Privacy Policy

Billion US Holdings LLC

1. Introduction

This Privacy Policy explains how Billion US Holdings LLC (“Billion,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you use the Billion application, website, non-custodial wallet, payment card, and related services (the “Services”). By using the Services, you acknowledge the practices described in this Policy. Capitalized terms not defined here have the meaning given in our Terms of Use.

2. Information We Collect

You can use the Billion Wallet without creating an account and without providing personal information to us. Your wallet keys and recovery phrase are generated and stored on your device, and we never have access to them in readable form (for encrypted backups, see “Signing in with Google or Apple” below). Depending on how you use the Services, we collect the following categories of personal information:

• Wallet and usage information — your public wallet addresses, the on-chain transactions you initiate, and device and usage information such as device identifiers, IP address, app and website interactions, and information collected through cookies and similar technologies.
• Optional account information — if you choose to create an account using social login, we receive limited profile information from your chosen provider, such as your name and email address, to create and secure your account.
• Communications — information you provide when you contact us, and our records of that correspondence.

Signing in with Google or Apple. If you choose to sign in with Google or Apple, we receive basic information from your account with that provider: a unique account identifier, your email address and whether it is verified (or, if you use Apple’s Hide My Email, a private relay address), your name if you have shared it, and technical details of the sign-in. We do not receive your Google or Apple password or access any other data in your Google or Apple account. We use this information to create your Billion account and sign you in, keep your account secure and prevent fraud, comply with our legal obligations, and send you service messages and news about Billion. We rely on the performance of our contract with you, our legitimate interests in securing and promoting the Services, and our legal obligations. You can unsubscribe from promotional emails at any time using the link in each email. When you sign in this way, we also store an encrypted backup of your wallet’s recovery phrase so that you can restore your wallet on a new device; it is encrypted on your device with a password or passkey that only you control, and we cannot decrypt it. We do not sell this information and do not use or share it to serve ads; we share it only as described in Section 4, for example with service providers that host our systems and send our emails. You can ask us to delete your account at any time by emailing [email protected]. We will then delete this information and your encrypted backup, except security logs and system backups, which we keep for no longer than 12 months, and information recorded on a public blockchain, which cannot be deleted. You can also remove Billion’s access in your Google or Apple account settings. Billion’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Identity verification and regulated services. Identity verification (KYC) for the Card and certain regulated features is performed by our licensed partners, not by Billion. When you apply for the Card or use those features, you register with and provide identity information (such as government-issued identification and proof of address) directly to our licensed partner, and that information is collected and held by the partner under its own privacy policy. Billion does not collect or store your identity documents; we may receive limited information such as your verification status. Buying or selling crypto (on-ramp and off-ramp) is handled by third-party providers who collect the information they need to provide those services under their own privacy policies.

3. How We Use Information

We use the personal information we collect to:

• provide, operate, and maintain the Services;
• enable the wallet, swap, card, and on-ramp and off-ramp features, including by connecting you to our licensed partners and third-party providers;
• secure the Services and protect against fraud and misuse;
• comply with our legal, regulatory, and recordkeeping obligations, including applicable sanctions requirements;
• communicate with you about the Services and respond to your requests; and
• analyze and improve the Services.

4. How We Disclose Information

We disclose personal information to:

• Licensed partners — that provide the Card and hold the card balance and that perform identity verification, to enable those features. As described above, identity verification information is collected and held by these partners under their own privacy policies.
• Third-party providers — such as on-ramp and off-ramp and swap providers, and service providers (for example, hosting, analytics, and customer support) that process information on our behalf and under our instructions.
• Legal and regulatory recipients — including regulators, law enforcement, and other parties where we believe disclosure is required by law or necessary to protect rights, safety, or the integrity of the Services.
• Corporate transactions — a successor or acquirer in connection with a merger, acquisition, financing, or sale of assets.

We do not sell your personal information for money, and we do not share it for cross-context behavioral advertising.

5. Cookies and Similar Technologies

We and our providers use cookies and similar technologies for functionality, security, and analytics. You can manage your preferences through your browser settings and, where available, our cookie controls. For more information, see our Cookie Policy.

6. International Transfers

We are based in the United States, and personal information may be processed in the United States and other countries where we or our providers operate. Where required, we use appropriate safeguards for cross-border transfers of personal information.

7. Data Retention

We retain the personal information we collect for as long as necessary to provide the Services and for legitimate business, legal, tax, and recordkeeping purposes. Identity verification records for the Card and regulated features are retained by our licensed partners in accordance with their policies and applicable law, and not by Billion.

8. Security

We use administrative, technical, and physical safeguards designed to protect the personal information we hold. No method of transmission or storage is completely secure. You are responsible for protecting your wallet keys, recovery phrase, and account credentials.

9. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information, including the right to:

• know about and access the personal information we hold about you;
• correct inaccurate personal information;
• delete personal information, subject to legal exceptions;
• opt out of the “sale” or “sharing” of personal information and of targeted advertising; and
• limit the use of sensitive personal information.

We do not discriminate against you for exercising your rights. We limit our own collection of personal information as described above; where sensitive personal information (such as government identifiers) is required for identity verification, it is collected by our licensed partners under their own privacy policies. You may exercise your rights, or use an authorized agent to do so, by contacting us at [email protected]. We will verify your request as required by law before responding, and where a request relates to information held by a partner, we will direct you to the appropriate partner. To delete your Billion account and the personal information associated with it, email [email protected] from the email address linked to your account.

10. Children

The Services are not directed to, and may not be used by, anyone under 18 years of age, and we do not knowingly collect personal information from children.

11. Changes to this Policy

We may update this Policy from time to time. We will post the updated Policy and update the “Last updated” date, and, where required by law, provide additional notice.

12. Contact Us

Billion US Holdings LLC — [email protected]. Registered office: 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex.