Privacy Policy

Last updated: May 21, 2026

1. Who We Are

Dollar (“the App”) is operated by OrkLabs S.A.S., a company incorporated under the laws of the Argentine Republic (“we,” “us,” or “our”). This Privacy Policy describes how we handle information in connection with the Dollar mobile application and the website at dollar.black.

By using the App, you agree to the practices described in this Privacy Policy.

2. Self-Custody Architecture

Dollar is a self-custody dollar wallet. Your private keys are derived on your device and never transmitted to our servers. We do not hold, manage, or have access to your funds, private keys, credentials, or any key material at any time. Anyone who obtains your recovery credentials can access your funds. If you lose access to your credentials, we cannot recover your funds. You are solely responsible for safeguarding them.

3. Information We Have Access To

Because Dollar operates on public payment rails (stablecoins, bitcoin, and other cryptocurrencies), certain transaction-level information is inherently public on those networks. The information we may have access to includes:

• Public addresses associated with your wallet — public by nature on the underlying networks and not, by themselves, identifying.
• Transaction data that passes through the protocols we interact with and may be visible to us and to other network participants.
• Publicly available network data — any information that is already publicly accessible through the underlying protocols.

We do not correlate this publicly available data with your real-world identity. Using the App itself does not require us to collect identifying information about you.

4. Information We Do Not Collect

We do not collect, store, or process:

• Private keys, credentials, recovery phrases, or key derivation material
• Government-issued identification (not required to use the App)
• Personal names, physical addresses, or contact information (unless you contact us directly or join a waitlist)
• Bank account or other financial-institution information
• Detailed transaction history linked to your identity

5. Information We May Collect

To maintain and improve the App and the website, we may collect minimal, non-identifying data:

• Device information — device model, operating system version, and app version for crash diagnostics.
• Anonymous usage analytics — aggregated, non-identifiable interaction data (e.g., which screens are visited) to improve the user experience.
• Push notification tokens — if you opt in to notifications, we store a device token to deliver alerts. This token is not linked to your wallet or identity.
• Waitlist / access requests — if you submit your email address to request access through dollar.black, we store the email (hashed for deduplication), the timestamp, and limited request metadata (IP-derived country/region, user-agent string, referrer) to contact you about access and detect abuse. We do not use this data for any other purpose.

We do not use cookies or similar tracking technologies on the dollar.black website beyond what is strictly necessary to operate it.

6. Third-Party Services

The App interacts with public payment rails (stablecoins on various blockchains, the Bitcoin network, and other cryptocurrency networks) to process transactions. These are decentralized protocols; we do not control them and are not responsible for their operation, availability, or privacy practices.

We may use third-party services for hosting, crash reporting, anonymous analytics, and email delivery for waitlist communication. These services operate under their own privacy policies.

7. Data Storage & Security

All sensitive material (private keys, credentials) is derived on your device and secured using platform-native encryption (iOS Keychain / Android Keystore). We have no access to this material.

Where we do process minimal data (such as analytics, push tokens, or access-request emails), we implement reasonable technical and organizational measures to protect it. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

In the event of a data breach affecting personal data, we will notify affected users and relevant authorities as required by applicable law.

8. International Data Transfers

OrkLabs S.A.S. is based in Argentina. If you access the App or the website from outside Argentina, any limited data we process (such as analytics, crash reports, or access-request emails) may be transferred to and processed in Argentina or other countries where our service providers operate. By using the App or submitting your information, you consent to such transfers.

9. Your Rights

Given our self-custody architecture, we hold minimal to no personal data. Depending on your jurisdiction, you may have rights regarding your personal data, including the right to access, correct, delete, or restrict its use.

• United States residents: If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect and the right to request deletion. Given our minimal data collection, we do not sell personal information.
• EU/EEA residents: You may have rights under the General Data Protection Regulation (GDPR), including the right to access, rectification, erasure, and data portability.

To exercise any of these rights, contact us at hello@dollar.black. We will respond within the timeframe required by applicable law.

10. Children's Privacy

Dollar is not directed at children under 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal data, please contact us and we will delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last updated” date. Continued use of the App after changes constitutes acceptance.

12. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Argentine Republic.

13. Contact

If you have questions about this Privacy Policy, contact us at:

OrkLabs S.A.S. — hello@dollar.black