Avis de confidentialité États-Unis

April 2025

This Privacy Notice explains how NALA Inc., Nala Payments LLC, and Mufasa Payments LLC (collectively known as “NALA”, “we”, “our”, “us”) collects, uses, discloses, and otherwise processes your personal information when you interact with any of our services (collectively, the “Services”). This includes situations where you:

• Visit our website at www.nala.com (the “Website”);
• Use our mobile application(s) (the “App”);
• Contact our customer service or support teams;
• Receive or open our emails, text messages, or advertisements;
• Engage with us through social media or other communication channels; or
• Use any of our products, tools, or features that reference or link to this Privacy Notice.

This Privacy Notice applies to information collected online and offline and governs how we handle your personal information in connection with our Services.
We may update this Privacy Notice from time to time to reflect changes in our business practices, technology, legal obligations, or for other reasons. When we update the Privacy Notice, we will revise the “Last Updated” date at the top of this page.
If we make material changes, we will notify you by reasonable means. This may include:

• Sending an email to the address associated with your account;
• Posting a prominent notice on our Website or within our App; or
• Providing notice through other appropriate channels.

We encourage you to review this Privacy Notice periodically to stay informed about our privacy practices. Your continued use of the Services following the posting of any updates constitutes your acceptance of those changes, unless otherwise stated.

We may be required or choose to provide additional notices to individuals in certain states or countries. Please refer below for disclosures that may apply to you:

• International Users: If you are located outside of the United States, please click here for additional region-specific privacy disclosures.
• California Residents: If you are a resident of the State of California, please refer to the end of this Privacy Notice for additional state-specific privacy disclosures.
• Nevada Residents: Pursuant to Chapter 603A of the Nevada Revised Statutes, Nevada residents may request to opt out of the sale of their personal information. While NALA does not sell your personal information, you may submit such a request to: support@nala.com

We collect certain personal information about you in relation to your use of our services. This may include:

• Information you provide directly to us (e.g., when you sign up, contact us, or fill out forms);
• Information obtained from third-party sources, where permitted by law; and
• Information collected automatically through technologies such as cookies and similar tracking tools, which help us understand your usage and preferences.

Information You Provide Directly To Us:

When registering, transacting, or contacting us, you may provide:

• Information About You:
  • Your full name
  • Your residential address
  • Your contact details (email address and your telephone number)
  • Your date of birth
  • Your social security number
  • Your identification information, including a photo verification
  • Your identity information including your image through a selfie verification
  • Your payment information (bank, debit card or pre-paid card information including billing address, PAN and CVV details, the sender name as well as the sort code and account number)
  • If you send high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law we may request additional commercial, personal and/or identification information.
  • Account sign-in information, such as email address, username, and password.
  • Communications you send to us (by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding the Website, our service, or general comments.

Also:

• Information About the Recipient: The individual making the transfer will provide us with the recipient's name, phone number, bank account, and purpose of payment. With your explicit consent, we may access your device’s contact list to autofill recipient details and streamline transactions. We do not send unsolicited messages to your contacts, nor do we use contact list information for any unrelated purpose.
• Information About the Potential Users: We may receive personal information about other potential users - for example, if you refer someone through our referral program or invite them to join our Services by importing your address book and/or adding their contact details manually. Before you share someone’s personal information with us, please make sure you have their permission. It’s your responsibility to only share information if it’s allowed under applicable laws.

Information Obtained From Third-Party Sources:

• Single Sign-On Account Login: We may also obtain information about you when you log in using single sign-on (“SSO”) through a third-party social network or authentication service, such as Google or Apple. We do this by using OAuth authentication, a secure mechanism to give NALA access to your account data, for example, your username, password, name, email address, and profile picture.
• Social Media: When you interact with us through a social media site or third-party service, such as when you like, follow, or share NALA content on Facebook, Twitter, Instagram, or similar sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties.
• Service Providers and Business Partners: We are also working closely with third parties (including, for example, service providers, business partners, sub-contractors in technical, payment and delivery service providers, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Information Collected Automatically:

When you use the Services, we may automatically collect:

• Device Technical Information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system.
• Information About Your Visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

If we combine or associate information from other sources with your information that we collect through the Services, we will treat the combined information in accordance with this Privacy Notice, the Terms of Service, and applicable law.

2. How Do We Use Your Information?
We process your personal information for the following purposes:

i. Service Relationship, which includes:

• Providing our Services, like storing, transferring (both domestically and internationally), and withdrawing electronic funds. We also offer digital wallet features and related financial services.
• Helping you out with customer support, managing your account, and keeping you updated — for example, if we change our terms or if you start but don’t finish your registration.
• Handling payments for the services you use, including billing and processing transactions.

ii. Communicating with you to provide you with information about our Services.
For example, to respond to your inquiries, resolve your problems and concerns, and in order to take steps prior to entering into a service engagement.

iii. Performing Service enhancement activities.
We use data like your activity on our Website and App, your device details, and your browsing behavior to make our Services better and easier to use. For example, we collect and look at clickstream data — things like which pages you visit, what you click on, and how you move through our site. This helps us understand what’s working (and what’s not), so we can improve how everything runs, personalize your experience, and show you content and offers that are more relevant to you.

iv. Ensuring proper administration of our business
which includes keeping appropriate records, training and quality assurance purposes, resolving complaints and managing our business relationships and opportunities.

v. Preventing, detecting and fighting fraud or other illegal or unauthorized activities
which includes monitoring operations, user activity, and networks for fraud prevention and crime detection purposes, including information from third parties who may monitor our Website and systems and alert us about suspicious activities, auditing our systems and deploying security measures.

vi. Request and verify by automated means your financial-related information,
as well as share it, where required, with the relevant authorities to comply with our legal obligations related to financial, Anti-Money Laundering and tax regulations, among others. When you enter in your personal details to obtain an initial quote using our service, we will check your identity and credentials provided through our third-party Know Your Customer / Anti-Money Laundering provider.

vii. Providing you with marketing communications about our Services:
We may use your personal information to provide you with information on related products and services that you may be interested in, such as other e-money and related payment services. This information will be provided electronically, either via our Website, App, or email. You may opt out of this at any time by emailing us at support@nala.com.

If you do not wish to receive marketing emails from us, you can also opt-out of receiving emails from us (except for emails related to the completion of your registration, correction of user data, change of password, and other similar communications essential to your transactions through the Services) by using the unsubscribe process at the bottom of any marketing email from us.

viii. To manage Cookies and Other Tracking Technologies:
Some browsers offer a "Do Not Track" (DNT) feature that lets you signal to websites that you do not want your online activities tracked. Currently, we do not respond to DNT signals. However, you may adjust your cookie preferences through our cookie consent tools and browser settings to control tracking.

Please see our Cookies Policy for more information on why we use cookies and how you can better control their use through your browser settings and other tools.

ix. To comply with our legal obligations,
as part of our general business operations, and for other business administration purposes. Where necessary, we may use your personal information to establish, exercise or defend legal claims in suspected or actual legal proceedings.

3. Sharing Your Information
In order to deliver and improve our Services, we may share your personal information with:

i. Our Service Providers and Partners:
We use third-parties to help us operate and improve our Services and facilitate the fulfilment of essential service functions. This includes trusted financial services partners, such as Priority Commerce, who assist with electronic fund transfers and banking services. When you use our Services involving EFTs, your identity and banking information is shared with these partners and processed according to their own privacy policies.

ii. In Corporate Transactions:
We may transfer your personal information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

iii. When Required by Law:
We may disclose your personal information if reasonably necessary with regulators, law enforcement agencies or authorities or where mandatory under a court order:

• (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements;
• (ii) to assist in the prevention or detection of crime (subject in each case to applicable law);
• (iii) to protect the health and safety of us, our users, or any person; or
• (iv) as otherwise required by applicable law.

iv. To Enforce Legal Rights:
We may also share information:

• (i) if disclosure would mitigate our liability in an actual or threatened lawsuit;
• (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties;
• (iii) to enforce our agreements with you;
• (iv) to reduce credit risk and collect debts owed to us; and
• (v) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.

v. With other entities within NALA Group:
When it is necessary for operational reasons such as the use of a group-wide logistics and IT infrastructure and for any administrative purposes to organise, develop and deliver our services and products, run our organisation and decide on future strategies.

In certain circumstances, including where required by applicable law, we may ask for your consent to share your personal information with explicitly identified third-parties, including entities within NALA Group, so that they can contact you for marketing purposes or provide you with their own products or services. You can withdraw your consent at any time by emailing us at support@nala.com.

Note that we do not sell your personal information. Where consent is required, we will seek it in advance and provide opt-out options.

4. How Long Do We Keep Your Information?
We retain personal information for as long as necessary for the purposes set out above. When no longer needed, information is securely deleted or anonymized, unless required to be retained for legal or regulatory reasons. Examples include (but are not limited to) compliance with financial, tax, or AML laws, or for dispute resolution and litigation.
In case you have any questions related to personal information retention, please contact us at privacy@nala.money.

5. How Do We Protect Your Information?
We implemented reasonable physical, technical, and organizational security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.
In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with applicable laws and regulations.

6. Control Over Your Information
You have the right to:

• Modify Your Account Information: Once you have registered for a NALA account, you may update or correct your profile information at any time by accessing your profile page through the Site.
• Deactivate Your Account: Your deactivated status is reflected promptly in our user databases; however, we may retain your information for a variety of purposes including legal/regulatory, compliance, backups and archiving, prevention of fraud and abuse, and analytics. Upon deactivation, you will no longer receive emails from us and links to third-party financial accounts, and Services will automatically terminate. If you have a money transfer transaction pending at the time you deactivate your account, your link to this service will terminate but your pending transfer will continue to completion.
• Opt-Out from Email Communications: From time to time, we may send you emails regarding updates to our Service, notices about our company, or information about the Services we offer. If you wish to unsubscribe from such emails, simply click the “unsubscribe” link provided at the bottom of the email communications. Note that you cannot unsubscribe from certain service-related email communications (e.g., account verification, technical or legal notices).

7. Children’s Personal Information
Our websites and online services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. We do not knowingly collect information from children. If you believe a child has provided us with data, please contact us, and we will delete it promptly.

8. Third-Party Websites
We do not permit third parties to collect personal information about your online activities over time and across different websites when you use our Services. However, please note that when you navigate to third-party websites via links on our Website or App, those third parties may independently collect information, subject to their own privacy policies.

9. How Can You Contact Us?
If you have questions regarding your privacy and rights, please let us know how we can help.

• Email: privacy@nala.money
• Post mail: International House, 221 River St, 9th Floor, Hoboken, NJ 07030
• Phone: (877) 716-9669

ADDITIONAL CALIFORNIA STATE DISCLOSURES

If you are a California resident, you are entitled to certain rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights apply to personal information that we collect, use, and share in the course of doing business in California.

Right to Know:
You have the right to request that we disclose the following information about our collection and use of your personal information during the 12 months preceding your request (up to twice per 12-month period):

• the categories and specific pieces of personal information we have collected;
• the categories of sources from which we collected the personal information;
• the business or commercial purpose for which we collected it;
• the categories of third parties with whom we shared the personal information; and
• the categories of personal information about you that we disclosed for a business purpose.

Right to Delete:
You have the right to request the deletion of the personal information we have collected from you, subject to certain limitations under applicable law (e.g., for compliance with legal obligations or internal business needs).

Right to Correct:
You have the right to request that we correct inaccurate personal information we hold about you.

Right to Opt-Out of Sale or Sharing:
We do not sell personal information in exchange for money. However, if in the future we engage in practices that meet the CCPA/CPRA’s definition of a “sale” or “sharing” (such as using cookies for cross-context behavioral advertising), you have the right to opt out.
If applicable, we will provide a clear link on our website labeled “Do Not Sell or Share My Personal Information” to facilitate this right.

Right to Limit Use of Sensitive Personal Information:
If we collect sensitive personal information (such as government ID, financial account information, or geolocation data), you have the right to limit its use to what is necessary for providing the requested service, unless we obtain your consent to use it for other purposes.

Right to Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA/CPRA rights. This means we will not:

• Deny you access to our Services,
• Charge you different prices or rates,
• Provide you with a different level or quality of services,
• Suggest that you may receive a different price or service level based on your exercise of these rights.

How to Submit a Request
To exercise any of your California privacy rights, you may contact us by:

• Email: privacy@nala.money
• Phone: (877) 716-9669

In your request, please specify:

• Your full name,
• Your preferred method of response (email or postal mail),
• Your street address (if postal mail is requested),
• Your city, state, and ZIP code.

We may need to verify your identity before processing your request. This may include:

• Verifying that your email or contact information matches the data we have on file;
• Requesting a valid, government-issued identification document for authentication.

Please note: For security reasons, we do not accept privacy requests by fax.

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