1. Introduction and scope
This Privacy Policy describes how LIQUMO ("LIQUMO", "we", "us") collects, uses, stores and protects information in connection with the LIQUMO website at liqumo.com, the LIQUMO mobile applications for iOS and Android, when available, and any related interfaces, APIs and services (collectively, the "Service"). By using the Service you acknowledge the practices described here. If you do not agree with them, please do not use the Service.
LIQUMO is designed around data minimisation. The Service is non-custodial: the most sensitive elements of on-chain activity, namely private keys and transaction signing, never reach our systems.
2. Controller and contact
The data controller for the Service is Liqumo Labs LLC, a Delaware limited liability company with its business and mailing address at 2810 N Church St, STE 91470, Wilmington, DE 19802, United States. For any question about this Policy or about how your information is handled, and to exercise the rights described in Section 12, contact us at support@liqumo.com or legal@liqumo.com. We aim to respond within 30 days.
3. Information we process
3.1 Public blockchain data. When you connect a wallet, we read your public wallet address, the address of your smart account where the website or the mobile applications use one, and the network you are connected to in order to display balances, positions and relevant market data. Balances are read through providers of network nodes, including PublicNode, dRPC, Tenderly and the official nodes of the supported networks, which receive the wallet address in these requests; the server keeps the result in memory for up to one minute and does not write it to storage, except for the information described in Section 3.6 (notifications) and Section 3.13 (portfolio history). A public address and the transactions associated with it are visible to anyone on public blockchains by design. When you request a swap quote, the website sends your wallet address, the network, the tokens and the amount to the swap service of Circle, which routes the swap through LI.FI and returns the transaction for you to sign.
3.2 Technical information. To deliver and secure the Service, our hosting provider processes the technical data of each request, such as IP address, browser or application version and the address requested. Server errors are reported to Sentry with the error message and stack trace only, without request headers, cookies, request bodies or address parameters. We do not build advertising profiles.
3.3 AI assistant conversations. The AI assistant is available when you are signed in with Apple, Google or email. Questions you submit to the AI assistant, and the answers generated, are processed to operate the AI assistant, to maintain session context and to control abuse. A conversation session holds the session identifier, the wallet address of your account and the most recent questions and answers. To answer, the AI assistant provider receives the question, the session history and the balances and positions of your wallet. The daily question limit is counted per account. Please do not include identity documents, account credentials, private keys or seed phrases in messages to the AI assistant.
3.4 Account identifiers. If you sign in with Apple, Google or email, sign-in is provided by Privy, which passes us the identifier issued for your account (and your email address where you provide it or the identity provider shares it) in order to maintain your session. Privy creates a wallet for such accounts; LIQUMO has no access to its keys. Access tokens issued by Privy are verified against Privy's public keys and are not stored.
3.5 Smart account operations. If you sign in with Apple, Google or email, the website and the mobile applications carry out deposits, withdrawals and other operations through a smart account controlled by the wallet that Privy creates for your account. Our server determines the address of the smart account, prepares each operation and, after you sign it, submits it; for this we process your Privy identifier, the owner wallet address, the smart account address, the network and the operation itself, including the tokens, amounts, protocols and the LIQUMO fee. Pimlico submits the operation to the network and, where LIQUMO pays the network fee, sponsors it; to prevent abuse we count sponsored operations per user per day. Once executed, the operation, the smart account address and its link to the owner wallet are public on the blockchain.
3.6 Notifications. If you enable notifications in a mobile application, we store your Privy identifier, the device push token, platform, notification service, environment and language (up to ten devices per account), and, to notify you about changes in risk and rates, the vault, network, risk level and rate of each of your positions at the last check, which we read for your wallet and smart account addresses every hour. Your notification feed keeps up to the 100 most recent events: the type of event, network, vault and pool, amount and asset of the operation, rate, risk level, operation and transaction hashes, and whether you have read it. Notifications belong to your account and cannot be read by wallet address. Apple Push Notification service and Firebase Cloud Messaging receive the device token and the text of each notification, which includes the amount, asset and pool name but not your wallet address. Signing out of the application deletes your devices, position monitoring and notifications from our servers.
3.7 Usage measurement. To understand how the Service is used, the website and the mobile applications record product events, such as page and screen views, sign-in, strategy selection, the start and outcome of deposits and withdrawals, and opening a pool, the AI assistant or a notification. Each event holds the event name, platform, application version, interface language, country derived by our hosting provider, strategy profile, network, asset symbol, sign-in method, execution method, error code, pool or vault, the amount in US dollars rounded to two significant digits and the duration of the step. Visitors are counted by a daily identifier: a hash of the IP address and browser or application details with a random salt that changes every UTC day and is deleted after two days, after which the identifier cannot be linked back to an IP address. We do not record wallet addresses, transaction hashes, account identifiers, IP addresses, browser details or AI assistant texts in these events, and we use no cookies or browser storage for them. Requests sent with a Global Privacy Control or Do Not Track signal are not recorded.
3.8 Support correspondence. If you contact us, we keep the correspondence and any information you choose to provide for as long as needed to resolve the request.
3.9 Partner and API requests. If you submit a white-label or API access request, we process the details you provide (name, work email, company, website and message) to evaluate the request, operate the resulting relationship and meet our contractual obligations. API usage logs (endpoint, timestamp, volume and region inferred from IP address) are processed for rate limiting, security and abuse prevention.
3.10 Swaps, limit orders and transfers. To quote and build a swap, a limit order or a cross-chain transfer, our server sends the network, tokens and amounts, and where needed to build the transaction your wallet or smart account address, to the routing services we use (KyberSwap and, where enabled, 1inch, 0x, Uniswap and Circle), to CoW Protocol for limit orders and to Circle for transfers. A limit order you sign is placed with CoW Protocol under your address and is public in its order book until it is filled, cancelled or expires. We do not store the status of a transfer: it is read from Circle each time you view it. For a transfer to or from Tempo, our server sends the networks, token and amount, your wallet or smart account address and the recipient address to Across to obtain a quote and build the deposit, reads the quote of the Stablecoin DEX of Tempo from a node of the Tempo network where OUSD is received or offered, checks both addresses against the sanctions list of the Chainalysis oracle on Arbitrum by read requests through providers of network nodes, and reads the status of the transfer from Across each time you view it; we do not store it. For a swap within Tempo, our server reads the quote of the Stablecoin DEX of Tempo from a node of the Tempo network and checks your address against the same sanctions list in the same way. For a transfer to another address within one network, our server receives the network, token and amount, your wallet or smart account address and the recipient address to build the transaction, and checks both addresses against the same sanctions list in the same way; the result of the check is not stored. The website keeps on your device a list of the recipient addresses you have used, so that it can ask you to check a new address; this list is not sent to us.
3.11 Testing of new features. If you agree to test a feature before it is available to all users, we record your Privy identifier and, where you give one, a name or alias in a list of testers, in order to give you access to that feature. The list is visible only to LIQUMO administrators and is not published. Changes to the list are recorded with their time.
3.12 Rewards of third-party programmes. To show the rewards that have accrued under third-party incentive programmes and to prepare a transaction to claim them, our server sends to Merkl, the distribution service of these programmes, the address for which rewards are requested and the network: in the mobile applications this is the address of your smart account, on the website the address of the connected wallet. Merkl receives these requests from our server and does not receive the IP address of your device. We receive the amounts and tokens of accrued and claimable rewards together with the data needed to claim them, and use this information only to display your rewards and to build the claim transaction, which shows the tokens and amounts before you sign it. The response is held in the memory of our server for up to 60 seconds to limit repeated requests and is not stored after that. If you have enabled notifications, we also check, for your wallet and its smart account, the rewards accrued in vaults with such programmes in which you hold a position, and keep for each network and reward token the last amount we notified you of and the time of that check, so that we notify you only of new rewards; these records are deleted when you sign out on all devices or delete your account. Merkl processes the requests under its own terms and privacy policy, and the programmes are run by their organisers, not by LIQUMO. When you claim rewards, the transaction and the amounts claimed are recorded on the blockchain and are publicly visible.
3.13 Portfolio history. If you sign in with Apple, Google or email, we keep a history of your portfolio so that the Service can show how its value changes over time. Once a day our server reads the portfolio of your account in the same way as for display under Section 3.1 and records its total value in US dollars for that day: positions in vaults and pools and wallet balances. Positions in pools for which LIQUMO does not build operations count towards the value but have no operation entries. We also record your deposits to and withdrawals from the vaults available through LIQUMO: the date, network, vault, asset, amount and transaction hash. Smart account operations are recorded once the network confirms the operation our server submitted; for operations signed in a wallet, the website or the application reports the transaction and our server verifies it on the blockchain, taking the asset and amount from the blockchain record. The history is linked to your Privy identifier and to the addresses of your account, namely the wallet that Privy created for you and your smart account. It starts on the first day you use the Service while signed in after the function is enabled and does not cover earlier periods. Wallets that you connect or link in addition to these addresses are not included. We use the history only to display the value chart of your portfolio and its operations. To stop recording for accounts that are no longer used, we also store the date you last used the Service while signed in, and we stop the daily record if you have not done so for 180 days; it resumes when you next sign in. Each daily value and each operation is kept for 365 days from its date. The whole history is deleted when you delete your account, and you can ask us to delete it without deleting your account by emailing support@liqumo.com; signing out does not delete it. If we delete the history at your request, we stop recording it until you ask us to resume, and keep a one-way hash of your account identifier for that purpose until you resume or delete your account. We keep no history for an external wallet used without signing in. Deposits, withdrawals and their amounts also remain publicly visible on the blockchain.
4. Information we never receive
We never receive, store or transmit private keys, seed phrases, wallet passwords or any equivalent credential, and we have no technical ability to initiate or sign transactions on your behalf. The website prepares transactions in your browser; for smart account operations of the website and the mobile applications, our server prepares the operation and submits it only after you have signed it. Signing happens exclusively in your wallet. Anyone requesting such credentials on our behalf is an impersonator.
5. Legal bases for processing
Where the GDPR or an equivalent regime applies, we process personal data on the following bases: performance of a contract (providing the Service you request, Art. 6(1)(b)); legitimate interests (security, fraud prevention and improvement of the Service, Art. 6(1)(f)); compliance with legal obligations (Art. 6(1)(c)); and, where required, your consent (Art. 6(1)(a)), which you may withdraw at any time without affecting prior processing.
6. Cookies and similar technologies
The LIQUMO website sets no cookies of its own, and usage measurement (Section 3.7) uses neither cookies nor browser storage. Your interface language is part of the page address. The website stores nothing in your browser and makes no requests to third parties other than the analytics described below until you choose to connect a wallet or sign in. When you do, the website starts the wallet connection libraries of Reown (WalletConnect) and Coinbase (Base Account) and the sign-in library of Privy. These libraries store connection and session data in your browser's local storage and IndexedDB, whichever wallet you then choose. Privy also receives usage events of its library and, through its service providers, security and error reports, and its security provider Cloudflare sets cookies on Privy's domain to protect the sign-in against automated abuse. The web application keeps a log of operations completed on your device and the read state of notifications there; this log is not sent to us. These are functional, not advertising, technologies. We use Cloudflare Web Analytics to measure page views and performance. It does not use cookies or local storage; Cloudflare receives the page address, referrer, browser type and approximate location derived from the IP address, and provides us with aggregate statistics only. We do not use advertising trackers. A wallet or sign-in provider you use may set its own cookies on its own domain under its own privacy policy.
7. Third-party processors
We share data only as needed to run the Service, with a limited number of service providers, each confined to its function: Cloudflare, Inc. (hosting, content delivery, data storage, usage measurement and aggregate website analytics); Privy (sign-in with Apple, Google or email, and the wallets created for those accounts, including usage events of its library and security and error reports processed by its service providers); Reown / WalletConnect (connection of external wallets; Reown receives the connected wallet address and connection events); Coinbase (the Base Account wallet connection library; it stores connection data in your browser once the wallet libraries start); Anthropic PBC (AI assistant answers; it receives the question, the session history and, where you are signed in, the balances and positions of your wallet, but not your contact details); Pimlico (submission and sponsorship of smart account operations); KyberSwap (swap quotes and routes); 1inch (swap quotes and routes, where enabled); 0x (swap quotes and routes, where enabled); Uniswap Labs (swap quotes and routes, where enabled); CoW Protocol (placement and settlement of limit orders); Morpho (public data of vaults and markets, read from the blockchain); Merkl (distribution of rewards of third-party incentive programmes; it receives from our server the smart account or wallet address and the network in requests for accrued rewards and claim data); providers of network nodes, including PublicNode, dRPC, Tenderly, the official nodes of the supported networks and the node operators of the Arc network (balance, position and transaction reads; they receive the wallet or smart account address in these requests); Apple Inc. and Google LLC (application distribution, sign-in and delivery of push notifications); Functional Software, Inc. (Sentry; server error reports); DeFiLlama (public market data); Circle (CCTP infrastructure for cross-chain transfers and the swap service; it receives your wallet address, the networks, tokens and amounts of the transfer or swap); Across Protocol (quotes, deposits and status of transfers to Tempo; it receives the networks, token and amount, your wallet or smart account address and the recipient address); and LI.FI (routing of swaps requested through Circle). These providers process information under their own privacy terms and may act as independent controllers for their part of the processing.
8. Sharing and disclosure
We do not sell personal information and do not share it for cross-context behavioural advertising. We may disclose information only: to the processors listed in Section 7; where required by law, regulation or valid legal process; to protect the rights, safety and security of LIQUMO, our users or the public; and in connection with a merger, acquisition or sale of assets, subject to this Policy.
9. International transfers
Our infrastructure and processors may be located in countries other than yours. Where the law requires a transfer mechanism, we rely on appropriate safeguards, including standard contractual clauses or an adequacy decision.
10. Retention
We retain information only for as long as necessary for the purposes in this Policy, unless a longer period is required by law: AI assistant sessions for 7 days and AI assistant question counters for 2 days; notifications for 90 days from their last change; device and position monitoring data for 180 days from the last registration of the device; pending operations awaiting an outcome notification for 1 day; prepared smart account operations for 11 minutes until submission and a record of the submission (operation hash, network, smart account address and time) for 7 days; sponsorship counters for 2 days; usage measurements for three months; partner and API requests for 180 days; entries in the list of testers until you leave the testing or the feature becomes available to all users, and records of changes to that list for 12 months; responses on accrued rewards in server memory for up to 60 seconds; for notifications about rewards, the last notified amount and time per network and reward token until you sign out on all devices or delete your account; portfolio history (daily value and the deposits and withdrawals prepared by LIQUMO) for 365 days from the date of each entry, or until you delete your account if earlier, and the date you last used the Service while signed in for as long as your history is kept; where you have deleted the history and recording is stopped, a one-way hash of your account identifier until you resume recording or delete your account; a one-way hash of the account identifier in the record of a history deletion by our staff for 365 days; support correspondence for up to 24 months; technical and security logs for up to 12 months; server error reports for the retention period of our error-reporting provider. Account identifiers are held by Privy for the life of the account. Blockchain records themselves are immutable public data outside our control.
11. Security
We apply access controls, encryption in transit, least-privilege infrastructure design and dependency monitoring. No method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security; we limit what we collect precisely to reduce exposure.
12. Your rights
Depending on your jurisdiction, you may have the right to access, rectify, erase, restrict or object to the processing of your personal data, to data portability, to withdraw consent, and to lodge a complaint with a supervisory authority. Residents of California and other U.S. states may have additional statutory rights, including the right to know, delete and opt out of sale or sharing (we do not sell or share data for advertising). Signing out of a mobile application deletes your devices and notifications from our servers. To exercise any other right, including an export or deletion of your other account data, email support@liqumo.com. We may need to verify your identity before acting.
13. Children
The Service is intended for users aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us information, contact us and we will delete it.
14. Changes to this Policy
We may update this Policy from time to time. The version and date above identify the current text. Material changes will be announced within the Service before they take effect. Continued use after the effective date of an update constitutes acceptance of the revised Policy.
15. Contact
Privacy questions, requests and complaints: support@liqumo.com or legal@liqumo.com.