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How Long We Keep Your Personal Data

Date: April 2026

We retain personal data only for as long as is necessary for the purpose for which it was collected, and in accordance with our legal obligations.

Account and identity data (KYC/AML)

Minimum 5 years from the end of the business relationship.

Our lawful basis: FTRA 2013 (Uganda); AML Act 2006 as amended (Tanzania); Rwanda AML/CFT framework; UK Money Laundering Regulations 2017

Transaction records

Minimum 5 years from the date of the transaction.

Our lawful basis: AML/CFT legislation across applicable jurisdictions

Financial crime compliance records (SARs, EDD, PEP screening)

Minimum 5 years may be longer where required by regulatory guidance.

Our lawful basis: AML/CFT legislation; regulatory authority guidance

Biometric and identity verification data

Not retained beyond what is necessary for verification purposes. Maximum retention confirmed per KYC provider DPA.

Our lawful basis: DPPA 2019 s.20; PDPA 2022 s.22; UK GDPR Art.9 i.e. special category data minimisation

Device and usage data

12 months from collection, unless required for an ongoing security or fraud investigation.

Our lawful basis: Legitimate interests i.e. operational security

Customer communications and support data

2 years from the date of last contact.

Our lawful basis: Legitimate interests i.e. dispute resolution and service improvement

Marketing preferences and consent records

Duration of the relationship plus 2 years.

Our lawful basis: UK GDPR Art.7(1) i.e. accountability for consent

Legal proceedings / regulatory investigation data

Duration of proceedings plus a reasonable period thereafter, then securely deleted or anonymised.

Our lawful basis: Legal obligation and legitimate interests in defending legal claims

At the end of each applicable retention period, personal data is securely deleted or irreversibly anonymised.

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Contact Us

mamanala@nala.com

Nairobi, Kenya

Mirage Towers Tower 2, Floor 8

USA

NALA Payments LLC
221 River Street 9th Floor Hoboken, New Jersey, 07030

UK

International House, 64 Nile Street, London, United Kingdom, N1 7SR

The Netherlands

Johan Cruijff Boulevard 65, 1101DL Amsterdam

Canada

36 Toronto Street, Suite 850
Toronto ONTARIO, M5C 2C5
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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