Privacy Policy

3.1 Information you provide

• Full legal name
• Date of birth
• Residential address
• Email address
• Phone number
• Government-issued identification documents
• Proof of address documentation
• Business registration and beneficial ownership information where applicable
• Tax identification numbers where required
• Source of funds information where required for compliance
• Partner and affiliate application information, including details about your market, audience, business network and partnership interest, where you apply to join the Moki partner or affiliate programme
• Any other information you provide when creating an account, completing verification, applying to a programme, or contacting us

3.2 Information collected automatically

• Device information including device type, operating system and browser type
• IP address and approximate location data
• Log data including pages visited, features accessed and time spent on the platform
• Transaction data including amounts, currencies, recipients, dates and references
• Session data and platform usage patterns
• Referral and affiliate tracking data, including which referral link was used and whether a referred user signed up or completed qualifying activity

We also collect cookies and similar technologies as described in Section 12 and in our Cookie Policy.

3.3 Information from third parties

• Identity verification results from verification providers
• Sanctions and politically-exposed-person screening results from compliance providers
• Risk and fraud information from authorised providers where applicable
• Information from regulated financial institution partners necessary to facilitate the services
• Information from payment network and card-issuing partners necessary to process card and payment activity
• Information processed through the stablecoin payment gateway, where a third party (such as a customer of a business using Moki) makes a stablecoin payment through the platform, including wallet addresses, transaction identifiers and payment amounts

3.4 Digital-asset and blockchain data

In connection with supported digital-asset functionality, we may process wallet addresses used through the platform, blockchain transaction identifiers and on-chain transaction data, and risk/screening results relating to wallet addresses, as required for compliance monitoring and as required by our regulated partners.

In connection with the stablecoin payment gateway, where a third party makes a payment in supported stablecoins to a business using the platform, we may process that payer's wallet address, transaction identifier and payment amount through the gateway infrastructure.

Assets held in a self-custody Moki-Tangem cold wallet are under the user's sole control. Moki does not hold, control or have access to private keys associated with the Moki-Tangem wallet. Data processing in connection with the Moki-Tangem wallet is limited to any activity visible through the platform interface and does not include access to or processing of private keys.

4.1 Providing the platform and services

• Creating and managing your Moki account
• Facilitating payments, transfers and transactions processed by our regulated partners
• Enabling cards, multi-currency accounts, currency exchange and supported digital-asset functionality
• Processing stablecoin payments through the payment gateway where a business accepts stablecoin payments from its customers
• Providing customer support and responding to enquiries

4.2 Identity verification and compliance

• Facilitating identity verification (KYC) and, for organisations, business verification (KYB)
• Supporting anti-money laundering screening, sanctions screening and transaction monitoring carried out by us and our regulated partners
• Supporting our partners' compliance with their financial-crime and reporting obligations
• Maintaining records required by applicable laws and by our regulated partners

4.3 Platform operation and security

• Detecting and preventing fraud, security incidents and unauthorised access
• Maintaining the security and integrity of the platform
• Analysing usage to improve the platform and user experience

4.4 Partner and affiliate programme administration

• Processing and evaluating partner and affiliate applications
• Managing referral tracking, commission calculation and revenue-share records
• Communicating with partners about the programme, their referrals and their commercial arrangements
• Monitoring partner compliance with programme requirements, including disclosure obligations and promotion restrictions

4.5 Communication

• Sending account notifications, transaction confirmations and security alerts
• Communicating changes to our services, terms or policies
• Responding to enquiries and support requests
• Sending marketing communications where you have provided consent or where permitted by applicable law

6.1 Regulated financial partners

We share personal data with the regulated financial institutions and licensed partners that provide the financial services accessed through the platform, hold and move funds, and issue cards. These partners process your data in accordance with their own regulatory obligations and privacy notices.

6.2 Payment gateway partners

Where a business uses the stablecoin payment gateway, personal data relating to the payment transaction (including wallet addresses and transaction identifiers) may be shared with the payment gateway partner that processes the stablecoin payment. This partner processes the data in accordance with its own privacy policy and applicable law.

6.3 Payment networks

We share personal data with payment and card networks as necessary to process transactions and card activity.

6.4 Verification and compliance providers

We share personal data with providers that carry out identity verification, sanctions and financial-crime screening and related checks.

6.5 Technology and infrastructure providers

We share personal data with technology providers supporting the platform, including cloud, storage and cybersecurity providers, who are required to process it only on our instructions.

6.6 Professional advisers

We share personal data with legal, accounting, audit and other professional advisers where necessary for our business and services.

6.7 Affiliated entities and programme partners

We may share personal data with our affiliated entities where necessary to provide the services, operate our business or meet regulatory obligations, subject to appropriate safeguards. In connection with the partner and affiliate programme, we may share referral and tracking data with partners to the extent necessary for programme administration and commission calculation.

6.8 Authorities and law enforcement

We, and our regulated partners, may disclose personal data to regulatory authorities, law enforcement and courts where required by applicable law or in response to lawful requests. Where a regulated partner is legally required to make regulatory filings or disclosures (including in relation to suspicious activity or sanctions), it may be prohibited by law from allowing us to notify you, and we may be similarly restricted.

6.9 Business transfers

In a merger, acquisition, restructuring or sale, personal data may be transferred as part of the transaction. We will take steps to ensure it remains protected.