Privacy Policy

Draft — under legal review

Last updated: 24 August 2026 · Effective date: 1 August 2026

Table of Contents

1. Overview

HHO Cash LLC, a Texas limited liability company (“HHO Cash,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy (“Policy”) explains how we collect, use, disclose, and safeguard information in connection with our website at hho.cash, our mobile applications, and any related interfaces (collectively, the “Platform”), and the non-custodial wallet software and related features we make available (collectively, the “Services”).

In summary:

• We do not collect, store, or have access to your complete private keys. Key material is generated and managed inside trusted execution environments by third-party infrastructure under a seedless architecture; the full key is reconstituted only transiently and only with your authenticated authorization.
• We do not sell your personal information.
• We collect the minimum information necessary to operate, secure, and improve the Services, including authentication credentials (such as email) required to create and access a seedless wallet.
• You control access to your wallet through your authentication credentials. Loss of those credentials may result in permanent loss of access to associated Digital Assets.

Your use of the Services is also governed by our Terms of Service, available at hho.cash/terms, which is incorporated into this Policy by reference.

2. Scope of This Policy

This Policy applies to information we collect through the Platform and the Services. It does not apply to information collected by any third party, including any DApp, decentralized exchange, on-ramp or off-ramp provider, or other Third-Party Service (as defined in our Terms of Service) that you may access through the Services. Those third parties are independent data controllers, and their collection and use of your information is governed by their own privacy policies, not this Policy.

By using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you should not access or use the Services.

3. Information We Collect

3.1 Information You Provide Directly

Depending on how you use the Services, you may choose to provide us with:

• Contact information, such as an email address (or other supported login method), which is used both to create and access a seedless wallet and, if you choose, for support or product communications;
• Account or profile information, such as a username or avatar, if the Services offer optional account features;
• Feedback, survey responses, and the content of your communications with our support team;
• If you choose to use optional identity-verified features (for example, a fiat on-ramp or off-ramp, or a co-branded payment product), Know Your Customer (“KYC”) information such as your legal name, date of birth, government-issued identification, and related verification data. This information is collected and processed on our behalf by a third-party verification provider; HHO Cash does not store or retain your KYC information in its own systems unless expressly stated otherwise for a specific feature; and
• If you use a payment feature, limited payment method information (such as the last four digits of a card or bank account) needed to let you identify and select a payment method; full card or account numbers are processed by our third-party payment processor and are not stored by HHO Cash.

3.2 Information Collected Automatically

When you use the Services, we may automatically collect:

• Device and usage information, such as device model, operating system, application version, browser type, crash logs, and general usage statistics;
• Your IP address, processed on a limited and, where feasible, transient basis, as described in Section 8;
• Publicly available blockchain data, including your public wallet address(es) and on-chain transaction history. This data is inherently public by virtue of how blockchain networks operate. We may also log or process certain of these public addresses and interactions for security monitoring, fraud prevention, abuse detection, and aggregated product analytics. Because the underlying data is already public on the blockchain, this processing does not involve private keys, authentication credentials, or non-public personal information; and
• Cookie and analytics data, as described in Section 7, where you have not disabled or opted out of such collection.

3.3 Information From Other Sources

If you choose to create or log into an account through a third-party platform (such as Google or Apple single sign-on), we may receive limited information from that platform, such as your email address, in accordance with that platform's own authorization and privacy practices. We may also receive information from marketing partners or analytics providers, which we may combine with information collected directly from you.

3.4 Authentication Information

When you create or access a seedless wallet, we and our third-party key-management infrastructure provider (currently Privy) process authentication credentials (such as email address or single-sign-on tokens) and related session data necessary to authorize wallet operations. That provider processes key material inside TEEs and does not share complete private keys with HHO Cash.

4. What We Do Not Collect

HHO CASH DOES NOT COLLECT, TRANSMIT, OR STORE YOUR COMPLETE PRIVATE KEY, OR ANY SECRET RECOVERY PHRASE, KEY MATERIAL IS GENERATED AND MANAGED VIA THIRD-PARTY TRUSTED EXECUTION ENVIRONMENT (TEE) INFRASTRUCTURE USING DISTRIBUTED KEY SHARDING. NEITHER HHO CASH NOR THE INFRASTRUCTURE PROVIDER HOLDS A COMPLETE PRIVATE KEY. THE FULL KEY IS RECONSTITUTED ONLY TRANSIENTLY INSIDE THE TEE, AND ONLY UPON YOUR AUTHENTICATED AUTHORIZATION, SOLELY FOR THE PURPOSE OF SIGNING.

We do not require government ID or financial account information to create or use a self-custody wallet through the Services. Such information is collected only where you affirmatively choose an optional feature that legally requires it (for example, identity verification for a fiat on-ramp), and is generally processed by a third-party provider rather than retained by HHO Cash.

5. How We Use Your Information

We use the information we collect to:

• provide, operate, and maintain the Services;
• personalize your experience, such as remembering preferences and settings;
• improve and develop the Services, including through aggregated or de-identified analysis of usage patterns;
• communicate with you, including responding to support requests and, where you have opted in, sending product updates or marketing communications;
• detect, investigate, and prevent fraud, abuse, security incidents, and violations of our Terms of Service;
• comply with applicable law, including sanctions, anti-money laundering, and tax obligations, where relevant to a specific feature; and
• exercise or defend legal claims and protect the rights, property, and safety of HHO Cash, our users, and others.

We do not use information collected through the Services to determine your eligibility for credit, insurance, housing, or employment, and we do not use sensitive personal information (such as government ID or biometric data collected by our verification providers) to infer characteristics about you beyond the specific purpose for which it was collected.

6. How We Share Your Information

We may disclose information about you in the following circumstances:

• Service providers and vendors. We work with third parties that provide hosting, cloud storage, analytics, customer support, payment processing, identity verification, and key-management / authentication infrastructure services on our behalf. These providers may only use your information to perform services for us and are contractually restricted from using it for their own purposes.
• Bank rail and identity verification. When you use a bank transfer, your name, email, date of birth, address, and identity document are collected and held by Bridge (Bridge Ventures Inc.), the licensed party on that rail. HHO Cash does not collect or store these documents. Bridge processes them under its own privacy policy and its obligations as a regulated money transmitter.
• Affiliates. We may share information with any corporate affiliate that controls, is controlled by, or is under common control with HHO Cash.
• Business transfers. If HHO Cash is involved in a merger, acquisition, reorganization, bankruptcy, or sale of some or all of its assets, information about you may be transferred as part of that transaction, subject to the terms of this Policy or a successor policy.
• Legal and regulatory disclosure. We may disclose information where we believe in good faith that disclosure is required by law, regulation, legal process, or governmental request, including to comply with sanctions or anti-money-laundering obligations.
• Protection of rights and safety. We may disclose information to investigate or address fraud, security threats, or violations of our Terms of Service, or to protect the rights, property, or safety of HHO Cash, our users, or others.
• Aggregated or de-identified data. We may share information that has been aggregated or de-identified such that it does not reasonably identify you, for research, analytics, or business purposes.

HHO CASH DOES NOT SELL YOUR PERSONAL INFORMATION, AND DOES NOT SHARE YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR THEIR OWN DIRECT MARKETING PURPOSES.

7. Cookies and Tracking Technologies

Our website and Platform may use cookies, pixels, and similar tracking technologies to operate core functionality, remember your preferences, and, where applicable and subject to your consent, measure and improve the performance of our marketing. You can control cookies through your browser settings and, where offered, through a cookie preference banner on our website. Disabling certain cookies may limit some functionality of the Platform.

Where we use third-party analytics providers (for example, to understand aggregate usage of our website), those providers may set their own cookies subject to their respective privacy policies.

8. IP Address Handling

Your IP address may be processed on a limited basis to: (a) establish the network connection necessary to deliver the Services; (b) detect and prevent denial-of-service attacks and other security threats; (c) determine your general region for the purpose of complying with regulatory or sanctions requirements applicable in your jurisdiction; and (d) route requests to improve performance.

WE DO NOT USE YOUR IP ADDRESS FOR ADVERTISING OR MARKETING PURPOSES BEYOND WHAT IS REQUIRED TO COMPLY WITH JURISDICTIONAL LEGAL REQUIREMENTS, AND OUR SYSTEMS ARE NOT DESIGNED TO LINK YOUR IP ADDRESS WITH YOUR WALLET ADDRESS, USERNAME, OR EMAIL ADDRESS.

9. AI-Assisted Features (If Applicable)

If the Services include automation or AI-assisted features (including any AI Agent referenced in our Terms of Service), we process the content of your inputs, queries, or feedback as necessary to deliver that functionality. Where we rely on third-party AI service providers to deliver these features, those providers are contractually bound to use your information only as instructed by us and not for their own independent purposes.

10. Third-Party Links and Services

The Services may link to, or allow you to interact with, DApps, decentralized exchanges, lending protocols, trading venues, and other Third-Party Services (including, for example, Morpho vaults, Hyperliquid, and similar protocols). These third parties operate independently of HHO Cash and act as independent data controllers with respect to any information you share with them or that is generated through your interaction with their services or interfaces.

When you deposit assets into a Morpho vault, engage in Strategies or copy-trading on Hyperliquid, or otherwise interact with any Third-Party Service, that protocol (and any front-end interface you use to access it) becomes the independent controller of the data associated with those interactions. This Policy does not apply to, and we are not responsible for, the privacy practices of any Third-Party Service. We encourage you to review the privacy policy of any third party before interacting with it.

11. Data Retention

We retain information for as long as necessary to fulfill the purposes described in this Policy, including to provide the Services, comply with legal obligations (such as tax, accounting, or recordkeeping requirements), resolve disputes, and enforce our agreements. When information is no longer needed for these purposes, we will delete or de-identify it, except where retention is required by law.

Because certain information you generate through the Services (such as public wallet addresses and transaction data) is recorded on public, decentralized blockchain networks, that information cannot be deleted, altered, or made private by HHO Cash. Blockchain networks are not operated or controlled by HHO Cash, and requests for deletion of on-chain data cannot be fulfilled by us.

12. Data Security

We implement reasonable technical, administrative, and physical safeguards designed to protect information we hold from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. If you believe your account or wallet has been compromised, please refer to the wallet security guidance in our Terms of Service and contact us using the information in Section 19.

13. International Data Transfers

HHO Cash is based in the United States, and information we collect is generally processed and stored in the United States. If you access the Services from outside the United States, you understand that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those of your jurisdiction. Where required, we use appropriate safeguards, such as standard contractual clauses, for transfers of personal data from the European Economic Area, the United Kingdom, or Switzerland.

14. Children's Privacy

The Services are not directed to individuals under the age of 18, and our Terms of Service require that users be at least 18 years old. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under the age required by applicable law (including under the Children's Online Privacy Protection Act), we will take reasonable steps to delete that information. If you believe a child has provided us with personal information, please contact us using the information in Section 19.

15. Your Privacy Rights

15.1 General Rights

Subject to applicable law and certain exceptions, you may have the right to:

• request access to, or a copy of, the personal information we hold about you;
• request correction of inaccurate or incomplete personal information;
• request deletion of your personal information;
• request a portable copy of your personal information;
• object to, or request restriction of, certain processing; and
• withdraw any consent you have previously provided, without affecting the lawfulness of processing before withdrawal.

To exercise these rights, please contact us using the information in Section 19. We may need to verify your identity before responding, and we may decline a request where permitted or required by law, in which case we will explain our reasons where required to do so.

15.2 Texas Residents

If you are a Texas resident, you have rights under the Texas Data Privacy and Security Act (“TDPSA”), including the right to confirm whether we are processing your personal data, to access that data, to correct inaccuracies, to request deletion, to obtain a portable copy of data you provided to us, and to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or certain profiling. HHO Cash does not sell personal data or engage in targeted advertising as those terms are defined under the TDPSA. If we deny a request, you may appeal by contacting us using the information in Section 19; if your appeal is denied, you may submit a complaint to the Texas Attorney General.

15.3 Other U.S. State Residents

If you reside in a state with a comprehensive privacy law (such as California, Colorado, Connecticut, Utah, Virginia, or others), you may have similar rights to access, correct, delete, and port your personal information, and to opt out of the sale of personal information, targeted advertising, or certain profiling. As noted above, HHO Cash does not sell your personal information or share it for cross-context behavioral advertising. You may exercise these rights, and, where applicable, designate an authorized agent to do so on your behalf, by contacting us using the information in Section 19. We will not discriminate against you for exercising any privacy right.

15.4 European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, we process your personal data on the basis of: performance of a contract with you; our legitimate interests in operating, securing, and improving the Services (balanced against your rights); compliance with our legal obligations; and, where applicable, your consent. In addition to the rights described in Section 15.1, you have the right to lodge a complaint with your local data protection authority. Contact details for EEA supervisory authorities are available at https://edpb.europa.eu, for the UK at https://ico.org.uk, and for Switzerland at https://www.edoeb.admin.ch.

16. Do Not Track and Global Privacy Control

Some browsers offer a “Do Not Track” signal or support the Global Privacy Control (“GPC”), a browser-based signal indicating a preference to opt out of certain data sharing. Where technically feasible and required by applicable law, we will honor a valid GPC signal as a request to opt out of the sale or sharing of your personal information, to the extent we engage in such practices. As noted above, HHO Cash does not currently sell personal information or share it for targeted advertising.

17. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, the Services, or applicable law. We will post the revised Policy on the Platform and update the “Last Updated” date above. Where a change is material, we will provide additional notice, such as through the Platform or by email, as appropriate. Your continued use of the Services after a revised Policy is posted constitutes your acceptance of the changes.

18. Definitions

19. Contact Us

If you have questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at:

hho cash LLC

605 W 9th Street, Suite #1097, Austin, TX 78701, United States

EIN 42-4361098

[email protected] — general questions

[email protected] — privacy requests. Kept separate on purpose: a notice with a deadline running on it must not sit in the same inbox as questions about fees.

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