Flash Funds LLC DBA FulusFlow

Privacy Policy

Effective date: May 1, 2026

This Privacy Policy explains how Flash Funds LLC DBA FulusFlow collects, uses, stores, and discloses personal information in connection with the FulusFlow website, onboarding workflows, compliance processes, and customer support communications.

FulusFlow operates using a non-custodial architecture. FulusFlow does not hold, custody, or control customer funds or customer private keys at any time.

Information we collect

Depending on how you interact with the service, FulusFlow may collect contact information, account information, transaction-related information, device and browser data, support communications, and compliance review records.

How we use information

FulusFlow uses personal information to provide and improve the service, onboard users, perform compliance checks, monitor for fraud and suspicious activity, communicate with customers, maintain security, and comply with legal obligations.

This includes customer identification, sanctions screening, transaction review, troubleshooting, record retention, internal analytics, and response to lawful requests from regulators or law enforcement.

How information is shared

FulusFlow shares information only where reasonably necessary to operate the service or comply with law. Categories of recipients may include identity verification partners, payment processing partners, wallet infrastructure providers, communications delivery providers, infrastructure and security vendors, legal counsel, auditors, and regulators.

FulusFlow does not sell, rent, or trade personal information for third-party marketing purposes.

Compliance disclosures

Because FulusFlow operates as a FinCEN-registered Money Services Business, personal information may be used and disclosed for sanctions screening, anti-money laundering review, suspicious activity reporting support, and other Bank Secrecy Act obligations. FulusFlow may also preserve or disclose records in response to subpoenas, court orders, lawful governmental requests, or internal compliance escalations.

Identity verification data

Identity verification is performed through specialized third-party verification services. FulusFlow may retain verification status, session identifiers, risk results, and related review notes. Full identity documents may be retained by the verification provider under that provider’s policies and legal obligations.

Data retention

Transaction and identity-related compliance records are retained for a minimum of 5 years to support Bank Secrecy Act obligations. Account and support records may be retained for operational, legal, fraud-prevention, and dispute-resolution purposes as permitted or required by law.

Security

FulusFlow uses administrative, technical, and organizational safeguards designed to protect personal information, including HTTPS/TLS encryption, network-edge security controls, access restrictions, audit logging, and secure infrastructure practices. No system can guarantee absolute security, but FulusFlow is designed to reduce operational and data risk as a core business principle.

Your choices and rights

Depending on your jurisdiction, you may have rights to request access to, correction of, or deletion of certain personal information, subject to legal retention requirements and compliance obligations. FulusFlow may decline deletion or modification requests where records must be preserved for regulatory, fraud-prevention, or dispute purposes.

Children’s privacy

FulusFlow is not directed to children under the age of 18 and does not knowingly provide services to minors.

International use

Personal information may be processed in the United States and in other jurisdictions where FulusFlow or its service providers operate. By using the service, you acknowledge that information may be transferred across borders in connection with service delivery and compliance review.

New York State exclusion

FulusFlow does not offer services to residents of New York State pending any future licensing strategy.

Changes to this policy

FulusFlow may update this Privacy Policy from time to time to reflect legal developments, operational changes, or service improvements. The updated version becomes effective when posted with a revised effective date.

Contact

Privacy questions and data requests may be sent to [email protected]. Compliance questions may be sent to [email protected].