Privacy Policy

Effective Date: 7/4/2025

‍Entity: Conduit Hodlings Inc. ("Conduit")

‍Applies to: Conduit Market, Conduit.Coffee, Conduit Merchant Portal (the"Services")

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1. Introduction

At Conduit Hodlings Inc., d/b/a Conduit / Conduit Market ("us", "we", "our" or the "Company"), we value your privacy and the importance of safeguarding your data. This Privacy Policy (the "Policy") describes our privacy practices across all services we provide. Specifically, it applies to:

• Conduit.Market: our pseudonymous marketplace
• Conduit.Coffee: our e-commerce store
• The Conduit Merchant Portal: backend services for merchants

Each of these services may differ in how they handle data. This policy outlines how we collect, store, access, and otherwise process information that can identify an individual ("Personal Data") while maintaining a high standard of user clarity and privacy respect.

Our business is registered in and operated from the United States, with no physical storefront. You can visit our website at https://conduit.market.

We comply with relevant privacy laws including:

• Canada’s PIPEDA and Quebec Law 25
• California CCPA / CPRA and CalOPPA
• Colorado, Utah, Connecticut, Virginia, Texas, Oregon, Montana, Delaware, Nebraska, New Hampshire, New Jersey, Minnesota, and Maryland privacy laws

We do not operate in the EU, UK, Brazil, or other jurisdictions subject to GDPR-equivalent regulation.

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2. Scope

This Policy applies to your use of Conduit services, including:

• Visiting conduit.market, conduit.coffee, or merchant portals we operate
• Interacting with our products or services
• Receiving newsletters (which are strictly voluntary opt-in)

We do not collect or store personal data from phone calls or SMS. We never use phone-based marketing.

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3. Personal Data We Collect

a) Conduit.Market (Marketplace)

• npub (Nostr public key) is used as your identity. Users may optionally use a randomly generated npub instead of one tied to their personal profile.
• We do not request or store personal identifiers like name, email, or address
• We log IP address and timestamp for basic security and abuse prevention
• We do not use third-party analytics, fingerprinting, or advertising cookies

b) Conduit.Coffee (Shop)

To process orders, we collect:

• Name, shipping address, and email (only for fulfillment)
• Payment information (processed via Strike or other third-party providers)
• Order history and feedback (optional)

We do not use your information for personalized ads or behavioral tracking.

c) Merchant Portal

• npub (public key) or email (for login and password recovery)
• Authentication records, IP address, and timestamps
• No sensitive data or profiling is performed

We may optionally log anonymized usage for UX improvement and service debugging only.

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4. Cookies & Usage Information

We use only essential and privacy-respecting cookies:

• Session tokens for login or order flow
• Preference cookies (language, currency)
• Anonymized analytics (if used, will be fully self-hosted or privacy-first like Plausible)

You can manage cookies using our Cookie Manager. We honor Global Privacy Control (GPC) signals. We do not use cookies for advertising.

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5. Why We Collect Data

We collect limited data for:

• Providing and securing access to services
• Fulfilling product orders
• Supporting user requests
• Preventing abuse or fraud
• Optional, anonymized research to improve UX
• Delivering voluntary newsletters

We do not collect or use personal data for behavioral ad targeting.

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6. Tools We Use to Store Data

We use the following tools, with service-specific data interactions as noted:

• ShipStation (Conduit.Coffee): used to generate shipping labels; stores customer name and shipping address.
• Strike (Conduit.Coffee): used to process payments; may store billing and payment method information.
• Ghost.org (All services): hosts our blog and voluntary newsletter; stores email addresses for subscribers who opt in.
• Proton (All services): used for encrypted email support; any customer inquiries are stored privately.
• Cal.com (Merchant Portal): used for scheduling optional meetings (e.g., onboarding); stores appointment info including name and email if provided.
• Railway (Merchant Portal): infrastructure platform that may log authentication records, IP addresses, and session tokens related to merchant login only.

We do not use Cloudflare, Google Analytics, or third-party tracking ad networks.

7. Data Transfers

We operate from the U.S. and may use U.S.-based servers. Data may be transferred internationally in accordance with standard contractual clauses where required.

8. Data Retention

We retain only the minimum data required to operate our services. Order information is stored for tax/legal compliance. Pseudonymous data can be deleted on request.

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9. Children's Privacy

Our services are not intended for users under 18 years old. We do not knowingly collect data from minors.

10. Your Rights

You may request:

• Access to your data
• Correction or deletion of your data
• Export of your data
• Removal from our newsletter (if opted in)

Please email contact (at) conduitbtc (dot) com with your request.

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11. Changes to This Policy

We’ll post updates to this page and notify users of material changes.

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12. Open-Source Code

We believe in transparency not only in our privacy practices, but also in our code. Conduit's core services are open source and available for public inspection. You can view our repositories at:

https://github.com/conduit-market

Our code is licensed under the Mozilla Public License 2.0 (MPL 2.0), which ensures transparency while allowing commercial use and modification under open-source terms.

We encourage users and developers to review how we handle data, participate in improving our platform, and help us uphold the highest privacy standards.

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13. Contact

To request data access, deletion, or ask a privacy-related question, contact:

Conduit Hodlings Inc.
3400 Cottage Way, Suite G2 PMB 23234
Sacramento, CA 95825, USA
Email: contact (at) conduitbtc (dot) com