Privacy Policy

Last updated: 07/3/2025

This Privacy Policy is part of the Splash Terms of Service. All terms, conditions, and terminology are consistent with the Terms of Service, and the Terms of Service are incorporated into this document by reference.

This policy governs the use of the Splash website at splashwallet.xyz and the associated tools and services.

Collectively, the website and the associated tools and services are referred to as the “Services” in these terms. The operator may offer other products and services.

The Services do not include outside websites or platforms which may be linked or interconnected to the Services. Such outside platforms may have their own terms of service, which control for all transactions on such platforms. These outside platforms may include, but are not limited to:

The Hyperliquid interface, owned by Hyperliquid Corp., at app.hyperliquid.xyz

Cybernetics Incorporated, a Delaware C-Corp, operates the Services. It and its affiliates are referred to in this document as the “operator,” “we,” or “us.”

The Blockchain

Blockchain technology is at the core of the service. Blockchains are decentralized public ledgers made up of digitally recorded data in a chain of packages called ‘blocks’. The way these blocks are linked is chronological, meaning that data which is finalized on a blockchain is impossible to reverse or otherwise censor once it is recorded. Since these ledgers are distributed all over the world (across several ‘nodes’ which replicate the ledger and form consensus to secure its accuracy), there is no single person or computer making decisions or otherwise administering the system (such as an operator of a cloud computing system), and there is no centralized place where it can be said to be located either.

By design, a blockchain’s records cannot be changed or deleted. All information recorded on blockchains, including any transactions you make when using them, are entirely public and immutable. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing, of your personal data. Data on the blockchain can’t be erased or changed.

In certain circumstances, to comply with our contractual obligations to you (such as delivery of tokens) it will be necessary to write certain personal data, such as your wallet address, onto the blockchain; this requires you to execute such transactions using your wallet’s private key.

In every case with respect to the App or the Services, the ultimate decision to (i) transact on the blockchain using your wallet address, as well as (ii) share the public key relating to your wallet address with anyone (including us) rests with you. If you make no transactions, then you make no publication to the blockchain.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the fact that most blockchains and particularly the ones relevant to the App are intrinsically public.

When you make a transaction on the blockchain, including those blockchains which you may interact with using the services, you are necessarily and always publishing information publicly. All blockchain transactions are available to the public and open for audit; and all of your transactions or interactions using blockchain will become immediately and immutably publicly available.

Individuals under the Age of 18

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit, or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

If we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns. If you are a parent or guardian and become aware that your child has shared personal data with our Services, please contact us so that we may remove such data. Note that we cannot delete information stored on public cryptographic blockchains.

Collecting Information
Things you and others do and provide.

Information and content you provide.

We collect the content, communications, and other information you provide when you use our Services, including when you create an account, initiate the use of the Services, create, or share content, and message or communicate with others.

As of Jul 4, 2025, the only information we collect, and store is the e-mail address that you use when creating an account.

We will never solicit or sell your data to a third party. This includes all information we collect. If you would like us not to store your e-mail address, you have a right to do so. E-Mail us at privacy@splashwallet.xyz to have any of your data deleted.

We may request more information from you in the future pursuant to the details of the Terms of Services. If we make such a request, or any change to our information collection practices; you will be notified, and this policy will be immediately updated. This information may include, but is not limited to:

Name

Address

E-Mail

Phone Number

SSN (or equivalent)

Financial Information

Date of Birth

Citizenship

Payment Information

Information used to verify your identity.

If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti- money laundering laws, US Treasury department rules or regulations or other legal requirements. If you seek to invest through an entity or corporation, you may provide us with documentation relating to the entity’s jurisdiction of formation, legal status and ownership. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.

Financial information.

In order to transfer funds, you may need to provide us or other third-party financial providers or partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, cryptocurrency, foreign currency or any other payment methods. You may agree to your personal and financial information being transferred, stored, and processed by such third parties in accordance with their respective privacy policies. This information will not be stored or accessible in any way by Cybernetics Incorporated and will be fully under control and pursuant to the respective third-party privacy policy.

Your usage.

We may collect information about how you use our Services, such as the types of content you view or engage with; the features you use; the actions you take; and the time, frequency, and duration of your activities.

Information about transactions made on our Services.

If you use our Services for transactions of any kind, we may collect information about them. We will not collect or store any information which is not publicly available on the blockchain.

Cookies

We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services.

Device Information

As described below, we collect information from and about the computers, phones, and other web-connected devices you use that interact with our Services, and we combine this information across different devices you use.

Information we obtain from these devices includes:

Identifiers: unique identifiers, device IDs, and other identifiers.

Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network. We will never store your IP address.

Cookie data: data from cookies stored on your device, including cookie IDs and settings.

Information necessary to enable push notifications: if you enable push notifications in our services, we will collect information from your device as may be necessary to enable such notifications

Information from partners.

See the “Third-Party Data Collection” section for additional information on third-party collection of data.

When using the Services

When using the Services, we may collect and process personal data. The data will be stored in different instances. We collect and use this information to provide you the Services and to debug issues and provide support.

On the Blockchain the following data may be stored:

addresses of externally owned accounts

transactions made;

token balances; and

positions or margin balances

The data will be stored on the Blockchain. Given the technological design of the blockchain, this data is necessarily public and it will not likely be possible to delete or change the data at any given time. Please see the “Blockchain” section above for more details.

In our web servers, we will store the following data:

Your e-mail

Tracking and Uses

We use the information we have (subject to choices you make) as described below and to provide and support the Services.

Here's how:

Provide, personalize and improve our Services.

We use the information we have to deliver our Services, including to personalize features and content.

Product research and development.

We use the information we have to develop, test and improve our Services, including by conducting surveys and research, and testing and troubleshooting new products and features.

Promote safety, integrity and security.

We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services, and promote safety and security.

Communicate with you.

We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us.

Because recognition of the Do Not Track HTTP header feature of your web browser is not standardized, the Services don’t recognize it for tracking purposes.

Third-Party Data Collection

Third parties may collect or receive certain information about you and/or your use of the Services to provide content, ads (including personalized ads), or functionality, or to measure and analyze ad performance, in or through the Services. These third parties include, but are not limited to:

Coinbase -- On/Off Ramp

Sphere -- On/Off Ramp

Privy.io -- The third-party service you use to generate private keys on the App

You may choose whether to receive certain personalized (also known as targeted) advertising from participating ad networks, audience segment providers, ad serving vendors, other service providers or entities by visiting websites operated by the Network Advertising Initiative and Digital Advertising Alliance or if you are a user in the European Economic Area, Your Online Choices. We adhere to the Self-Regulatory Principles for Online Behavioral Advertising.

Retention

The Services may keep the information we gather about you an unlimited length of time.

To request that information collected about you be deleted, please contact us at privacy@splashwallet.xyz. A valid request must include sufficient information to identify your personal data. Note that we cannot delete information stored on public blockchains. All transactions you make on the blockchain are entirely public, and immutable.

Sharing

The Services only share information about you with others as follows:

We may also transfer your personal data to a third party as a result of a business combination, merger, asset sale, reorganization or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process.

We will also share your information with third-party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harm our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your data, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in our Privacy Policy.

To operate the Services, we share information about you as needed with our service providers, including financial institutions, accountants, auditors, lawyers, payment processors, information technology consultants, advisors, and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Services. The information is only shared so long as you have an account on the Services.

We may share information about you with US, state or international regulators, SEC, or FINRA where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas.

The Services may contain links to third party websites and may redirect you to third party websites. These sites include, among others, service providers who have a relationship with the operator. Third party websites are not under our control, and we are not responsible for any third-party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to these websites does not imply an endorsement by the operator, or of the provider of such content or services, or of any third-party website. Please be aware that when you enter a third-party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website.

Opt–Out

If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at service@splashwallet.xyz to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Services.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Contact

If you have comments or questions about the privacy policies of the Services, contact privacy@splashwallet.xyz

Changes

The Services may change their privacy policy at any time. Check this page for the latest.