Privacy Policy
JHD Investment Group LLC (d/b/a eWallet) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, share, and protect your personal information.
At a Glance
- We collect information necessary to verify identity, operate your wallet, and comply with regulations.
- Your data is protected with encryption, tokenization, and industry-standard security measures.
- We do not sell your personal information.
- We share data with partners only as necessary to provide our services.
Key Disclosures
eWallet is not a bank. Banking services are provided by our partner banks.
1. Introduction
JHD Investment Group LLC ("eWallet," "we," "us," or "our") provides digital wallet services, payment processing, debit card issuance, business invoicing, and related financial technology solutions.
eWallet is not a bank. We are a financial technology company registered with FinCEN as a Money Services Business (MSB #31000303711381). Wallet funds are held in custodial accounts at partner banks, including Chase Bank. The eWallet Debit Card is issued by Sunrise Banks, N.A., Member FDIC, pursuant to a license from Mastercard.
This Privacy Policy describes how we collect, use, disclose, store, and protect your information when you use our mobile apps, web applications, business portals, and related services (collectively, the "Services").
By using our Services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use our Services.
2. Information We Collect
We collect personal and business information necessary to verify your identity, operate your wallet, process transactions, issue cards, maintain regulatory compliance, and protect the platform.
2.1 Identity Verification Information (KYC/KYB)
For individuals (KYC):
- Full legal name
- Date of birth
- Residential address
- Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)
- Government-issued ID (driver's license, passport, state ID)
- Selfie or photo for identity matching
- Email address and phone number
For businesses (KYB):
- Legal business name and DBA
- Employer Identification Number (EIN)
- Business address
- State of incorporation and formation documents
- Beneficial ownership information (owners with 25%+ ownership)
- Business license or registration documents
- Authorized representative information
2.2 Financial & Transaction Information
- Bank account information (account and routing numbers, via Plaid tokens)
- Debit card information (tokenized via Stripe)
- Wallet transaction history (deposits, withdrawals, transfers)
- Debit card transaction history
- ACH, RTP, and wire transfer details
- Invoice and payment records
- Dispute and chargeback records
2.3 Device & Technical Information
- Device type, model, and operating system
- Device identifiers (IMEI, advertising ID)
- IP address and geolocation data
- Browser type and version
- App version and crash reports
- Session duration and feature usage
2.4 Communications Data
- Customer support messages and call recordings
- Dispute documentation
- Application forms and onboarding data
- Survey responses and feedback
2.5 Sensitive Permissions
Our mobile app may request access to:
- Camera: For scanning IDs, taking selfies for identity verification, and scanning QR codes
- Photo Library: For uploading ID documents or profile photos
- Location: For fraud detection and compliance purposes
- Biometrics: For secure app authentication (Face ID, Touch ID, fingerprint)
- Push Notifications: For transaction alerts and security notifications
3. How We Use Your Information
We use your information for the following purposes:
3.1 Service Delivery
- Create and manage your account
- Process deposits, withdrawals, and transfers
- Issue and manage your debit card
- Process invoice payments
- Provide customer support
3.2 Identity & Compliance
- Verify your identity (KYC) and business (KYB)
- Screen against OFAC sanctions lists and watchlists
- Monitor transactions for fraud and suspicious activity
- File required regulatory reports (including SARs)
- Comply with anti-money laundering (AML) requirements
3.3 Security & Fraud Prevention
- Detect and prevent unauthorized access
- Monitor for suspicious transactions
- Investigate security incidents
- Protect against fraud and abuse
3.4 Communications
- Send transaction confirmations and alerts
- Provide account and security notifications
- Respond to customer inquiries
- Send service updates and legal notices
3.5 Improvements & Analytics
- Analyze usage patterns to improve services
- Develop new features and products
- Conduct research and analysis
- Debug and fix technical issues
We do not sell your personal information.
5. Our Service Partners
We partner with regulated financial institutions and service providers to deliver our Services. Your use of eWallet involves sharing data with these partners:
Each partner maintains their own privacy policy and data protection practices. Links to partner privacy policies are available upon request.
6. Data Security
We implement industry-standard security measures to protect your data:
6.1 Encryption
- Data in transit is encrypted using TLS 1.2+
- Data at rest is encrypted using AES-256
- Sensitive fields use additional application-level encryption
6.2 Payment Card Security
Card funding, tokenization, and payment processing occur within PCI DSS–compliant environments provided by our authorized third-party processors. We do not store raw card numbers.
6.3 Infrastructure Security
- Our production systems operate in SOC 2–certified data centers provided by Vultr
- Network segmentation and firewall protection
- Audited access controls and logging
- Our security controls align with ISO 27001 standards
6.4 Access Controls
- Role-based access control (RBAC)
- Multi-factor authentication for administrative access
- Regular access reviews and audits
- Employee security training
6.5 Monitoring & Response
- 24/7 security monitoring
- Intrusion detection systems
- Incident response procedures
- Regular security assessments
While we implement robust security measures, no system is completely secure. We cannot guarantee absolute security of your data.
7. Data Retention
We retain your data as follows:
7.1 Regulatory Requirements
We are required by anti-money laundering (AML) regulations to retain identity verification data, transaction records, and related compliance data for a minimum of 5 years after account closure or the date of the transaction.
7.2 Retention Periods
- Identity & KYC/KYB Data: Minimum 5 years after account closure
- Transaction Records: Minimum 5 years from transaction date
- Account Information: Duration of account plus 5 years
- Customer Support Records: 3 years or as required for disputes
- Device & Technical Data: Up to 2 years
- Marketing Data: Until consent is withdrawn
7.3 After Retention Period
After the required retention period, data is securely deleted or anonymized. Some aggregated, anonymized data may be retained indefinitely for analytics and research purposes.
8. Your Privacy Rights
Subject to applicable law, you may have the following rights:
8.1 Access
You can request a copy of the personal information we hold about you.
8.2 Correction
You can request correction of inaccurate or incomplete personal information.
8.3 Deletion
You can request deletion of your personal information, subject to legal retention requirements. Due to AML regulations, we must retain certain data for a minimum of 5 years.
8.4 Data Portability
You can request a copy of your data in a structured, commonly used format.
8.5 Opt-Out
You can opt out of marketing communications at any time.
8.6 How to Exercise Your Rights
To exercise any of these rights, contact us at:
- Email: privacy@ewallet.app
- Phone: 1-877-827-0995
We will respond to your request within 30 days. We may need to verify your identity before processing your request.
10. International Data Transfers
Your data is primarily processed and stored in the United States. If you access our Services from outside the United States, your information will be transferred to and processed in the United States.
By using our Services, you consent to the transfer of your information to the United States and other countries that may have different data protection laws than your country of residence.
11. Children's Privacy
Our Services are not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18. If you believe we have collected information from a child under 18, please contact us immediately at privacy@ewallet.app.
12. California Privacy Rights (CCPA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
12.1 Right to Know
You can request information about the categories and specific pieces of personal information we collect.
12.2 Right to Delete
You can request deletion of personal information, subject to legal exceptions.
12.3 Right to Non-Discrimination
We will not discriminate against you for exercising your CCPA rights.
12.4 Notice at Collection
We collect the following categories of personal information:
- Identifiers (name, SSN, address, email, phone)
- Financial information (bank accounts, transaction data)
- Biometric information (facial recognition for ID verification)
- Internet/network activity (IP address, device data)
- Geolocation data
- Professional information (for business accounts)
12.5 Do Not Sell
We do not sell personal information. We do not and will not sell your personal information to third parties.
To exercise your CCPA rights, contact us at privacy@ewallet.app or call 1-877-827-0995.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes:
- We will post the updated policy with a new effective date
- We will notify you via email or in-app notification for significant changes
- Your continued use after the effective date constitutes acceptance
We encourage you to review this Privacy Policy periodically for any updates.
14. Contact Information
For privacy-related questions, data requests, or concerns:
Privacy Team
- Email: privacy@ewallet.app
- Phone: 1-877-827-0995
Data Protection
- Email: dpo@ewallet.app
Mailing Address
- JHD Investment Group LLC
- Attn: Privacy Team
- 830 Julie Rivers Dr, Suite 203
- Sugar Land, TX 77478