Privacy Policy

1. Introduction and Scope

Finturu LLC, together with its subsidiaries, affiliates, and related entities (collectively referred to as "Finturu", "Finturu Group", "we", "our", or "us"), is committed to protecting the privacy and security of personal information entrusted to us by merchants, users, partners, service providers, and other stakeholders.

This Privacy Policy describes how Finturu collects, processes, uses, shares, and safeguards personal information when individuals interact with Finturu's services, platforms, infrastructure, websites, applications, and associated technologies.

Finturu operates a global commerce infrastructure platform that enables businesses to participate in international trade through integrated financial and operational services, including payment processing, merchant enablement technologies, settlement infrastructure, logistics integrations, and related digital services.

This Privacy Policy applies to all personal information processed by Finturu in connection with:

• Customers and merchants using our services.
• Users of Finturu platforms and digital services.
• Partners, vendors, and service providers.
• Employees, contractors, and job applicants.
• Shareholders and investors.
• Individuals who interact with Finturu through commercial or operational relationships.

Depending on the context, Finturu may act either as:

• Data Controller, determining the purposes and means of processing personal data; or
• Data Processor, processing data on behalf of merchants, partners, or financial institutions.

2. Categories of Personal Information Collected

Identification Information

Finturu may collect personal identifiers necessary to verify identity and establish commercial or contractual relationships. Such information may include an individual's name, date of birth, nationality, identification numbers, government-issued identification documents, tax identification numbers, or other identifiers required for regulatory compliance.

This information is typically collected during onboarding procedures, identity verification processes, or compliance checks associated with anti-money laundering and financial regulations.

Contact Information

To facilitate communication and service delivery, Finturu may collect contact details such as email addresses, telephone numbers, billing addresses, and mailing addresses.

These contact details may be used to communicate operational notifications, account updates, service information, and legally required communications.

Financial and Transactional Information

Where Finturu provides payment-related services, it may process financial or transactional information necessary to facilitate transactions and settlements.

This may include transaction history, payment instructions, merchant identifiers, settlement information, payout details, or other financial data required to process payments or reconcile accounts.

Sensitive payment information, such as card details, is processed through secure and compliant payment infrastructure providers operating under applicable security standards.

Technical and Device Information

When users interact with Finturu's platforms, websites, or digital services, certain technical data may be collected automatically. This may include internet protocol (IP) addresses, browser information, device identifiers, operating system details, timestamps of activity, and system logs.

This information supports system security, fraud prevention, operational monitoring, and service improvements.

Business and Corporate Information

For merchants, partners, and corporate clients, Finturu may collect business-related information necessary to establish commercial relationships.

This may include corporate registration data, beneficial ownership information, business activity descriptions, website domains, operational details, or other information required for regulatory and onboarding purposes.

Compliance and Risk Data

As part of its compliance obligations, Finturu may collect or generate information related to regulatory screening and risk management activities. This may include sanctions screening results, transaction monitoring indicators, fraud prevention signals, and other data used to assess risk and comply with financial regulations.

3. Purposes of Data Processing

Finturu processes personal information for legitimate business purposes consistent with the services it provides and its legal obligations.

Personal data may be used for purposes including the establishment and maintenance of commercial relationships, the provision and improvement of services, regulatory compliance, risk management, operational administration, and communication with stakeholders.

In particular, Finturu processes personal information to:

• Provide and operate its services and platforms
• Facilitate payment transactions and financial operations
• Verify identities and conduct onboarding procedures
• Comply with legal, regulatory, and compliance requirements
• Monitor transactions to prevent fraud and financial crime
• Communicate service-related notifications and updates
• Respond to inquiries, complaints, or support requests
• Improve system functionality and user experience
• Conduct internal analysis, reporting, and operational planning

Where personal information is used for marketing communications, Finturu will obtain consent where required by applicable law.

4. Sharing and Disclosure of Personal Information

Finturu may share personal information with certain categories of third parties when necessary for operational, legal, or regulatory purposes.

Such disclosures occur only where appropriate safeguards and contractual protections are in place.

Personal information may be shared with:

Financial Infrastructure Partners

To facilitate payment services and financial operations, Finturu may share information with financial institutions, payment processors, card networks, settlement partners, and banking infrastructure providers involved in transaction processing.

Operational Service Providers

Finturu relies on specialized third-party service providers that support operational activities such as cloud hosting, compliance monitoring, identity verification, fraud detection, analytics, and communication services.

These providers process personal information under strict contractual obligations and are permitted to use the information only for the purposes specified by Finturu.

Regulatory Authorities and Legal Obligations

Finturu may disclose personal information to governmental authorities, regulators, courts, or law enforcement agencies where required by applicable law, regulation, or legal process.

Corporate Transactions

In the event of a corporate transaction such as a merger, acquisition, financing event, restructuring, or sale of assets, personal information may be transferred as part of the transaction, subject to appropriate confidentiality protections.

5. Non-Affiliated Third Parties and User Choice

Finturu does not sell personal information to third parties.

Personal information may be shared with non-affiliated service providers only when necessary to support Finturu's operations, provide services, or comply with legal obligations.

Where personal information is used for marketing or promotional communications, individuals will have the ability to opt out of such communications through mechanisms such as unsubscribe links, account settings, or direct requests submitted to Finturu.

Operational communications necessary for the provision of services may continue to be sent even if marketing communications are declined.

6. Consent and Communication Preferences

Where required by law, Finturu obtains consent from individuals prior to processing personal information for specific purposes, including certain marketing communications.

Consent may be obtained through digital acceptance mechanisms, onboarding processes, or other authorized means.

Individuals may withdraw their consent at any time by contacting Finturu or by using the opt-out mechanisms available in communications.

Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal.

7. Security and Protection of Personal Information

Finturu maintains a comprehensive security program designed to protect personal information against unauthorized access, misuse, loss, or alteration.

Security measures implemented by Finturu include administrative, technical, and organizational safeguards designed to meet industry standards.

These measures may include encryption of sensitive data during transmission, restricted access controls based on operational roles, system monitoring and logging, vendor security assessments, and employee training programs related to data protection.

Finturu periodically reviews and updates its security practices to maintain appropriate levels of protection for the personal information it processes.

8. International Data Transfers

Because Finturu operates globally, personal information may be transferred across international borders, including to jurisdictions where Finturu or its service providers operate infrastructure.

When such transfers occur, Finturu implements safeguards designed to ensure that personal information remains protected in accordance with applicable data protection standards.

9. Data Retention

Finturu retains personal information only for the period necessary to fulfill the purposes for which it was collected, including the provision of services, compliance with legal obligations, dispute resolution, and enforcement of contractual rights.

Certain financial or regulatory requirements may require retention of records for extended periods consistent with applicable laws.

10. Rights of Individuals

Individuals may have rights regarding their personal information depending on the jurisdiction in which they reside.

These rights may include the ability to access personal information held by Finturu, request correction of inaccurate data, request deletion of personal information where permitted by law, or object to certain types of processing.

Requests related to personal data may be submitted to:

privacy@finturu.com

Finturu will review and respond to such requests in accordance with applicable legal requirements.

11. Changes to This Privacy Policy

Finturu may update this Privacy Policy periodically to reflect changes in legal requirements, business operations, or technological developments.

When material changes are made, Finturu will provide notice through appropriate communication channels, including website updates or direct notifications where applicable.

The updated version of the policy will include the effective revision date.

12. Contact Information

Finturu LLC and its subsidiaries and affiliates (collectively, "Finturu Group") maintain internal governance structures designed to ensure compliance with applicable privacy, data protection, and financial regulatory requirements.

Oversight of data protection practices is coordinated through Finturu's internal privacy and compliance functions, which are responsible for monitoring adherence to this Privacy Policy, applicable regulatory frameworks, and internal security standards.

Individuals who wish to exercise their data protection rights, submit privacy inquiries, report concerns, or request additional information regarding the processing of personal data may contact Finturu through the designated privacy communication channels.

Privacy and Data Protection Requests

Requests related to personal data, including access, correction, deletion, or objections to processing, may be submitted to:

privacy@finturu.com

All requests will be reviewed and processed in accordance with applicable data protection regulations and internal compliance procedures.

Data Protection and Compliance Inquiries

Questions related to Finturu's privacy practices, security safeguards, or regulatory compliance may be directed to the Finturu privacy and compliance team at:

compliance@finturu.com

Finturu will review such inquiries and respond within a reasonable timeframe consistent with applicable regulatory obligations.