Privacy Notice

How Monida collects, uses, and protects your information.

MONIDA PAYMENT CORPORATION

Effective Date: October 15, 2026 | Version: 3

1810 E Sahara Ave, Ste 75048, Las Vegas, NV 89104 | contact@monida.app

Your privacy matters to us. This Privacy Notice explains what information Monida collects from you, how we use it, who we share it with, and the choices you have.

1. About This Notice and Our Company

Monida Payment Corporation ("Monida," "we," "us," or "our") is a Delaware corporation registered to do business in California, with its principal place of business at 1810 E Sahara Ave, Ste 75048, Las Vegas, NV 89104. This Privacy Notice applies to all individuals who use our cross-border remittance platform, including our mobile application, website, and related services (collectively, the "Services").

This Privacy Notice is incorporated by reference into our User Agreement. Defined terms used here but not defined herein have the meanings given in our User Agreement. By using the Services, you acknowledge that you have read and understood this Privacy Notice and consent to the practices described herein.

We may update this Privacy Notice from time to time. We will notify you of material changes by email or through the Platform before the changes take effect. The "Effective Date" above indicates when the most recent version took effect.

2. Information We Collect

Because Monida provides regulated financial services (money transmission), we are required by law to collect certain personal and financial information from you. The information we collect falls into the categories described below.

2.1 Information You Give Us Directly

When you register, use the Services, or contact us, you may provide:

Identity Information: Full legal name, date of birth, government-issued ID number (e.g., passport, state ID, driver's license number), and a copy of that ID document;
Contact Information: U.S. home address, mobile phone number, and email address;
Recipient Information: Name, bank account details, mobile wallet number, or other delivery information for the person receiving your transfer;
Transaction Information: Amount sent, destination country and currency, transfer instructions, and payment confirmation details;
Customer Support Communications: Records of your inquiries, complaints, and correspondence with our support team; and
Optional Profile Information: Language preference, profile nickname, or other information you voluntarily add to your account.

2.2 Information Generated by Your Use of the Services

When you access or use the Platform, we automatically collect:

Device Information: Device type, operating system, browser type, and unique device identifiers;
Log and Usage Data: IP address, access timestamps, pages or screens viewed, session duration, and navigation paths within the Platform;
Location Information: Approximate geographic location derived from your IP address. If you grant permission, the Platform may access your device's precise GPS location to help identify nearby Incomm retail locations; and
App Interaction Data: Button taps, feature usage, and in-app navigation patterns used to improve the Platform.

2.3 Information From Third Parties

Monida may receive information about you from third-party sources, including:

Identity Verification Providers: Third-party services that help us verify your identity and document authenticity as required by law;
Fraud Prevention and Compliance Providers: Data brokers and screening services that help us detect fraud, money laundering, and sanctions exposure;
Incomm and Retail Partners: Confirmation of cash payment receipt from authorized retail locations; and
Regulatory Databases: Government and law enforcement databases we are required or permitted to consult for compliance purposes.

3. How We Use Your Information

Monida uses the information we collect for the following purposes:

3.1 Providing and Operating the Services

Processing, confirming, and completing money transfers;
Verifying your identity and the identity of recipients as required by law;
Communicating with you about your account and transactions;
Sending transaction confirmations, receipts, and status updates; and
Providing customer support and resolving disputes.

3.2 Legal and Regulatory Compliance

Complying with federal and state money transmission laws and regulations;
Conducting anti-money laundering (AML) and counter-terrorism financing (CTF) screening;
Screening against OFAC and other government sanctions lists;
Filing Currency Transaction Reports (CTRs), Suspicious Activity Reports (SARs), and other required regulatory reports;
Responding to lawful requests from law enforcement or government agencies; and
Retaining records as required by applicable law.

3.3 Security and Fraud Prevention

Detecting, investigating, and preventing fraud, unauthorized access, and other illegal activity;
Monitoring transactions for suspicious patterns; and
Protecting the security and integrity of the Platform and user accounts.

3.4 Improving the Platform

Analyzing usage patterns to improve the functionality and user experience of the Platform;
Diagnosing and fixing technical issues; and
Developing new features or services.

3.5 Communications and Marketing

Sending you service-related notifications (such as transaction alerts, policy updates, and security notices); and
Sending you promotional communications about Monida's products and services, where you have opted in or where permitted by applicable law. You may opt out of marketing communications at any time. Promotional communications are sent by email only. We do not send promotional text messages.

4. How We Share Your Information

Monida does not sell your personal information. We share your information only in the following circumstances:

4.1 Service Providers and Partners

We share information with third-party companies that help us operate the Services, including:

Identity verification and fraud detection providers;
Payment processors and licensed money transmitters who execute the transfer;
Incomm and its affiliated retail network for cash payment processing;
Cloud hosting, data storage, and IT infrastructure providers;
Customer support platform providers; and
Communications providers (for SMS and email notifications), which act solely on our behalf and may not use the information for their own purposes.

All service providers are contractually required to protect your information and use it only for the purposes we specify.

4.2 Recipient Financial Institutions

To complete your transfer, we share the required information with the recipient's bank, mobile wallet provider, or cash payout location in the destination country. This may include your name, the amount sent, and a transaction reference number.

4.3 Legal and Regulatory Disclosures

We may disclose your information when required by law or regulation, including:

In response to lawful subpoenas, court orders, or government requests;
To comply with federal and state money transmission reporting requirements;
To prevent or investigate fraud, money laundering, or other illegal activity; or
To protect the rights, property, or safety of Monida, our users, or the public.

4.4 Business Transfers

If Monida is involved in a merger, acquisition, restructuring, or sale of all or a portion of its assets, your information may be transferred as part of that transaction.

We will notify you of any such change and the choices available to you.

4.5 With Your Consent

We may share your information with additional third parties when you have given us your explicit consent to do so. This section does not apply to mobile information or SMS opt-in and consent data, which is never shared with third parties or affiliates for marketing or promotional purposes (see Section 12).

5. Data Retention and Deletion

5.1 Retention Periods

Monida retains your personal information for as long as necessary to provide the Services and fulfill the purposes described in this Privacy Notice, and as required by applicable law. Because Monida is a regulated money services business (MSB), federal law generally requires us to retain transaction records and identity documents for a minimum of five (5) years from the date of the transaction or account closure.

After the applicable retention period expires, we will securely delete or anonymize your personal information unless a longer retention period is required or permitted by law.

5.2 Account Closure

If you close your Monida account, we will retain your information for the legally required retention period and then delete or anonymize it. Closing your account does not result in immediate deletion of your information where retention is required by law.

6. Your Rights and Choices

Depending on where you live, you may have certain rights regarding your personal information. We honor these rights to the extent required by applicable law.

6.1 Access and Correction

You may request access to the personal information we hold about you and ask us to correct any inaccuracies. You can update basic account information directly through the Platform. For additional requests, contact us at contact@monida.app.

6.2 Deletion

You may request that we delete your personal information. We will honor such requests to the extent permitted by law. Please note that we are required by federal law to retain certain records for a minimum of five (5) years, and we cannot delete information that is subject to legal holds, ongoing investigations, or mandatory regulatory retention.

6.3 Marketing Opt-Out

You may opt out of receiving marketing communications from us at any time by clicking the "unsubscribe" link in any marketing email, or by contacting us at contact@monida.app. We may still send you transactional and service-related communications even if you opt out of marketing.

6.4 Location Data

You can disable precise location access at any time through your device settings. Note that disabling location access may affect certain Platform features, such as the ability to locate nearby Incomm retail locations.

6.5 Push Notifications

You can manage push notification preferences through your device settings.

6.6 Data Portability

Where required by applicable law, you may request a copy of your personal information in a structured, commonly used, and machine-readable format.

7. Security Measures

Monida uses administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit using TLS protocols, encryption of sensitive data at rest, access controls limiting who within Monida can access personal information, regular security assessments and monitoring, and employee training on data protection and information security best practices.

No security system is completely impenetrable. If you suspect that your account has been compromised or that your personal information has been accessed without authorization, please contact us immediately at contact@monida.app.

8. Children's Privacy

The Services are intended for individuals who are eighteen (18) years of age or older. Monida does not knowingly collect personal information from individuals under the age of 18. If we learn that we have collected personal information from a minor, we will delete that information promptly. If you believe we may have collected information from a minor, please contact us at contact@monida.app.

9. International Data Transfers

To complete your international money transfers, Monida must share certain information with service providers and financial institutions located in destination countries, including Mexico, Guatemala, and other countries where we operate. These countries may have data protection laws that differ from the laws of the United States.

When we transfer information internationally, we take reasonable steps to ensure that appropriate safeguards are in place, including requiring recipient parties to protect information using commercially reasonable security measures and using it only as needed to complete your transfer. By using the Services, you acknowledge and consent to the international transfer of your information as necessary to complete your requested transactions.

10. California Privacy Rights (CCPA/CPRA)

This section applies to California residents only and supplements the rest of this Privacy Notice.

10.1 Categories of Personal Information Collected

In the past twelve (12) months, Monida has collected the following categories of personal information from California residents, as defined by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Identifiers: Name, address, email, phone number, IP address, government ID number;
Personal Records (Cal. Civ. Code 1798.80): Name, address, ID number, bank account details;
Commercial Information: Transaction history and transfer records;
Internet or Electronic Network Activity: Usage data, log data, device information;
Geolocation Data: Approximate or precise location (where permitted); and
Sensitive Personal Information: Government ID numbers and financial account information.

10.2 Purposes of Collection

We collect and use this information for the business purposes described in Section 3 of this Privacy Notice, including providing the Services, complying with legal obligations, fraud prevention, and improving the Platform.

10.3 Sensitive Personal Information

Monida collects certain "sensitive personal information" as defined by the CPRA (including government identification numbers and financial account information). We use this information only for the purposes of providing the Services and complying with our legal obligations under applicable money transmission law. We do not use sensitive personal information for purposes of inferring characteristics about consumers.

10.4 Sale and Sharing of Personal Information

Monida does not sell personal information within the meaning of the CCPA/CPRA. We do not share personal information with third parties for cross-context behavioral advertising purposes.

10.5 Your California Privacy Rights

California residents have the following rights under CCPA/CPRA, subject to certain exceptions:

Right to Know: The right to request that Monida disclose the categories and specific pieces of personal information we have collected about you, the purposes for collection, and the categories of third parties to whom we have disclosed it;
Right to Delete: The right to request deletion of personal information we have collected about you, subject to legal exceptions;
Right to Correct: The right to request correction of inaccurate personal information;
Right to Opt Out of Sale/Sharing: The right to opt out of the sale or sharing of your personal information (Monida does not sell or share personal information for advertising purposes);
Right to Limit Use of Sensitive Personal Information: The right to limit use of sensitive personal information to specific permitted purposes (Monida already limits its use as described above); and
Right to Non-Discrimination: Monida will not discriminate against you for exercising any of the rights described above.

10.6 How to Exercise Your California Rights

To exercise your California privacy rights, submit a verifiable consumer request to us at:

Email: contact@monida.app
Mail: Monida Payment Corporation, 1810 E Sahara Ave, Ste 75048, Las Vegas, NV 89104

We will respond to your verifiable request within forty-five (45) days of receipt, with an extension of up to an additional forty-five (45) days where necessary, as permitted by law. You may designate an authorized agent to make requests on your behalf. We will require verification of both the agent's authority and your identity before processing such requests.

10.7 Retention Schedule (California)

We retain each category of personal information collected from California residents for the period described in Section 5.1 of this Privacy Notice, or as required by applicable law.

11. Third-Party Links and Services

The Platform may contain links to third-party websites or services. This Privacy Notice does not apply to those third-party sites, and Monida is not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party site or service you visit.

12. SMS Messaging and Mobile Information

When you provide your mobile phone number, you consent to receive SMS text messages from Monida containing one-time verification codes (two-factor authentication) and account and transaction security alerts. We send a verification code when we need to confirm it is you, for example to verify your mobile number when you sign up, on a new device, for a higher-risk transfer, when you change your credentials, or when you recover your account. We use your mobile number only to verify your identity, protect your account, and send these service messages.

Message frequency varies based on your account activity. Message and data rates may apply. Reply STOP to opt out at any time, or HELP for help. Verifying your mobile number when you sign up requires a text message. On a device you have already registered, we may verify you by push notification instead of a text message, with a text message as a fallback. If you reply STOP, we will stop texting your number, and some actions (such as verifying your mobile number, signing in on a new device, or recovering your account) may be limited or unavailable. You may also contact us at contact@monida.app or +1 951 448 0010.

We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with or sold to any third parties or lead generators. We may share mobile information only with service providers (such as our SMS delivery provider) acting on our behalf solely to deliver these messages; they may not use it for any other purpose.

13. Contact Us and Privacy Inquiries

If you have questions, concerns, or complaints about this Privacy Notice or our data practices, or if you want to exercise your privacy rights, please contact our Privacy team at:

Monida Payment Corporation — Privacy Team

1810 E Sahara Ave, Ste 75048

Las Vegas, NV 89104

Email: contact@monida.app

Phone: +1 951 448 0010