Privacy Policy

1. Introduction

Control Money (“Control Money”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, store and protect your personal information when you:

• visit our website;
• use our mobile application;
• create an account;
• complete identity verification;
• invest using our platform;
• communicate with us; or
• otherwise use our services.

This Privacy Policy applies to all products and services offered by Control Money unless a separate privacy notice applies.

By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

2. Scope

This Privacy Policy applies to:

• prospective users;
• registered users;
• website visitors;
• customers;
• authorised representatives;
• beneficial owners;
• business partners where applicable.

3. Information We Collect

We collect information directly from you, automatically through your use of the Platform, and from trusted third parties.

A. Identity Information

This may include:

• full legal name;
• date of birth;
• nationality;
• PAN;
• Aadhaar (where legally permitted);
• passport details;
• driver’s licence;
• government-issued identification;
• photograph;
• selfie;
• video verification;
• signature.

B. Contact Information

• email address;
• mobile number;
• residential address;
• correspondence address.

C. Financial Information

• bank account details;
• payment history;
• deposits;
• withdrawals;
• investment history;
• transaction records;
• portfolio balances;
• yield history.

D. Compliance Information

• KYC documents;
• AML verification records;
• sanctions screening;
• politically exposed person (PEP) checks;
• source of funds;
• source of wealth (where applicable);
• tax residency;
• tax identification numbers.

E. Technical Information

We automatically collect:

• IP address;
• browser type;
• operating system;
• device identifiers;
• session information;
• crash reports;
• cookies;
• advertising identifiers (where permitted);
• app analytics.

F. Blockchain Information

Because certain transactions occur on public blockchain networks, we may collect:

• wallet addresses;
• blockchain transaction hashes;
• smart contract interactions;
• supported token balances;
• blockchain timestamps.

Information recorded on public blockchains may be permanently accessible.

4. How We Collect Information

We collect information:

• directly from you;
• during onboarding;
• during KYC;
• when you use our Services;
• from payment partners;
• from blockchain analytics providers;
• from identity verification providers;
• from banking partners;
• from public databases;
• from regulators where legally permitted.

5. Why We Use Your Information

We use personal information to:

• create and manage accounts;
• verify identity;
• comply with AML/KYC obligations;
• prevent fraud;
• process deposits and withdrawals;
• facilitate investments;
• manage wallets;
• calculate yield;
• provide customer support;
• improve products;
• secure the Platform;
• detect suspicious activity;
• comply with legal obligations;
• respond to regulators;
• conduct internal analytics.

6. Legal Basis for Processing

Depending on your jurisdiction, we process information because:

• it is necessary to perform our contract with you;
• we have legal obligations;
• we have legitimate business interests;
• you have provided consent where required;
• it is necessary to protect vital interests or prevent fraud.

7. Sharing Your Information

We may share your information with:

• Identity Verification Providers - to verify your identity.
• Banking & Payment Partners - to process deposits and withdrawals.
• Wallet Infrastructure Providers - to create and maintain digital wallets.
• Custodians - to safeguard digital assets.
• Liquidity Providers - to execute trades.
• Blockchain Analytics Providers - to detect fraud and financial crime.
• Cloud Service Providers - to securely host our infrastructure.
• Professional Advisers - including lawyers, auditors and accountants.
• Regulators & Government Authorities - where required by law.

8. International Data Transfers

Control Money operates globally.

Your information may be transferred to jurisdictions outside your country of residence.

Where required by law, we implement appropriate safeguards for international transfers, including contractual commitments and technical security measures.

9. Cookies & Similar Technologies

We use cookies and similar technologies to:

• remember preferences;
• maintain login sessions;
• improve website performance;
• understand user behaviour;
• enhance security.

Users may manage cookie preferences through browser settings, although disabling certain cookies may affect Platform functionality.

10. Marketing Communications

Where permitted by law, we may send information regarding:

• product updates;
• educational content;
• platform announcements;
• new investment opportunities;
• promotions.

You may opt out of marketing communications at any time.

Operational and security communications cannot generally be opted out of.

11. Automated Decision-Making

We may use automated systems to:

• verify identity;
• assess fraud risk;
• detect suspicious transactions;
• perform sanctions screening;
• monitor unusual activity.

Where required by Applicable Law, Users may request human review of significant automated decisions.

12. Data Security

We implement industry-standard security measures, including:

• encryption in transit and at rest;
• role-based access controls;
• multi-factor authentication;
• security monitoring;
• penetration testing;
• vulnerability assessments;
• disaster recovery procedures;
• incident response plans.

While we strive to protect your information, no electronic system can guarantee absolute security.

13. Data Retention

We retain personal information only for as long as necessary to:

• provide the Services;
• comply with Applicable Law;
• satisfy AML and financial record-keeping requirements;
• resolve disputes;
• prevent fraud;
• enforce our agreements.

Where possible, information will be securely deleted or anonymised after the applicable retention period.

14. Your Privacy Rights

Subject to Applicable Law, you may have the right to:

• access your personal information;
• correct inaccurate information;
• request deletion;
• withdraw consent;
• object to certain processing;
• request portability;
• request restriction of processing.

Some requests may be declined where legal or regulatory obligations require continued processing.

15. Children’s Privacy

The Platform is not intended for persons below the age of eighteen (18), or such higher minimum age as required under Applicable Law.

We do not knowingly collect personal information from children.

16. Third-Party Services

Our Platform may integrate with third-party services.

This Privacy Policy does not apply to third-party websites or services.

Users should review the privacy policies of those third parties before using their services.

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Material changes will be communicated through:

• the Platform;
• email;
• in-app notifications; or
• other appropriate communication channels.

The latest version will always be available on our website.

18. Contact Us

For privacy-related questions or requests, you may contact:

Email: compliance@control.money

19. Grievance Officer (India)

In accordance with applicable Indian law, Control Money shall designate a Grievance Officer.

The following details will be published before launch:

• Name
• Email
• Office Address
• Contact Number
• Complaint Resolution Timeline

20. Regulatory Compliance

This Privacy Policy is intended to operate alongside applicable privacy and financial services laws, including, where applicable:

• India’s Digital Personal Data Protection Act, 2023;
• the Information Technology Act, 2000 and related rules;
• the Prevention of Money Laundering Act, 2002;
• applicable tax and financial reporting obligations; and
• other data protection laws applicable in jurisdictions where Control Money operates.

Where there is any inconsistency between this Privacy Policy and mandatory legal requirements, the mandatory legal requirements shall prevail.