Fynzon Privacy and Terms
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Introduction

In this policy, we, us, our, and Fynzon P2P refer to Fynzon P2P. For more information about us and how to contact us, see Section 11. We respect your privacy and are committed to protecting it through our compliance with this Policy. This privacy policy (Policy) applies when we are acting as a data controller with respect to the personal data of our users. This Policy describes how we collect, use, and share personal data of consumer users across our platforms, including the Fynzon P2P website, Fynzon P2P's mobile and desktop application (the App), and services offered to users (collectively referred to as the Services), and from our partners and other third parties. When using any of our Services, you consent to the collection, transfer, storage, disclosure, and use of your personal data as described in this Policy. This Policy does not apply to anonymized data, as it cannot be used to identify you. Please read this Policy carefully to understand our policies and practices regarding your personal data and how we will treat it.

By accessing or using the Services, you agree to this Policy. Our Services also incorporate privacy controls which affect how we will process your personal data. Please refer to Section 5 for a list of rights regarding your personal data and how to exercise them. This Policy may change from time to time. Your continued use of the Services after we make changes is deemed acceptance of those changes, so please check the Policy periodically for updates.

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Information Fynzon Collects

There are three general categories of personal data we collect.

Information you give to us
  • We collect your account data, which may include personal identification information such as your name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email address, Face ID and formal identification information such as Tax ID number, passport number, driver's licence details, national identity card details, photograph identification cards, and/or visa information (collectively, Account Data).

    The Account Data may be processed for the purposes of providing our Services, satisfying anti-money laundering and know-your-customer obligations, and ensuring the security of the Services, maintaining backups of our databases, and communicating with you. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested Services.

  • We process financial information such as bank account, credit card, or PayPal information when you order Services to facilitate the processing of payments (Payment Information). The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
  • We may process information contained in or relating to any communication that you send to us (Correspondence Data). The Correspondence Data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
  • We may process information included in your personal profile, which may include your location, time zone, and website (Profile Data). The Profile Data may be processed for the purposes of providing you a better user experience when using the Services. The legal basis for this processing is your consent.
Information we automatically collect from your use of the services

When you use the Services, we may automatically process information about your computer and internet connection (including your IP address, operating system, and browser type), your mobile carrier, device information (including device and application IDs), search terms, cookie information, as well as information about the timing, frequency, and pattern of your service use, and information about to the transactions you make on our Services, such as the name of the recipient, your name, the amount and type of cryptocurrency, and timestamp (Service Data).

The Service Data is processed for the purpose of providing our Services. The legal basis for this processing is the adequate performance of the contract between you and us, to enable us to comply with legal obligations, and our legitimate interest in being able to provide and improve the functionalities of the Services.

Information we collect from third parties

From time to time, we may obtain information about you from third-party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. The legal basis for processing such data is compliance with legal obligations.

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Disclosure of personal data
  • We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
  • We may disclose Service Data to a variety of third-party service providers insofar as reasonably necessary to improve the functionalities of the Services. For example, we may disclose Service Data to obtain useful analytics, provide in-app support to mobile app users, determine location data, and provide search engine functionality to our users.
  • We may share aggregated data (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
  • In the event of a dispute in a P2P transaction, we may disclose some of your Personal Data with the counterparty to such a transaction to the extent we deem required, in our discretion, to resolve the dispute.
  • In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; or in order to protect your vital interests or the vital interests of another natural person; to protect the safety or integrity of the Services, or to explain why we have removed content or accounts from the Services; or to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use the Services.
  • We offer individuals the opportunity to choose (opt-out) whether their personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. In order to opt-out from disclosure of your personal information, please write to us at [Fynzon P2P Support].
Biometric and Face Data Collection
  1. Purpose and Scope of Face Data Collection
    We collect, store, and process your selfie image and the associated unique face geometry data extracted from it ( 'Face Data' ) for the sole and exclusive purpose of verifying your identity against the photograph on your government-issued identification (e.g., Aadhaar card, as specified by your local jurisdiction).
    • Exclusive Use: The Face Data is used exclusively for the KYC Selfie Verification process.
    • Verification Steps: This process specifically involves:
      1. Extracting the face region and its geometry from your uploaded selfie.
      2. Comparing the extracted Face Data to the photographic image on your provided identification document using a trusted, third-party service provider (Signzy) to generate a match score.
    • Critical Necessity: This data is critical for robust fraud prevention and for fulfilling our mandatory legal and regulatory requirements regarding Customer Due Diligence (CDD) and Know Your Customer (KYC) norms.
  2. Retention and Use Limitations
    We are committed to minimizing the retention and restricting the use of your Face Data:
    • Purge Upon Account Deletion: Once a user chooses to delete their Fynzon account, all associated Face Data and biometric templates will be permanently deleted from our active systems, subject only to mandatory regulatory "cool-off" or legal hold periods required by financial law.
    • No Permanent Biometric Templates: Raw facial geometry data (biometric templates) is not retained by Fynzon once the matching process is finalized. We only retain the selfie image and the verification status for audit trails.
    • Retention Period: We retain your Face Data only for as long as is strictly necessary to fulfill the purpose of verification, to meet mandated regulatory retention periods (e.g., records retention rules), and for essential security and fraud prevention purposes.
    • Strict Limitations: Your Face Data will not be:
      • Shared with third parties for marketing, advertising, or promotional purposes.
      • Used to train external or third-party artificial intelligence models.
  3. How We Process Your Face Data (KYC Selfie Verification Process)
    The technical steps for the KYC Selfie Verification process are as follows:
    StepActionPurpose/Description
    1. User Uploads Selfie The user uploads a clear selfie image directly within the Fynzon App interface. Initiates the identity verification process.
    2. Secure Storage (AWS S3) The Fynzon backend securely stores the raw selfie image and generates a temporary, time-bound URL from our secure storage environment (Amazon Web Services S3). Ensures the raw image is stored in a secure, compliant infrastructure.
    3. Face Extraction (Signzy API) We pass the secure S3 URL to our third-party provider's (Signzy) Face Extraction API to calculate, isolate, and generate the unique facial geometry/region (the Face Data). Converts the image into measurable, biometric data for comparison.
    4. Face Match (Signzy API) The extracted Face Data is then compared with the photo captured from the user's provided government ID (e.g., Aadhaar) using Signzy’s Face Match API. Determines the probability that the selfie and ID photo belong to the same person.
    5. Verification Result Signzy returns a definitive match score to Fynzon. Based on internal thresholds, the user is subsequently marked as KYC Verified or KYC Failed in our system. Completes the regulatory requirement and grants/denies access based on verification status.
International transfers of your personal data
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In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). We and our other group companies have offices in India, USA, and Singapore. To facilitate our operations, we may transfer, store, and process your information within those countries or with service providers based in Europe, India, Asia Pacific, and North America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy.

Where we transfer, store, and process your personal information outside of the EEA, we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. Transfers to our affiliated entities, to our service providers, and other third parties will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission or applicable certification schemes.

Your rights with regard to personal data

In this Section 5, we have summarised the rights that you have under data protection law based on whether you are a resident of the European Economic Area (EEA Resident) or you are not a resident of the EEA (Non-EEA Resident). Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

  • Non-EEA Residents. If you are a Non-EEA Resident, you may access and verify your Personal Information held by Fynzon P2P by submitting a written request to us at [Fynzon P2P Support].
  • EEA Residents. If you are an EEA Resident, your principal rights under data protection law are:
    1. the right to access;
    2. the right to rectification;
    3. the right to erasure;
    4. the right to restrict processing;
    5. the right to object to processing;
    6. the right to data portability;
    7. the right to complain to a supervisory authority; and
    8. the right to withdraw consent.
  • As an EEA Resident, you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by writing to us at [Fynzon P2P Support].
  • As an EEA Resident, you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You can request correction or modification of your personal data by writing to us at [Fynzon P2P Support]
  • In some circumstances, as an EEA Resident, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defence of legal claims. You can request the deletion of your account by writing to us at [Fynzon P2P Support].
  • In some circumstances, as an EEA Resident, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
  • As an EEA Resident, you have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.
  • As an EEA Resident, you have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
  • As an EEA Resident, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
  • To the extent that the legal basis for our processing of your personal data is:
    1. consent; or
    2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, and you are an EEA Resident, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. You can request to download your account information by writing to us at [Fynzon P2P Support].
  • To the extent that the legal basis for our processing of your personal data is consent and you are an EEA Resident, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
  • You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 5.