> ## Documentation Index
> Fetch the complete documentation index at: https://docs.moove.xyz/llms.txt
> Use this file to discover all available pages before exploring further.

# Privacy Policy

> moove.xyz Platform Privacy Policy.

*Last updated: 21 June 2026* 

This Privacy Policy ("Policy") constitutes a legally binding agreement between you ("User", "you" or "your") and Moove Hong Kong Group Limited ("moove.xyz", "we", "us" or "our"), a company duly incorporated in Hong Kong SAR, governing how we collect, use, store, share, and protect personal data in connection with your access to and use of the moove.xyz Platform and related services.

This Policy is ancillary to the Terms of Service, which govern your overall use of the Platform. In the event of any conflict or ambiguity, the Terms of Service shall prevail.

By accessing or using the moove.xyz Platform, you acknowledge that you have read, understood, and agreed to be bound by this Policy in full. If you do not agree to this Policy, you must not access or use the Platform.

## 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 such as the Ramp Services (defined below), and counterparties who interact with moove.xyz's services, whether directly or through third-party integrations.

1.2 This Policy does not apply to third-party websites, services, protocols, or Licensed Partners that may be linked to or integrated with the Platform. moove.xyz is not responsible for the privacy practices of such third parties, and your use of a Licensed Partner's regulated service may also be governed by that Licensed Partner's own privacy notice.

1.3 In this Policy, "Ramp Services" means the fiat on-ramp and fiat off-ramp functionality made available through the Platform and provided by independent, licensed third-party providers (each a "Licensed Partner"), and "regulated products" means products made available through the Platform that require identity verification to access. As at the date of this Policy, the only regulated product is the Ramp Services (Moove Ramp).

## 2. Our KYC-Free-by-Default Approach

2.1 moove.xyz is, by default, a non-custodial and KYC-free Platform. For the core functionality of the Platform — including sending, receiving, swapping, and staking digital assets through your self-custodied wallet — we do not collect or require government-issued identification, biometric data, or other sensitive identity information, and you remain in full control of your wallet and identity at all times.

2.2 In respect of that core functionality, we do not collect or store, and cannot access:

a. Wallet private keys, seed phrases, or passwords; \
b. Bank account or credit card numbers; or \
c. Government-issued identification or biometric identifiers.

2.3 Identity verification information is collected only where, and only for so long as, you choose to access a regulated product. As at the date of this Policy, that means only where you use the Ramp Services (Moove Ramp). If you do not use a regulated product, the categories of data described in Clause 4 (Identity Verification Data) do not apply to you. Where we do collect such data, we collect 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 unauthorised purpose.

## 3. Technical and Usage Data We May Collect

3.1 In order to operate and improve the Platform, moove.xyz may collect limited technical, usage, and contact data from all Users, including but not limited to:

a. Public blockchain 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. Business, personal, or operating 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.

## 4. Identity Verification Data (Regulated Products Only)

4.1 Where you choose to access a regulated product (currently the Ramp Services), and to enable moove.xyz and the Licensed Partners to comply with applicable anti-money laundering, counter-terrorist financing, counter-proliferation financing, sanctions, and "know your customer" ("KYC") laws and requirements, we collect and process 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. Biometric data, including a facial-geometry scan and related "liveness" data used to confirm that you are a real, present person and that you match your identification documents.

4.2 We collect this data directly from you and, where applicable, from identity-verification, sanctions-screening, and fraud-prevention service providers engaged to support the verification process.

4.3 We collect this data 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.

## 5. Roles: Data Controller and Processor

5.1 In respect of the Identity Verification Data described in Clause 4, moove.xyz acts as a data controller: we determine the purposes and means of processing that data for identity verification and compliance purposes. The relevant Licensed Partner may act as a separate or joint controller, and certain service providers act as our processors. Each Licensed Partner is responsible for its own processing of your data under the regulated service it provides to you.

5.2 We will only share Identity Verification Data with a Licensed Partner or service provider to the extent necessary to provide the regulated product, to complete verification and screening, or to comply with applicable law, and subject to appropriate contractual safeguards.

## 6. How We Use Your Data

6.1 moove.xyz may use the data described in this Policy for the following purposes:

a. To operate, maintain, and improve the Platform and its features; \
b. To verify your identity and eligibility to access regulated products, and to perform KYC, sanctions, politically-exposed-person, adverse-media, device, wallet, and transaction screening and ongoing monitoring (regulated products only); \
c. To provide the Ramp Services and other regulated products, including by transmitting the necessary information to the relevant Licensed Partner; \
d. To monitor usage patterns and detect, prevent, and investigate abuse, fraud, financial crime, or security threats; \
e. 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; \
f. To analyse performance and user engagement for product development; and \
g. To communicate with users regarding their account, verification status, transactions, and Platform updates.

6.2 We process your biometric 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 biometric data for any other purpose, do not use it for advertising or profiling, and do not sell it.

6.3 moove.xyz does not use your data for behavioural advertising, unsolicited marketing, or the sale of personal data.

6.4 We process data on one or more of the following legal grounds:

a. Compliance with a legal obligation (e.g. KYC, AML/CTF, sanctions, and record keeping requirements); \
b. Performance of a contract, or steps taken at your request prior to entering a contract (e.g. providing a regulated product you have requested); \
c. Your explicit consent (which we obtain separately for the collection and processing of biometric data, and which you may withdraw, subject to the consequence that you will no longer be able to access the regulated product); and \
d. Legitimate interests (e.g. fraud prevention, security, and Platform optimisation), where not overridden by your rights.

## 7. Sharing of Data

7.1 moove.xyz does not sell, rent, or trade your data to third parties.

7.2 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, sanctions and fraud screening, hosting, analytics, or infrastructure, under strict confidentiality and data-protection obligations; \
c. Regulatory, supervisory, tax, or law enforcement authorities, if required by applicable law, court order, or lawful request, including for AML/CTF, sanctions, and Travel Rule purposes; and \
d. Third-party protocols or integrations you choose to interact with, in which case your data is shared directly and voluntarily by you.

7.3 moove.xyz shall not be liable 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 the privacy policies of any Licensed Partner or third-party service you engage with.

## 8. Cookies and Tracking Technologies

8.1 moove.xyz uses cookies and similar technologies (such as local storage and pixels) to enhance your experience on the Platform. These technologies help us maintain session state and user preferences, enable core Platform functionality, and collect anonymised usage analytics to improve performance and usability.

8.2 Cookies may be set by moove.xyz ("first-party cookies") or by third-party services we use ("third-party cookies"). The types of cookies we may use include essential cookies (required for the Platform to function), performance cookies (anonymised usage data), and functional cookies (preferences and settings).

8.3 You may disable cookies through your browser settings, although doing so may impair certain features. moove.xyz does not use cookies for advertising, retargeting, or behavioural profiling.

## 9. Data Retention

9.1 moove.xyz retains data only for as long as necessary to fulfil the purposes outlined in this Policy or to comply with legal obligations.

9.2 You acknowledge that, where we collect Identity Verification Data and other records in connection with a regulated product, applicable AML/CTF and financial-crime laws and Licensed Partner requirements require us (and the Licensed Partner) to retain certain records for a minimum period after the end of your relationship with us or after a transaction (typically five (5) to seven (7) years, depending on the applicable jurisdiction). During that period we are legally unable to delete such records on request. We delete or anonymise this data once the applicable retention period expires and it is no longer required.

9.3 We retain biometric data only for as long as necessary to complete and, where required, evidence the verification, and we delete or irreversibly anonymise biometric source images and templates once they are no longer required for the permitted purpose or the applicable retention period, whichever is the shorter consistent with law.

9.4 Public blockchain data is immutable and may be permanently recorded on-chain. moove.xyz does not control or delete on-chain data.

## 10. Data Security

10.1 moove.xyz implements reasonable and 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 appropriate safeguards to sensitive data.

10.2 No system is completely secure. You acknowledge that you use the Platform and transmit data at your own risk.

10.3 You are solely responsible for securing your wallet, private keys, devices, and account credentials.

10.4 In the event of a data breach affecting your personal data, moove.xyz will notify affected users and the relevant regulators in accordance with applicable laws and within the timeframes they require.

## 11. International Data Transfers

11.1 moove.xyz 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.

11.2 Where we transfer personal data internationally, we apply appropriate safeguards as required by applicable data protection law. By using the Platform, you acknowledge that your data may be transferred to and processed in such jurisdictions.

## 12. Your Rights

12.1 Depending on your jurisdiction, you may have certain rights under applicable data protection laws, including:

a. The right to access the data we hold about you; \
b. The right to request correction or deletion of your data; \
c. The right to object to or restrict certain processing activities; \
d. The right to data portability; and \
e. The right to withdraw consent where processing is based on consent (including consent to biometric processing).

12.2 These rights are subject to legal limits. In particular, where we are legally required to retain Identity Verification Data and related records for AML/CTF or other regulatory purposes (see Clause 9.2), we may be unable to delete that data, or to stop processing it, until the applicable retention period expires. Withdrawing consent to biometric processing will prevent you from accessing the relevant regulated product.

12.3 To exercise any of these rights, please contact us at [legal@moove.xyz](mailto:legal@moove.xyz). We may request additional information to verify your identity, conducted securely and retained only as long as reasonably necessary.

## 13. Children's Privacy

13.1 The Platform is not intended for use by individuals under the age of eighteen (18). We do not knowingly collect data from minors.

13.2 If you believe a minor has provided us with personal data, please contact us immediately at [legal@moove.xyz](mailto:legal@moove.xyz).

## 14. Changes and Version Control

14.1 moove.xyz may update this Privacy Policy from time to time, including to reflect new regulated products or new Licensed Partners. Any changes will be published on this page and are effective upon publication.

14.2 Your continued use of the Platform constitutes your acceptance of the updated Policy. No individual notice will be provided, save where individual notice is required by applicable law (for example, in respect of material changes to the processing of sensitive or biometric data).

14.3 This versioning approach is consistent with Clause 13 of the Terms of Service, which governs updates to Platform policies.

## 15. Governing Law and Jurisdiction

15.1 This Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region.

15.2 You agree that the courts of Hong Kong SAR shall have exclusive jurisdiction to resolve any dispute or claim arising out of or in connection with this Policy or your use of the Platform. This clause is subject to Clause 15 of the Terms of Service, which governs dispute resolution and arbitration.

## 16. Contact Information

16.1 If you have any questions, concerns, or requests regarding this Privacy Policy, you may contact us at [legal@moove.xyz](mailto:legal@moove.xyz).