1. Introduction; Who We Are
TokenOS AI, LLC is the controller of the personal information described in this Policy. Capitalized terms not defined here have the meanings given in our Terms of Service. Where the Terms of Service require Node Operators to be verified and screened before payouts are released, this Policy describes the information involved, who processes it, how long it is kept and the rights you have in relation to it.
The Platform is intended for persons aged eighteen (18) or older. We do not knowingly collect personal information from anyone under eighteen and will delete any such information we discover.
2. Information We Collect
2.1. Blockchain & Wallet Data. We collect public blockchain data when you connect to the Platform, including your cryptographic wallet addresses, token balances ($TOS), staking participation, node purchases and payouts, token launches and x402 transaction history across supported chains.
2.2. Agent and Build Data. When you use the Context & Intent Engine (CIE), the IDE or the Agent Builder, we collect the prompts, intent decompositions, code, project files and architectural configurations you input into the workspace, together with build logs and preview data.
2.3. Compute, Node and Hardware Data. For both TokenOS-provisioned nodes and external hardware (BYOG — bring your own GPU) we collect operational data including hardware specifications, serial numbers and device fingerprints, Intel TDX (or equivalent) attestation reports, firmware and driver versions, uptime and performance statistics, verification metrics and service-fee accrual. To verify where hardware is physically located we also collect network telemetry: IP addresses and autonomous-system information, multi-vantage-point latency measurements, routing paths and connection metadata. We do not accept self-reported hardware location.
2.4. Platform Usage, Device and Location Data. We automatically collect IP addresses, approximate geolocation derived from IP address, browser and device type, operating system, language, referring pages, session identifiers and interactions with Platform dashboards. We use VPN, proxy, Tor and hosting-provider detection and device-intelligence signals to enforce the Restricted Jurisdiction block and to detect fraud.
2.5. Identity Verification Data (Node Operators). To verify Node Operators before we issue a node entitlement, register external hardware or release a payout, we use a third-party identity verification provider, currently Didit Identity, Inc. and its affiliate Didit Identity Spain, S.L. (“Didit”). When you complete verification, Didit collects, as our service provider and through its own hosted flow: images and data extracted from your government-issued identity document (passport, national identity card or driver's licence), including your name, date of birth, document number, issuing country and expiry date; a selfie and liveness capture; your declared country of residence and, where a step-up applies, your residential address and a proof-of-address document; for identity documents issued by certain countries, your email address; and device and network signals. Didit presents its own terms and privacy notice in the flow. TokenOS receives from Didit the outcome of the verification, session and case reference identifiers, your verified full legal name, date of birth, country of residence, document type, issuing country and expiry date, a summary of screening results, risk-signal categories and the assigned tier. TokenOS does not receive or store copies of your identity document, your selfie or liveness recording, biometric data, your full document number or your residential address (we store the country and the proof-of-address outcome only). TokenOS personnel never request identity documents by email, support ticket, chat or messaging application.
2.6. Business Verification Data. If you verify a business, we and Didit collect the entity's legal and trade names, registration number, jurisdiction and date of formation, registration status, registered and operating addresses, formation and governance documents, an ownership and control structure chart with the names and percentage interests of each beneficial owner, evidence of the authorized representative's authority, and the identity verification data described in Section 2.5 for the authorized representative and each beneficial owner or controlling person. Business source documents are held by Didit or in the compliance case file; TokenOS stores the verified entity attributes and ownership summary.
2.7. Sanctions, Watchlist and Wallet Screening Data. We and our Verification Providers screen Node Operators, their beneficial owners and representatives, Compute Buyers, Enterprise Customers and connected wallet addresses against government sanctions lists (including the OFAC SDN and Consolidated lists, BIS lists, the Consolidated Canadian Autonomous Sanctions List and, where applicable, UN, EU and UK lists), politically-exposed-person sources and, for enhanced-review cases, adverse-media sources, at onboarding and on a recurring basis. We use blockchain-analytics services to assess a wallet's direct and indirect exposure to sanctioned addresses, mixers and other high-risk counterparties. We record the list family, list version, match disposition, reviewer and date of every result. Where identity fraud is confirmed, the associated wallet and device identifiers are added to an internal deny list.
2.8. Payout Wallet Proofs. When you designate or change a payout wallet we collect the chain and address, the challenge message we issued, your signature, the time of signing and the wallet screening result, and we retain the history of every payout wallet change.
2.9. Accredited-Investor Verification Data. Where a Node Operator attests to accredited-investor status under Rule 506(c) of Regulation D, we or a verification agent acting for us may collect and review supporting evidence such as tax forms, bank or brokerage statements, credit reports, entity formation and financial documents, written confirmations from a broker-dealer, investment adviser, attorney or accountant, and written representations regarding minimum investment and financing. We retain the verification record and the basis relied upon.
2.10. Tax Information. Before releasing payouts we collect IRS Form W-9 or the applicable Form W-8, including taxpayer identification numbers, and we generate information returns where required by law. Tax forms and identifiers are stored separately from verification records with access restricted to our finance and legal functions.
2.11. Compute Buyer and IaaS Customer Identification Data. For Compute Buyers and Enterprise Customers, and in particular foreign persons obtaining Infrastructure-as-a-Service capacity, we collect the information required by our Customer Identification Program under Executive Order 13984: legal name, address, nationality or jurisdiction, means and source of payment, email address, telephone number, IP addresses used to access the service, beneficial-ownership information for entities, and any disclosure you make regarding the training of large AI models.
2.12. Communications and Support. We collect the content of your communications with us, including support requests made through our Zendesk-powered help desk, verification status enquiries, compliance correspondence and arbitration notices, and the verified email address associated with your operator account.
3. How We Use Your Information
We use the information we collect to:
- Facilitate the building, deployment and operation of AI agents and dApps, and process wallet-to-wallet settlements via the x402 protocol.
- Manage node deployments, verify hardware identity, integrity and physical location, route workloads, and calculate and settle node service fees and staking distributions under the v4 protocol fee allocation (50/25/25).
- Verify the identity of Node Operators, their representatives and beneficial owners; confer or withhold Verified Status; prove control of payout wallets; and evaluate the payout gate at every release.
- Screen users and wallets against sanctions, watchlist and politically-exposed-person sources; compute the OFAC fifty-percent rule across ownership structures; assign risk tiers under our Counterparty Standard; enforce the Restricted Jurisdiction block; and block, hold or report property where required by sanctions law.
- Comply with export-control, IaaS customer-identification, data-security, securities, tax and other legal obligations, including reporting to OFAC, BIS, the Department of Commerce, FinCEN, the IRS and other authorities where required.
- Verify accredited-investor status and eligibility, and record the version of the Terms of Service you accepted.
- Detect, investigate and prevent fraud, identity misuse, account compromise, circumvention of our controls and abuse of the Platform.
- Provide support, communicate verification and payout status, send security and compliance notices, and respond to your requests.
- Maintain the security, reliability and performance of the Platform and analyze how it is used so that we can improve it.
- Establish, exercise or defend legal claims and enforce our Terms of Service and commercial contracts.
4. Legal Bases for Processing
Where the law of your jurisdiction (including Canada, the European Economic Area and the United Kingdom) requires a legal basis, we rely on: performance of a contract with you (operating the Platform and paying Node Operators); compliance with legal obligations (sanctions screening, export controls, recordkeeping, tax and regulatory reporting); our legitimate interests in preventing fraud and financial crime, securing the Platform and enforcing our terms, balanced against your rights; and your consent, which we or our Verification Provider obtain in the verification flow for the processing of biometric information and which you may withdraw, subject to the consequence that verification—and therefore node activation and payouts—cannot be completed without it.
5. Biometric Information Notice
Didit's selfie and liveness checks create biometric information derived from the geometry of your face. It is used solely to confirm that you are the person shown on your identity document, to detect presentation attacks and to detect the same face appearing across multiple accounts, and for no other purpose. Didit presents its own notice and obtains your written consent in the verification flow before capture. Biometric information is processed and retained by Didit, not by TokenOS, for the period we configure with Didit under our retention schedule, and is then permanently destroyed; it is destroyed in any event no later than the time the purpose of collection has been satisfied or within the period required by applicable biometric-privacy law, whichever is earlier. Biometric information is never sold, leased, traded or otherwise profited from, and is not disclosed except to Didit as our service provider, with your consent, or as required by law. Residents of Illinois, Texas, Washington and other jurisdictions with biometric-privacy statutes have the rights described in those statutes; this Section serves as our written retention and destruction policy for biometric information.
6. Hardware Privacy & Confidential Compute
For compute nodes, TokenOS utilizes hardware-enforced privacy, including Intel TDX secure enclaves where applicable. As a routing network, we prioritize data isolation. The actual data, models and contextual workloads processed by Compute Buyers inside the nodes remain encrypted. TokenOS does not have access to, and does not collect, the contents of the compute workloads executed on the network. Attestation reports and telemetry describe the hardware and its location, not the workload.
7. Information Sharing
We do not sell your personal information and we do not share it for cross-context behavioral advertising. We share information only in the following circumstances:
- Identity verification and screening providers: currently Didit, which processes your information on our behalf to verify your identity or business and to screen you and your wallets against sanctions, watchlist and politically-exposed-person sources, as described in Sections 2.5 to 2.7; and blockchain-analytics, IP-geolocation, device-intelligence and accredited-investor verification services that act as our processors under written agreements.
- Infrastructure and operations providers: cloud hosting, database, email, analytics, support-desk (Zendesk) and security vendors that assist in operating the Platform, and the third-party model providers (including OpenAI, Anthropic and Google) that process prompts within the CIE.
- Regulators and authorities: OFAC, BIS, the Department of Commerce, FinCEN, the IRS, the SEC, the Department of Justice, Global Affairs Canada and other governmental, regulatory, tax or law-enforcement authorities where we are required or permitted by law to report, including reports of blocked property, export-control matters, large-AI-model training by foreign persons and tax information returns.
- Legal process and protection: in response to a subpoena, court order, regulatory audit or lawful request; to enforce our Terms of Service; or to protect the rights, property, safety or security of TokenOS, our users or the public.
- Corporate transactions: in connection with a merger, acquisition, financing, reorganization or sale of assets, subject to confidentiality obligations.
- With your direction or consent.
Our service providers are bound by contract to process information only on our instructions and to protect it appropriately. We limit what we send to each provider to what it needs: for example, verification inquiries carry your TokenOS operator identifier as the reference, not your wallet address alone.
9. Blockchain Immutability
Any transactions executed on decentralized networks (such as staking $TOS, purchasing node terms, receiving payouts, launching tokens or making x402 payments) are public and immutable. We cannot erase or alter data that is published to decentralized ledgers, and our screening of public wallet activity necessarily draws on that data.
10. International Transfers
TokenOS is organized in the United States and stores and processes information in the United States. Didit processes and stores identity verification data in the European Union (on Amazon Web Services infrastructure) and transfers the verification outcome and verified attributes described in Section 2.5 to TokenOS in the United States under the European Commission's standard contractual clauses or another recognized transfer mechanism. If you are located outside the United States—including in Canada, the European Economic Area or the United Kingdom—your information is transferred to and processed in the United States, and your identity verification data is processed in the European Union, where privacy laws may differ from those of your jurisdiction. Where required, we rely on contractual safeguards with our service providers and on the necessity of the transfer for the performance of our contract with you and for compliance with legal obligations.
11. Data Retention
We retain information for as long as necessary to fulfil the purposes described in this Policy, to comply with legal obligations, to resolve disputes and to enforce our agreements. In particular:
- Verification outcomes, screening results and list versions, tier decisions, holds and releases, payout wallet proofs, payout evidence and related audit events: ten (10) years after your relationship with TokenOS ends, to meet United States sanctions recordkeeping obligations (31 C.F.R. § 501.601).
- Export-control records relating to hardware provenance, location and licensing: not less than five (5) years (15 C.F.R. Part 762).
- IaaS Customer Identification Program records and data-security-program records: for the periods required by the applicable regulations.
- Tax forms, taxpayer identifiers and information returns: for the periods required by the Internal Revenue Service.
- Identity documents, selfies, liveness recordings, biometric information, full document numbers and proof-of-address or business source documents held by Didit: for the period set in our retention schedule, after which Didit deletes them; these are not subject to the ten-year rule, which applies to TokenOS decision records rather than biometric source material.
- Operational, build and usage data: for as long as your wallet or account remains active and thereafter as necessary for the purposes above.
A litigation hold, preservation demand or regulatory inquiry suspends deletion of the records it covers, in every system, until it is lifted.
12. Your Rights and Choices
Depending on where you live, you may have the right to access the personal information we hold about you, to receive a copy of it in a portable format, to correct inaccurate information, to request deletion, to object to or restrict certain processing, to withdraw consent, and not to be discriminated against for exercising these rights. You may exercise these rights by contacting us at info@tokenos.ai. We will verify your identity before responding and will respond within the time required by applicable law.
We cannot delete verification outcomes, screening results, wallet proofs, payout records or other decision records that we are required by law to retain, or information needed to complete a transaction, detect fraud or security incidents, or defend legal claims; where we decline a request on these grounds we will tell you which records are kept and why. Requests concerning information held by Didit may also be made directly to Didit using the contact details in its verification privacy notice. Residents of Canada may contact the Office of the Privacy Commissioner of Canada; residents of the European Economic Area and the United Kingdom may lodge a complaint with their supervisory authority; California residents may exercise the rights described in the California Consumer Privacy Act, including the right to know, delete and correct, and may appeal a decision by replying to our response. We do not sell personal information or share it for cross-context behavioral advertising, and we do not use sensitive personal information for purposes other than those permitted by law.
13. Security
We protect information using administrative, technical and physical safeguards appropriate to its sensitivity, including encryption in transit and at rest, role-based access controls with multi-factor authentication for compliance and administrative systems, separation of duties between the teams that decide verification outcomes and the teams that execute payouts, restricted and logged access to any raw identity material held by our Verification Provider, exclusion of production identity data from development and test environments, and the exclusion of identity documents, selfies, document numbers and biometric data from our databases, logs and support systems. Our Verification Provider maintains SOC 2 Type II and ISO 27001 certifications. No system is perfectly secure; if we learn of a breach affecting your information we will notify you and the relevant authorities as required by law.
14. Changes to This Policy; Contact
We may update this Policy from time to time. Material changes will be announced on the Platform or by notice to the contact details associated with your account. Questions, requests and complaints regarding this Policy or our handling of your information may be directed to info@tokenos.ai.