Privacy Policy

1. Who we are

USD2 Foundation (“USD2”, “we”, “us”) operates usd2.org, a self-custodial wallet interface for USD₮ issued on the Bitcoin Network using RGB, together with fiat funding and redemption via partner banks in Switzerland and a peer-to-peer OTC deal matching service.

This policy explains what data we process when you use the site, the wallet interface, and the OTC deal book. Privacy questions can be sent to privacy@usd2.org.

2. What never leaves your device

The wallet is self-custodial. Your BIP39 recovery phrase is generated in your browser, encrypted with a key derived from your device passkey, and stored only in your browser’s local storage. We do not receive, transmit, escrow, or back up your recovery phrase, private keys, or passkey secrets, and we cannot recover them if you lose your device and your backup.

• Recovery phrase and derived private keys — device only.
• Passkey material and PRF-derived encryption keys — device and authenticator only.
• Encrypted wallet backups you export — stored wherever you choose to save them.

3. Data we do process

• Account identifiers: a wallet account ID and passkey credential ID (public key only) used to recognise your device at sign-in.
• Fiat funding and redemption data: name, address, date of birth, nationality, identity documents, IBAN and payment references, and source-of-funds information collected to satisfy Swiss anti-money-laundering and banking requirements at our partner banks.
• OTC deal data: the terms you publish (side, amount, price, chain, settlement route, expiry), deal status transitions, and the counterparty addresses or RGB invoices you provide for settlement.
• Technical data: IP address, browser and device type, timestamps, and error logs used to secure and operate the service.
• Support correspondence you send to us.

4. Public blockchain data

Bitcoin transactions, RGB consignments, and transactions on any counterparty chain used in an OTC swap are recorded on public or shared ledgers that we do not control. Once broadcast, that data is permanent, publicly visible, and cannot be amended or deleted by us or by you. Addresses and invoices can be linked to each other through chain analysis.

5. Why we process it

• To operate the wallet interface, deal book, and status tracking you request (contract performance).
• To issue, mint, and redeem USD₮ against CHF or EUR wires through partner banks (contract and legal obligation).
• To comply with Swiss AML/KYC, sanctions screening, tax, and record-keeping obligations (legal obligation).
• To prevent fraud, abuse, and market manipulation on the OTC book (legitimate interests).
• To send transactional notifications about deposits, transfers, and deal events (contract performance or consent).

6. Who we share it with

We share the minimum necessary data with our partner banks and payment institutions in Switzerland, identity-verification and sanctions-screening providers, our hosting and infrastructure providers, and with authorities or regulators where we are legally required to do so.

In an OTC deal, the settlement details you publish (amount, price, chain, and the receive route you enter) are disclosed to your matched counterparty so settlement can complete. We never disclose your identity documents to counterparties.

We do not sell personal data and we do not use it for third-party advertising.

7. Retention

KYC records and transaction records connected to fiat funding or redemption are retained for at least ten years as required by Swiss financial-services law. OTC deal records are retained for the same period where they relate to a settled fiat leg, and otherwise for up to two years after expiry or completion. Technical logs are retained for up to twelve months.

8. Your rights

Subject to Swiss data-protection law and, where applicable, the GDPR, you may request access to, correction of, or deletion of your personal data, object to or restrict certain processing, request a portable copy, and lodge a complaint with your supervisory authority. Requests that conflict with our statutory retention duties, or that concern data already recorded on a public blockchain, cannot always be fulfilled. Write to privacy@usd2.org.

9. Cookies and local storage

We use strictly necessary browser storage to hold your encrypted wallet, session state, and interface preferences. We do not use advertising or cross-site tracking cookies.

10. Security

Wallet secrets are encrypted at rest in your browser using envelope encryption with a passkey-derived key, and signing actions require a fresh passkey verification. Server-side data is encrypted in transit and at rest and access is restricted on a need-to-know basis. No system is perfectly secure; you are responsible for the security of your device, your passkey, and your exported backups.

11. Changes

We may update this policy as the service, our partner banks, or applicable law change. Material changes will be announced on usd2.org before they take effect.