How We Use Your Personal Data and Our Lawful Basis

Date: April 2026

We process your personal data only for the purposes set out below and only where we have a valid lawful basis.

Why lawful basis matters

Your lawful basis determines which rights you can exercise. Where we rely on legitimate interests, you may object. Where we rely on consent, you can withdraw it. Where we rely on contract performance or legal obligation, we cannot stop that processing without affecting our ability to provide the Service.

Providing the Service

Creating and operating your LCY wallet account; processing remittances and currency exchanges; managing balances; processing payments; providing transaction records.

LAWFUL BASIS: Performance of a contract with you.Uganda: DPPA 2019 s.13(2)(b) | Tanzania: PDPA 2022 s.14(b) | Rwanda: DPL Art.12(b) | UK: UK GDPR Art.6(1)(b)

KYC, AML, and CFT compliance

Verifying your identity; ongoing transaction monitoring; sanctions and PEP screening; filing Suspicious Activity Reports (SARs) where required. We have no discretion over this processing i.e. it is required by law.

LAWFUL BASIS: Compliance with a legal obligation.Uganda: DPPA 2019 s.13(2)(c); FTRA 2013 | Tanzania: PDPA 2022 s.14(c); AML Act 2006 | Rwanda: DPL Art.12(c) | UK: UK GDPR Art.6(1)(c); MLR 2017

Fraud prevention and financial crime detection

Monitoring transactions for suspicious patterns; detecting and investigating unauthorised account access; risk-scoring transactions.

LAWFUL BASIS: Legitimate interests (protecting our customers and the integrity of the financial system). LIA available on request from dpo@nala.money

Service improvement and analytics

Analysing aggregated usage patterns to improve product performance. This does not involve automated individual decision-making with legal or similarly significant effects.

LAWFUL BASIS: Legitimate interests (improving the Service for all users). LIA available on request from dpo@nala.money

Transactional communications

Sending transaction confirmations, account alerts, security notifications, service updates, and other communications necessary to provide the Service.

LAWFUL BASIS: Performance of a contract with you. UK: UK GDPR Art.6(1)(b)

Marketing communications

Sending information about NALA products, features, offers, and promotions. You may opt out at any time via the link in any marketing email or through your in-app notification settings.

LAWFUL BASIS: Your consent. UK: UK GDPR Art.6(1)(a); PECR Reg.22. Consent may be withdrawn at any time.

Legal claims and regulatory proceedings

Retaining and disclosing personal data where necessary to establish, exercise, or defend legal claims; responding to regulatory investigations or audits.

LAWFUL BASIS: Legitimate interests (legal claims) and legal obligation. UK: UK GDPR Art.6(1)(c) and (f)

Legitimate Interests Assessments (LIA)

Where NALA relies on legitimate interests as its lawful basis, we have carried out a Legitimate Interests Assessment to confirm that our interests do not override your rights and freedoms. LIA summaries are available on request from dpo@nala.money

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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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