We have create a Key Recovery (KRS) that lets users recover their wallets if they lose their device, paper wallet or can't find their initial seed phrase.
At signup the user has the option to create a 2-of-3 multi-signature wallet, where one key is stored on the user's device, one by us.
The third key, the recovery key, is not stored on any of our servers, We only store the questions the user had to answer to generate the recovery key. The questions are different for each user, and the answers are personal identifiable information.
To generate the recovery key, users must answer the questions used to create it, and retrieve their wallet.
Users have the option to opt-out during the signup process and not generate the recovery key. But they assume the risk of not being able to recover their wallet, if they lose their private key or initial seed phrase.