How We Protect
Your Privacy

This Privacy Policy explains how MothPay Limited ("we") collects, uses, stores, and protects personal information you provide or generate when using our services. By using our services, you agree to this policy.

1. Data We Collect

1.1 Information You Provide

• Identity information: Name, date of birth, nationality, government-issued ID number
• Contact information: Email address, phone number, mailing address
• Business information: Company name, registration number, business license, director details
• Financial information: Bank account details, transaction history, source of funds declaration

1.2 Automatically Collected Information

• Technical information: IP address, device identifiers, browser type, operating system
• Usage data: Access times, page view history, feature usage
• Cookie data: Session tokens, preferences, analytics identifiers (see Cookie Policy)

2. How We Use Your Data

We process your personal data on the following lawful bases:

• Providing, maintaining, and improving our payment services
• Verifying your identity and completing the KYC/KYB process (legal obligation)
• Processing transactions and sending related notifications
• Fulfilling AML, anti-fraud, and sanctions compliance obligations
• Responding to customer service requests and complaints
• Sending important service updates and security alerts
• Analyzing usage patterns to improve product experience (legitimate interest)
• Complying with applicable laws, regulations, and regulatory requirements

3. Data Sharing

We do not sell your personal data. We only share it in the following limited circumstances:

• Financial institution partners: Sharing necessary transaction data with banks and clearing institutions to process payments
• Regulatory authorities: Providing legally required information to financial regulators, law enforcement, or courts
• Service providers: Third-party partners for cloud services, identity verification, etc., bound by strict confidentiality agreements
• Business transfers: Data transferred under the terms of this policy in mergers, acquisitions, or asset sales
• With your consent: In situations where we have your explicit written consent

4. Data Security

We employ multiple layers of bank-grade security measures to protect your data:

• AES-256 encryption at rest
• TLS 1.3 encryption in transit
• Multi-factor authentication (MFA)
• Regular penetration testing and security audits
• Principle of least privilege and strict access controls for employees

In the event of a data breach, we will notify affected users and relevant regulatory authorities within the legally required timeframe.

5. Data Retention

We retain data for the following periods in accordance with legal requirements:

• Transaction records: Minimum 5 years (regulatory requirement)
• KYC documents: Minimum 5 years after account closure
• Account information: Minimum 7 years after account closure
• Communications: Minimum 3 years
• SAR-related records: Minimum 5 years, longer in some jurisdictions
• Marketing data: Until you withdraw consent
• Cookie data: See specific retention periods in our Cookie Policy

Upon expiry, data is securely deleted or irreversibly anonymized, unless legally required to be retained.

6. Cookie Use

We use cookies and similar technologies to improve your experience, maintain session security, and analyze website traffic. For details, please see our Cookie Policy.

7. Your Data Rights

Under applicable data protection laws (including GDPR, PDPA), you have the right of access, rectification, erasure, restriction of processing, data portability, and objection. To exercise these rights, contact service@mothpay.com and we will respond within 30 days.

8. Third-Party Services

Our services may contain links to third-party websites or integrate third-party identity verification services. We are not responsible for the privacy practices of these third parties and recommend you review their respective privacy policies.

9. Children's Privacy

MothPay's services are only for enterprise clients and their authorized representatives who are 18 years or older. We do not serve minors and do not knowingly collect personal information from them.

10. Policy Changes

We may update this Privacy Policy from time to time. For material changes, we will:

• Display a prominent change notice within the platform
• Send notification to your registered email address
• Ask you to confirm acceptance of the new policy on your next login

For questions about this policy, contact: service@mothpay.com