Privacy Policy | Spondula

Spondula Ltd (“Spondula”, “we”, “us”, or “our”) operates the Spondula mobile application and web platform (collectively, the “Service”). This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use the Service.

By creating an account or using the Service you acknowledge that you have read and understood this policy.

1. Information We Collect

1.1 Information You Provide

Account information: email address, display name, first and last name, date of birth, country of residence, and account type (personal or merchant).
Authentication credentials: password (hashed, never stored in plain text), PIN (hashed locally), and optional TOTP multi-factor authentication secret.
Wallet information: your Spondula wallet address and an encrypted backup of your recovery phrase (AES-256-GCM encrypted with your PIN; we cannot decrypt it).
Identity verification (KYC): government-issued photo ID, proof of address document, and a selfie for identity matching. These are uploaded securely and used solely for verification purposes.
S Handle: your chosen unique username (e.g. #yourname) for receiving payments.
Contact information: phone number (optional, for discoverability). If you enable contacts sync, device contact phone numbers are checked against our database to find existing Spondula users — we do not store your address book.
Chat messages: messages exchanged with other Spondula users through our in-app messaging feature.
Payment method details: bank account name and sort code/IBAN for fiat on/off-ramp functionality. We do not store full bank account numbers on our servers.
Feedback and support: any information you provide when contacting us at support@spondula.com.

1.2 Information Collected Automatically

Device and session data: browser type and version, operating system, device type (mobile/tablet/desktop), and IP address. This data is collected when you log in and is used to display your active sessions and detect unauthorised access.
Transaction data: on-chain transaction records including sender, recipient, asset, amount, timestamp, and block number. These are recorded on the public Spondula blockchain and cached locally for performance.
Usage preferences: theme, default currency, auto-lock duration, and notification settings stored locally on your device.

1.3 Information We Do NOT Collect

We do not use third-party analytics services (no Google Analytics, Mixpanel, or similar trackers).
We do not use advertising cookies or tracking pixels.
We do not sell, rent, or trade your personal data to third parties.

2. How We Use Your Information

We use the information we collect to:

Create and manage your account.
Process and record transactions on the Spondula network.
Verify your identity as required by applicable anti-money-laundering (AML) and know-your-customer (KYC) regulations.
Enable you to send, receive, and exchange digital assets.
Provide in-app messaging between users.
Display your active device sessions and allow remote session revocation for security.
Send transactional notifications (e.g. payment received, KYC status updates).
Detect and prevent fraud, unauthorised access, and other illegal activity.
Respond to support requests.
Comply with legal obligations.

3. Non-Custodial Wallet Architecture

Spondula is a non-custodial wallet. Your private keys and recovery phrase are encrypted on your device using AES-256-GCM with a key derived from your PIN. The encrypted backup stored on our servers cannot be decrypted by Spondula — only you hold the decryption key. If you lose your PIN and recovery phrase, we cannot recover your wallet.

4. Legal Basis for Processing (GDPR)

If you are located in the UK or European Economic Area, we process your data under the following legal bases:

Contract performance: processing necessary to provide the Service (account management, transactions, messaging).
Legal obligation: identity verification and transaction monitoring required under AML/KYC regulations.
Legitimate interest: fraud prevention, security monitoring, and service improvement.
Consent: optional features such as contacts sync and phone number discoverability, which you can enable or disable at any time.

5. Data Storage and Security

Account data and KYC documents are stored in Google Firebase (Cloud Firestore and Cloud Storage), hosted in data centres within the European Union.
All data in transit is encrypted via TLS 1.2+. Data at rest is encrypted by Google Cloud's default encryption.
KYC documents are stored in a restricted Firebase Storage bucket accessible only to authorised admin personnel during the review process.
Device sessions are tracked per user and can be revoked remotely from the app.
We enforce Content Security Policy (CSP), HSTS with preload, and X-Frame-Options: DENY headers.

6. Data Sharing

We share your personal data only in the following circumstances:

Service providers: Google Cloud / Firebase for hosting and storage; no other third-party processors at this time.
Other Spondula users: your display name, S Handle, and wallet address are visible to users you transact or chat with. Your discoverability settings control whether other users can find you by email or phone number.
Blockchain: transaction data (sender address, recipient address, amount, asset) is recorded on the public Spondula blockchain and is visible to anyone with access to the network.
Legal requirements: we may disclose data to law enforcement or regulators when required by applicable law, court order, or regulatory request.

7. Data Retention

Account data: retained for as long as your account is active.
KYC documents: retained for a minimum of 5 years after account closure, as required by AML regulations.
Transaction records: on-chain data is permanent and immutable by design. Off-chain caches are retained for the life of your account.
Chat messages: retained for the life of the conversation. You may delete individual conversations.
Session data: active sessions are retained until revoked or until 90 days of inactivity.

When you delete your account, we remove your personal data from our systems within 30 days, except where retention is required by law.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

Access the personal data we hold about you.
Rectify inaccurate or incomplete data (via the Personal Details panel in the app).
Erase your account and associated data (account deletion is available in the app).
Restrict or object to processing in certain circumstances.
Data portability: receive your data in a structured, machine-readable format.
Withdraw consent for optional features (contacts sync, phone discoverability) at any time via Privacy settings.

To exercise any of these rights, contact us at privacy@spondula.com.

9. Children's Privacy

The Service is not intended for anyone under the age of 13. We do not knowingly collect personal data from children under 13. Our onboarding process includes an age verification gate. If we learn that we have collected data from a child under 13, we will delete the account and associated data promptly.

10. International Transfers

Your data is processed and stored within the European Union via Google Cloud. If you access the Service from outside the EU, your data will be transferred to and processed in the EU. We rely on Google Cloud's data processing agreements and Standard Contractual Clauses where applicable.

11. Cookies and Local Storage

Spondula does not use tracking cookies. We use browser local storage to persist your encrypted wallet data, transaction cache, user preferences, and session identifier. This data stays on your device and is not transmitted to third parties.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be communicated via in-app notification or email. The “Effective” date at the top indicates the latest revision. Continued use of the Service after changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions about this Privacy Policy or your personal data, contact us at:

Email: privacy@spondula.com
General support: support@spondula.com