SPDY Mobile Application

Privacy Policy

Last updated: August 31, 2026

SPDY (“SPDY,” “we,” “us,” or “our”) provides a mobile application for account, payment, digital-asset wallet, merchant, and over-the-counter transaction services. This Privacy Policy explains how we collect, use, share, retain, and protect information when you use the SPDY app.

Information we collect

Depending on the features you use, we may collect:

• Account and contact information: name, email address, phone number, password and account identifiers.
• Profile and identity information: date of birth, gender, country, state, city, street address, postal code, profile photo, and identity-verification information or documents you submit through our verification provider.
• Financial and transaction information: bank-account details, payment and transaction history, transaction amounts, currencies, counterparties, wallet addresses, and digital-asset balance or transfer information.
• Device and app information: device identifiers and push-notification tokens, app settings, security or authentication information, and crash or diagnostic information.
• Camera, photos, and location: when you choose to use them for identity verification or to scan/upload information, the app may access your camera, photo library, and location. We request these permissions only when needed for the feature.

How we use information

We use information to create and secure accounts; verify identity and eligibility; provide wallets, payments, merchant, and OTC transaction services; process and administer transactions; communicate service, security, and transaction updates; prevent fraud and abuse; comply with legal, regulatory, tax, anti-money-laundering, and recordkeeping duties; troubleshoot; and improve the app.

How we share information

We share information only as needed to provide the services, meet legal obligations, or protect users and our services. This can include:

• Service providers: Firebase/Google for authentication, database, storage, notifications, and crash reporting; Persona for identity verification; Fireblocks for digital-asset wallet infrastructure; and payment, liquidity, market-data, blockchain-data, and communications providers used to process or support transactions.
• Transaction participants and financial partners: where needed to complete a requested transaction, including merchants, banks, payment processors, digital-asset providers, and liquidity providers.
• Legal and safety recipients: regulators, law enforcement, professional advisers, or other parties when required by law, legal process, or to protect rights, safety, security, or prevent fraud.
• Business transfers: in connection with a merger, financing, acquisition, reorganization, or sale of assets, subject to applicable law.

We do not sell personal information for money. We do not use personal information for third-party behavioral advertising.

Data retention

We retain information for as long as needed to provide the services and for legitimate business, security, dispute-resolution, legal, regulatory, tax, and recordkeeping purposes. Retention periods may be longer where financial-services or anti-money-laundering requirements apply.

Your choices and rights

You may update certain profile information in the app. You can control device permissions, including camera, photos, location, and notifications, in your device settings. You may request access to, correction of, or deletion of personal information by contacting us. We will respond in accordance with applicable law; some information may need to be retained for legal, regulatory, security, fraud-prevention, or transaction-record purposes.

You may request account deletion in the app. Deleting an account removes the account and related information from active systems where applicable, subject to the retention requirements described above.

Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No system or method of transmission can be guaranteed completely secure.

Children

The SPDY app is not directed to children, and we do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us so that we can review the request.

International processing

Your information may be processed in countries other than the one where you live. Those countries may have data-protection laws that differ from the laws in your country.

Changes to this policy

We may update this Privacy Policy when our practices, services, or legal requirements change. We will post the updated policy here and revise the “Last updated” date.

Contact us

For privacy questions or requests, email marco@spdyapp.com.