Privacy Policy

Last Updated: February 10th, 2026

This Privacy Policy explains how Split (“Split,” “we,” “our,” or “us”) 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, when available, participation in Split’s bitcoin rewards program. 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 your private keys and cannot access user funds.

2.3 Transaction and Rewards Data

To operate the Service and calculate rewards, Split may collect limited metadata associated with payments you initiate through the app, including:

• Payment amount
• Timestamp
• Whether the receiving identifier matches a participating merchant identifier stored by Split (e.g., a merchant public key)
• Limited internal identifiers needed to attribute spend and calculate rewards (e.g., month/period keys and totals)
• Rewards payout records (e.g., payout amount, timestamp, and status) when rewards are issued

We do not collect names or contact details for typical use. We do not collect your private keys or seed phrase. We do not need itemized purchase details to run Split. We do not intentionally use invoice descriptions/memos for rewards attribution.

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 information, IP-derived region (approximate), and error logs/crash diagnostics. This information is used for reliability, debugging, and security.

3. How We Use Information

We use the limited information we collect to:

• Operate and maintain the Service
• Identify participating merchants using technical identifiers (e.g., merchant public keys)
• Calculate rewards eligibility and proportional rewards amounts
• Issue rewards payouts and maintain payout records
• Monitor for abuse, fraud, or misuse (including attempted manipulation of rewards)
• Improve performance and reliability
• Comply with legal obligations

Split does not sell personal data.

4. Rewards Program and Merchant Attribution

When available, Split may distribute bitcoin rewards to eligible users based on spending with participating merchants during a given period (for example, a calendar month). Split attributes eligible spend by comparing the receiving identifier of a payment (such as a merchant public key) against Split’s database of participating merchant identifiers.

Rewards are discretionary and may be funded by Split and/or sponsors. Rewards are not guaranteed, may change over time, and may be paused or discontinued. Split does not require item-level purchase information to calculate rewards, and we do not control merchants’ goods, services, pricing, or fulfillment.

5. Analytics and Advertising

Split may use limited usage and transaction metadata for internal analytics, product improvement, and fraud prevention. We do not use your transaction metadata for third-party targeted advertising. 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 in the following circumstances:

• With service providers who assist in operating the Service (e.g., infrastructure providers), subject to contractual confidentiality and security obligations
• When required by law, legal process, or a valid government request
• To investigate or prevent illegal activity, fraud, security threats, or abuse of the Service

If Split works with sponsors to fund rewards, Split may share high-level, aggregated program reporting (for example, total eligible spend or total rewards distributed) that is not intended to identify individual users.

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, calculate and administer rewards, 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 for typical use, 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.