Privacy & Data Protection
Effective 3 June 2026
1. Introduction and Defined Terms
1.1 This Privacy Policy (the “Policy”) describes how Spondula (“Spondula”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects the Personal Information of any person who accesses or uses the Services (“you”, “your”, or the “User”).
1.2 In this Policy, unless the context otherwise requires: (a) “Personal Information” means any information relating to an identified or identifiable natural person that we collect, hold, or process in connection with the Services; (b) the “Services” means the wallet, identity, verification, and related infrastructure made available by Spondula across the ecosystem; and (c) “S-Handle” means the unique identifier associated with your account within the ecosystem.
1.3 This Policy operates alongside, and is to be read together with, our Terms of Use.
2. Our Commitment to Privacy
2.1 Spondula is committed to protecting Personal Information and to handling User data responsibly and in accordance with applicable law.
2.2 We shall collect only such Personal Information as is necessary to provide the Services, comply with our legal obligations, protect Users, and maintain the integrity of the ecosystem.
3. Information We Collect
3.1 We collect only such information as is necessary to provide the Services, comply with our legal obligations, protect Users, and maintain the integrity of the ecosystem.
3.2 Depending on your use of the platform, the Personal Information we collect may include, without limitation: (a) Account Information, comprising your name, email address, telephone number, S-Handle, and account preferences; (b) Identity-Verification Information, where verification is required, comprising government-issued identification, date of birth, residential address, selfie or biometric verification, and supporting documentation; (c) Transaction Information, comprising transfers, payment requests, Creator Page interactions, wallet activity, and transaction references; and (d) Device Information, comprising device type, operating system, browser information, security and authentication information, and IP address.
4. Purposes for Which We Collect Information
4.1 We may use the Personal Information we collect for the following purposes, including without limitation: (a) to provide the Services; (b) to verify identity; (c) to prevent fraud; (d) to protect Users; (e) to comply with our legal obligations; (f) to improve platform functionality; (g) to provide customer support; and (h) to maintain the security of the ecosystem.
4.2 Identity verification shall be governed by our KYC & AML Policy.
5. No Sale of Personal Information
5.1 Spondula does not sell user personal information to third parties.
6. Access to Personal Information
6.1 Access to Personal Information shall be restricted to authorised personnel, approved service providers, and such third parties as may be necessary to provide the Services, satisfy our legal obligations, or protect the ecosystem.
7. Disclosure to Third Parties
7.1 We may disclose Personal Information to the following categories of recipient, including without limitation: (a) identity-verification providers; (b) compliance providers; (c) fraud-prevention providers; (d) technology providers; (e) legal authorities, where required by law; and (f) independent ecosystem participants, where necessary to facilitate services requested by you.
7.2 Personal Information shall be disclosed only where there exists a legitimate business, legal, compliance, or operational reason to do so.
8. Cookies and Similar Technologies
8.1 We may use cookies and similar technologies to improve functionality, security, analytics, and the User experience.
8.2 You may control certain cookie settings through your browser, to the extent such controls are made available to you.
9. Retention of Information
9.1 Retention periods shall vary depending on legal requirements, regulatory obligations, fraud-prevention needs, security requirements, and business operations.
9.2 For the avoidance of doubt, certain records may be retained even after an account has been closed, to the extent required for the purposes described in clause 9.1.
10. Your Rights
10.1 Subject to applicable law, you may exercise the following rights in respect of your Personal Information: (a) you may request access to the Personal Information held by Spondula; (b) you may request that we update or correct your Personal Information where it is inaccurate or incomplete; and (c) you may request the deletion of your Personal Information, where such deletion is permitted by applicable law.
10.2 Notwithstanding clause 10.1(c), certain records may be retained where necessary for legal, regulatory, audit, fraud-prevention, or compliance purposes.
11. Transaction Information
11.1 Spondula may process such Transaction Information as is necessary to provide the Services, maintain security, satisfy compliance obligations, and support the operations of the ecosystem.
12. Visibility of Wallet Balances
12.1 The visibility of balances and transactions depends upon the architecture of the underlying network. Certain transaction information may be visible on the ledger, whereas personal identity information shall remain protected through platform controls and privacy safeguards.
13. Marketing Communications
13.1 Spondula may communicate with you in relation to account activity, security alerts, product updates, service announcements, and promotional campaigns.
13.2 You may manage your marketing preferences where, and to the extent, such controls are made available to you.
14. Information Security
14.1 Spondula employs technical, organisational, and operational safeguards designed to protect Personal Information against unauthorised access, misuse, loss, or disclosure.
14.2 For the avoidance of doubt, no system can guarantee absolute security; nevertheless, the protection of User information remains a core priority of Spondula.
15. Contacting Spondula About Privacy
15.1 Any questions regarding privacy, Personal Information, or data protection may be directed to [email protected].