“Money Movers” LLC was established on August 23, 2009, its identification code is: 200274318. On January 14, 2013, the company was registered as a payment service provider by the National Bank of Georgia, registration number 0008-9004; the legal and actual address of “Money Movers” LLC is: Georgia, Tbilisi, 0159, David Aghmashenebeli Alley N172 g. E-mail address: info@mm.ge, phone: +995 32 203 33 33. “Money Movers” LLC while providing payment services is obliged to be guided by the principles established by the Georgian legislation and international standards in the processing and protection of personal data. The present document refers to the terms and conditions of processing, using, updating and storing personal data of clients by “Money Movers” LLC. The provider protects the privacy of personal data of its clients according to the standards established by the Georgian and international legislation. It does not use them illegally; and in case of the client’s request, it inevitably provides him/her with complete information concerning the processing of the personal data. “Money Movers” LLC processes the personal data of the following persons: customer (natural and/or legal persons), with whom it establishes a one-time or long-term business relationship, other natural and legal persons, non-legal persons, state or local self-government units, legal entities under public law, work searchers, payment system providers and other financial institutions. “Money Movers” LLC uses the client’s personal data only if there is a specific contractual and/or legal basis. The provider has a legal basis for using the data if there are business related and/or commercial purposes. It is important that the data processing by the provider is not harmful. And the processing of the personal data of a minor is possible by the provider taking into account the Georgian legislation and the best interests of the minor.

“Money Movers” LLC uses personal data for the following purposes:

• a) for business and working relations;
• b) for performing payment services properly and in good faith;
• c) for developing and implementing marketing activities;
• d) for establishing and studying how the client uses the provider’s products and services;
• e) for conducting researches, receiving recommendations, advice which is necessary for improving the service and/or introducing a new product;
• f) for providing products and services;
• g) for making and managing payments by the client;
• h) for managing commission and interests;
• i) for detecting financial crimes (money laundering, financing of terrorism), implementing preventive measures and submitting reports;
• j) for assigning and managing risks to the provider itself and clients;
• k) for fulfilling other obligations established by law, including conducting audits;
• l) for reviewing complaints and finding ways to resolve them;
• m) for fulfilling obligations properly under the Agreement.
• The legitimate interest of processing data for the above-mentioned purpose is:
• a) fulfillment of contractual obligations by the provider properly and in good faith;
• b) data update;
• c) provision of products and services desired by the client;
• d) fulfillment of the obligations imposed by the Georgian legislation properly and in good faith.

In addition, the provider, as a data processor, has a legal basis established by the legislation and international regulations, which obliges it to obtain, process, update and store personal data in the volume necessary for the thorough and proper implementation of its activities.

“Money Movers" LLC uses different types of personal information, which are grouped as follows:

• 1) financial - a person’s financial situation, status, history of financial activity, information on completed transactions;
• 2) contact/communication - registration and actual (residential) address, e-mail, mobile phone number that the provider obtains from the client or from e-mails or other telecommunication channels;
• 3) sociodemographic - information about the client, his/her job, profession, citizenship, education, social status and income;
• 4) related to transactions - information on transfers/payments made by the client or another person, incomes and expenditures, when and where the said transaction was made. On account numbers of electronic wallets, as well as on transactions made from/to accounts existing in other financial or non-financial institutions;
• 5) contractual - detailed information about delivered products and rendered services;
• 6) location-related - location-related data, which may be obtained by the provider through the mobile phone, through the address of a computer connected to the Internet, or according to the location of the facility where the client performs payment operations using a card;
• 7) behavioral data - details about how clients use the provider’s products or service;
• 8) technological - information about the equipment/devices used for using the products/services.
• 9) open access data and public records - information available in public sources, including information existing in public electoral lists, as well as other information legally available on the Internet;
• 10) regarding social relations - information about family members (marital status, children) and contact persons;
• 11) documentary - information reflected in documents of different formats and their copies. Such documents include a passport, identity document, birth certificate, driver’s license and other documents of personal identification.

The provider receives personal data from clients in the following cases:

• a) when a person becomes its client;
• b) when the client registers on the provider’s online services;
• c) when the client uses the provider’s products or services;
• d) when the client talks on the phone or visits the service center of the provider or its agent;
• e) when the client uses the provider’s website, mobile application and online consulting functionality (online chat);
• f) when the client sends letters to the provider by post or e-mail;
• g) when the client performs payment operations;
• h) when the client uses the provider’s payment or related services;
• i) when a person wants to be employed in “Money Movers” and sends a resume and an application.

The provider collects data from such organizations as the public registry, civil registry, other payment service providers, other financial institutions and public organizations.

Any person whose personal data is collected, processed and used by “Money Movers” LLC can request the provision of the following types of information from the provider:

• a) which of his/her data is processed by the provider;
• b) for what purpose the said data is processed;
• c) what legal basis does the provider have for processing the personal data;
• d) how the personal data is processed;
• e) to whom (if any) the personal data of the person will be shared;
• f) what is the basis and purpose for providing the personal data;.

The person has the right to request a copy of the data that the provider processes. The person whose data is processed has the legal right to request the amendment, update, addition, blocking, deletion or destruction of the data if it is incomplete, inaccurate, outdated or illegally obtained. In such a case, “Money Movers” LLC must act in accordance with the Georgian legislation, which may not allow the provider to immediately delete the personal data. Such obligations may arise from anti-money laundering, tax, payment service, provider performance and consumer rights protection laws.

The provider has the right to request and receive personal data from third parties, for example, from a financial or non-financial institution participating in the payment operation, from the electronic database of the LEPL State Service Development Agency, etc. Information is requested in accordance with the Georgian Law “On Personal Data Protection”.

Sharing of personal data may be necessary in cases provided for by the Georgian legislation or with those organizations that must provide the provider with the product or service selected by the client. For example: if the client has a prepaid card of the provider, detailed information about the client’s transaction may be transferred to the companies that help the provider provide this service (such as: Georgian Card, Crocobet, Bank of Georgia, etc.). If the Provider uses the services of third parties, other providers, in the course of its normal activities, it may be necessary to share the personal data with them in order to perform specific tasks. Examples of cooperation with third party service providers are as follows:

• a) legal, auditing and other professional services provided by lawyers, notaries, authorized persons, auditing companies, etc.;
• b) detection, investigation and prevention of fraud and other types of crime or misdemeanour, which are carried out by special bodies;
• “Money Movers” LLC may share the personal data if the provider structure changes in the future, for example:

• 1) if the provider sells and/or alienates its assets, or carries out a merger operation.
• 2) if any of the above-mentioned processes are implemented, “Money Movers” LLC may share personal data with the relevant party, however, in this case, the mentioned party must undertake the obligation to protect the data security and confidentiality in advance.
• In any case, if the provider shares the personal data with third parties, it must take all measures to ensure their protection.

The provider also uses personal data in the process of making automatic decisions, the aforementioned personal data may be owned or received by “Money Movers” LLC from other persons based on the authority granted by the legislation, or the Agreement signed with the client or their consent. Which helps the provider to make quick, fair and efficient decisions. Automated decisions are reflected on the quality of the provider’s current and future products or services. If there is no proper basis (legislative, contractual basis, consent of the client), the client can refuse the automatic processing of the personal data, including if the aforementioned results in legal, financial or other significant consequences. Examples of the automated decisions are as follows:

• a) Determination of fraud

Personal data helps the provider to determine whether the client’s accounts may be used for fraud or money laundering purposes or not. If the provider detects a risk of fraud, it has the right to temporarily suspend transactions on suspicious accounts or refuse to provide the corresponding service for the safety of the client.

• b) Payment and related service purposes.

The provider stores personal data throughout the service period; also, for a period of up to 15 years after the end of the service for the following reasons:

• 1) to answer questions and complaints;
• 2) to justify that we treat the client fairly;
• 3) for proceedings according to established regulations.

It is possible for the provider to keep personal data for more than 15 years, unless it has a relevant legal basis to delete it.

The present document of the personal data protection policy may be amended in accordance with the legislation and/or changes in the personal data processing rules of the provider. The current version was created on July 29, 2022.