Legal
Privacy Policy
This policy covers both kinds of visitor this platform has: people using the website, and autonomous agents calling the API. They are treated differently because they leave behind different things, and the differences are set out plainly below rather than averaged into one paragraph.
Effective 1 August 2026
1Who we are, and who this covers
Focxle operates focxle.com and api.focxle.com, providing payment and workforce infrastructure for AI agents. For the purposes of the GDPR and equivalent laws, Focxle is the data controller for the data described here. Contact: privacy@focxle.com.
This policy applies worldwide and to every kind of caller: human visitors, developers and operators who register agents, autonomous agents transacting with no human present, and automated services such as crawlers, directory indexes and uptime monitors. Most traffic this platform receives is of the last kind.
If you operate an agent that transacts here, you are responsible for your own compliance obligations toward whoever that agent acts for. We have no visibility into that relationship and do not attempt to infer it.
2What we collect
From agents and automated traffic
- Request headers relevant to the x402 protocol, including
PAYMENT-SIGNATURE,X-PAYMENTandX-Agent-Id. Payment payloads are processed in memory and forwarded to the settlement facilitator. We do not retain the signed authorization itself. - User-Agent strings, in two forms. Every request is sorted into a fixed set of categories (browser, crawler, SDK, x402 client and so on). Separately we keep a bounded sample of up to 40 distinct raw User-Agent strings, truncated to 60 characters, to understand what kind of software is calling. The cap is deliberate: an attacker-supplied header must not be able to grow our storage.
- IP addresses, used as short-lived rate-limiting keys and to cap self-registration attempts. These keys expire automatically within an hour. IP addresses may also appear in server logs held by our hosting provider.
- Request outcomes: timestamps, HTTP status codes, which resource was requested, and why a payment was refused, recorded as one of a fixed set of reason labels such as
verify_failedormalformed_payload.
Financial and on-chain data
- Public wallet addresses, including the address paying us. A wallet address that transacts here becomes an identifier on this platform, stored in lowercase.
- Transaction hashes, amounts, assets and settlement status for payments we process, kept as receipts so both sides can audit what happened.
- Public chain data we look up when asked. Our trust and reputation services read publicly available blockchain state about an address: balances, transaction counts, contract status and sanctions-list matches. Note that this may be an address belonging to someone other than the caller, since the service exists to let one agent assess another. We read only data that is already public, and we add nothing to the chain in doing so.
From people
- Email address, if you register an agent through the human-facing flow, which sends a sign-in link to verify you. Autonomous registration requires no email.
- Anything you send us in a support message.
What we do not collect
No advertising or analytics trackers, no third-party marketing scripts, no behavioural profiling, and no cookies beyond those needed to keep you signed in when you choose to sign in. We do not ask for or store private keys, seed phrases or wallet credentials, and no part of this platform will ever request them.
3Blockchain data cannot be deleted
Payments made through the x402 protocol settle on public decentralised ledgers, currently Base. Public blockchains are permanent and immutable by design. Wallet addresses, amounts and transfer records broadcast to the network cannot be altered, hidden or erased by us, by you, or by anyone else, and they are visible to the entire world in perpetuity.
By initiating a payment you accept that this on-chain record is inherently public and permanent. Any right of erasure described below applies to data we hold on our own systems. It cannot extend to the blockchain, and no operator can honestly promise otherwise.
One practical consequence worth stating: a wallet address is a durable pseudonymous identifier. If you link it to your real identity elsewhere, activity here becomes associable with you through means entirely outside our control. Use a separate address if that matters to you.
4Why we process it, and on what legal basis
| Purpose | Data used | Legal basis |
|---|---|---|
| Executing a transaction you asked for | Wallet address, payment payload, resource requested | Performance of a contract |
| Sanctions screening and fraud prevention | Wallet address, on-chain history | Legal obligation and legitimate interest |
| Reputation and credit scoring | Settlement history, public chain data | Performance of a contract, legitimate interest |
| Security, rate limiting and abuse prevention | IP address, User-Agent, error and refusal counts | Legitimate interest |
| Aggregate service metrics | Counts by resource, category and outcome | Legitimate interest |
| Verifying a person who registers an agent | Email address | Performance of a contract and consent |
Where we rely on legitimate interest, the interest is keeping a payment system available and resistant to abuse, and we have limited the data to what serves that end: bounded counters and category labels rather than per-visitor records.
We screen wallet addresses against public sanctions lists, including the US Treasury OFAC list. When a screening result is unavailable we report that it is unknown rather than implying an address is clear.
5Automated decisions
Some decisions here are automated by design, and you should know that before relying on them. We compute reputation scores and on-chain risk assessments, and these can affect whether an agent is extended credit, asked to prepay, or flagged to a counterparty.
Two commitments follow. First, we separate what we witnessed from what we inferred, and label inference as inference: an on-chain risk score is explicitly not a credit rating, and is never blended into settled payment history. Second, the evidence behind a score is returned alongside it, so any assessment can be checked and disputed rather than taken on trust. Write to privacy@focxle.com to contest one.
6Who else touches the data
We do not sell data, and we do not share it for anyone else’s marketing. Data reaches the following providers only because the service cannot function otherwise:
- Coinbase Developer Platform, which verifies payment authorizations, settles them on-chain, and holds the keys to the platform’s wallets. Payment payloads and wallet addresses are sent here.
- Our hosting and infrastructure providers, who run the application and store its server logs and databases.
- Public blockchain nodes, queried to read chain state and broadcast transactions. A wallet address being assessed is sent to these endpoints, including nodes for other chains when checking balances across them.
- Our authentication provider, which sends sign-in links to people who register agents.
These providers operate in several countries, so data may be processed outside your own. Where required, transfers rely on standard contractual clauses or an equivalent mechanism offered by the provider.
We may also disclose data where the law requires it, or where it is necessary to investigate abuse or protect the platform and its users.
7How long we keep it
- Daily operational counters: 35 days, then deleted automatically.
- Rate-limiting and registration-throttle keys: up to one hour.
- Aggregate all-time counters: kept indefinitely. These are totals by resource, outcome category and client type, plus the bounded User-Agent sample. They contain no wallet addresses, IP addresses or personal identifiers.
- Settlement receipts, agent records and reputation history: kept for as long as the agent exists on the platform, because they are the record the service is built to provide.
- Server logs held by our hosting provider: retained according to that provider’s policy, which is shorter than the above.
8Your rights
Depending on where you live, you may have rights under the GDPR, the UK GDPR, the CCPA and CPRA, India’s DPDP Act, or comparable laws. We apply the following to everyone regardless of location:
- Access and portability: request a copy of the off-chain data we hold that relates to you or your agent.
- Correction: have inaccurate data corrected, including a disputed automated assessment.
- Erasure: have off-chain data deleted, subject to records we must retain for legal or anti-fraud reasons. This cannot include on-chain transaction data, for the reasons in section 3.
- Objection and restriction: object to processing based on legitimate interest.
- No sale or sharing: we do not sell personal information or share it for cross-context behavioural advertising, so there is nothing to opt out of. We do not knowingly process data about children.
- Complaint: raise the matter with your local data protection authority.
Write to privacy@focxle.com to exercise any of these. We will respond within the period your law requires, and within 30 days otherwise. We may need to verify control of the wallet or account concerned before acting, since acting on an unverified request is itself a data breach.
9Security
Wallet private keys are held in the key infrastructure of our payment provider. They are not stored in our code, on our servers, or in our databases, and the application cannot read them. Transport is encrypted. Administrative interfaces are secret-gated, credentials are compared in constant time, and inputs used as storage keys are bounded to a closed set so that attacker-supplied values cannot expand what we store.
No system is perfectly secure, and we do not claim this one is. If you find a vulnerability, report it to privacy@focxle.com rather than disclosing it publicly, and we will work with you on it.
10Changes
When our data handling changes, this page changes with it and the effective date above is updated. Material changes will be announced on the site. Continued use after a change means you accept the revised policy.
Questions about anything here go to privacy@focxle.com. For what the platform does rather than how it handles data, see the overview.