Privacy Policy
Effective Date: 10 September 2025
At Wallet of Satoshi (ACN 630 329 690), we are committed to safeguarding your privacy in accordance with the Privacy Act 1988 (Cth). This Privacy Policy outlines how we collect, access, use, and share your personal information, including data related to custodial and self-custody services. It also details our secure data handling practices, retention and deletion policies, and your rights.
1. Who We Are
This Privacy Policy applies to Wallet of Satoshi Pty Ltd, a provider of digital payment services facilitating Bitcoin and Lightning Network transactions, including custodial and self-custody wallet functionalities.
Contact us:
2. What Data We Collect
We collect and hold the following types of personal information:
- Email Address: Collected when you register for our app or contact us.
- Name: Optionally provided if included in your communications with us (e.g., via email).
- Transaction Data: Details of your Bitcoin and Lightning Network transactions, including amounts, timestamps, and wallet addresses.
- Usage Data: Information such as IP addresses, device identifiers, browser types, pages accessed, and dates/times of visits to our services.
- Cookies and Tracking Technologies: Data collected via cookies and similar technologies to track browsing behavior on our website.
- Analytics Data: Aggregated data from tools like Google Analytics to analyze app performance and enhance our services.
3. How We Collect Your Data
We collect your information in the following ways:
- Direct Collection: When you register for our app or contact our support team.
- Third-Party Collection: From service providers supporting self-custody functionality (e.g., LightSpark) or analytics providers.
4. How We Use Your Data
Your information is used to deliver and improve our services, including:
- Processing and facilitating payments on the Bitcoin and Lightning Networks.
- Complying with legal and regulatory obligations, such as anti-money laundering (AML) and counter-terrorism financing (CTF) laws.
- Enhancing our relationship with you through personalized support and service improvements.
- Preventing fraud and securing your account against unauthorized access.
- Developing new features and conducting user research to enhance the app experience.
- Sending promotional materials, from which you may opt out at any time.
5. Data Sharing
We share your information only as necessary to provide our services or meet legal requirements:
- Trusted Service Providers: We engage providers for data storage, analytics, and operational support to facilitate our services.
- Self-Custody Processing: For self-custody accounts, transaction data (e.g., amounts, timestamps, wallet addresses) may be processed by LightSpark to enable non-custodial Bitcoin and Lightning Network transactions, in accordance with their Privacy Policy.
- Legal Authorities: We may disclose data to regulators (e.g., AUSTRAC) or law enforcement agencies when required by law or to comply with legal processes.
- Business Partners: We may share data with partners offering complementary services related to Wallet of Satoshi, with your consent where required.
- Corporate Transactions: In the event of a merger, acquisition, or sale, your data may be transferred as part of the transaction, subject to confidentiality obligations.
- Cross-Border Disclosure: Some service providers, such as LightSpark, may be located overseas (e.g., in the United States). We take reasonable steps to ensure these providers comply with privacy standards comparable to the Privacy Act 1988 (Cth).
We do not sell, trade, or rent your personal information to third parties for marketing purposes.
6. How We Protect Your Data
We implement industry-standard security measures to protect your information, including:
- Encryption: Data is encrypted both in transit and at rest to prevent unauthorized access.
- Access Controls: Only authorized personnel with a legitimate need can access your data.
- Secure Infrastructure: Our servers are maintained with regular updates to address vulnerabilities.
- Security Assessments: We conduct periodic assessments to identify and mitigate risks.
- Employee Training: Staff are trained on data protection and privacy best practices.
7. Data Retention and Deletion
We retain your information only for as long as necessary to:
- Provide our services and fulfill our contractual obligations.
- Comply with legal requirements, such as AML/CTF record-keeping obligations.
You may request deletion of your data by emailing support@walletofsatoshi.com. We will process such requests within 30 days, subject to any legal retention requirements.
8. Use of Cookies and Analytics
We use cookies and analytics tools to enhance your experience and analyze service performance. You will be notified of cookie use via a website banner, and you can manage preferences through your browser settings:
- Cookies: These enable website functionality and track user activity. Disabling cookies through your browser may affect site functionality.
- Google Analytics: We use Google Analytics to understand app and website usage. You can opt out via the Google Analytics opt-out browser add-on.
9. Public Data and Statistics
We may publish aggregated, anonymized statistics about app usage, such as the total number of payments processed or average transaction fees. These statistics do not identify individual users and are used to provide insights into our service performance.
10. Your Rights
Under the Privacy Act 1988 (Cth), you have the right to:
- Access the personal information we hold about you.
- Request corrections or updates to inaccurate or incomplete data.
- Opt out of marketing communications at any time.
- Request deletion of your data, subject to legal retention obligations.
To exercise these rights, please contact us at support@walletofsatoshi.com.
11. Complaints and Feedback
If you believe we have not adhered to this Privacy Policy or applicable privacy laws, please contact us at:
We aim to resolve complaints within 30 days. If your concern remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC):
12. Data Breach Notification
In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth). We will take prompt action to mitigate risks and inform you of steps to protect your information.
13. App-Specific Permissions and Access
The Wallet of Satoshi app requires certain permissions to function effectively:
- Camera: To scan QR codes for initiating payments or wallet interactions.
- Internet Connection: To process transactions and communicate with the Bitcoin and Lightning Networks.
- Storage: To store transaction history locally on your device for self-custody accounts or on our servers for custodial accounts.
14. Definitions
For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:
- Bitcoin network: The primary Bitcoin blockchain where transactions are recorded and settled directly on the Bitcoin protocol.
- Custodial Account: A wallet managed by Wallet of Satoshi or its designated service providers, where we hold and manage the private keys and funds on your behalf.
- Layer 2: A secondary framework built on top of the Bitcoin network, such as the Lightning Network, designed to enhance transaction speed and reduce costs while leveraging Bitcoin’s security.
- Lightning Network: A Layer 2 solution built on top of the Bitcoin network, designed to facilitate faster and lower-cost transactions while maintaining Bitcoin’s security properties.
- Self-Custody Account: A wallet where you retain sole control over the private keys and associated recovery materials, with no access or control by Wallet of Satoshi.
- Spark: A third-party Layer 2 solution developed by LightSpark that powers the self-custody functionality within the Wallet of Satoshi application.
15. Policy Updates
We may update this Privacy Policy periodically to reflect changes in our services or legal requirements. The latest version will be available at walletofsatoshi.com/privacy.html. For material changes, we will provide reasonable notice via the app, website, or email.