MothPrivacy Policy
1. Introduction
This Privacy Policy explains how Hong Kong Yunmo Technology Co., Limited (the "Company", "we", "us") collects, uses, discloses, stores and protects your Personal Data when you use the MothCard-branded services, website and mobile application (the "Services"). By using the Services, you agree to this Privacy Policy and any updates we may issue from time to time.
"Personal Data" means any information relating to an identified or identifiable individual. It does not include anonymized data.
2. What Personal Data We Collect
We may collect and process the following categories of Personal Data:
| Category | Examples |
|---|---|
| Identity data | Name, ID documents, photo, gender, date of birth, nationality |
| Contact data | Phone number, email, residential address |
| Financial data | Transaction history, wallet activity, payment information |
| Device data | Device model, OS version, identifiers |
| Network and location data | IP address, network type, approximate location |
| Usage data | App interaction, feature usage, push interaction statistics |
3. How We Use Your Personal Data
We process your Personal Data for purposes including but not limited to:
- Verifying your identity and onboarding, including KYC and AML checks
- Providing and managing your account, Digital Wallet and MothCard
- Processing payments and providing transaction records
- Detecting and preventing fraud, misuse or security threats
- Complying with legal obligations, regulatory investigations or law enforcement requests
- Analytics, audits, customer support and service optimization
- Marketing and promotional campaigns, subject to your consent where required
4. Legal Basis for Processing (EEA and UK Residents)
If you are located in the European Economic Area ("EEA") or the United Kingdom, our legal basis for collecting and using your Personal Data depends on the data concerned and the context. We rely on one or more of the following:
- Performance of a contract — to provide the Services you request.
- Consent — where you have given us consent, for example for marketing. You may withdraw consent at any time.
- Legal obligation — to comply with KYC, AML and other regulatory requirements.
- Legitimate interests — for fraud prevention, security and service improvement, where not overridden by your rights.
For users outside the EEA and UK, including Hong Kong residents, we process Personal Data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) and other applicable laws.
5. Disclosure of Your Data
We may share your Personal Data with:
- Our affiliates, subsidiaries, employees or authorized representatives
- Third-party service providers, such as KYC and AML vendors, partner card issuing institutions, payment processors and custodians
- Marketing and analytics partners
- Legal, regulatory or government authorities as required by law
- Potential acquirers or investors in a merger or restructuring
6. International Transfers
Due to the global nature of our Services, your data may be transferred to and stored in locations outside your home jurisdiction, including Hong Kong. We ensure such transfers comply with applicable data protection laws and implement appropriate safeguards. For EEA and UK residents, transfers outside the EEA and UK are made under appropriate safeguards, such as Standard Contractual Clauses, where required.
7. Data Retention
We retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting or reporting requirements.
- KYC and AML records — retained for the period required by applicable anti-money-laundering laws, typically five to seven years after the end of the customer relationship.
- Transaction records — retained as required by applicable law and for dispute resolution.
- Account data — retained while your account is active and for a reasonable period thereafter.
When Personal Data is no longer needed, we will securely delete or anonymize it.
8. Your Rights
We aim to take reasonable steps to let you access, correct, or delete your Personal Data, or limit its use.
If you are an EEA or UK resident, you have the following rights under the GDPR and UK GDPR:
| Right | Meaning |
|---|---|
| Access | Obtain a copy of the Personal Data we hold about you. |
| Rectification | Have inaccurate or incomplete data corrected. |
| Erasure | Request deletion of your data, subject to legal retention obligations. |
| Restriction | Request that we restrict processing of your data. |
| Data portability | Receive your data in a portable format. |
| Objection | Object to our processing of your data. |
| Withdraw consent | Withdraw consent at any time where processing is based on consent. |
To exercise your rights, contact us at privacy@mothcard.io. We may verify your identity before responding. We will respond within the timeframe required by applicable law; under the GDPR this is generally within one month.
Residents outside the EEA and UK, including Hong Kong, may exercise applicable rights under local law, such as access and correction under the Hong Kong PDPO, via the same contact.
9. Cookies
We may use cookies and similar technologies on our website and App to enhance your experience. You can manage cookie preferences in your browser settings; disabling cookies may affect your experience.
10. Data Security
We implement industry-standard security measures, including encryption and access controls, to protect your Personal Data. However, no system is completely secure, and we cannot guarantee absolute protection.
11. Third-Party Links
Our platform may contain links to third-party sites and services. We are not responsible for their content or privacy practices. Please review their policies separately.
12. Children's Data
The Services are not intended for individuals under 18. We do not knowingly collect Personal Data from minors. If we learn that we have collected such data, we will delete it.
13. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version takes effect upon posting. We encourage you to review it periodically. Material changes may be notified through the App or by email.
14. Language
This Privacy Policy may be available in multiple languages. In case of any discrepancy, the English version prevails.
15. Contact Us
For any questions about this Privacy Policy or to make a data-related request, email privacy@mothcard.io with the subject line "PRIVACY REQUEST".