Privacy Policy

Last Updated: December 19th, 2025

This Privacy Policy explains how Split (“Split,” “we,” “us,” or “our”) collects, uses, and protects information when you use the Split platform, including our mobile applications and related services (collectively, the “Service”). By using the Service, you agree to the collection and use of information as described in this Privacy Policy.

1. Overview

Split is designed to be privacy-preserving by default. We provide non-custodial software that enables payments over the Bitcoin Lightning Network and participation in merchant-offered rewards. We do not custody user funds.

2. Information We Collect

2.1 Information We Do Not Collect

Split does not collect:

• Names
• Email addresses (unless you voluntarily contact us)
• Phone numbers
• Physical addresses
• Bank account information
• Government-issued identification
• Private keys or wallet seed phrases

2.2 Wallet and Identity Information

Users are identified within the Service by a Lightning wallet public key or equivalent cryptographic identifier generated by wallet software (including the Breez Spark SDK). We do not control or manage wallet keys and cannot access user funds.

2.3 Transaction Data

Split collects limited transaction metadata generated during use of the Service, including:

• Payment amounts associated with merchant transactions
• Confirmation that a transaction involved a registered merchant public key

Split does not:

• Log user-to-user payments
• Store transaction memos or invoice descriptions
• Store full transaction histories
• Associate transactions with personal identity information

All transaction data is derived from use of the Service and underlying wallet software.

2.4 Device and Usage Information

We may collect limited technical information necessary to operate and secure the Service, such as app version, basic device identifiers, and error logs/crash diagnostics. This information is used solely for operational and security purposes.

3. How We Use Information

We use the limited information we collect to:

• Operate and maintain the Service
• Identify registered merchants
• Support reward functionality
• Monitor for abuse, fraud, or misuse
• Improve performance and reliability
• Comply with legal obligations

Split does not sell personal data.

4. Rewards and Merchant Data

Rewards are created, offered, and fulfilled by merchants. Split does not guarantee reward availability and does not control how merchants fulfill rewards. Any data related to rewards is used only to support platform functionality and enforcement against abuse.

5. Analytics and Advertising

Split currently uses transaction and usage data only for internal analytics. We do not currently use transaction data for advertising, targeted marketing, or third-party promotions. If our data practices change in the future, we will update this Privacy Policy and provide notice as required by law.

6. Data Sharing

We do not sell or rent user data. We may share limited information:

• With service providers who assist in operating the Service (e.g., infrastructure providers)
• When required by law, legal process, or regulatory request
• To investigate or prevent illegal activity, fraud, or security threats

All sharing is limited to what is reasonably necessary.

7. Data Security

We implement reasonable technical and organizational measures to protect the limited data we collect. However, no system is completely secure. You acknowledge that use of the Service is at your own risk. Split cannot recover lost wallet keys or reverse Lightning payments.

8. Data Retention

We retain information only for as long as necessary to operate the Service, comply with legal obligations, and enforce our Terms of Service. We periodically review and delete data that is no longer required.

9. Children’s Privacy

Split does not knowingly collect personal information from children. If you believe a child has provided personal information to Split, please contact us so we can take appropriate action.

10. Your Choices

Because Split does not collect traditional personal identity information, there may be limited ability to access, modify, or delete data associated with your use of the Service. You may stop using the Service at any time.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be effective when posted. Continued use of the Service after changes constitutes acceptance of the revised policy.

12. Contact Us

Email: taylor@split-loyalty.com

Split is based in Washington, DC.