Privacy Policy

Your privacy is important to us at muno. We respect your privacy regarding any information we may collect from you across our website and mobile application. muno, operated by Boldswitch LTD (also referred to as "muno," "we," "us," or "our"), takes steps to protect your privacy. In this Privacy Notice ("Notice"), we describe the types of personal information we may collect from you in connection with your use of our websites including muno.ng, the muno wallet, our crypto-to-fiat platform, mobile application, social media pages, or other online properties (collectively, the "Website"), or when you use any of the products, services, content, features, technologies, or functions we offer (collectively, the "Services"). This Notice is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Website and Services. Please note that our Service offerings may vary by region. For all purposes, the English language version of this privacy notice shall be the original, governing instrument.

We collect information that relates to you ("Personal Data") in connection with your use of the Website, our Services, or otherwise in the context of our relationship with you. The types of Personal Data that we may obtain from you may include: Biographical Data, including: • Full name • Email address • Physical address • Phone number • Country of residence • Date of birth muno Account Details, including: • Profile picture • Account creation date • Default currency • Linked bank account details • BVN (Bank Verification Number) • NIN (National Identification Number) muno Account Activity, including: • Transaction history • Swap activity (crypto sent, NGN received) • Account notifications • Account status Data relating to your Digital Asset wallet, including: • Deposit wallet addresses (generated per session) • Wallet balances • Transactions received • Transactions sent Data Collected in connection with Know Your Customer (KYC) Compliance, including: • Government-issued ID (BVN / NIN) • Proof of identity verified via third-party KYC providers • Photographs, if you elect to provide them Device and Website Usage Data, including: • IP addresses • Cookie ID and/or other device identifiers • Device characteristics, date & time of access • Language preferences • Information on actions taken while using the Website Mobile Application Usage Data, including: • Session data: IP address, OS version, device brand and model, unique device identifiers, browser used, time of access, network connection details • Cookie ID and/or other device identifiers • Crash and application error diagnostics data • Information on actions taken while using the mobile application

The business purposes for which we collect, use, retain, and share your Personal Data may include: To provide Services through operating the Website, including to: 1. Register, create, and maintain your account 2. Authenticate your identity and/or your access to an account 3. Initiate, facilitate, process, and/or execute crypto-to-fiat conversion transactions 4. Communicate with you regarding your account or any Services you use 5. Perform KYC, creditworthiness, or other similar reviews 6. Evaluate applications and account eligibility 7. Compare information for accuracy and verification purposes To manage risk and protect you and other users: 8. To manage risk and protect you, other persons, and the Website and Services 9. To provide a personalized experience and implement your preferences 10. To better understand customers and how they use and interact with the Services For marketing and business purposes: 11. To market to you and provide personalized offers and promotions 12. To provide you with location-specific options, functionalities, and offers 13. To comply with our policies and obligations, including disclosures and responses to requests from law enforcement authorities and/or regulators in accordance with any applicable Nigerian law, rule, regulation, or judicial order 14. To resolve disputes, collect fees, or troubleshoot problems 15. To provide customer service and communicate with you 16. To manage our business and support audit, compliance, and corporate governance functions We may also process Personal Data for other purposes based upon your consent when required by applicable law.

We collect Personal Data from a number of sources, including: • Directly from you: We collect Personal Data directly from you when you use our Website or Services, communicate with us, or interact directly with us. • From service providers and/or data processors who assist us in providing the Website or the Services: We may engage service providers to assist us in facilitating the Website or the Services to you, at our direction and on our behalf. • From third-party KYC and identity verification providers who help us verify identity, prevent fraud, and protect the security of transactions. • From third-parties who help us evaluate your financial standing, assess risk, or prevent money laundering and other financial crimes. • From third-parties who help us analyze Personal Data, improve the Website or the Services, market products or services, or provide promotions and offers to you. • From social media platforms, if you interact with us through social media or use social login features. • From financial institutions and payment processors connected to your linked Nigerian bank accounts.

Under certain circumstances, we may disclose certain Personal Data with other persons. The categories of persons with whom we may share Personal Data include: • Service providers and/or data processors: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These may include identity verification, transaction processing, fraud prevention, and customer support providers. • Financial institutions and payment processors: We share necessary information with Nigerian banks and payment networks involved in processing your NGN payouts. • Affiliates and business partners: We may share information with affiliates that receive referrals from our Website. • Other third-parties for our business purposes or as permitted or required by applicable Nigerian law, including: — To comply with any legal, regulatory or contractual obligation, or with any legal or regulatory process (such as a valid court order or subpoena) — To establish, exercise, or defend legal claims — In response to a request by a government agency, such as law enforcement authorities, the CBN, SEC, EFCC, or other Nigerian regulatory bodies — To enforce our Terms of Service or internal policies — To prevent physical harm or financial loss, in connection with an investigation of suspected or actual illegal activity — To protect our or others' rights, property, or safety — To facilitate a purchase or sale of all or part of muno's business

Please note that we may transfer Personal Data we collect about you to countries other than Nigeria. Those countries may not have the same data protection laws as Nigeria. When we transfer your Personal Data to other countries, we take steps designed to ensure that the transfer is in accordance with applicable law, including the Nigeria Data Protection Act (NDPA) and any other applicable Nigerian data protection regulations. We will always ensure appropriate safeguards are in place to protect your Personal Data during any international transfer.

A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. Our Website uses cookies and tracking technologies to operate, and to target advertising that may be of interest to you. You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Website, but your ability to use some features or areas of our Website may be limited. muno may partner with third-party analytics and advertising networks to display relevant advertising on the muno Website or on third-party websites. Ad network partners use data technologies to collect information about your online activities to provide you targeted advertising based upon your interests. You may opt out from targeted advertising by adjusting your browser or device settings. Please note this does not opt you out from being served advertising; you will continue to receive generic ads that are not based on your specific interests.

We retain Personal Data for the period necessary for the purposes for which it was collected, or for such periods as required by applicable Nigerian law. This may involve retaining Personal Data for periods following the completion or termination of your account. KYC and identity verification records may be retained for a minimum of 5 years after the end of the business relationship, as required by Nigerian AML/CFT regulations. We make efforts to delete your Personal Data once it is no longer required for any of the business purposes described above or as required by law.

muno has implemented safeguards designed to protect your Personal Data, including measures designed to prevent Personal Data against loss, misuse, and unauthorized access and disclosure. Our security measures include: • End-to-end encryption for sensitive data in transit • Encrypted storage of sensitive fields (BVN, NIN) • Secure PIN hashing using industry-standard algorithms • Two-factor authentication (2FA) support • Session management and token expiry controls • Regular security reviews and audits Still, muno cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection. Transferring data through the Internet always carries some risk, even if muno makes efforts to protect data once it has received it.

muno's Website and Services are not intended for children under the age of 18. We do not knowingly collect data from children under the age of 18. If we learn that we have collected information, including Personal Data, from an individual under 18 years of age, we will delete that information immediately and close the associated account. By using our Services, you represent that you are at least 18 years of age.

Under the Nigeria Data Protection Act (NDPA) and applicable regulations, you have the following rights regarding your Personal Data: • Right of access: You may request a copy of the Personal Data we hold about you. • Right to rectification: You may request correction of inaccurate or incomplete Personal Data. • Right to erasure: You may request deletion of your Personal Data, subject to legal retention requirements. • Right to restrict processing: You may request that we limit how we use your Personal Data in certain circumstances. • Right to data portability: You may request a copy of your Personal Data in a structured, commonly used format. • Right to object: You may object to certain types of processing, including direct marketing. • Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time. To exercise any of these rights, please contact us at [email protected].

muno reserves the right to change this Notice from time to time. We will notify you of modifications to this Notice by: • Posting a revised version of this Notice on the muno Website or app • Sending you an email notification (if you have provided your email address) • Displaying a prominent notice on the muno home screen We recommend that you periodically check the Website for any changes. Your continued use of our Services after any changes to this Notice constitutes your acceptance of the updated Notice.

If you have any questions about this Notice, or wish to make an inquiry with us regarding Personal Data or privacy, please contact us at: Company: Boldswitch LTD Privacy inquiries: [email protected] Support: [email protected] Website: muno.ng Address: Plot 5 Steve Oransanye Street, 4th Avenue, Gwarinpa, Abuja, Nigeria We aim to respond to all privacy inquiries within 5 business days.