NADAPAY™ PRIVACY POLICY

Last Updated: January, 2026

INTRODUCTION

Tranx Financial Services d/b/a NadaPay ("NadaPay, " "we, " "us, " or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our mobile application, or engage with our financial products and services (collectively, the "Services").

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information").

Identity Data: Name, date of birth, social security number (SSN), passport number, driver’s license details, and other government-issued identification.

Contact Data: Email address, telephone number, billing address, and shipping address.

Financial Data: Bank account numbers, payment card details, wallet addresses, transaction history, and source of funds information.

Technical Data: IP address, device type, operating system, browser type, and geolocation data.

Biometric Data: Facial scans or fingerprints used for identity verification (KYC).

HOW WE USE YOUR INFORMATION

We use your Personal Information for the following purposes:

To provide, operate, and maintain our Services.

To process transactions and manage your digital wallet.

To verify your identity and comply with legal obligations (KYC/AML).

To prevent fraudulent activity and enhance security.

To communicate with you regarding updates, offers, and support.

To improve our platform through analytics and research.

SHARING YOUR INFORMATION (SERVICE PARTNERS)

We do not sell your Personal Information. However, to provide our Services, we share data with trusted Third-Party Service Partners ("Partners") who perform critical functions on our behalf. These Partners are contractually obligated to protect your data.

We share data with Partners for the following purposes:

Banking & Settlement: To process wire transfers, ACH payments, and hold custodial funds.

Card Issuance: To issue virtual and physical cards and process card transactions.

Liquidity & Exchange: To facilitate currency conversion (FX) and stablecoin settlement.

Identity Verification: To validate your identity documents and perform background checks.

Risk & Compliance: To monitor transactions for fraud, sanctions screening, and anti-money laundering (AML) compliance.

INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. By using NadaPay, you consent to the transfer of your data to the United States, the United Kingdom, and other jurisdictions where our Partners operate.

DATA SECURITY

We use administrative, technical, and physical security measures to help protect your Personal Information. While we have taken reasonable steps to secure the Personal Information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

YOUR DATA RIGHTS

Depending on your jurisdiction (e.g., GDPR, CCPA), you may have the right to:

Request access to the personal data we hold about you.

Request correction of inaccurate or incomplete data.

Request deletion of your personal data (subject to regulatory retention requirements).

Object to or restrict the processing of your data.

To exercise these rights, please contact us at compliance@nadapay.io.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible.

CONTACT US

If you have questions or comments about this policy, you may contact us at:

Email: compliance@nadapay.io