Effective: 1 September 2026

Controller: Wave Space Exploration, UAB, Girulių g. 10-201, 12112 Vilnius, Lithuania, company no. 306727148

Contact: privacy@wave.space

This Privacy Policy outlines how UAB Wave Space Exploration ("Wave Space Exploration," "we," "us," or "our") collects, uses, processes, discloses, shares, transfers, and protects personal information obtained through our services. This Privacy Policy applies to all users of Wave Space Exploration's services, including visitors to our website, applicants, customers, and partners.

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1. In short

Matter Money is a self-custodial Bitcoin wallet. Your keys, your transaction history and your contacts live on your device. We do not hold your bitcoin, we cannot move it, and we cannot see your balance.

We collect very little. What we do collect is listed in §3, and every item says why we have it and how long we keep it. Two things people usually assume we collect, and we do not:

• Your wallet balance and payment history. They are on your device and, for Bitcoin network data, on the public Bitcoin/Ark network. We do not receive them.
• Your identity documents. When you verify your identity, the documents go to our verification provider and to the licensed partner behind the euro services. They do not pass through our servers.

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2. Two policies, one company

Matter Money and wave.space are the same company — Wave Space Exploration, UAB. They are not two businesses passing data to each other. They are two service families with two policies, because the data protection roles are genuinely different:

2.1. This policy: The Bitcoin wallet — keys, sending, receiving, contacts, messaging, app settings.  Our Role: Controller

2.2. wave.space Privacy Policy — https://www.wave.space/privacy-policy : The euro account, IBAN, debit card, identity verification, buying and selling, Rewards

For the euro services, the wave.space Privacy Policy is the document that governs. In short, and as it explains: where we process your data on the instructions of Lightspark Payments Europe AS and the card issuer, we act as a data processor; where we process additional data of our own, we act as a data controller. Lightspark's own obligations are theirs to answer for — you can reach their data protection officer at dpo.eu@lightspark.com.

You accept the wave.space terms and privacy policy at the point you create a wave.space account inside the app.

Our wallet servers relay that traffic; they do not store it. Requests to the euro platform pass through the Matter Money backend so the app never needs the platform's credentials. We keep no copy of the contents. The only thing retained from that traffic is the shape of responses — which fields exist and what type they are, never any value — so we can detect when the platform's API changes.

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3. What we collect

3.1 Held only on your device — never sent to us

Your recovery key (in the Secure Enclave / StrongBox), your passcode, your transaction history, your contacts and Nostr identity, your app settings, and your wave.space session token (in the system keychain).

3.2 An encrypted backup of your recovery key

At setup we escrow an encrypted copy of your recovery key with Turnkey, in a hardware-secured vault. We never see it in readable form. Releasing it requires two independent approvals — a code sent to your recovery email and a human review by our support team — so neither we nor Turnkey alone can release it.

• Why: so you can recover your wallet if you lose your device.
• Kept: while your wallet exists, or until you ask us to delete it.
• Deleting it: Settings → Security → Delete your backup. This composes an email to deletion-request@wave.space naming the exact vault records held for you; we delete them by hand and confirm when it is done.
• Why a person and not a button. The vault is locked so that neither we nor Turnkey can act on it alone — that is what keeps your key safe — so a delete has to be carried out deliberately rather than triggered by a request arriving. We would also rather this took a few minutes and a human than be one mistaken tap away from destroying the only copy of your key that is not on your phone. It is irreversible: afterwards, losing your device and your passkey means losing your bitcoin, and nobody can undo that. See §7.

3.3 Your recovery email

• Why: the second factor when you recover a wallet on a new device.
• Kept: while your wallet exists.

3.4 A device identifier and a pseudonymous analytics identifier

Random values generated on your device. They are not your name, your email or your Apple ID, and they are not linked to your wallet.

• Why: to route push notifications, and to count usage.
• Note: product analytics are off in the current release. The feature ships disabled and sends nothing — not "sends less", nothing. Before it is switched on we will ship an in-app consent control and update this policy.
• Kept: the device identifier lasts as long as the app is installed and is erased when you wipe the wallet. Usage events, once analytics is switched on, are kept for 12 months.

3.5 Bug reports you choose to send

If you report a bug — from Settings, or by shaking the device — we receive your description, technical diagnostics, and a screenshot if you attach one. A screenshot of a wallet app can show balances and payment details, so it is only ever sent when you attach it deliberately.

• Kept: 90 days, then deleted automatically.

3.6 Crash diagnostics

Technical details of a crash — no payment data, no keys.

3.7 Identity verification — collected by the provider, not by us

Identity checks are part of the euro services and are performed by Sumsub. The verification screen runs inside our app, but the documents and the selfie you take go directly to Sumsub. The Matter Money wallet servers never receive them and do not store them.

Sumsub collects your identity documents, a facial image, and the personal details you enter. That processing is covered by the wave.space Privacy Policy (§2) and by Sumsub's own privacy notice, published on their website.

3.8 Public Bitcoin and Nostr network data

Bitcoin transactions are public by design. If you use a Lightning address, a Nostr profile or Nostr messaging, the identifiers involved are published to public relays. Messages are end-to-end encrypted; who you message and when may still be visible to relay operators.

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4. What we never collect

Your recovery key in readable form · your passcode · your balance · your identity documents · your card number · your location · contacts from your phone's address book · advertising identifiers.

We do not track you across apps or websites, we run no advertising SDKs, and we do not sell or share personal data for advertising.

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5. Who we share with

Lightspark Payments Europe AS — What? Account, card and verification data for the euro services. Why? To provide the euro account, IBAN, card and trading services

‍Sumsub. What? Identity documents and facial image, collected directly. Why? Identity verification for the above

‍Turnkey — What? Your encrypted recovery key, unreadable to them. Why? Recovery escrow

‍Apple / Google — What? Push notification tokens. Why? Delivering notifications

Fly.io — What? Infrastructure. Why? Running our backend (Frankfurt, Germany)

Turnkey, Apple, Google and Fly.io act as processors on our instructions. The roles for the euro services — where we act as processor for Lightspark and where as controller — are set out in §2 and in the wave.space Privacy Policy.

Bitcoin swaps are executed by independent providers (currently Satora / LendaSwap) under a contract signed on your device. We pass no personal data to them.

We may also disclose personal data where we are legally required to — for example, to a court, a regulator or a competent authority.

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6. Where data is processed

Our wallet servers are in Frankfurt, Germany — inside the EEA. Your data does not leave the EEA to reach us.

Some of the recipients in §5 process personal data outside the EEA. Where they do, we ensure the transfer complies with Articles 44 to 49 of the GDPR and is protected by an appropriate safeguard — the European Commission's Standard Contractual Clauses, an adequacy decision, or another legally recognised mechanism — as recorded in our agreement with each of them.

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7. Your rights

Under the GDPR you may request access, correction, erasure, restriction, or portability, object to processing, and withdraw consent at any time. Contact privacy@wave.space, or in the app Settings → Help & about → Privacy request. We respond within one month.

Erasure has its own address: deletion-request@wave.space. The app composes those emails for you — Settings → Security → Delete your backup, and Settings → wave.space account → Delete your account — because both are irreversible and are carried out by a person rather than by a request arriving. It is a route, not a requirement: a request that reaches any of our addresses is still a valid request and we will act on it.

You may also complain to your national supervisory authority — in Lithuania, the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).

Three limits worth stating plainly:

• We cannot erase the Bitcoin blockchain. Transactions are public and permanent.
• Deleting your recovery backup is irreversible, and it removes the only copy of your key that is not on your device (§3.2).
• Closing your wave.space account does not erase everything immediately. European anti-money-laundering law requires certain records to be kept for up to five years after the account closes, as the wave.space Terms & Conditions set out. Erasing your wallet on the device does not close that account, and closing that account does not erase your wallet.

8. How long we keep things

We keep personal data only as long as we need it for the purpose it was collected for, and for as long as the law requires. Where a period is fixed, §3 states it. Where it is not, we decide using: how long our relationship with you lasts, what the law requires us to retain, whether the data is still needed to defend a legal claim, and any instruction you have given us.

9. Deleting your data

To remove eEverything on the device

Do This: Settings → Security → Wipe wallet

Effect: Keys, history, contacts and settings erased. Irreversible without recovery.

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To remove your wave.space account

Do this: Settings → wave.space account → Delete your account, or email deletion-request@wave.space

Effect: Closed under the wave.space Terms, subject to the retention in §7

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To remove the escrowed copy of your recovery key

Do this: Settings → Security → Delete your backup, or email deletion-request@wave.space

Effect: We delete the vault records by hand and confirm. Irreversible — see §3.2

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To remove bug reports

Do this: Automatic after 90 days, or ask us

Effect: Deleted

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10. Children

Matter Money is not for under-16s and we do not knowingly collect their data. The euro services require you to be 18, and your date of birth is verified before any of them unlock — so that limit is enforced by a check, not by a promise.

11. Security

We protect personal data with encryption in transit and at rest, hardware-backed key storage on your device, access controls on our systems, and regular review. No system is perfectly secure, so keep your device and its passcode protected too — and remember that nobody legitimate will ever ask you for your recovery code, your passcode or your key.

12. Changes

We will post changes here and, for material ones, notify you in the app at least 30 days before they take effect — the same notice period as our Terms.

13. Contact

Wave Space Exploration, UAB Girulių g. 10-201, 12112 Vilnius, Lithuania · Company no. 306727148

Privacy and data-protection requests: privacy@wave.space Deletion requests (your account, or your escrowed key): deletion-request@wave.space Support: help@wave.space · Abuse reports: abuse@wave.space Lightspark data protection officer: dpo.eu@lightspark.com

By using Matter Money you acknowledge that you have read and understood this Privacy Policy.

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