1. Information We Collect

The information we collect depends on the products and services you request and the requirements applicable to your account.

• Identity and contact details: Name, date of birth, address, email address, telephone number, and identification details.
• Financial information: Account details, transaction history, payment information, and other financial records necessary to provide requested services.
• Verification information: Documents and information required for identity checks, customer due diligence, fraud prevention, and compliance.
• Eligibility information: Military or veteran verification details when relevant to a product or eligibility requirement.
• Technical information: IP address, browser, device information, security logs, and interactions with our website.
• Communications: Information you provide when contacting customer support or submitting a request or complaint.

We may also receive information from authorized service providers, financial institutions, and verification partners when permitted by law.

2. How We Use Your Information

We may use your information to:

• Open, maintain, and service eligible accounts.
• Verify identity and assess product eligibility.
• Process authorized transactions and service requests.
• Protect accounts and detect suspicious activity.
• Meet applicable legal, regulatory, and recordkeeping obligations.
• Respond to inquiries, complaints, and disputes.
• Maintain and improve our systems and digital services.
• Send service notifications and permitted marketing communications.

We process information only for purposes permitted by applicable law and consistent with the services we provide.

3. When We Share Information

We do not sell personal information to third parties for monetary consideration. Where permitted by law, information may be shared with:

• Service providers supporting technology, security, identity verification, and customer support.
• Financial institutions and payment partners involved in authorized transactions.
• Regulators, courts, and public authorities when required or permitted by law.
• Fraud-prevention organizations when necessary to investigate suspicious activity.
• Professional advisers and authorized recipients where appropriate.

We limit disclosures to what is appropriate for the relevant purpose and apply safeguards where required.

4. International Data Transfers

Because our operations are based in the Cayman Islands and our customers may reside in the United States and elsewhere, information may be processed in different jurisdictions.

International transfers will be conducted in accordance with applicable data protection laws. Where required, we will implement appropriate contractual, technical, or organizational safeguards.

5. Security and Account Protection

We use administrative, technical, and organizational measures designed to protect personal and financial information against unauthorized access, misuse, alteration, or loss.

• Use a strong, unique password.
• Enable multifactor authentication when available.
• Never share your password or one-time verification codes.
• Use trusted devices and secure networks.
• Review account activity regularly.
• Report suspected unauthorized access immediately.

No electronic system can be guaranteed completely secure. We will take reasonable steps to manage security risks and respond to incidents.

6. Data Retention

We retain information for as long as reasonably necessary to provide services, maintain records, resolve disputes, prevent fraud, and meet legal obligations.

When information is no longer required, we will take appropriate steps to delete it, anonymize it, or securely dispose of it, subject to applicable retention requirements.

7. Your Privacy Rights

Depending on your location and applicable law, you may be entitled to request access to, correction of, deletion of, or a copy of certain personal information.

You may also have rights to object to certain processing, withdraw consent where applicable, or opt out of eligible marketing communications.

Some rights are subject to legal exceptions. We may need to verify your identity before processing a request.

To exercise an applicable privacy right, contact us using the details in the Contact Us section.

8. Additional Information for US Customers

US financial privacy, consumer protection, and state privacy laws may impose additional requirements depending on our legal status, products, and activities.

Where applicable, we will provide required financial privacy notices and information about available consumer rights. Separate product-specific disclosures may also apply.

Our Cayman Islands location does not, by itself, determine which US laws apply. Applicability depends on the circumstances and relevant law.

9. Cookies and Website Technologies

Our website may use cookies and similar technologies to maintain secure sessions, remember preferences, improve functionality, and understand website performance.

Where consent is required for non-essential technologies, we will request it as required by law. Disabling certain cookies may affect website functionality.

10. Electronic Communications and Policy Updates

Where permitted by law, we may send account notices, security alerts, transaction updates, and service communications electronically. Required consent for electronic records will be obtained separately where applicable.

We may update this policy to reflect changes in our services, practices, or legal obligations. The latest version will be published on our website, with notice provided where required.

Essential account and security notices may continue even if you opt out of promotional communications.

11. Online Banking Terms of Use

Eligibility and registration

You must meet the eligibility requirements applicable to the service and provide accurate information during registration. Unless the relevant product expressly provides otherwise, online account registration is limited to individuals aged 18 or older.

Authorized use

You may use online banking only for authorized purposes. You must protect your credentials, follow security instructions, and promptly report suspected unauthorized access.

Transactions and verification

Transactions may be subject to available funds, verification checks, processing schedules, payment-network rules, and applicable law. Additional checks may result in delays or restrictions where permitted or required.

Suspension of access

We may restrict or suspend access where reasonably necessary to protect accounts, investigate suspected fraud, maintain security, or comply with legal requirements. Notice will be provided where required and legally permitted.

Unauthorized transactions and errors

Report unrecognized transactions or suspected errors promptly through a verified official channel. Liability, reimbursement rights, reporting deadlines, and dispute procedures depend on the applicable product terms and governing law.

Availability of services

We aim to provide reliable digital services, but temporary interruptions may occur because of maintenance, technical issues, security events, or circumstances outside our reasonable control.

12. Contact Us

For privacy inquiries, data requests, or concerns about the handling of your information, contact us using our verified official details.