Privacy Policy

Effective date: May 21, 2026

Foundation Devices, Inc. ("Foundation," "Company," "we," "our," or "us") respects your privacy and is committed to handling personal information responsibly. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information in connection with our websites, products, customer accounts, checkout, support, marketing, and related services (collectively, the "Services").

By using the Services, you acknowledge that personal information will be handled as described in this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Services.

Privacy-Forward Purchasing

Foundation designs and sells products for customers who care about privacy and self-custody. We seek to collect and retain only the personal information reasonably necessary to operate our business, provide the Services, fulfill orders, comply with law, prevent fraud and abuse, provide support, and maintain accurate business records.

We do not sell your wallet secrets, seed phrases, recovery phrases, private keys, PINs, passwords, or other secrets. You should never provide those secrets to Foundation, Shopify, Intercom, Flexport, any carrier, or any support representative. Foundation cannot recover lost seed phrases or private keys and will never ask you to disclose them.

Personal Information We Collect

The categories of personal information we collect depend on how you interact with us.

Order and checkout information. When you place an order, we collect and process information needed to complete the transaction, such as products ordered, shipping details, billing details, discount codes, order notes, payment status, fraud-prevention signals, taxes, duties, and order history. Payment card and wallet-payment details are processed by Shopify, payment processors, and payment-method providers. We do not store full payment card numbers.

Customer account information. If you create or use a customer account, we may process account credentials, contact information, order history, saved addresses, marketing preferences, and related account activity through Shopify and related services.

Support and communications. If you contact us, we may collect the contents of your message, contact information, order details, device or application context you choose to share, chat or support history, and related correspondence. We use support and messaging tools, including Intercom, to receive and respond to support requests, provide chat or help experiences, manage support history, and improve support quality. You should not provide wallet secrets, seed phrases, recovery phrases, private keys, PINs, or passwords through support channels.

Shipping, fulfillment, and customs information. We process information needed to fulfill and deliver orders, including recipient name, shipping address, phone number, email address, order contents, customs information, tax or duty details, and tracking information. We currently use Flexport as our primary fulfillment and logistics provider. Where applicable, we may also use carriers, customs brokers, and regional distribution partners, including Bitcoin Brabhant for certain EU or European orders as described in our Shipping Policy.

Website, analytics, and device information. When you visit our websites or interact with our Services, we and our service providers may collect information such as IP address, browser type, device type, operating system, pages viewed, referring pages, interactions with site features, checkout events, cart events, approximate location, cookies, pixels, advertising identifiers, and other usage information.

Marketing and preference information. If you subscribe to updates, respond to a campaign, interact with ads, or otherwise opt in to marketing, we may process your email address, preferences, consent status, engagement with our communications, and related attribution or analytics information.

Information from third parties. We may receive information from service providers, commerce platforms, fraud-prevention vendors, analytics providers, advertising platforms, payment processors, shipping partners, and other third parties that help us operate the Services.

How We Use Personal Information

We may use personal information for the following purposes:

to provide, operate, maintain, and improve the Services;
to process orders, payments, taxes, duties, shipping, returns, warranty claims, and customer support requests;
to create and maintain customer accounts and order history;
to communicate with you about orders, products, security, support, updates, policies, and marketing;
to detect, prevent, investigate, and respond to fraud, abuse, security incidents, chargebacks, and unlawful activity;
to personalize, measure, and improve the website, checkout, support, marketing, and customer experience;
to conduct analytics, attribution, and advertising measurement;
to comply with legal, tax, accounting, customs, sanctions, consumer-protection, and regulatory obligations;
to enforce our terms, policies, and rights; and
for other purposes with your consent or as otherwise permitted by law.

Shopify and Commerce Services

Our store, checkout, customer accounts, order processing, payment flows, fraud-prevention features, and certain analytics and commerce services are operated through Shopify. When you interact with our store or checkout, personal information may be collected and processed by Shopify to provide these services to us and to you.

Shopify may also provide features such as Shop Pay, Shop, customer accounts, fraud prevention, checkout acceleration, analytics, and other commerce services. Shopify's own privacy terms may apply to information Shopify processes for its own services. Shopify's consumer privacy information is available at https://www.shopify.com/legal/privacy/consumers, and Shopify privacy controls are available at https://privacy.shopify.com/.

Cookies, Analytics, and Advertising

We and our service providers may use cookies, pixels, tags, local storage, software development kits, and similar technologies to operate the Services, remember preferences, keep carts and checkout working, provide support features, measure site performance, understand traffic, debug errors, prevent fraud, measure advertising, and improve our Services.

These technologies may be provided by Shopify, Intercom, Google, Meta, X, and other analytics, support, or advertising service providers. For example, we may use Intercom for support messaging, Google Analytics or related Google services, Meta Pixel or related Meta services, X advertising or conversion tools, and similar services to understand traffic, measure ad performance, attribute conversions, detect problems, provide support, and improve the customer experience.

Where required, we will seek consent before using certain cookies or similar technologies. Consent requirements may vary by region and by the type of technology used.

You can often control cookies through browser settings. Some platform-level choices may also be available through Shopify privacy controls, Google, Meta, X, and other providers. Blocking certain cookies or pixels may affect site functionality, checkout, support features, analytics, and advertising measurement.

How We Share Personal Information

We may disclose personal information to the following categories of recipients:

Commerce platform providers, including Shopify and related Shopify services;
Payment and fraud-prevention providers, including payment processors, payment-method providers, chargeback processors, and fraud-screening tools;
Fulfillment and logistics providers, including Flexport, carriers, customs brokers, regional distribution partners, and related service providers needed to deliver products;
Support, communications, and email providers, including Intercom and tools used to provide support chat, manage support history, send transactional emails, send support replies, provide security notices, deliver firmware or product updates, and send marketing communications;
Analytics and advertising providers, including Google, Meta, X, and similar providers used for measurement, analytics, attribution, advertising, and campaign optimization;
Professional advisors, including lawyers, accountants, auditors, insurers, consultants, and financial institutions;
Government, regulatory, customs, law-enforcement, or other parties when we believe disclosure is required or appropriate to comply with law, legal process, sanctions, customs requirements, tax obligations, consumer-protection rules, or to protect rights, safety, and security; and
Business transaction parties in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction.

We may also disclose aggregated or de-identified information that does not reasonably identify you, subject to applicable law.

Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, fulfill orders, maintain customer accounts and order history, provide support, comply with legal, tax, accounting, customs, fraud-prevention, chargeback, warranty, audit, and regulatory obligations, resolve disputes, and enforce our agreements.

Retention periods vary depending on the nature of the information, the purposes for which it is processed, the systems in which it is stored, and applicable legal, contractual, operational, tax, accounting, customs, security, and compliance requirements. Records maintained in Shopify, payment, fulfillment, logistics, tax, accounting, customer-support, and related systems may be retained for different periods.

Where we no longer have a legitimate business or legal need to retain personal information, we will delete, redact, de-identify, or otherwise handle it in accordance with applicable law and the capabilities of the systems in which the information is stored.

Your Privacy Choices and Requests

Depending on where you live, you may have rights to request access to, correction of, deletion of, portability of, or restriction of certain personal information, and to object to or opt out of certain processing. These rights may be subject to limitations and exceptions under applicable law.

You may submit a privacy request by contacting us at hello@foundation.xyz. We may need to verify your identity and your relationship to the information before processing a request.

For Shopify customer data, we may process access or erasure requests through Shopify's merchant tools. In connection with such requests, Shopify may redact personal information such as a customer's name and address while retaining certain order information, such as what was sold and the date and time of sale, in the merchant admin. If you use Shop or Shop Pay, you may also have direct privacy controls through Shopify, the Shop app, or Shopify's privacy portal at https://privacy.shopify.com/.

You may unsubscribe from marketing emails by using the unsubscribe link in those emails or by contacting us. We may still send transactional or service-related messages.

Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your account credentials, wallet secrets, seed phrases, recovery phrases, private keys, PINs, passwords, and device access. Foundation cannot recover wallet secrets and cannot reverse blockchain transactions.

International Processing

We are based in the United States, and we may process and store personal information in the United States and other countries. Our service providers, including Shopify, payment providers, Flexport, carriers, customs brokers, Intercom, analytics providers, and support providers, may process information in multiple jurisdictions. These jurisdictions may have privacy laws that differ from those where you live.

Where required, we rely on appropriate legal mechanisms to transfer personal information across borders.

Children

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, please contact us.

Other Websites and Services

The Services may link to third-party websites, apps, platforms, wallets, payment methods, carriers, support tools, or other services. We are not responsible for the privacy practices of third parties. You should review their privacy policies and terms.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated effective date. If we make material changes, we may provide notice as required by law.

How to Contact Us

If you have questions or requests regarding this Privacy Policy or our privacy practices, contact us at:

Foundation Devices, Inc.
Attn: Legal - Privacy
6 Liberty Square #6018
Boston, MA 02109
Email: hello@foundation.xyz