Privacy & Data Policy

We collect information from and about you when you register with us or use our products, services or apps (our “Service”) or use our website or software applications, or access or use third-party services that use our Application Programming Interface (“API”).

• When registering with us as a customer, we ask you for detailed information, which we will use to verify your identity and protect against fraud, among other reasons discussed below.
• We gather Personal Data at other times when managing your Moleculus account, such as from surveys, during support or customer care or during investigations.
• We automatically collect information sent to us by your computer, mobile phone or other device to improve your experience.
• When you use a location-enabled device with our Service, we may collect geographical location data or use various means to determine your location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots.

As you interact with our website or software applications, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, and other similar technologies. Cookies are small data files stored on your hard drive by a website. Cookies help us make our website and Service and your use of them better by allowing us to recognize your browser and capture and remember certain information. Please see our Cookie Policy for additional information. You can also adjust your browser settings to disable cookies, but it may affect your ability to use the Service and our website.

We may receive data from third parties about you. This may include technical data from analytics and advertising partners like Google, from identity verification providers, as well as from other financial institutions.

Moleculus only collects the Personal Data we need in order to offer and support our Service and meet our legal and regulatory obligations, which may vary depending on our relationship with you.

Here is an overview of the Personal Data we collect from or about you:

• Identity verification data: To verify your identity, we collect your name, address, phone, email, and other similar information. We may also require you to provide additional Personal Data for verification purposes, including your date of birth, taxpayer or government identification number, or a copy of your government-issued identification. We may obtain information from affiliated and non-affiliated third parties, such as credit bureaus, identity verification services, and other screening services to verify that you are eligible to use our Services, and will associate that information with the information we collected from you. As part of our identity verification process, Moleculus uses Veriff to verify your identity by determining whether a selfie you take matches the photo in your government-issued identification. Veriff’s facial recognition technology collects information from your photos that may include biometric data, and when you provide your selfie, you will be asked to agree that Veriff may process biometric data and other data (including special categories of data) from the photos you submit and share it with Moleculus. Automated processes may be used to make a verification decision. Veriff’s privacy policy describes its collection, processing, storage and use of your personal data in more detail. In lieu of Veriff, some users may choose to use globalID to verify their identity. GlobalID is a digital identity platform that allows users the ability to store their personal data securely on their devices and directly control who can access that data. GlobalID’s privacy policy describes its collection, processing, storage and use of your personal data in more detail.
• Address verification data: Moleculus uses Trulioo to validate your physical address. Automated processes may be used to make a verification decision. Trulioo’s privacy policy describes its collection, processing, storage and use of your personal data in more detail. We additionally may require further address verification and validation through our partner, SumSub by requesting that you provide us with documentation verifying your physical address such as bank statements, utility bills, Internet/cable TV/house phone line bills, tax returns, council tax bill, and or government-issued certifications of residence. SumSub’s privacy notice describes its collection, processing, storage and use of your personal data in more detail.
• Financial data: In addition to identity verification, Moleculus may collect various information regarding your finances through third parties in order to be able to perform the transactions you request on the platform and to ensure compliance with regulatory requirements (e.g., anti-money laundering laws) and our own internal policies; in order for this to function, we must share certain elements of your Personal Data with these third parties. The information we receive from these third parties may include accounts you hold, balances, transactions, and a risk score. When linking your existing bank account to the Moleculus platform, users in certain jurisdictions may use Plaid, a third-party service, to seamlessly link accounts, and in order to do so, information about your bank account is shared by Plaid with Moleculus. The collection and transfer of this information are subject to Plaid’s privacy policy.
• Account activity data: We collect information about your transactions, payments from or to you, and your other activities on our site or Service and other details of products and services you have purchased from us.
• Application use data: We may collect data on your interaction and use of our Service. This includes visits to our website or app, sign-up activity, your bank account, credit card , other payment details to enable you to enter into transactions on the Service, along with any additional information you may disclose to our user support team in order to resolve problems you report.
• Your device data: We collect and process your internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or any of our software applications.
• Marketing data: We collect and process your preferences in receiving marketing from us, your email address, including hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising, and where you may have seen Moleculus advertisements.

Listed below are the ways in which we may use and process your Personal Data and the legal grounds we rely on to do so.

• Providing our Service to you: It may sound obvious, but we need your data to make Moleculus work in the first place. Without your name, banking information and other details, we simply could not offer you our products and services.
• Identity verification: As a financial institution, it is essential that we are able to confirm the true identity of our users. There are rules and regulations across the globe that require we identify our customers, including laws concerning anti-corruption, anti‐bribery, anti‐terrorism, and anti‐money laundering.
• Fraud Prevention: We use the personal information we collect in connection with providing you our services to detect and prevent fraudulent activity. We share this information with Sift, a third party service provider, to assist us with this effort. Sift uses various technologies to capture various device identifiers, such as canvas fingerprinting and may use automated decision making in order to detect and prevent fraudulent activity. To learn more about Sift, please see their Service Privacy Notice.
• Account Security: We use your phone number for our account two-factor authentication process. This includes sending SMS or text messages (including by an automatic telephone dialing system) to any of the phone numbers provided by you or on your behalf in connection with your Moleculus account.
• Keeping you informed: It is important for security and financial transparency that we keep you aware of your transactions and related activity at Moleculus. We will send you emails with confirmations, invoices, technical notices, updates, security alerts, legal and support and administrative messages.
• Investigations: Occasionally, we need to look at your account activity in order to check and protect against fraudulent, unauthorized or illegal behavior.
• Customer care: We strive to make sure you can easily use our products with no headaches, but sometimes you need help. Our customer care team will occasionally need access to your account data in order to fix any issues or answer your questions.
• Managing and improving our Service: We like to understand how our users engage and use Moleculus in order to make sure Moleculus is the best it can be. This process includes combining different account, transactional, marketing and other data to analyze the effectiveness and performance of our Service.
• Behavioral Advertising and Analytics (including attribution statistics): This process includes combining different account, transactional, marketing, and cross-device tracking. When we apply these techniques we may use your Personal Information to provide you with targeted advertisements, banners, or marketing communications we believe may be of interest to you. We may also use information from your mobile device, such as: browser type, device type and model, IDFA Identifiers, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier for advanced attribution, acquisition, and analytical purposes including personalized or lookalike advertising. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page here.

You can opt-out of targeted advertising by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• AdRoll: https://help.adroll.com/hc/en-us/articles/216599538-Opting-Out-of-Personalized-Advertising
• AppsFlyer: https://www.appsflyer.com/optout You can view the Appsflyer privacy policy here.
• Google Analytics: http://myactivity.google.com/

Additionally, you can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. Or by visiting any of the links below: http://optout.networkadvertising.org/or http://youronlinechoices.eu/.

For more information, see our Cookie Policy.

• Communicating with you: We want you to be aware of product updates, news, events, and promotions and, if you consent, we will send you information, including regular personalized emails, to keep you up to date with all things Moleculus.
• Business operations: We may need to use your Personal Data for our business operations, including internal training and administration, legal compliance, to enforce our legal rights, to protect third party rights, and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
• Website and software applications: We use data analytics to improve our website and software applications, activities and operations, products/services, events, etc.
• Third parties: If you (i) use our Service and/or platform by (a) using an application (whether directly or by authorizing an application to use our Service and/or platform), (b) using a link provided by a third-party, or (c) any third party integrations or (ii) if you partner with us in a program or other business arrangement where a third-party intermediary is involved all such third parties may receive detailed information about your account, your use of the Service, transaction history or even the ability to take actions on your behalf. When you authorize an application or third party integration via the Moleculus platform, you will be notified of what Personal Data will be shared with these third parties. Information collected by these applications or third-party integrations are subject to their terms and policies and are required by contract by Moleculus to maintain the confidentiality and security of your Personal Data.

The primary legal grounds upon which we collect and process your Personal Data are:

• through obtaining your consent at the time of collection,
• due to the necessity of doing so to perform the services as requested,
• in order to comply with our legal obligations, and
• to pursue our legitimate interests (e.g., to improve our services).

Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using that data.

We have implemented security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We protect your Personal Data by maintaining physical, electronic, and procedural safeguards, incorporating tested security technologies, in compliance with applicable laws. We may use network safeguards such as firewalls and data encryption, enforce physical access controls, and authorize access to Personal Data only for those people who require access to fulfill their job responsibilities.

In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Those with access to your Personal Data are carefully screened, periodically reevaluated, and are required to keep all your Personal Data confidential.

We sometimes share your information internally between employees and contractors of the Moleculus Group (including those based outside the USAropean Economic Area (“EEA”)), in particular in connection with activities undertaken jointly or in common with such group members and/or provide IT and system administration services and undertake management reporting.

We do not sell, trade or otherwise transfer your Personal Data to third parties other than third parties who assist us in operating our Service, third parties who assist us in facilitating certain programs and other business arrangements for which you have expressly agreed to participate, management and reporting, maintaining compliance with relevant laws (including compliance with relevant anti-corruption, anti‐bribery, anti‐terrorism, and anti‐money laundering laws), conducting our business or supporting our users, or providing you with applications or services integrated via our API. We require that those third parties agree to keep this information confidential and secure on the same conditions and protection levels we provide to you as a user, in accordance with relevant privacy laws, including the GDPR. A complete list of our sub-processors can be viewed here

We may also release your information to certified and authorized law enforcement officials when we believe release is appropriate to comply with the law, enforce our terms or policies, or protect the rights, property, or safety of Moleculus, our users, or others. We have a set of guidelines for how we engage with law enforcement officials that are available to the public here.

Finally, in the event of the sale or transfer of ownership, your data would be shared with the new owners.

Moleculus is headquartered in the United States. Many of our affiliates and third party service providers are based outsidethe USA and most managed within USA, so processing of your Personal Data may involve a transfer of your Personal Data outsidethe USA and most managed within USA and may be maintained or accessed in servers or files located in countries outsidethe USA and most managed within USA, including the United States.

By voluntarily providing your Personal Data on or via this website or app, you consent to its transfer, processing and storage in the United States or other countries outsidethe USA and most managed within USA, some which have not been deemed bythe USA and most managed within USA to have “adequate” privacy safeguards.

Whenever we transfer any Personal Data outsidethe USA and most managed within USA, we will put in place an adequate level of protection to ensure that any such transfers comply, and are consistent with applicable USA data protection laws, including with respect to transfers among Moleculus affiliates, the standard data protection clauses adopted by the USA Commission.

Please contact us at data.privacy@moleculus.network if you are located in the USA and want further information on the specific mechanism used by us when transferring Personal Data outside ofthe USA and most managed within USA.

As part of our transparency, we publish our holding and transactions on our Transparency Page. Our Reservechain™ and Reserveledger™ do not contain any Personal Data. The amount, asset class and time-stamp of all transactions conducted using our Service is a permanent part of the publicly-accessible Reservechain™ and Reserveledger™. Only users who are party to the transaction have the ability to access Personal Data associated with their transactions.

You have the right to:

• Access the Personal Data we store and process about you or to request a copy of it to transfer to another service provider.
• Request that we correct inaccurate data about you.
• Ask us to delete or object to us processing your data, although for legal reasons (e.g. anti-money laundering rules and regulations) we cannot always do this.
• Withdraw your consent to receive marketing emails.

Your marketing preferences can be updated on the Moleculus Platform under your user settings or through any Newsletter via the “Unsubscribe” link. For all other Data Privacy inquiries, please submit your request through our standard customer support process, by contacting our Support Team. Also, under the relevant privacy laws ofthe USA and most managed within USA (including the USAropean Union’s General Data Protection Regulation) in respect of your EEA Personal Data you may have a number of important rights. For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the USAropean Information Commissioner’s Office (ECO) on individual’s rights under the USAropean Union’s General Data Protection Regulation here.

Moleculus maintains reasonable procedures to help ensure that your Personal Data is reliable for its intended use, accurate, complete, and current.

• We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, as well as other factors required by General Data Protection Regulation or other laws to which we are subject.
• When it is no longer necessary to retain your Personal Data, we will securely delete it, subject to applicable law and regulations.
• In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
• If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
• Should you make a Data Subject request through our standard customer support channel, we will retain the minimum required amount of data in order to keep a record of your request and the action we took to resolve it.

Please be aware that we may keep your Personal Data for five years or more from the date you cease to be our customer, depending on applicable law or regulations in the jurisdictions we operate.

We do not knowingly solicit or collect information from individuals under 18. If we become aware that a child under the age of 18 has provided us with Personal Data, we will close the account and restrict their information. If you believe that we might have collected Personal Data from a child under 18, please contact us using the information below.

In compliance with applicable laws, we may send you personalized marketing information, including by email, and such information may include product and service updates, industry news, our events, activities and offers, information about our business and personnel, and tips. We may combine your Personal Data such as age, transaction history, account usage to improve the value and specificity of these communications.

You can ask us to stop sending you marketing messages or information at any time by following the “unsubscribe” link on any marketing message sent to you or by updating your contact preferences directly on the Moleculus Platform. Please note, it may take up to 10 days for this to take effect. Where you opt-out of receiving these marketing messages or publications, this will not apply to Personal Data collected by or provided to us in connection with a specific purpose, request, order, event or activity or any dealings with you, and you may still receive emails from us relating to the operation of the Moleculus service, like transaction confirmations.

This version was last updated on the date indicated above and historic versions are archived and can be obtained by contacting us. We may update this Privacy Statement from time to time as we deem necessary or appropriate in our sole discretion. If there are any material changes to this Privacy Statement, we will notify you by email, by means of a notice on the Moleculus Platform, or as otherwise required by applicable law. We encourage you to review this Privacy Statement periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Any changes to this Privacy Statement take effect immediately after being posted or otherwise provided by us.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

This Privacy Statement applies to all of the services offered by the Moleculus Group and services offered on third-party sites, such as advertising services. This Privacy Statement does not apply to services that have separate privacy notices that do not incorporate this Privacy Statement.

This Privacy Statement doesn’t apply to the information practices of other companies and organizations that advertise our services or to services offered by other companies or individuals, including products or sites that may include our Services or be linked from our Services.

This website and app may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

You can direct any questions or complaints about the use or disclosure of your Personal Data to us by contacting us as set out below. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data as soon as possible.

If you have any questions about this Privacy Statement or need to contact us, please email us at data.privacy@moleculus.network, or contact us by mail at 530 Fifth Avenue, Suite 3A, New York, NY 10036. All Data Subject Requests should be submitted to our Customer Support Team.

As Moleculus is based in the United States it has appointed Moleculus, Ltda a company incorporated in Portugal (Co. Number: PT513095136), to be its representative withinthe USA and most managed within USA. They may be contacted at data.privacy@moleculus.network.

If you are resident in the USAropean Union and are dissatisfied with the resolution of your complaint in respect of your EEA Personal Data, you may contact the USA data protection authority in your jurisdiction using the contact details provided here for further information and assistance.

If you have a complaint, first contact Moleculus Inc. at 1-888-677-9280 or support@moleculus.network, and if you still have an unresolved complaint regarding Moleculus Inc.'s money transmission activity, please direct your complaint to:

Consumer Financial Protection Bureau 855-411-2372, 855-729-2372 (TTY/TDD) www.consumerfinance.gov

In addition, if you are a Texas resident: Texas Department of Banking 2601 North Lamar Boulevard Austin, Texas 78705 1-877-276-5554 (toll free) www.dob.texas.gov