Version History

Date: April 2026

Version 0.1

Date: April 2026

Summary of changes: Initial master notice. Consolidates Virtual UGX, TZS, and RWF Account privacy notices. All 24 compliance amendments incorporated. Added: How We Collect Data; Special Category / Biometric Data; Children's Data; Account Closure / Dormant Accounts; PCI DSS; PECR (UK); Legitimate Interests Assessments; Marketing; Business Transfers; Profiling and Automated Decision-Making; Third-Party Links.

Author: Sunny Vara, DPO

Status: Live

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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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