Privacy policy

Purpose This privacy notice is provided by and is applicable to your use of its U.S. Services and Surfaces.

Merov complies with and respects all privacy laws. This Privacy Policy describes your privacy rights and how you can exercise these rights.

We respect your privacy, and we are committed to protecting your personal information. This Privacy Policy will inform you as to how Merov Companies and their affiliates (collectively, "", we, us, our) handle your personal information when using any of our products, services, or applications, when visiting or using our websites or mobile applications, or using our white-label services (collectively, “Surfaces”).

Please note that our Services and Surfaces are not intended for minors below the age of 18 years, and we do not knowingly collect data relating to minors.

1. Important information and who we are

It is important that you read this Privacy Policy together with any other notice or policy that we may provide on certain occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements but is not intended to override those other notices or policies. If you do not agree with our policies and practices, your choice is to not use our Services or Surfaces. By accessing or using the Surfaces you agree to this Privacy Policy and consent to our data practices set forth herein.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We review and update our Privacy Policy from time to time. Your continued use of our Services or Surfaces after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

Third-party Links The Site may include links to third-party websites, plug-ins, and applications ("Third-Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control Third-Party Sites and are not responsible for their privacy and data security practices. When you leave our Site, we encourage you to read the privacy notice of every Third-Party Site you visit or use.

2. The information we collect about you

Personal information is a broad term which includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (de-identified data).

The definition of personal information includes the specific pieces of personal information which we have described below. Depending on whether and how you use our Services or Surfaces, we may collect, use, store and transfer different kinds of personal information about you which we have grouped in categories as follows: Identity Data

full name,
maiden name,
last name,
username or similar identifier,
date of birth and gender,
biometric information, including a visual image of your face,
video and voice recordings,
national identity cards, passports, driving licenses or other forms of identification documents.
Social Identity Data

your group/company data,
information on referrals related to you,
political background,
close connections,
behavioral data,
risk assessment,
compliance assessment.
Contact Data

residence details,
billing address,
delivery address,
home address,
work address,
email address and telephone numbers,
proof of address documentation.
Financial Data

bank account,
payment card details,
virtual currency accounts,
stored value accounts,
amounts associated with accounts,
external account details,
source of funds and related documentation.
Transactional Data

details about payments to and from you,
other details of any transactions you enter into using the Services or Site or App.
internet connectivity data,
internet protocol (IP) address,
operator and carrier data,
login data,
browser type and version
device type, category and model,
time zone setting and location data,
language data,
application version and SDK version,
browser plug-in types and versions,
operating system and platform,
diagnostics data such as crash logs and any other data we collect for the purposes of measuring technical diagnostics, and other information stored on or available regarding the devices you allow us access to when you visit the Site, or use the Services or the App.
Profile Data

your username and password,
your identification number as our user,
information on whether you have account and the email associated with your accounts,
requests by you for products or services,
your interests, preferences and feedback,
other information generated by you when you communicate with us, for example when you address a request to our customer support.
Usage Data

information about how you use the Surfaces, the Services, mobile applications and other offerings made available by us, including:
device download time,
install time,
interaction type and time,
event time, name and source.
Marketing and Communications Data

your preferences in receiving marketing from us or third parties, ○ your communication preferences,
your survey responses.
We also collect certain biometric information (e.g. visual image of you), which we use, in conjunction with our sub-contractors, to verify your identity for onboarding purposes.

Certain personal information may be sensitive and used only in accordance with applicable law. We may also collect, use, and share information that has been anonymized or de-identified, including statistical or demographic data, for any purpose (“Aggregate Consumer Information”). For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregate Consumer Information with your personal information so that it can directly or indirectly identify you, we treat the combined data as Personal Information pursuant to applicable law.

If You Refuse to Provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, including the ability to offer or provide or continue to provide Services or other functionality on our Surfaces.

3. How is your personal information collected

We use different methods to collect information from and about you including through:

Direct interactions. You may give us your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Services, by email, through the mobile application or otherwise. This includes personal information you provide when you:

visit the Site
apply for, access or attempt to access the Services
create or modify an account
subscribe to our publications
use any of the Services
request marketing to be sent to you
enter a competition, promotion or survey, including through social media channels
give us feedback or contact us
Automated technologies or interactions.

As you interact with us via our Site, we will automatically collect Technical Data about your equipment, browsing actions, activity, and patterns. We collect this data by using cookies, server logs, and other similar technologies. We will also collect Transactional Data and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites employing our cookies. You may find more information about how we use cookies and make adjustments to certain preferences through the Cookie Preferences section available on the Site.

Third parties or publicly available sources.

We also obtain information about you, including Social Identity Data from third parties or publicly available sources. These sources may include:

fraud and crime prevention agencies
a customer referring you
public blockchains
publicly available information

4. How we use your personal information

We will only use your Personal Information in accordance with applicable law and in accordance with this Privacy Policy. For the most part, we will use your Personal Information in the following ways to provide Services:

When necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
To comply with a legal obligation
For business purposes and in accordance with this Privacy Policy
Purposes for which we will use your personal information

We have set out below an illustrative example of the common ways we may use your Personal Information:

To register you as a new customer
To carry out and comply with legal and compliance obligations
To process and deliver the Services and any features and functionality
To prevent abuse of our Services, Site, and promotions
To manage our relationship with you which will include notifying you about certain changes to our terms or Privacy Policy, asking you to leave a review, take a survey or keeping you informed of our business and product development
To keep our records updated and to evaluate how customers use our products/services
To manage, process, collect and transfer payments, fees and charges, and to collect and recover payments owed to use
To ensure proper management of our payments, fees and charges and collection and recovery of payments owned to us
To manage risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, fraud and other background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and response to complaints and resolving them
To enable you to partake in a prize draw, competition or complete a survey
To gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business
To administer and protect our business, the Site, and social media channels including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
To make suggestions and recommendations to you about goods or services that may be of interest to you
To use the services of social media platforms or advertising platforms some of which will use the personal information they receive for their own purposes, including marketing purposes
To record voice calls and other conversations for compliance, quality assurance, and training purposes Marketing
We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your Personal Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you. You may receive marketing communications from us if you have requested information from us or used the Services and have not opted out of receiving that marketing.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Further, you can let us know directly that you prefer not to receive any marketing messages by emailing

When you opt-out of receiving these marketing messages, this will not apply to service messages which are directly related to use of our Services (e.g. change in the terms and conditions or this Privacy Policy). Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Surfaces may become inaccessible or not function properly. For more information about the cookies we use, please review the Cookie Preferences available on the Site.

Sale or Transfer of Business

We may need to process your Personal Information in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving all or a part of our shares, business or assets.

5. Disclosures of Your Personal Information

We may share your Personal Information with our third-party service providers, agents, subcontractors, and other associated organizations, our group companies and affiliates in order to complete tasks, provide the Services, and use of the Merov Surfaces to you on our behalf, and otherwise fulfill our obligations. When using third-party service providers, we request they respect the security of your Personal Information and treat it in accordance with the law. We may share your Personal Information and other data you provide to us for the following purposes:

To verify your identity.
To detect and prevent fraud, money laundering, terrorist financing, and other financial crimes and illicit activities.
To facilitate the provision of services and relevant business operations to support our delivery of the Services and related aspects to you.
To improve our information, technology, and security systems including websites and mobile applications.
To provide customer service.
To promote our Services if you submit a product review or post content on public areas of our Services, or social media accounts.
To transfer our rights and duties under the relevant terms and conditions governing the use of any Services (to the extent allowed).
To comply, in our belief, with a legal request or to protect or enforce our rights, including to comply with an applicable law or regulation, or in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability, and to protect the rights, property, and safety of us or others.
To evaluate, effectuate, or otherwise transfer your personal information as part of a proposed or actual sale, merger, restructuring, transfer, or exchange of all or a portion of our assets to another company.
We may disclose the following categories of personal information to the following categories of third parties:

Companies and organizations that assist us in processing, verifying or refunding transactions or orders
Identity verification agencies
Fraud or crime prevention agencies
Anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services
Any third party because of any restructure, sale or acquisition of our group or any affiliates
Regulatory and law enforcement authorities, where the law allows or requires us to do so

6. Personal Information Security

While there is an inherent risk in any information being shared over the internet, we have put in place commercially reasonable security measures to prevent your Personal Information from being accidentally lost, used, damaged, or accessed in an unauthorized or unlawful way, altered, or disclosed.

In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your Personal Information on our instructions. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse such as by maintaining the confidentiality of your Personal Information.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a qualifying breach when required.

7. Personal Information retention

How long will you use my personal information for?

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Here are some exemplary factors which we usually consider when determining how long we need to retain your Personal Information and data:

in the event of a complaint;
if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims, the respective personal information (e.g., email addresses and content, chats, letters) will be kept in accordance with the statutory limitation period applicable following the end of our relationship;
to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal information, including relevant sanctions regimes: under the Bank Secrecy Act and its related statutes we are obliged to retain your Personal Information for a period of at least 5 years after the end of our relationship; and information needed for audit purposes;
in accordance with relevant industry standards or guidelines;
in accordance with our legitimate business need to prevent abuse of the promotions that we launch.
We will retain a customer’s personal information for the time of the promotion and for a certain period after its end to prevent the appearance of abusive behavior.

Please note that under certain conditions, you can ask us to delete your Personal Information.

8. Your legal rights Under certain circumstances, you may have certain rights in relation to your Personal Information:

Right to know about Personal Information collected, and how it is used and disclosed.
Right to request correction of certain Personal Information.
Right to request deletion of certain Personal Information.
Right to opt-out of the sharing of certain Personal Information.
If you wish to exercise any of the rights set out above or if you want to raise a question, complaint or a concern about our privacy policy and practices, please contact Data Protection Officer at

When allowed by applicable law and required, we will take steps to disclose and deliver to you, free of charge, your Personal Information accordingly. We may also contact you to ask you for further information in relation to your request to speed up our response.

Non-Discrimination You will not receive a discriminatory treatment if you choose to exercise any of the rights conferred to you above.

Children’s Privacy respects the privacy of children, and we are committed to complying with the Children’s Online Privacy Protection Act (herein called “COPPA”). We do not knowingly collect Personal Information from children under the age of thirteen (13). If you are a parent or guardian and you are aware that your child under the age of 13 has provided us with personally identifiable information, please contact us. If we become aware that we have collected personally identifiable information from children without verification of parental consent, we take steps to remove that information from our servers.