy (this “Policy”) for jtx.com (“JTX”) applies to JTX, including any associated subdomains (the “Website”), and any tools, services, features, and functionalities available through the Website (collectively, the “Services”) that are operated by IBRL Group S.A., a Panama corporation (“IBRL,” “we,” “us,” or “our”). For purposes of this Policy, “you” and “your” refers to users of the Services. For purposes of applicable data protection laws, we are the entity responsible for the processing of personal data described here (also known as the controller or business).

By accessing or using the Services, including by joining the waitlist, you acknowledge that you have carefully read this Policy, and that you understand all of it. If you do not agree to this Policy, do not use, access, connect to, interact with, or download any of the Services or provide your information to us.

We may update this Policy from time to time. If we make material changes, we will update the “Last Updated” date at the top of this Policy and, where required or appropriate, provide you with additional notice.

When we collect personal data from you in association with your application for or our provision of financial products or services, a separate privacy notice that we will provide to you will apply.

This Policy does not apply to any third-party websites, protocols, wallets, or services that may be accessible through the Services. We are not responsible for the privacy practices of those third parties and encourage you to review their policies separately.

1. Information We Collect and Why We Collect it

When you access, use, connect to, or interact with the Services, we may collect certain categories of information about you, including personal data, from a variety of sources.

The information in the below categories may be processed for a variety of purposes, including to:

(a) provide the Services;

(b) enable your access to, use of, connection to, and interaction with the Services (e.g., facilitating your connection to the Website or engaging in any verification activities as noted below, allowing for account creation, enabling trading functionality, etc.);

(c) assist in ensuring security, safety, and stability of the system, us, users, and others, including by detecting and taking steps to prevent fraudulent or other unauthorized use of the Services;

(d) tailor features and content to you and your device, with your consent;

(e) communicate with you regarding your account, the Services, or our relationship with you;

(f) communicate with you regarding offers and things we think you may be interested in;

(g) monitor and improve the Services, including by conducting research;

(h) make the information anonymous so that it no longer identifies you;

(i) exercise our legal rights or defend against legal claims; and

(j) comply with any applicable legal obligations or prevent fraud.

We may process your personal data for other purposes where we have your consent or authorization to do so. And we may use information that does not identify you for any lawful purpose.

We may use AI tools, including machine learning, to enhance and improve the Services; your experience; and our processes, products and services. And we may use such tools to protect your account and the Services from fraud and other unauthorized or unlawful activities.

Information You Provide to Us

Information you provide to us may include:

  • Contact information, such as your email address;

  • Account credentials and profile information if you create an account, including any information provided when you authenticate via Privy or other wallet infrastructure partners, other third parties, or a connected email address;

  • The transactions you initiate or approve;

  • Financial account information;

  • Communications you send us, such as support requests, feedback, or responses to surveys; and

  • Any other information you choose to submit through the Website or via the Services.

If you contact us, including to participate in a waitlist or any other program we administer in relation to the Services, we will collect the content of the communications we have with you and any personal data contained therein.

Information Collected Automatically

We and our service providers may automatically collect certain technical and usage information, including:

  • Device and browser information, such as internet protocol (“IP”) address, device type, browser type and version, operating system, and internet service provider;

  • Usage data, such as pages viewed, features accessed, time and date of access, referring URL, transmission protocol used, and other interactions with the Services;

  • Geolocation data derived from your IP address, which we use to the extent reasonably necessary to determine your jurisdiction;

  • Log data, including server logs that record access requests, timestamps, and error information;

  • Personal data such as transaction data or history, among other things;

  • Cookie and tracking technology data, as described below.

  • Product analytics and interaction event data.. This includes records of the actions you take within the Services and associated event properties, including: authentication, consent, and onboarding actions; wallet linking, selection, and delegation actions; funding, deposit, and withdrawal actions; token searches, market selections, watchlist changes, and chart interactions; trading activity such as quote requests, order submissions and cancellations, and slippage and price-impact settings; portfolio and profit-and-loss views; social sharing and referral actions; settings changes; and error, latency, and other diagnostic information. Associated properties may include asset and market identifiers, order type and side, approximate (banded) transaction amounts, selected third-party providers, referral codes, and session and device identifiers.

  • Consent records, including whether you have granted or withdrawn your consent to analytics tracking, and the status of that consent.

  • Referral information, including any referral code associated with your access to the Services and whether you arrived through a referral.

  • Session replay and recording data. When session replay is active, we record your interactions with the Services so that your sessions can be reconstructed and played back. Depending on how this feature is configured, these recordings may capture your on-screen activity and the pages and screens you view; your mouse movements, clicks, taps, scrolling, and navigation; the timing and sequence of your interactions; text and values you enter into, or that are displayed on, the Services (which may include information such as email addresses, wallet addresses, balances, order details, and other account or transaction information); the contents of network requests and responses; console and diagnostic logs; and related device, browser, and session identifiers. We use session replays to understand and improve how users experience the Services, to diagnose and fix technical problems, and to detect and prevent fraud, abuse, and security incidents.

Wallet and Blockchain Information

When you connect a digital wallet to the Services, we may collect:

  • Any digital asset, smart-contract, or protocol address (“Wallet”) information and associated on-chain transaction data or geolocation data; and

  • Publicly available on-chain transaction data or history associated with your Wallet, such as your blockchain transaction history, token holdings and other information associated with your linked Wallet.

Blockchain transactions are publicly visible by nature. Information recorded on a public blockchain is immutable and outside our control.

Wallets are not owned, operated, or controlled by us, and are provided by third parties that have their own terms of use and privacy policies, which you should review before connecting a Wallet to the Services.

In light of the above, you acknowledge and understand that when you connect a Wallet to the Services, we may obtain onchain transaction data, balances and history associated with that Wallet. For purposes of applicable data protection laws, the source of this data is the public blockchain on which the transactions are recorded. We may process this data for the purposes described in this Policy.

Information from Third-Party Providers

The Services are supported by sign-in via Privy. When you authenticate through Privy (provided by Horkos, LLC d/b/a Privy) or a linked email address, Privy may share certain account information with us, such as your email address or wallet address, consistent with Privy’s own Privacy Policy. We encourage you to review Privy’s privacy policy before connecting your account. When processing personal data in association with Privy’s integration with our platform — such as your email address, wallet identifiers, and IP address — Privy acts as a service provider on our behalf.

We may also receive information about you from other third-party services providers, advertising partners, and others that we engage to help us operate, maintain, and improve the Services. This may include aggregated or de-identified usage data as well as information linked to your device or browser.

2. How We Disclose Information

We may disclose your information to: (a) third parties, including Jito Labs, Inc. and the Jito Foundation, including third-party vendors and service providers as necessary to perform their contracted services — including cloud hosting, data storage, product analytics, wallet screening and blockchain intelligence, authentication and embedded-wallet infrastructure providers (including Horkos, LLC d/b/a Privy), customer support, and security services; and (b) third-party analytics and advertising partners to help us determine usage of the Services, measure the effectiveness of our communications, and deliver relevant content, among other things.

We also may disclose your information if we are involved in a merger, acquisition, financing, reorganization, bankruptcy, dissolution, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

We may disclose your information to law enforcement agencies, regulators, courts, other government authorities, or third parties when we believe disclosure is required or permitted by law, including to comply with legal process, respond to a regulatory inquiry, or protect the rights, property, or safety of us, our users, or others.

We may disclose your information for other purposes with your consent or at your direction. We do not sell your personal information.

3. Cookies and Tracking Technologies

We and our third-party service providers may use cookies, web beacons, pixel tags, local storage, and similar tracking technologies to collect information about your access to and use of the Services. These technologies help us:

  • Keep you signed in and remember your preferences.

  • Understand how users navigate and use the Services.

  • Measure the effectiveness of our communications and features.

  • Detect and prevent fraud and security threats.

Most browsers allow you to control cookies through their settings. Disabling certain cookies may limit your ability to use some features of the Platform. Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.

We treat our analytics and session-replay technologies (including those provided by PostHog) as non-essential.

4. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with legal obligations, resolve disputes, establish or defend legal claims, and enforce our agreements.

To determine the appropriate retention period for specific categories of information, we consider: the nature and sensitivity of the information; the purposes for which it was processed; whether those purposes can be achieved through other means; and applicable legal, regulatory, and contractual requirements.

Certain information associated with blockchain transactions may be permanently recorded on a public blockchain and cannot be deleted.

5. Data Security

We implement and maintain technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. No security system is impenetrable. We cannot guarantee the ongoing impenetrability of any of your personal information transmitted to or from the Services, or stored on our systems. Transmission of information to the Services is at your own risk. If you believe your account or information has been compromised, please contact us.

6. Your Rights and Choices

Subject to applicable law and certain limitations, you may have the following rights with respect to your personal information:

  • Access. You may request confirmation of whether we process personal information about you, and request a copy of that information.

  • Correction. You may request correction of inaccurate or incomplete personal information.

  • Deletion. You may request that we delete your personal information, subject to certain exceptions (for example, where we are required by law to retain it).

  • Portability. Where technically feasible and required by applicable law, you may request that we transfer your personal information to you or a third party in a structured, machine-readable format.

  • Restriction and Objection. You may request that we restrict or cease processing your personal information in certain circumstances.

  • Withdrawal of Consent. Where we rely on your consent as the legal basis for processing, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

  • Opt-Out of Marketing. You may opt out of marketing communications at any time by following the unsubscribe instructions in any such communication, or by contacting us directly.

In addition to the rights described above, you can register a complaint with a data protection supervisory authority or other regulatory agency in your jurisdiction.

To exercise any of the above rights, please contact us at [email protected]. We will respond to verifiable requests in accordance with applicable law. We may require you to verify your identity before processing your request. We will not discriminate against you for exercising any rights provided under applicable law.

Children

The Services are intended solely for users who are 18 years of age or older. We do not knowingly collect or solicit personal information from any person under the age of 18. If you believe we have inadvertently collected personal information from a minor, please contact us immediately, and we will take prompt steps to delete such information.

If you reside in a jurisdiction that requires a different age for purposes of applicable data protection laws, you must reach such age in order to be able to provide the necessary consent under those laws.

7. Contact Us

If you have questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at [email protected].