Privacy Policy
Effective Date: May 17, 2026 · Grey Dog Software, LLC · Razor Wallet
1. Who We Are
Grey Dog Software, LLC operates the Razor Wallet prototype program. This Privacy Policy explains what personal data we collect, how we use it, and your rights under applicable law including the California Consumer Privacy Act (CCPA/CPRA) and, where applicable, the EU/UK GDPR.
Grey Dog Software, LLC2961 E Nighthawk Wy, Phoenix, AZ 85048-0573, United States
Email: razor.wallet@proton.me
Phone: +1 (602) 483-7291
2. Information We Collect
- Application Data: When you apply for beta or partnership tracks, we collect your name, email address, Telegram/Discord handle, GitHub profile (if provided), and a description of your use case.
- Wallet Data: Your private keys and seed phrase are generated and stored exclusively on your device. We never collect, store, or transmit this data.
- Swap Metadata: For prototype diagnostics, anonymized swap event data (chain pair, HTLC state transitions, timing — not linked to identity) may be collected to improve the engine's reliability.
- Technical Data: IP address, browser and app version, operating system, and usage patterns.
- Communications: Emails, messages, and feedback you send us.
3. How We Use Your Information
- To evaluate and manage beta and partnership applications.
- To communicate with you about your application, access, and product updates.
- To improve the atomic swap engine, HTLC reliability, and wallet UX.
- To detect and prevent fraud, abuse, and security threats.
- To comply with applicable US federal and state law.
4. Legal Basis for Processing
- Consent: For program enrollment and optional communications.
- Contract Performance: To provide access and support as requested.
- Legitimate Interest: Security, fraud prevention, and product improvement.
- Legal Obligation: Applicable US federal and Arizona state law.
5. Data Sharing
We do not sell your personal information. We may share data with cloud infrastructure providers under standard data processing agreements, and with legal/compliance advisors under confidentiality obligations. We will disclose data to law enforcement when required by applicable law.
6. Your Privacy Rights
California residents (CCPA/CPRA): You have the right to know what personal information we collect, to delete it, to correct inaccurate data, and to opt out of any sale. We do not sell personal information.
Arizona residents: You have the right to access and correct your personal data. Contact us to exercise these rights.
EEA/UK residents (GDPR): You have rights of access, rectification, erasure, restriction, portability, and objection. You may lodge a complaint with your local supervisory authority.
To exercise any right: razor.wallet@proton.me
7. Data Retention
- Beta application data: program duration plus 12 months.
- Anonymized swap diagnostics: 6 months.
- Technical logs: 30 days.
- Communications: 3 years.
8. Security
We implement TLS 1.3 encryption in transit, strict access controls, and regular security reviews. You will be notified of confirmed data breaches as required by Arizona and applicable federal law.
9. Cookies
We use only strictly necessary session cookies to operate this website. A cookie notice is displayed on first visit. No advertising or behavioral tracking cookies are used.
10. Children
The Service is not directed at persons under 18. We do not knowingly collect data from minors.
11. International Transfers
Data is primarily processed in the United States. For EEA users, we rely on Standard Contractual Clauses where applicable.
12. Changes
We may update this Privacy Policy. Material changes will be communicated to active program participants via email at least 30 days in advance.
13. Contact
Grey Dog Software, LLC2961 E Nighthawk Wy, Phoenix, AZ 85048-0573, United States
Email: razor.wallet@proton.me
Phone: +1 (602) 483-7291