What Personal Data We Collect

Date: April 2026

The following categories of personal data are collected in connection with your LCY wallet account.

Personal identification information

Full name; date of birth; nationality; email address; phone number; government-issued ID; residential address; selfie or portrait photograph for KYC purposes. We need this. Without it, we cannot open your account or verify who you are and meet KYC/AML obligations.

Account information

Account number; account type; account status; transaction history; account balances; linked payment methods (bank account details, card details); account preferences. We need this to run your account and provide the Service.

Authentication and identity verification data

Username; password (hashed); security questions; one-time passcodes; device trust data. Where biometric processing occurs (facial recognition, liveness detection), explicit consent obtained. We need this to keep your account secure. We will always ask your permission before using biometric checks.

Transaction data

Transaction amounts; source and destination currencies; sender and recipient names and account details; timestamps; exchange rates applied; fees charged; reference numbers; payment routing information. We need this to send and receive money on your behalf and keep a record of your transactions.

Communication and support data

Records of communications with customer support; feedback, complaints, and enquiries; marketing communication preferences. Only collected when you contact us. Your marketing preferences are optional so you can change them at any time.

Device and usage data

IP address; device type and identifiers; operating system; browser type; app version; session data; feature usage patterns; crash and error logs. Collected automatically when you use the app or website. You can control non-essential tracking through our Cookie Notice, this can be located at https://nala.money/cookie-notice

Financial crime compliance data

Politically exposed person (PEP) status; sanctions screening results; source of funds declarations; enhanced due diligence documentation where required. The law requires this. We are legally obliged to carry out these checks under anti-money laundering rules.

Special category data — biometric processing

NALA or our KYC providers may process biometric data (facial recognition, liveness detection) to verify your identity. This is special category data requiring additional legal protections.

Lawful basis: Your explicit consent (DPPA 2019 s.20; PDPA 2022 s.22; UK GDPR Art.9(2)(a)).You may withdraw consent at any time, however withdrawal may mean we cannot complete KYC and therefore cannot provide the Service.

Payment card data — PCI DSS

Card data is handled in accordance with the Payment Card Industry Data Security Standard (PCI DSS). Card details are processed through certified payment processors. Full card numbers are never accessible to NALA staff.

Children's data — minimum age

The NALA Service is not directed at children under the age of 18. We do not knowingly collect personal data from anyone under 18. Contact dpo@nala.money if you believe we hold data relating to a child.

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In the United Kingdom, NALA Payments Ltd is a registered EMD agent of Modulr FS Limited, which is an Electronic Money Institution authorised by the Financial Conduct Authority with firm reference number 900573. Electronic Money products are not covered by the Financial Services Compensation Scheme (FSCS). Customer funds will be held in one or more segregated accounts and safeguarded in line with the Electronic Money Regulations 2011. For more information, please see Modulr’s UK Safeguarding Explanation here.

In the European Union, NALA Payments Netherlands B.V. is a partner of Modulr Finance B.V., a company registered in the Netherlands with company number 81852401, which is authorised and regulated by De Nederlandsche Bank (DNB) as an Electronic Money Institution (relationship number R182870) for the issuance of electronic money and payment services. Your account and related payment services are provided by Modulr Finance B.V. Your funds will be held in one or more segregated accounts and the full value safeguarded in line with the Financial Supervision Act.

In the United States, Nala Inc. partners with the financial services software company, Sila Inc. (“Sila”) and Priority Technology Holdings Inc. (“Priority Commerce”), either directly or through its subsidiary Finxera, Inc. (NMLS #1168701) and/or its authorized affiliates, contractors and partners (including but not limited to the following Banks: Wells Fargo, N.A., Comerica Bank, Axos Bank, and Western Alliance Bank) to offer you electronic fund transfers and provide you with an account. Nala Inc. is a financial technology company, not a bank.

Mufasa Payments LLC, a subsidiary of Nala Inc., partners with Lead Bank (NMLS #635532) to offer you electronic fund transfers and provide you with an account. Mufasa Payments LLC is a financial technology company, not a bank.

In certain states in the United States where it holds the necessary licenses, money transmission services may be provided by Nala Payments LLC (NMLS: 2530895), a subsidiary of Nala Inc., pursuant to its own state-issued money transmitter licenses and registration as a Money Services Business (MSB) with the United States Treasury Financial Crimes Enforcement Network (MSB: 31000335047569). In such cases, the partnership with Mufasa Payments LLC, Sila Inc. and Lead Bank N.A. may not be utilized or required. The availability of services and regulatory status may vary by geographic location and customer location.

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