Privacy Policy.

This policy covers the Olbra mobile app. The olbra.org website has its own Privacy Policy.

Data controller

Olbra ApS

CVR

39729482

LEI

8945001XWFMRUTCAK575

Registered office

Krudtløbsvej 12, 1439 København K, Denmark

Supervision

Finanstilsynet (Danish FSA), authorised 11 February 2025, ref. 17547

Privacy contact

[email protected]

Your key is generated on your device the first time you open the app and stays there. Olbra holds no key that can move funds out of your account, and we cannot recover your key for you. The e‑money tokens we issue (PLNY, EURY, USDY) carry the controls the law requires of an issuer, and those controls apply to the token itself.

Our authorisation as an e‑money institution covers the e‑money tokens the app carries — not the app, and not the other assets you can hold in it.

Payments in the app settle on public blockchains. Addresses, amounts and times are public, permanent and outside anyone's control, including ours. Once a transaction is confirmed it cannot be edited, hidden or deleted, by us or by you.

Only what a category applies to you. If you never use a feature, we hold nothing for it.

Account

Email address if you give one, your Apple account identifier if you sign in with Apple, a password hash, your account status, and your verification status and country.

Sessions

A hash of your session token, your IP address and your device's user‑agent string. Sessions expire after 30 days of inactivity.

Device

Your Apple push notification token, if you turn notifications on. This is the only device identifier we hold.

Wallet

Your public blockchain address and the chains you use.

Phone and email you add

Stored only as a one‑way keyed hash, so we can match a payment to you without holding the number or address itself. The one exception is the pre‑launch signup list, where we keep the phone number in readable form because we have to send you an SMS; it is never returned by the app and is deleted when the campaign ends or when you leave it.

Payments and requests

Amounts, tokens, counterparty addresses, transaction hashes, the status of payments sent to a phone or email before they are claimed, and any short note you attach to a money request.

Buying and selling

Order records: amount, currency, fees, method, the provider's reference, the receiving address, status, and the IP address the order was placed from.

Identity verification

The outcome only — status, country, level, expiry date, the provider's customer reference, and the provider's response kept as evidence for the record. We do not hold your identity documents, your selfie, your national identification number, your date of birth or your home address.

Card

The last four digits, expiry month and year, status and limits; and for each purchase the merchant name, city, category, amount and any cashback. We never hold the full card number or the security code.

Rewards

Your points, tasks, streaks, who invited you and who you invited, and a pseudonymous label on the public board. The label is derived from an internal identifier, never from your phone number, and your number is never shown anywhere public.

Activity log

A record of each change to your account — who did it, what changed and when — kept for security and to meet our record‑keeping duties.

Some data never reaches us at all. Your key, its backup, your session token and any unclaimed payment secret are held in the iOS Keychain, unlocked with Face ID, Touch ID or your passcode. The backup copy is synchronised through your iCloud Keychain so you can restore it on a new device; that copy is governed by Apple's terms, not ours.

The names, phone numbers and email addresses you see next to people you have paid are stored on your device only, because we hold those identifiers as hashes. They are wiped when you sign out.

When you pick someone from your contacts, the picker runs outside the app. The app never gains access to your address book — only the single phone number or email you tap comes back, and it stays on your device.

• No advertising identifier, and no tracking of you across other apps or websites.
• No location. The app pre‑fills a country from your device's region setting and never asks for location access.
• No analytics or advertising software in the app. The app asks for one permission: Face ID.
• No access to your contacts, camera, photos or microphone.
• No recovery phrase, and no copy of your key.
• No identity documents, selfies, national identification numbers, dates of birth or home addresses.

To run the app

Creating your account, moving your payments, quoting and executing exchanges, buying and selling, Earn, the card, and support. Performance of our contract with you — GDPR Art. 6(1)(b).

To meet legal duties

Anti‑money‑laundering obligations, record keeping, tax and reporting, and responding to lawful requests from authorities. Legal obligation — Art. 6(1)(c).

To keep the service safe

Detecting fraud and abuse, rate limiting, preventing fake accounts and referral abuse, and diagnosing errors. Our legitimate interests — Art. 6(1)(f).

With your consent

Push notifications, letting other people find you by your phone number or email, and marketing messages. Consent — Art. 6(1)(a). You can withdraw any of these at any time, in the app.

We do not sell your data and we do not share it for advertising. We use the following providers, each only for what it is listed for.

Payment ramp provider

When you buy or sell with a card or bank transfer. Receives your account reference, the IP address of the order, your receiving address and the amounts. It runs identity verification in its own screen, so your documents and selfie go to it and never to us — for that step it is an independent controller under its own privacy policy, and we receive only the outcome.

SMS provider

Sending verification codes and payment invitations to a phone number.

Email provider

Sending verification codes and payment invitations to an email address.

Apple

Push notification delivery, Sign in with Apple, and the iCloud Keychain backup of your key.

Error diagnostics

Crash and error reports, with personal data stripped before they are sent. Only an internal request identifier and your account identifier are attached.

Blockchain infrastructure

Node, routing and market‑data providers used to read balances, price assets and build transactions. They see blockchain addresses and amounts, never your name or contact details.

Authorities and advisers

Where the law requires it, or to establish or defend a legal claim.

Some of our providers are based in the United States. Where data leaves the European Economic Area we rely on the European Commission's Standard Contractual Clauses, or on an adequacy decision where one applies. Write to [email protected] for a copy of the safeguards for a specific transfer.

Closing your account removes your access and your personal data, except the records above that we are required to keep. On‑chain transactions are not ours to delete.

Sessions

30 days from last use.

Identity verification and payment records

Five years from the end of our relationship with you, as Danish anti‑money‑laundering law requires. Longer only where an authority or a legal claim requires it.

Activity log

Five years, for the same reason.

Pre‑launch signup phone number

Deleted when the campaign ends, or when you leave it.

Everything else

Deleted or anonymised when you close your account.

You can ask us for a copy of your data, to correct it, to delete it, to restrict or object to how we use it, and to receive it in a portable form. Where we rely on consent, you can withdraw it at any time without affecting what we did before. Write to [email protected] and we will answer within one month.

Two things we cannot do: undo a blockchain transaction, and delete records anti‑money‑laundering law requires us to keep. We will tell you which is which if it applies to your request.

If you are not satisfied, you can complain to the Danish Data Protection Agency (Datatilsynet), or to the supervisory authority where you live.

• Datatilsynet — Danish Data Protection Agency Lead supervisory authority

• Your key is generated on your device, never leaves it in readable form, and is unlocked with Face ID, Touch ID or your passcode.
• Session tokens are stored as hashes — a copy of our database does not let anyone sign in as you.
• Phone numbers and email addresses used for finding people are stored as one‑way keyed hashes, so there is no readable contact directory to steal.
• Card numbers and security codes are never stored by us.
• Every change to your account is written to an activity log.

The app is for people aged 18 and over. We do not knowingly process data about children. If you believe a child has an account, write to [email protected] and we will remove it.

If we change this policy we update the date at the top of this page and, where the change is significant, tell you in the app. This page is the current version at all times.

Privacy questions: [email protected]. Anything else: [email protected].

• Olbra app — Terms of Service The terms these services run under
• Complaints How to complain and what happens next