Privacy Policy

This Privacy Policy explains how [Moneyr Limited] (company name and Hong Kong company number to be added), registered at [registered office address in Hong Kong — to be added] (“Moneyr,” “we,” “us”), collects, uses, shares, and protects personal data when you use our website and Services.

1. Data we collect

We collect the following categories of personal data:

• Account data: name, email address, and authentication data (we use passwordless sign-in links and, if you choose, Google sign-in).
• Identity verification (KYC) data: government ID documents, the ID number extracted from them, a selfie used for liveness and face-matching, address, and source-of-funds information, collected when verification is required to use certain features.
• Screening data: results of sanctions and politically-exposed-person (PEP) screening we’re required to perform as part of anti-money-laundering (AML) compliance.
• Transaction data: payments sent and received, wallet balances, currency conversions, crypto deposit addresses and on-chain deposits, and payout details (bank/e-wallet account information).
• Payment card data: card and digital-wallet payment details are collected and processed directly by our payment processor, Stripe — Moneyr does not store full card numbers.
• Technical data: IP address and basic device/browser information, collected for security, fraud prevention, and to operate the Services (see our Cookie Policy).

2. How we use your data

• To create and operate your account and wallet.
• To process payments, conversions, deposits, and payouts.
• To verify your identity and screen for sanctions/PEP exposure, as required by anti-money-laundering law.
• To detect, prevent, and investigate fraud and abuse.
• To provide customer support and respond to your requests.
• To comply with legal, regulatory, and law-enforcement obligations.
• To send you service communications (transaction confirmations, security alerts, sign-in links) and, where you’ve agreed, product updates.

3. Who we share data with

We share personal data only where necessary to provide the Services:

• Stripe — to process card, Apple Pay, and Google Pay payments.
• CAMP — our crypto custody partner, to provision wallet subaccounts, deposit addresses, balances, and swaps.
• Identity verification and AML screening providers — to perform document verification, face matching, and sanctions/PEP screening.
• Cloud infrastructure and storage providers — to host our application and securely store KYC documents.
• Regulators, law enforcement, and banking partners — where required by law or to complete a payout you’ve requested.

We do not sell your personal data.

4. International data transfers

Because our service providers operate internationally, your data may be transferred to and processed in countries other than your own, including outside Hong Kong. Where required, we rely on appropriate safeguards for such transfers.

5. Data retention

We retain account and transaction data for as long as your account is active and afterward for the period required by applicable anti-money-laundering and financial record-keeping laws. KYC documents and screening records are retained for the statutory period required of a regulated payments business.

6. Your rights

Subject to applicable law, you may request access to, correction of, or deletion of your personal data, and may object to certain processing. Because we’re required to retain KYC and transaction records for compliance purposes, some data cannot be deleted while your account is active or during the mandatory retention period. To exercise a right, contact us at legal@moneyr.app.

7. Security

We use encryption in transit and at rest, access controls, and biometric/liveness checks on sensitive identity workflows to protect your data. No system is completely secure, and we encourage you to use a unique, secure email account for sign-in.

8. Children

Moneyr is not directed at, and we do not knowingly collect data from, anyone under 18.

9. Changes to this policy

We may update this Privacy Policy from time to time. We’ll update the “Last updated” date above and, for material changes, provide notice in the product or by email.

10. Contact

Questions about this policy or a data request? Email legal@moneyr.app.