Privacy policy

A conversion platform cannot run without identity data: anti-money-laundering rules require it from the first euro converted. The honest question is therefore not “do you collect data”, but which data, why, for how long, and who else sees it.

The controlling entity is being incorporated. Its legal name, legal form and registered address will be published on the legal notice page as soon as they are verifiable. In the meantime, the contact address below is the single entry point for any request about your data, and it is already live.

No data protection officer is appointed to date. Will one be? Yes: large-scale processing of identity data in a regulated setting makes the appointment necessary. Until it is effective we do not pretend otherwise, and requests are handled through the address below.

Every piece of data collected is data to protect, to retain, to delete at the right time and to hand back on request. The product is built to ask for as little as possible, as late as possible.

• Quoting is public: you get a net amount with the fee breakdown, with no account and no email address.
• Identity verification is asked for at the tier where it becomes mandatory, not at sign-up.
• No advertising tracker is set, and no browsing data is sold or shared for commercial purposes.
• Bank details are encrypted and stripped from application logs: they never appear in clear text in a log line.

Every processing activity rests on an identified legal basis. This is more than a formality: the basis determines which rights you hold. Data processed under a legal obligation cannot be erased on request while the mandated period runs; data processed under our legitimate interest can be objected to on reasoned grounds.

We keep nothing “by default”. Each category has a period, a deletion trigger and an automatic purge at term.

We rely on processors for hosting, transactional email and SMS delivery, identity verification, deposit address risk analytics and payment execution. Each acts on documented instructions, under a contract compliant with Article 28 GDPR.

The named list of these processors is not published while the contracts are unsigned. We prefer an accurate category to a vendor name displayed to look established: publishing the name of a partner with whom nothing is contracted would be a false statement, and that is exactly what this site refuses to do.

The list will be published here, name by name, role by role, with the location of processing, as soon as the service goes live. Any later addition will trigger a version update of this document.

Two activities structurally involve a transfer outside the Union: identity verification, whose vendors often operate from the United Kingdom or the United States, and payout execution on local rails outside Europe — PIX in Brazil, M-Pesa in Kenya, NIP in Nigeria. Sending money to Kenya means passing the beneficiary’s name and number to a Kenyan institution: that is the material condition of the payment.

What frames those transfers

• An adequacy decision of the European Commission where one exists for the country concerned.
• Failing that, the Commission’s standard contractual clauses, together with a transfer impact assessment taking local government access law into account.
• Additional technical measures: minimising the fields transmitted, encryption in transit and at rest, per-corridor segregation.
• No transfer of convenience: if a purpose can be served from inside the Union, it is.

You may request a copy of the safeguards applying to a specific transfer. We then provide the mechanism used and the destination country, without the commercial clauses of the contract.

A privacy policy that lists seven rights without saying which one hits which wall helps nobody. Here are the rights and, for each, the limit that actually applies in our context.

1. Write to the privacy contact address from the email address linked to your account, or from your account area.
2. We verify your identity. Where reasonable doubt exists we ask for one additional verification element — never a fresh copy of an identity document if we already hold a valid one.
3. We answer within 30 days. Where the request is complex or multiple, that period may be extended by 2 months, and we tell you with the reason before the initial deadline.
4. The answer is free. A manifestly unfounded or repetitive request may lead to a reasoned refusal, never to a silent charge.

If our answer does not satisfy you, you may lodge a complaint with the supervisory authority of your country of residence. That route is open unconditionally and without having to tell us first.

Three checks are automated and can have a direct effect on you: matching your name against sanctions lists, document-based identity verification, and deposit address risk analytics. A match or a failure can suspend an order with no prior human involvement.

You can always ask for a human review. An analyst then reopens the file, you can put your case, and the initial decision can be reversed. The only situation where the detailed reason cannot be shared with you is a reported suspicion: the law then forbids us from discussing it.

Encryption in transit and at rest, environment segregation, least-privilege access, logging of every access to a verification file, mandatory second factor for internal access. The technical measures are described in detail on the dedicated page.

In the event of a personal data breach likely to create a risk to your rights, we notify the supervisory authority within 72 hours and inform you directly where the risk is high. We also publish a post-incident note, even where individual notification is not required.

No advertising tracker, no social network pixel and no audience measurement tool is installed today. The only cookies set without your consent are those that make the site work: the language, the session, and the record of your cookie choice.

The service is not intended for minors and identity verification checks the date of birth. If we find that an account was opened by a minor, it is closed and the associated data deleted, subject to the records regulation requires us to keep.

Any substantive change — a new purpose, a new recipient, a new transfer outside the Union — gets a new version number, an entry in the history at the foot of this page, and direct notice if you hold an account. We do not change a purpose silently.