Privacy Policy

This Privacy Policy explains how Movia Technologies Inc. (“Movia”, “we”, “us” or “our”) collects, uses, shares and protects personal data when you use the Movia mobile app, the website at www.movia.app and related services (the “Services”). It should be read together with our Terms and Conditions.

Movia Technologies Inc. is a company registered in Wyoming, United States, with its registered address at 1309 Coffeen Avenue STE 1200, Sheridan, Wyoming 82801 and its office at 2201 Broadway, Oakland, California 94612.

Movia is the controller of the personal data described here, except where a Partner, such as our card issuer, acts as a controller in its own right under its own privacy notice. You can contact us about privacy at any time at info@movia.money.

Account and sign-in. Your name and email address, and the one-time codes we send to confirm it. If you sign in with Apple or Google, we receive your name, email address and an account identifier from that provider.

Profile. Your full name and an optional profile photo, which are shown to members of your trips.

Identity verification. Your legal name, date of birth, nationality, address, identity document images and details, a selfie or short video, and the facial geometry derived from them to confirm that the document is yours and that you are present (see Biometric data). We also receive the outcome of sanctions, politically exposed person and adverse media screening.

Financial profile. Your occupation, annual income, the purpose of your account and your expected monthly spending, which our card and wallet Partner requires before opening an account.

Trips. Trip names, dates and destinations, who you invite and who joins, and your role as organizer or member.

Payments and transactions. Contributions you make and request, balances, card transactions (amount, currency, merchant, date and status), withdrawals, wallet addresses and bank details used for funding or returns.

Device and usage. Your IP address, browser or device type and operating system, sign-in sessions, and security logs.

Preferences. Notification choices, language, region and appearance settings.

Communications. Messages you send us and our replies. If you join the waitlist on our website, your email address.

We do not access your contacts or precise location. If you unlock the app with Face ID, Touch ID or a device passcode, that check happens on your device and we never receive the biometric data it uses.

Most personal data comes from you. We also receive it from our identity verification provider, our card and wallet Partner, banks and payment networks, Apple or Google when you sign in with them, and other members of your trips, for example when an organizer invites you or a member requests money from you.

Where data protection laws such as the GDPR or UK GDPR apply, we rely on the following legal bases.

• To provide the Services (performance of our contract with you): creating your account, running trips, pooling contributions, operating the trip card, processing withdrawals, sending service messages and providing support.
• To meet legal obligations: verifying your identity, anti-money-laundering and counter-terrorist-financing checks, sanctions screening, keeping records, reporting suspicious activity and responding to lawful requests from authorities.
• For our legitimate interests, balanced against your rights: keeping the Services secure, preventing and investigating fraud, fixing problems, improving the Services, and establishing or defending legal claims.
• With your consent: processing biometric data where the law requires consent, optional notifications, and adding you to the waitlist. You can withdraw consent at any time; this does not affect processing that already took place.

We do not sell your personal data, and we do not share it for cross-context behavioural advertising.

Identity verification is carried out for us by Sumsub (Sum and Substance Ltd), a specialist identity verification provider. When you verify, Sumsub captures your identity document and a selfie or short video, and compares the face in each to confirm the document belongs to you and that you are a real person present at the time. This comparison creates biometric data (facial geometry), which is a special category of personal data in many countries.

• We and Sumsub use biometric data only to verify your identity, meet our legal obligations and prevent fraud. It is never used for advertising, and it is never sold, leased or traded.
• Before capture, we ask for your explicit consent where the law requires it, including under the GDPR, the UK GDPR and the biometric privacy laws of US states such as Illinois, Texas and Washington.
• Biometric data is kept only as long as needed for verification, fraud prevention and legal record-keeping, and is permanently destroyed when that purpose is satisfied, or within three years of your last interaction with us, whichever comes first, unless a law or court order requires us to keep it longer.
• Sumsub processes this data under contract with us and applies its own security safeguards. Its privacy notice is available on its website.

Verification results may be automated. If an automated check means you cannot open an account, you can ask for a person to review the decision, explain your point of view and contest it by emailing info@movia.money.

We share personal data only as needed for the purposes above, with:

• Our identity verification provider, Sumsub, to verify your identity and screen against sanctions and other lists.
• Our card and wallet Partner, Rain, and the banks, card networks and payment processors it works with, to open your account, issue and run the trip card, and move funds.
• Other members of your trips, who see your name, profile photo, contributions and trip spending.
• Service providers who host our systems, deliver email, collect waitlist sign-ups and provide sign-in with Apple or Google, under contracts that limit their use of your data.
• Professional advisers, such as lawyers, auditors and insurers.
• Regulators, law enforcement and courts, where the law requires it or to protect the rights, property or safety of our users, Movia or others.
• A buyer or successor, if Movia is involved in a merger, acquisition or sale of assets, subject to this Policy.

Our Partners and service providers may process personal data outside the country where you live, including in the United States, the United Kingdom and the European Economic Area. When we transfer personal data out of the UK or the EEA to a country without an adequacy decision, we use safeguards recognised by law, such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum. You can ask us for a copy of these safeguards.

We keep personal data only as long as we need it:

• Account, profile, trip and preference data: while your account is open, then deleted or anonymised within 90 days of closure, unless one of the periods below applies.
• Identity verification, transaction and AML records: for at least five years after our relationship ends, or longer where the law requires.
• Biometric data: as set out in Biometric data.
• Security logs and sessions: sessions expire automatically; logs are kept for as long as needed to keep the Services secure.
• Waitlist sign-ups: until launch or until you ask us to remove you.

We use technical and organisational measures to protect personal data, including encryption in transit, access controls limited to staff who need the data, secure credential storage on your device, and contracts that require our providers to do the same. No system is completely secure, so please keep your device and sign-in details safe and tell us at info@movia.money if you suspect unauthorised access.

Depending on where you live, you may have the right to:

• access the personal data we hold about you and get a copy;
• correct inaccurate or incomplete data;
• have your data deleted;
• restrict or object to how we use it;
• receive your data in a portable format;
• withdraw consent where we rely on it; and
• not be subject to a decision based solely on automated processing that significantly affects you.

Some rights are limited by law. For example, we must keep identity verification and transaction records for a set period even if you ask us to delete them, and we will tell you when that applies.

UK and EEA. You can complain to your local data protection authority, such as the Information Commissioner’s Office in the UK or the supervisory authority where you live in the EEA. We would appreciate the chance to address your concern first.

United States. Residents of California and other states with consumer privacy laws have the right to know what personal data we collect, use and disclose, and to access, correct and delete it. We do not sell or share personal data for targeted advertising, and we use sensitive personal data, such as identity documents and biometric data, only for the purposes permitted by those laws. We will not discriminate against you for exercising your rights. You may use an authorised agent, and if we decline your request you may appeal by replying to our decision.

To exercise any right, email info@movia.money from the address linked to your account. We may need to verify your identity first, and we will respond within the time the law requires, usually one month.

Our website and app use only the cookies and on-device storage needed to keep you signed in, remember your preferences and keep the Services secure. We do not use advertising cookies or third-party advertising trackers.

Our website uses PostHog to count visits and waitlist sign-ups in cookieless mode: it sets no cookies, stores nothing on your device and identifies visitors only by a hash that changes daily, so visits cannot be linked to you. If we introduce analytics that store data on your device, we will update this Policy and ask for your consent where the law requires it.

The Services are not intended for anyone under 18, and we do not knowingly collect personal data from children. If you believe a child has given us personal data, contact info@movia.money and we will delete it.

We may update this Policy from time to time. We will show the date of the latest version at the top of this page, and if a change materially affects how we use your personal data, we will tell you in the app or by email before it takes effect.

For questions about this Policy or to exercise your rights, email info@movia.money. You can also write to Movia Technologies Inc., 2201 Broadway, Oakland, California 94612.