Privacy Policy

AstraP2C

Effective Date: August 14, 2026

Replaces version dated December 11, 2025

Who we are. SeleneP2C LLC, a Wyoming limited liability company, doing business as AstraP2C ("Astra P2C," "Astra," "we," "us," or "our"), provides a payroll-integrated platform through which eligible employees of participating employers direct post-tax pay toward automated Bitcoin purchases, held as cbBTC in wallets the employees control. This Privacy Policy describes how we collect, use, disclose, and protect personal information in connection with the Astra platform and services (the "Services"). It applies to enrolled employees, employer program administrators, and visitors to our website.

1. Information We Collect, and What We Deliberately Do Not

We designed the platform to collect the minimum personal information needed to run the benefit.

  • Enrollment and account information: your name, work email, an identifier assigned by your employer, your work state and state of residence (used to determine eligibility, including jurisdictions where the Services are unavailable), and your authentication credentials.
  • Election and payroll information: your contribution elections and change history, and the per-cycle payroll information your employer provides to administer your deductions.
  • Wallet and transaction information: your wallet address and records of purchases, fees, deliveries, and cost basis.
  • Device and usage information: IP address, browser and device type, and sign-in and security logs, collected automatically to secure and operate the platform.
  • Communications: records of your correspondence with our support.

What we do not collect: we do not collect your Social Security number, your home street address, or your private keys, and we do not have access to your wallet's signing credentials. Identity verification (KYC) is performed by Coinbase when you access Coinbase services; information you provide to Coinbase for that purpose goes directly to Coinbase and is governed by Coinbase's own privacy policy, not this one.

2. How We Use Information

  • Provide, operate, secure, and support the Services, including enrollment, eligibility screening, processing deductions and purchases, and delivering assets to your wallet.
  • Maintain transaction and cost-basis records and make them exportable to support your tax reporting.
  • Perform sanctions and wallet-address screening and meet our legal, banking-partner, and Coinbase-related compliance obligations.
  • Communicate with you about the Services, including required disclosures, confirmations, and support.
  • Analyze and improve the Services using aggregated or de-identified information that does not identify you.

We do not use your personal information for targeted advertising, and we do not send marketing on behalf of third parties.

3. How We Share Information

  • Coinbase: to provision your wallet and execute and deliver purchases. Coinbase acts as an independent controller for the services it provides to you under its own terms and privacy policy.
  • Your employer: your employer's payroll administrators can see your enrollment status and contribution elections as needed to run payroll. Your employer cannot see or control your wallet or your assets.
  • Service providers: banking, payment, hosting, screening, and support providers that process information on our behalf under contractual confidentiality and security obligations.
  • Legal and safety: to comply with law, legal process, or regulatory and banking-partner requirements, or to protect the rights, safety, and security of Astra, our users, or others.
  • Business transfers: in connection with a merger, financing, or sale of assets, subject to this Policy's protections.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

4. Public Blockchain Data

Your wallet address and on-chain transactions are recorded on the Base network, a public blockchain. Public blockchain records are visible to anyone, are replicated across the network, and cannot be altered or deleted by Astra or anyone else. While a wallet address does not directly display your name, it is pseudonymous rather than anonymous, and third parties may attempt to associate addresses with individuals. Deletion rights described in this Policy apply to information in our systems, not to public blockchain records.

5. Security

We maintain administrative, technical, and organizational safeguards appropriate to the information we process, including encryption in transit and at rest, role-based access controls, multi-factor authentication for administrative access, logging and monitoring, and a documented incident response plan. Your assets are secured by Coinbase's key infrastructure in a wallet you control; we never hold your private keys. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

6. Retention

We retain personal information for as long as needed to provide the Services and for the periods required by our legal, tax, wage-record, and banking-partner obligations. Enrollment records, payroll-deduction authorizations, elections, and transaction confirmations are retained during your participation and for at least six (6) years thereafter, and remain exportable by you as described in your Enrollment Consent. When retention is no longer required, we delete or de-identify the information; residual copies in routine backups are protected until scheduled destruction.

7. Your Rights and Choices

Depending on your state of residence, you may have rights to access, correct, delete, or obtain a portable copy of your personal information, and to appeal a decision on your request. We extend the following to all users regardless of state: you may access and export your records through the platform; you may correct your information in the platform or by contacting us; and you may request deletion of information we are not legally required to retain (see Sections 4 and 6 for blockchain and retention limits). We will verify your request, respond within the time required by applicable law (and in any event within forty-five (45) days), and will not discriminate against you for exercising your rights. Authorized agents may submit requests as permitted by law. To exercise rights or appeal, contact privacy@astrap2c.com.

8. Cookies and Analytics

We use cookies and similar technologies for sign-in, security, and to understand how the platform is used. We do not use advertising cookies. You can control cookies through your browser; disabling them may limit some features. Our platform does not respond to "Do Not Track" signals, and because we do not sell or share personal information for advertising, opt-out preference signals do not change our processing.

9. Children

The Services are limited to individuals 18 or older, and we do not knowingly collect information from anyone under 18. If you believe a minor has provided information, contact us and we will delete it.

10. Changes to This Policy

We may update this Policy from time to time. For material changes, we will provide notice through the platform or by email before the change takes effect, with the new effective date shown above. Prior versions are available on request.

11. Contact

SeleneP2C LLC d/b/a AstraP2C, Rochester, NY.

Privacy requests: privacy@astrap2c.com

General support: support@astrap2c.com

Document Classification: Public

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