1. Introduction
This Privacy Policy explains how Meridian Digital Labs LLC ("Meridian Digital Labs," "we," "us," or "our") handles information in connection with America Wallet, a self-custodial mobile cryptocurrency wallet application (the "App" or the "Services").
America Wallet is designed around a core principle: the people using our App should retain control of their own funds and their own information. Meridian Digital Labs does not hold your digital assets, does not hold your keys, and does not require you to create an account with us to use the App.
By downloading, installing, or using America Wallet, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how we handle information as described here, please do not use the App.
2. The Self-Custodial Model — What This Means For Your Privacy
America Wallet is self-custodial software. This has direct consequences for what we can and cannot see about you:
- Your Secret Recovery Phrase is generated on your device and stored only on your device. We never see it, never transmit it, and never have a copy of it.
- Your private keys are generated on your device and stored only on your device. We never see them, never transmit them, and never have a copy of them.
- We cannot access, freeze, seize, recover, or restore your digital assets. If you lose your Secret Recovery Phrase, we cannot help you recover your wallet.
- We do not maintain user accounts. You do not create a username or password with Meridian Digital Labs to use the App.
This architecture is intentional. It is also a limitation on what we can do for you: because we hold nothing, we cannot give back anything that is lost.
3. Information We Do Not Collect
We want to be direct about what we do not collect, because this differs from most mobile applications:
- We do not collect your Secret Recovery Phrase.
- We do not collect your private keys.
- We do not collect your password, PIN, or biometric data used to unlock the App. These are stored on your device by your device's operating system.
- We do not collect your name, physical address, date of birth, social security number, or government identification documents as a condition of using the basic wallet functions of the App.
- We do not sell your personal information to third parties. We do not rent it, and we do not share it with advertisers for targeted advertising.
Some features of the App rely on third-party services that do collect identifying information directly from you. Those services are described in Section 6.
4. Information We Do Collect
When you use America Wallet, the following categories of information may be collected:
4.1 Wallet Addresses and Transaction Data
To display your balances and transaction history, the App queries public blockchain networks using your public wallet addresses. These addresses are not secret — they are designed to be shared — but they are associated with you through your device.
Because blockchains are public ledgers, any transaction you send or receive is permanently recorded on a public network that anyone in the world can read. This is a property of the blockchain itself and is not something we control.
4.2 Network and Device Information
When the App connects to blockchain nodes and third-party services, the following information is typically transmitted:
- Your IP address (used for network routing, abuse prevention, and sanctions screening)
- Device type, operating system, and operating system version
- App version and build identifier
- General geographic region (derived from IP address, not precise location)
We use this information to operate the App, diagnose technical issues, prevent abuse, and comply with applicable sanctions laws.
4.3 Diagnostic and Crash Reports
If you opt in, we may collect diagnostic information when the App crashes or encounters an error. These reports describe what the App was doing at the time of the failure and may include device information. They do not contain your Secret Recovery Phrase or private keys.
Diagnostic reporting is off by default and can be turned on or off from the App settings at any time.
4.4 Usage Analytics
If you opt in, we may collect anonymized usage information, such as which screens you visit and which features you use. This information is used to improve the App. It is not tied to your wallet address or any identifier that would let us reconstruct your identity.
Analytics reporting is off by default and can be turned on or off from the App settings at any time.
4.5 Push Notifications
If you enable push notifications, your device's push notification token will be collected so that we can deliver messages to your device. You can disable push notifications at any time in your device settings.
4.6 Customer Support Correspondence
If you contact us for support, we will receive whatever information you choose to send us — typically an email address and a description of your issue. We keep this information only as long as needed to resolve your issue.
5. How We Use Information
We use the information described in Section 4 for the following purposes:
- To operate the App and provide the features you request, such as displaying balances and broadcasting transactions
- To diagnose and fix technical problems
- To detect and prevent fraud, abuse, and security incidents
- To comply with legal obligations, including sanctions compliance
- To communicate with you about the App, including service announcements and, if you opt in, product updates
- To improve the App based on aggregated usage patterns
We do not use your information to build advertising profiles, and we do not use it to train artificial intelligence models.
6. Third-Party Services We Rely On
America Wallet integrates with third-party services that have their own privacy practices. When you use these features, you are interacting with the third-party provider, and their privacy policy applies to the information they collect.
6.1 On-Ramp and Off-Ramp (Transak)
If you use the Buy or Sell feature to exchange fiat currency for digital assets, you will be routed to a third-party service (currently Transak) to complete the transaction. That service will collect identification information from you directly — typically a government-issued ID, photograph, and proof of address — as required by applicable money transmission and anti-money-laundering laws.
Meridian Digital Labs does not receive or store the identification documents you provide to the on-ramp provider. We may receive a transaction confirmation indicating that a purchase or sale was completed.
Transak's privacy practices are governed by Transak's own privacy policy, which you should review before completing any transaction.
6.2 Blockchain RPC Providers
To read balances and broadcast transactions, the App connects to blockchain node providers (such as Infura and similar services). These providers see your IP address and the wallet addresses you query. They do not receive your Secret Recovery Phrase or private keys.
6.3 Swap and Bridge Aggregators
When you use the Swap feature, the App queries third-party aggregators to find exchange routes. These aggregators see your wallet address and the tokens involved. They do not receive your Secret Recovery Phrase or private keys.
6.4 Future Integrations
As America Wallet adds new features — such as savings through third-party lending protocols, perpetual trading, or a debit card — additional third parties will be involved, each with their own privacy practices. We will update this Privacy Policy to reflect those relationships before the features become available.
7. When We Share Information
We share information only in the limited circumstances described below:
- Service providers. We share information with vendors that help us operate the App, such as cloud hosting, error reporting, and customer support platforms. These vendors are contractually restricted to using the information only to provide services to us.
- Third-party services you choose to use. When you use Buy, Sell, Swap, or other features powered by third parties, the relevant third party will receive the information needed to complete that feature.
- Legal compliance. We may disclose information if we reasonably believe disclosure is required by law, court order, subpoena, or other legal process, or is necessary to protect the rights, property, or safety of Meridian Digital Labs, our users, or the public.
- Sanctions screening. We may use IP addresses and related signals to screen for users in sanctioned jurisdictions as required by United States law.
- Business transfers. If Meridian Digital Labs is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to customary confidentiality protections.
We do not sell personal information, and we do not share it for cross-context behavioral advertising.
8. Blockchain Data Is Public
The public nature of blockchains deserves a separate note. Every transaction you send from America Wallet is broadcast to a public blockchain network and becomes permanently visible to anyone in the world. This includes:
- Your wallet address
- The destination address
- The amount and asset transferred
- The time of the transaction
This information cannot be deleted, because blockchain ledgers are designed to be immutable. If you require financial privacy, you should understand these characteristics before using any blockchain-based application, including America Wallet.
9. Stablecoin and Asset-Specific Considerations
America Wallet currently supports three digital assets: USDC, USDT, and Bitcoin (BTC). Meridian Digital Labs does not issue, manage, or guarantee any of these assets. USDC is issued by Circle, USDT is issued by Tether, and Bitcoin is a decentralized network with no issuer.
Transactions involving these assets are recorded on their respective public blockchains. The issuers of USDC and USDT may have the technical ability to freeze tokens at specific addresses in response to legal process; this is a property of those tokens, not of America Wallet, and is outside our control.
10. Data Retention
We keep information only as long as we need it for the purposes described in this Privacy Policy or as required by law. Server logs and diagnostic data are typically retained for a limited period and then deleted or aggregated. Support correspondence is retained for as long as needed to resolve the matter and for a reasonable period afterward.
Blockchain data cannot be deleted by us. It is stored on public ledgers we do not control.
11. Data Security
We use commercially reasonable technical and organizational measures to protect the information we handle. No system is perfectly secure, and we cannot guarantee absolute security.
The most important security measures, however, are ones only you can take:
- Safeguard your Secret Recovery Phrase. Write it down and store it offline.
- Never share your Secret Recovery Phrase with anyone, including anyone claiming to represent Meridian Digital Labs. We will never ask you for it.
- Use a strong device passcode and enable biometric unlock where available.
- Keep your device's operating system updated.
12. Your Rights and Choices
Depending on where you live, you may have rights concerning the information we handle about you. These may include the right to access, correct, delete, or port certain information, and the right to object to or restrict certain processing.
Because America Wallet is self-custodial and we do not maintain user accounts, the information we hold about any individual user is typically limited. To exercise your rights, please contact us using the information in Section 17. We will respond in accordance with applicable law.
12.1 California Residents
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), provides you with specific rights regarding your personal information, including the right to know, the right to delete, the right to correct, and the right to opt out of the sale or sharing of personal information.
Meridian Digital Labs does not sell personal information and does not share it for cross-context behavioral advertising as those terms are defined under the CCPA.
12.2 European Economic Area, United Kingdom, and Switzerland
America Wallet is designed for the United States market. If you are located in the European Economic Area, the United Kingdom, or Switzerland, please be aware that the App may not be intended for use in your jurisdiction. If you nonetheless use the App, the General Data Protection Regulation or equivalent local law may apply. You may have rights of access, rectification, erasure, restriction, portability, and objection under those laws.
13. Children's Privacy
America Wallet is not intended for use by children under the age of 18, and we do not knowingly collect information from anyone under 18. If you believe a person under 18 has used the App, please contact us and we will take appropriate action.
14. International Users
America Wallet is operated from the United States. If you use the App from outside the United States, information you provide or that is collected about you will be transferred to and processed in the United States, which may have different data protection standards than your home jurisdiction.
15. "Not a Bank" and Regulatory Context
America Wallet is software. Meridian Digital Labs is not a bank, is not a licensed money transmitter in most jurisdictions, and does not provide banking services, checking accounts, savings accounts, deposit accounts, or any FDIC-insured product. America Wallet balances are not deposits, are not FDIC-insured, and are not SIPC-protected. This Privacy Policy does not change that, and using America Wallet does not create a banking or custodial relationship between you and Meridian Digital Labs.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will post the revised version with a new "Last Updated" date. If the changes are material, we will provide additional notice through the App or through other reasonable means. Your continued use of the App after the revised Privacy Policy takes effect means you accept the revised terms.
17. Contact Us
If you have questions about this Privacy Policy or how Meridian Digital Labs handles information, you can reach us at:
Meridian Digital Labs LLC [INSERT REGISTERED TEXAS ADDRESS] Email: [INSERT PRIVACY CONTACT EMAIL]
18. Governing Law
This Privacy Policy and any dispute arising from or related to it is governed by the laws of the State of Texas, without regard to its conflict-of-laws principles, except where applicable privacy laws require otherwise.