Definitions

Date: April 2026

NALA / we / us / our

NALA Inc., incorporated in Delaware, USA acting as data controller for all LCY wallet services.

Partner

A licensed financial institution or payment service provider with whom NALA has entered a commercial arrangement. Details in the NALA Partner Schedule.

Service

Any NALA Local Currency wallet service i.e. mobile application, web platform, account management tools, transaction processing, and associated features.

Personal data

Any information relating to an identified or identifiable natural person, as defined in the applicable data protection law for your jurisdiction.

Special category data

Personal data revealing racial or ethnic origin, political opinions, religious beliefs, genetic data, biometric data used for unique identification, health data, or data concerning sex life or sexual orientation.

Biometric data

Data resulting from specific technical processing relating to physical, physiological, or behavioural characteristics allowing unique identification i.e. including facial recognition data and liveness detection data.

Data controller

The entity that determines the purposes and means of processing personal data. NALA Inc. is the data controller for the processing described in this notice.

Data processor

An entity that processes personal data on behalf of and only on the instructions of a data controller.

Joint controller

Where NALA and another entity (such as a Partner) each determine the purposes and means of processing personal data for a specific activity, both are joint controllers.

Consent

A freely given, specific, informed, and unambiguous indication of agreement, expressed through a clear affirmative action. Silence and pre-ticked boxes do not constitute consent.

Legitimate interests

A lawful basis permitting processing where NALA has a genuine, proportionate business need that does not override the data subject's interests. LIAs available on request.

Profiling

Automated processing of personal data to evaluate, analyse, or predict personal aspects relating to an individual.

KYC

Know Your Customer i.e. identity verification and due diligence processes required by anti-money laundering legislation.

AML/CFT

Anti-Money Laundering and Counter-Terrorism Financing i.e. regulatory requirements applicable to financial services businesses including NALA.

DPPA 2019

The Data Protection and Privacy Act 2019 of Uganda, as amended.

PDPA 2022

The Personal Data Protection Act 2022 of Tanzania, as amended.

DPL 2021

Law N° 058/2021 of 13/10/2021 on the Protection of Personal Data and Privacy in Rwanda, as amended.

UK GDPR

Regulation (EU) 2016/679 as retained in UK law by the European Union (Withdrawal) Act 2018, read with the Data Protection Act 2018.

PECR

The Privacy and Electronic Communications Regulations 2003 (UK) — governing cookies, electronic marketing, and electronic communications.

SCCs

Standard Contractual Clauses — contractual safeguards approved by the European Commission for international transfers of personal data.

IDTA

UK International Data Transfer Agreement — the UK mechanism approved by the ICO for international transfers from the United Kingdom.

DPA

Data Processing Agreement i.e. a written contract required by law where a data controller engages a data processor.

JCA

Joint Controller Arrangement i.e. a written agreement between joint controllers governing their respective responsibilities.

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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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