Privacy Policy

Introduction

Welcome to Sovrency, a non-custodial self-custody wallet built for long-term crypto wealth management.
This Privacy Policy explains how we collect, use, protect, and share information when you interact with:

• Our website (sovrency.com)

• Our mobile and web applications

• Our hardware devices (including Silicon Key and Backup Card)

• Any related services, tools, or communications (together, the “Service”)

By using Sovrency, you agree to the practices described in this Policy and our Terms & Conditions.
Sovrency is designed around a crypto-native privacy ethos:

• We do not custody your assets.

• We do not see or store your private keys.

• Most sensitive cryptographic operations happen on-device or in secure hardware.

This document is a draft and should be reviewed by qualified legal counsel, including in the UAE and any other relevant jurisdictions.

1. Information We Collect

We aim to collect only what we need to run and improve Sovrency.

1.1 Information you provide

• Contact details

  • Email address and any other contact information you provide (e.g. when joining a waitlist, contacting support, or subscribing to updates).

• Account / profile details (if applicable)

  • Display name or other optional profile data, if you choose to set them.

• Support communications

  • Messages you send us via email, forms, or in-app support (including attachments you choose to share).

1.2 Information we collect automatically

When you use our website or apps, we may collect:

• Basic usage and device data

  • IP address (often truncated or anonymized where possible)

  • Browser type, OS, app version

  • Pages viewed, features used, time spent

• Product interaction data

  • Button clicks, screen flows, error events

  • Non-sensitive logs that help us debug and improve performance

Where possible, this data is aggregated or pseudonymized and used for analytics and reliability.

1.3 Blockchain and transaction-related data

Because Sovrency is a wallet:

• We do not collect or store your private keys.

• We may process information such as:

  • Public wallet addresses

  • Network, token, and transaction metadata

  • Policy configuration (e.g. Transaction Policies, limits, whitelists)

Most of this data is already public on-chain.
We use it to power features like SignSight, Transaction Policies, and security checks.

1.4 Hardware and security data

For Silicon Key, Backup Card, and related flows we may process:

• Device identifiers or configuration status (e.g. “Silicon Key set up / not set up”)

• High-level security posture (e.g. “Everyday Mode / Sovereign Mode”, “Backup Card configured / not configured”)

We do not read or store raw secrets from your Silicon Key, Backup Card, or secure enclave.
Those keys stay within secure elements and MPC flows by design.

1.5 Optional data

You may choose to provide:

• Feedback and feature requests

• Participation in surveys or research interviews

• Community interactions (e.g. email or social channels)

This information is optional and used to improve the Service.

2. How We Use Your Information

We use the information we collect for the following purposes:

1. Provide and operate the Service

   • Enable wallet creation and management

   • Run Everyday and Sovereign Modes

   • Support Transaction Policies, SignSight, and Security Engine checks

   • Coordinate MPC operations and device pairing

2. Improve the Service

   • Understand how features are used

   • Fix bugs, improve performance and security

   • Prioritize product improvements based on aggregated usage patterns

3. Security and abuse prevention

   • Detect unusual or clearly abusive behavior (e.g. attack patterns, spam)

   • Protect users and infrastructure from misuse

4. Communication

   • Respond to your support requests

   • Send important updates about security, changes, or incidents

   • Send product news and marketing (where permitted, with opt-out)

5. Compliance

   • Comply with applicable laws and regulations

   • Respond to lawful requests from authorities (subject to legal requirements)

We do not sell your personal information to third parties.

3. Data Security

We design Sovrency with a security-first, non-custodial mindset.

• Keys in secure elements

  • Portable Key lives in your device’s secure enclave.

  • Silicon Key and Backup Card hold key shares in secure hardware.

  • Guardian Key operates on HSMs.

  • We do not see or store your private keys.

• Encryption and hardening

  • We use industry-standard encryption for data in transit and at rest where applicable.

  • Access to internal systems is restricted to authorized personnel under strict controls.

• MPC and policy-based controls

  • Our MPC architecture and Transaction Policies are designed to avoid single points of failure and to enforce rule-based controls.

No system is perfectly secure.
You understand that:

• Compromise of your device, passkeys, Silicon Key, Backup Card, or email can still lead to loss of access or funds.

• We cannot guarantee that unauthorized access or breaches will never occur.

4. Cookies and Tracking

4.1 Website cookies

On sovrency.com, we may use:

• Essential cookies – for basic functionality (e.g. remembering session or language preferences).

• Analytics cookies – to understand aggregated usage (e.g. which pages are visited and for how long).

You can control cookies through your browser settings.
Blocking some cookies may affect site functionality.

4.2 Analytics tools

We may use privacy-conscious analytics tools (e.g. privacy-friendly or self-hosted solutions, or standard tools configured with safeguards) to collect aggregated, pseudonymized data, such as:

• Page views and navigation flows

• Device type / OS / browser (without attaching it directly to your on-chain identity)

We do not use analytics to try to reconstruct your entire on-chain history or “deanonymize” you as a person.

5. Data Sharing and Third Parties

We may share limited information with third parties in these situations:

1. Service providers

   • Hosting providers, email delivery services, analytics tools, customer support tools, etc.

   • They process data only on our behalf and under confidentiality obligations.

2. Legal and compliance

   • If required by law, regulation, or a valid legal request from authorities.

   • To protect the rights, property, or safety of Sovrency, our users, or others.

3. Business transfers

   • In the event of a merger, acquisition, or similar transaction, user-related data may be transferred as part of the business, subject to this Policy.

We do not sell your personal information to third parties.

On-chain data is public by nature; any use of public blockchain data is separate from your personal account details.

6. Your Choices and Rights

Depending on your jurisdiction, you may have some or all of the following rights:

• Access – to request a copy of personal information we hold about you.

• Correction – to ask us to correct inaccurate or incomplete information.

• Deletion – to request deletion of certain information, subject to legal and technical limits.

• Restriction or objection – to ask us to limit certain types of processing.

• Opt-out of marketing – you can unsubscribe from marketing emails at any time by using the unsubscribe link or contacting us.

Because Sovrency is non-custodial:

• We cannot delete or alter on-chain data, since it is recorded on public blockchains.

• We generally cannot recover your wallet if you lose your keys or hardware.

To exercise any rights or make privacy-related requests, contact us at: [email protected] (or the support email listed below).

7. Children’s Privacy

Sovrency is not intended for children under 13 years of age.

We do not knowingly collect personal information from children.
If we become aware that a child has provided us with personal information, we will take reasonable steps to delete it where appropriate.

If you believe a child has used Sovrency and provided personal data, please contact us.

8. International Data Transfers

Sovrency operates from the United Arab Emirates (UAE) and may use service providers in other countries.

This means your information may be transferred to and processed in countries that may have different data protection laws than your own.
Where required, we will take reasonable measures to ensure appropriate safeguards are in place.

9. Changes to This Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in our Service

• Changes in our data practices

• Changes in applicable laws

When we do, we will update the “Last updated” date at the top and may provide additional notice (e.g. via the App or email, where appropriate).

Your continued use of Sovrency after an update means you accept the revised Policy.

10. Contact Us

If you have questions, requests, or concerns about this Privacy Policy or our data practices, you can contact us at:

• Email: [email protected]

• Support: [email protected]

• Website: https://sovrency.com

By using Sovrency, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.