Spend Logo Spend

Privacy Policy

Effective Date: July 14, 2025 | Version: 1.2

This Privacy Policy governs how Spend ("we," "us," or "our") collects, uses, and discloses your information. By downloading, accessing, or using our self-custody cryptocurrency wallet application ("App"), you ("User," "you") agree to be bound by this Privacy Policy and our Terms of Use, available at https://spendwallet.cc/terms. If you do not agree to this Privacy Policy or the Terms of Use, do not use the App.

1. Information We Collect

We believe in data minimization and collect only what is essential to provide our service. The information we collect includes:

  • Wallet Addresses: Your public Solana wallet address along with your public USDC-on-Solana token address is used to identify your account on the blockchain and to associate it with notification services if you opt-in. We never have access to your private keys.
  • FCM Tokens & Notification Preferences: If you choose to receive push notifications, we securely store a Firebase Cloud Messaging (FCM) token linked to your wallet address, along with your specific notification settings.
  • Transaction Hashes: To prevent sending you duplicate notifications for a single transaction event, we temporarily store the publicly-available, unique hash of a transaction.

2. How We Use Your Information

Your information is used strictly for the following purposes:

  • To Send Transaction Notifications: If you opt-in, we use your wallet addresses, your FCM token, and your notification preferences to push real-time notifications about your on-chain transaction activity.
  • For Notification Deduplication: We temporarily use transaction hashes to enhance your user experience by ensuring you receive each notification only once.

3. Data Retention

We retain your information for the following periods:

  • Wallet Addresses: Stored only while you have notifications enabled in the app settings. Automatically deleted when you disable notifications.
  • FCM Tokens: Stored only while you have notifications enabled in the app settings. Automatically deleted when you disable notifications.
  • Notification Preferences: Stored only while you have notifications enabled in the app settings. Automatically deleted when you disable notifications.
  • Transaction Hashes: Temporarily stored for deduplication purposes and automatically deleted within 24 hours of creation.

4. Data Storage and Security

We are committed to protecting your information. As a self-custody wallet, the core principle is that you control your keys and your funds.

  • On-Device Storage: Your private keys are encrypted and stored exclusively on your local device. We cannot access them. You are solely responsible for their security.
  • Third-Party Storage: The limited data we handle (FCM tokens and temporary transaction hashes) is stored securely using Cloudflare's D1 and KV storage services, which employ industry-standard encryption and security measures.
  • International Data Transfers: Our notification service utilizes Google Firebase, which may process data internationally. All transfers are protected by appropriate safeguards.

5. Data Sharing and Disclosure

We do not sell, trade, or rent your personally identifiable information. Your data is not shared with third parties, except:

  • Service Providers: We work with trusted third-party service providers (such as Google Firebase for notifications) who are bound by strict data protection agreements.
  • Legal Requirements: We may disclose information if required by law, regulation, legal process, or governmental request.
  • Safety and Security: We may disclose information to protect the rights, property, or safety of our users or others.

6. Your Rights and Choices

You have complete control over your data within the Spend app and the following rights:

  • Push Notifications: You can opt-out of push notifications at any time by navigating to the App's settings and disabling them. Doing so will initiate the deletion of your FCM token, wallet address link, and all associated notification preferences from our storage systems. Due to Cloudflare's edge caching, complete deletion may take up to 60 seconds.
  • Data Access: You can request access to the personal information we hold about you.
  • Data Deletion: You can request deletion of your personal information at any time.
  • Data Portability: You can request a copy of your data in a machine-readable format.

To exercise any of these rights, contact us at privacy@spendwallet.cc.

7. Children's Privacy

Our App is not intended for individuals under the age of 13 (or 16 in the European Union). We do not knowingly collect personal information from children under these ages. If we become aware that a child has provided us with personal information, we will take immediate steps to delete it.

8. Regional Privacy Rights

Depending on your location, you may have additional privacy rights:

  • European Union: Under GDPR, you have rights to access, rectify, erase, restrict processing, object to processing, and data portability.
  • California: Under CCPA, you have rights to know what personal information is collected, delete personal information, and opt-out of sale (though we don't sell data).
  • Other Jurisdictions: We respect and comply with applicable privacy laws in all jurisdictions where we operate.

9. Changes to Our Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

  • Update the "Effective Date" and Version Number: The date and version number at the top of this policy will reflect when changes become effective.
  • Post the Updated Policy: The revised policy will be made available on our website and accessible through the app's privacy policy link.
  • Provide Notice for Material Changes: For significant changes that substantially affect how we collect, use, or share your information, we will provide prominent notice through the app interface or other appropriate means.

Your continued use of the App after any changes become effective constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

If you do not agree with any changes to this Privacy Policy, you should discontinue use of the App.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: support@spendwallet.cc