1. Scope of the Policy
1.1 This Policy applies to all users of the moove.xyz Platform, including visitors, wallet users, account holders, users of Regulated Products, and counterparties who interact with moove.xyz’s services, whether directly or through third-party integrations. 1.1A The Platform is available only to natural persons acting on their own account. moove.xyz does not onboard companies, partnerships, trusts, foundations or other legal entities, does not perform entity due diligence, and does not collect beneficial ownership information or corporate records. The personal data described in this Policy is therefore data about individuals. Clause 3.2 of the Terms of Service sets out the restriction in full. 1.2 This Policy does not apply to third-party websites, services, protocols, or Licensed Partners linked to or integrated with the Platform. Your use of a Licensed Partner’s regulated service is also governed by that Licensed Partner’s own privacy notice. 1.3 Capitalised terms not defined in this Policy have the meanings given in the Terms of Service. In particular, “Regulated Product” has the meaning given in the Terms of Service: a product made available through the Platform that is provided by a Licensed Partner, or that moove.xyz identifies as requiring identity verification to access. The Regulated Products available at any time are identified in the Product Schedule.2. Verification Is Scoped, Not Universal
2.1 moove.xyz is non-custodial. For the Self-Custody Services — holding, sending, receiving, swapping and bridging digital assets through a wallet you control — we do not collect or require government-issued identification, biometric data, or other identity documents, and you remain in control of your wallet and your identity at all times. 2.2 In respect of the Self-Custody Services, we do not collect or store, and cannot access: a. Wallet private keys, seed phrases, recovery phrases, or passwords;b. Bank account or payment card numbers; or
c. Government-issued identification or biometric identifiers. 2.3 Identity verification data is collected only where you choose to access a Regulated Product. Verification confirms the identity of an individual; because moove.xyz does not onboard entities, no corporate or beneficial-ownership verification is carried out. If you do not use a Regulated Product, Clause 4 does not apply to you. Where such data passes through the Platform, we handle it on a need-to-know and data-minimisation basis, use it only for the purposes described in this Policy, encrypt and secure it, and never use it for any other purpose. 2.4 This is not anonymity. Not requiring identity documents is not the same as operating without controls. We screen and monitor activity across the Platform as described in Clause 5, irrespective of whether you are verified, and blockchain transactions are recorded on public ledgers and are permanently traceable.
3. Technical and Usage Data We Collect
3.1 To operate and improve the Platform, we may collect limited technical, usage, and contact data from all users, including: a. Public blockchain addresses, counterparty addresses, and transaction metadata;b. Device type, browser type, operating system, and language preferences;
c. IP address, approximate geolocation, and time zone;
d. Interaction data such as clicks, page views, and feature usage;
e. Error logs and diagnostic information;
f. Email addresses or contact details; and
g. Where you choose to display it on your Moove Profile, a business or contact address. 3.2 Where it is not collected as part of Regulated Product verification, this data is collected in a pseudonymised or anonymised form where possible. 3.2A Where we collect personal data directly from you, we tell you at or before the point of collection what we are collecting, why, to whom it may be transferred, and that you may request access to and correction of it. That statement is given on the relevant screen in the Moove App or on the website, and this Policy supplements it. 3.3 IP address and location. We use your IP address and approximate location to determine the jurisdiction from which you are accessing the Platform, to apply territorial restrictions and geo-blocking, to screen against sanctioned and restricted jurisdictions, and to detect attempts to circumvent those restrictions. Access from a jurisdiction in which the Platform is not made available may be blocked. 3.4 Contacts. If you use Moove Contacts to save the people you transact with, we process the contact details you enter. Where those details relate to another person, you are responsible for ensuring you have a lawful basis for providing them to us, and you should not save information the other person would not expect you to. 3.5 Payers. If you open a Moove Profile or a Payment Link to pay someone, whether at a moove.xyz address or at a domain that person has connected, we collect the public wallet address you pay from, the transaction details, and the technical data described in Clause 3.1(b) to (e). We use it to display and complete the payment, to operate the controls in Clause 5, and to secure the Platform, and we are the data user for that data. The person you are paying is responsible for their own terms and their own privacy notice in respect of what they sell you.
4. Identity Verification Data and Face Data (Regulated Products Only)
4.1 Where you choose to access a Regulated Product, the Licensed Partner providing it is required by applicable anti-money laundering, counter-terrorist financing, counter-proliferation financing, sanctions, and “know your customer” laws to verify your identity. Verification is performed by an established, specialist identity-verification provider engaged for that Licensed Partner. Through the Platform you provide, and we transmit to that provider and Licensed Partner, additional personal data which may include: a. Your legal name;b. Date of birth and nationality;
c. Email address and mobile telephone number;
d. Residential or business address;
e. Government-issued identification documents (such as passport, national ID, or driver’s licence) and the data they contain;
f. A photograph or “selfie”; and
g. Face data, meaning biometric data derived from images of your face captured during verification, including “liveness” signals used to confirm that you are a real, present person and that you match your identification document. Where the app uses on-device face-tracking capabilities of your device (such as Apple’s TrueDepth APIs), the depth and expression data those capabilities produce is processed on your device only, is never received, stored, or retained by us or by any provider, and does not form part of the data held about you — see Clauses 4.4 to 4.11. 4.2 The identity-verification provider collects this data through its verification technology within the Moove App or website and processes it for the Licensed Partner. More than one provider may be engaged, and which one performs your verification depends on the corridor and product you are using; providers may change from time to time. Each is engaged under written contract, is bound by the standard in Clause 4.8, and processes your data only for verification, compliance and fraud prevention. We receive from the provider and Licensed Partner the outcome of your verification and a reference to it. 4.3 Data is handled on a strict need-to-know and data-minimisation basis — only what is reasonably necessary to verify your identity, complete compliance screening, and provide the Regulated Product.
Face Data
4.4 What face data is collected, and how. To complete liveness verification you will be asked to capture images of your face using your device’s camera. The verification provider’s technology analyses those images, and the way your face moves during capture, to confirm that a real, live person is present at the moment of capture and to prevent presentation attacks using photographs, video replay, or masks. Depending on the provider and your device, part of that analysis takes place on your device and part on the provider’s systems. On supported Apple devices the app may use Apple’s TrueDepth APIs during capture to read the spatial orientation and expression of your face in real time; that data is processed on your device only. We do not use face data for advertising, marketing, profiling, personalisation, product development, or any other purpose; we do not sell, rent, or trade it; and we do not use it to build or contribute to any facial-recognition database, or to identify you other than by matching you to your own verification record. 4.5 On-device processing and what leaves your device. Depth and expression data produced by your device’s own face-tracking capabilities, including Apple’s TrueDepth APIs, is processed entirely on your device. It exists only in memory for the duration of the capture session, is discarded when that session ends, is not written to storage, is not transmitted to moove.xyz or to any provider, is not logged, and is not retained by anyone. What leaves your device is the images captured during verification, the liveness signals derived from them by the provider’s technology, and the verification outcome. We do not receive the images or the liveness signals; they are transmitted to the identity-verification provider for the Licensed Partner. The provider does not use them to build or contribute to any facial-recognition database and uses them only to match you to your own verification record. 4.6 Consent. We collect face data only where you have chosen to access a Regulated Product, and only with your express, separate consent, obtained at the point of verification. You may decline. If you decline, you will not be able to access that Regulated Product, but you may continue to use the Self-Custody Services described in Clause 2. 4.7 Sharing of face data. Depth and expression data produced by your device’s own face-tracking capabilities is not shared with anyone, because it never leaves your device. The images captured during verification, the liveness signals derived from them, and the verification outcome are held by the identity-verification provider for the Licensed Partner and are shared only with: a. The identity-verification provider performing your verification, acting for the Licensed Partner and bound by the standard in Clause 4.8;b. The Licensed Partner providing the Regulated Product, to the extent necessary for that Licensed Partner to meet its own legal and compliance obligations; and
c. Regulatory, supervisory, or law enforcement authorities, where required by applicable law, court order, or lawful request. We do not sell, rent, trade, or otherwise disclose face data or your selfie for advertising, marketing, analytics, or any commercial purpose. 4.8 Third-party protection standard. Any third party that receives face data through the Platform, including the images captured during verification, is bound by a written agreement requiring it to provide the same or equal protection of that data as is stated in this Policy, including equivalent obligations as to purpose limitation, confidentiality, encryption in transit and at rest, access control on a need-to-know basis, retention limits, deletion on our instruction, breach notification, and the prohibition on sale or secondary use. No such third party is permitted to use face data for its own purposes. 4.9 Retention of face data. Depth and expression data produced by your device’s own face-tracking capabilities is not retained at all, as described in Clause 4.5. The identity record, including the images captured during verification and the verification outcome, is held by the Licensed Partner or its identity-verification provider for the period that partner’s law requires — typically five (5) to seven (7) years from the end of your relationship with that partner or from the relevant transaction — and is then deleted or irreversibly anonymised. Throughout that period it is kept encrypted and access-restricted on a need-to-know basis, and is used only for identity verification, compliance, and fraud prevention. We retain only the verification outcome, a reference to it, the corridor and the date, for as long as your account is active and for twelve (12) months afterwards, or longer while any report, investigation or lawful request is live. These rules prevail over the general retention position in Clause 10. 4.10 How to delete your face data. Because depth and expression data produced by your device is never stored, there is nothing to delete once a capture session ends. You may at any time request deletion of the images captured during verification and related verification data by either: a. Contacting us through the in-app support channel in the Moove App; or
b. Emailing legal@moove.xyz from the email address associated with your account, with the subject line “Face Data Deletion Request”. We will verify your request, instruct the identity-verification provider and the Licensed Partner holding that data to action it, delete what we hold within thirty (30) days, and confirm to you in writing once we are told deletion is complete. Where the Licensed Partner’s law prevents deletion of part of the record, we will tell you which data is retained, by whom, on what basis, and until when. 4.11 How to revoke your consent. You may withdraw your consent to our collection and use of face data at any time, using either channel set out in Clause 4.10, or by declining or exiting the verification flow before capture. On withdrawal, we will cease all further processing of your face data and delete or irreversibly anonymise it in accordance with Clause 4.9, and will instruct any third party holding it to do the same. Withdrawing consent means you will no longer be able to access the relevant Regulated Product, but it does not affect your access to the Self-Custody Services.
5. Screening, Monitoring and Automated Decisions
5.1 We process personal data to operate financial-crime controls across the Platform, for all users, irrespective of whether you have been verified. This processing includes: a. Screening wallet addresses and counterparty addresses against sanctions lists and against blockchain-analytics risk data;b. Screening Moove Handles, Moove Profile content and Payment Link content;
c. Assessing device and connection risk, including IP address and location, for fraud and jurisdiction screening; and
d. Monitoring transaction patterns for indicators of financial crime, fraud, or sanctions evasion. 5.2 For Regulated Products, we and the Licensed Partners additionally conduct identity, sanctions, politically-exposed-person, adverse-media and ongoing-monitoring screening as described in Clause 4. 5.3 Automated decisions. Some of these controls operate automatically, and an automated decision may result in a transaction being declined or delayed, or in a Moove Handle, Moove Profile, Payment Link or API key being suspended or disabled. In general terms, the logic involves matching identifiers against sanctions and watchlist data, applying risk scores supplied by screening providers to wallet addresses and devices, and applying rules to transaction patterns. 5.4 Your right to human review. Where an automated decision produces a legal effect for you or similarly significantly affects you, you may request that it be reviewed by a person, may express your point of view, and may contest the decision, by writing to legal@moove.xyz. The review will be carried out by someone who was not responsible for the original decision. We may be unable to disclose the detail of what a control identified, or the fact that a report has been made, where we are prohibited from doing so by law. 5.5 We carry out this processing to comply with legal obligations that apply to us, including our reporting obligations under the Organized and Serious Crimes Ordinance (Cap. 455), and to prevent fraud and financial crime. It is not carried out for your benefit or reliance, and it does not guarantee that any transaction or counterparty is lawful or free from risk.
6. Roles: Data User, Controller and Processor
6.1 moove.xyz is the data user under the Personal Data (Privacy) Ordinance (Cap. 486), and the controller under equivalent laws elsewhere, for the data described in Clauses 3 and 5 and for the verification outcome and reference described in Clause 4.9. 6.2 We make Regulated Products available only through partners that are licensed, registered or otherwise authorised to provide the relevant regulated activity in the jurisdictions in which they provide it. Each Licensed Partner is the data user, and the controller under equivalent laws elsewhere, for the identity record described in Clause 4 and for the personal data it processes to provide its regulated service, under its own privacy notice. The identity-verification provider processes that record for the Licensed Partner. moove.xyz and each Licensed Partner are separate and independent controllers, not joint controllers. 6.3 Screening, hosting, analytics and infrastructure providers act as our processors, under written contract and on our instructions. Each is required to process personal data only for the purposes we specify, to keep it confidential, to secure it in transit and at rest, to restrict access on a need-to-know basis, to delete it on our instruction, and to notify us of any breach. None is permitted to use your personal data for its own purposes, and none is permitted to sell it.7. How We Use Your Data, and On What Basis
7.1 We use the data described in this Policy for the following purposes: a. To operate, maintain, and secure the Platform and its features;b. To verify your identity and eligibility to access Regulated Products, and to perform the screening described in Clause 5 (Regulated Products only for identity screening);
c. To operate financial-crime screening and monitoring across the Platform for all users, as described in Clause 5;
d. To provide Regulated Products, including by transmitting the necessary information to the relevant Licensed Partner;
e. To determine your jurisdiction and apply territorial restrictions;
f. To detect, prevent, and investigate abuse, fraud, financial crime, or security threats;
g. To comply with applicable legal, regulatory, AML/CTF, sanctions, tax, and reporting obligations, and to respond to lawful requests from regulators, courts, or law enforcement;
h. To communicate with you regarding your account, verification status, transactions, and Platform updates; and
i. To analyse aggregated and de-identified usage for product development. 7.2 Purpose limitation. Under Data Protection Principle 3 of the Personal Data (Privacy) Ordinance, we will not use your personal data for a new purpose that is unrelated to the purpose for which it was collected without your express and voluntary consent. In particular, personal data collected for identity verification and compliance is used only for the purposes in Clauses 7.1(b), (c), (d), (f) and (g). It is not used for product analytics under Clause 7.1(i) except in aggregated or de-identified form from which you cannot be identified. 7.3 Biometric data. We process biometric data, including face data, solely to verify your identity and confirm liveness for the purpose of accessing Regulated Products and preventing fraud and impersonation. We do not use it for any other purpose, do not use it for advertising or profiling, and do not sell it. The sharing, retention, deletion, and consent-withdrawal rules specific to face data are set out in Clauses 4.4 to 4.11. 7.4 We do not use your data for behavioural advertising, and we do not sell personal data. 7.5 Direct marketing. We do not currently use your personal data for direct marketing. If that changes, we will notify you as required by Part 6A of the Personal Data (Privacy) Ordinance, tell you what data and what classes of goods and services are involved, and obtain your consent before doing so. You may opt out at any time, free of charge, by writing to legal@moove.xyz. We do not and will not provide your personal data to any other person for use in direct marketing. 7.6 Legal bases (where GDPR or a similar regime applies). Where your data is protected by the EU or UK GDPR or an equivalent regime, we process it on one or more of these bases: compliance with a legal obligation (sanctions, reporting, record keeping, and, for the Licensed Partner, KYC and AML/CTF verification); performance of a contract or steps taken at your request (providing a product you have requested); your explicit consent to the capture of face data (obtained separately, and withdrawable); and legitimate interests (fraud prevention, security, and Platform integrity), where not overridden by your rights. The Personal Data (Privacy) Ordinance does not use this framework; where it applies, our processing is governed by the Data Protection Principles and, where required, by your consent.
8. Sharing of Data
8.1 We do not sell, rent, or trade your personal data. 8.2 We may share data with: a. Licensed Partners, to the extent necessary to provide a Regulated Product you have chosen to use and to enable that Licensed Partner to meet its own legal and compliance obligations;b. Service providers who assist with identity verification (for the Licensed Partner, as described in Clause 4), sanctions and fraud screening, hosting, analytics, or infrastructure, under the confidentiality and data-protection obligations described in Clauses 4.8 and 6.3. Any third party that receives biometric or face data through the Platform is contractually required to provide the same or equal protection of that data as is stated in this Policy (see Clause 4.8);
c. Regulatory, supervisory, tax, or law enforcement authorities, if required or permitted by applicable law, court order, or lawful request, including for AML/CTF, sanctions, and Travel Rule purposes, and including where we make a report under Clause 5.5; and
d. Third-party protocols or integrations you choose to interact with, in which case your data is shared directly and voluntarily by you. 8.3 We may also share data in connection with a merger, acquisition, reorganisation or sale of assets, subject to the recipient being bound to protections no less protective than this Policy. 8.4 moove.xyz is not responsible for the privacy or data-security practices of any Licensed Partner or third-party service you choose to use in conjunction with the Platform. You are advised to review their privacy notices.
9. Cookies and Tracking Technologies
9.1 We use cookies and similar technologies (such as local storage and pixels) to maintain session state and preferences, enable core Platform functionality, and collect usage analytics to improve performance and usability. 9.2 We use three categories: essential cookies, required for the Platform to function and set on the basis of necessity; functional cookies, which remember your preferences and settings; and performance cookies, which collect usage analytics. We do not use cookies for advertising, retargeting, or behavioural profiling. 9.3 Where consent is required for non-essential cookies — including for users in the European Economic Area and the United Kingdom — we ask for it through a consent banner before those cookies are set, and you may accept or reject non-essential categories, and change your choice at any time. Rejecting non-essential cookies does not prevent you from using the Platform. 9.4 You may also control cookies through your browser settings, although disabling essential cookies may impair core functionality.10. Data Retention
10.1 We retain data only for as long as necessary to fulfil the purposes in this Policy or to comply with legal obligations. Our retention periods are:
10.2 Where an applicable financial-crime law, or a Licensed Partner requirement, requires us or the Licensed Partner to retain a record, it cannot be deleted on request during that period. We delete or irreversibly anonymise data once the applicable period expires and it is no longer required.
10.3 Biometric data, including face data, is subject to the specific rules in Clauses 4.5 and 4.9 to 4.11, which prevail over this Clause 10 in respect of that data.
10.4 Public blockchain data is immutable and may be permanently recorded on-chain. moove.xyz does not control or delete on-chain data.
11. Data Security
11.1 We implement appropriate technical and organisational measures to protect data from unauthorised access, loss, misuse, or alteration. Identity verification data and biometric data are encrypted in transit and at rest, access is restricted on a need-to-know basis, and we apply additional safeguards to sensitive data. 11.2 No system is completely secure. You acknowledge that you use the Platform and transmit data at your own risk. 11.3 You are solely responsible for securing your wallet, private keys, recovery phrase, devices, and account credentials. We cannot recover a lost recovery phrase. 11.4 In the event of a data breach affecting your personal data, we will notify affected users and the relevant authorities in accordance with applicable laws and within the timeframes they require, such as seventy-two (72) hours where the GDPR or the Nigeria Data Protection Act applies. Where no mandatory notification applies, we will still notify you where the breach is likely to cause you harm. 11.5 Security issues may be reported to legal@moove.xyz.12. International Data Transfers
12.1 We may process and store data in jurisdictions outside your country of residence, including Hong Kong SAR and other locations where our service providers and Licensed Partners operate. 12.2 Where we transfer personal data internationally, we apply appropriate safeguards, including contractual protections equivalent to those recommended by the Privacy Commissioner for Personal Data in Hong Kong and, where the GDPR applies, standard contractual clauses or another lawful transfer mechanism.13. Your Rights
13.1 Depending on your jurisdiction, you may have rights to: a. Access the personal data we hold about you;b. Request correction of inaccurate data;
c. Request deletion of your data;
d. Object to or restrict certain processing;
e. Receive your data in a portable form;
f. Withdraw consent where processing is based on consent, including consent to biometric processing; and
g. Request human review of an automated decision, as described in Clause 5.4. 13.2 Hong Kong. Under the Personal Data (Privacy) Ordinance you have the right to make a data access request and a data correction request. We will respond within 40 days. We may charge a fee that is not excessive for complying with a data access request, and we will tell you the amount before proceeding. You may also complain to the Privacy Commissioner for Personal Data, Hong Kong. 13.3 Other jurisdictions. Where the GDPR or UK GDPR applies, you may lodge a complaint with your local supervisory authority. Where the Nigeria Data Protection Act applies, you may complain to the Nigeria Data Protection Commission. Where United States state privacy laws apply, we confirm that we do not sell or share personal data for cross-context behavioural advertising. 13.4 These rights are subject to legal limits. Where we or the Licensed Partner are legally required to retain identity verification data and related records (see Clause 10.2), that data cannot be deleted, and its processing cannot be stopped, until the applicable period expires. Withdrawing consent to biometric processing will prevent you from accessing the relevant Regulated Product but does not affect your access to the Self-Custody Services. 13.4A Where a legal restriction applies to a request, including the exemption for the prevention or detection of crime in section 58 of the Personal Data (Privacy) Ordinance or a prohibition on disclosing that a report has been made, we will still respond within the statutory period, will comply with the request so far as the restriction allows, and will tell you that a legal restriction applies where we cannot say more. 13.5 To exercise any right, contact legal@moove.xyz. We may request additional information to verify your identity, which we handle securely and retain only as long as necessary. Requests concerning face data are handled as described in Clauses 4.10 and 4.11.