How We Collect Your Personal Data

Date: April 2026

We collect your personal data in three ways:

1. Directly from you

You provide personal data directly to us when you:

Create and register your NALA account
Complete our identity verification (KYC) process — including uploading identity documents
Make or receive payments and transactions through your LCY wallet
Contact our customer support team
Respond to surveys or participate in product research
Set your communication and marketing preferences

2. Automatically when you use the Service

When you use our mobile application or web platform, we automatically collect:

Device information (device type, operating system, device identifiers)
Usage data (features accessed, session duration, navigation patterns)
Technical data (IP address, browser type, crash reports)
Transaction metadata (timestamps, amounts, currency pairs, payment routing data)
Cookies and similar tracking technologies — see our Cookie Notice

3. From third parties

We may receive personal data about you from third parties, including:

Identity verification and KYC providers i.e. to verify your identity and meet our AML obligations
Fraud prevention and sanctions screening services i.e. to assess and manage financial crime risk
Our licensed Partners i.e. who may share account or transaction data in connection with delivering your wallet service
Regulatory authorities i.e. where we are required to receive information about you by law

Data minimisation

NALA collects only the personal data that is necessary for the specific purpose for which it is collected. If we need to collect a new category of data in future, we will update this notice before that collection begins.

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