Privacy Policy
Last updated: October 16, 2026
This is a working draft prepared as a starting point for ThirdMoney's legal team and counsel to review, localize per operating country's data protection law, and finalize — it is not yet final legal text.
1. Information we collect
To provide the Service, we collect:
- Account information — your phone number, name, username, email (if provided), and country.
- Identity verification (KYC) information — documents you submit such as a national ID, passport, proof of address, or, for Business accounts, a business registration certificate.
- Transaction information — deposits, withdrawals, transfers, group and campaign contributions, and merchant payments you make or receive, including amounts, currencies, and counterparties.
- Device and usage information — IP address, device and browser type, and how you interact with the Service, including for fraud detection and security.
2. How we use it
We use your information to: operate your wallet and process your transactions; verify your identity and meet our legal and regulatory obligations (including anti-money-laundering rules); detect and prevent fraud and abuse; provide customer support; send you transactional messages (like OTP codes and payment confirmations) and, where you've agreed, other communications; and improve the Service.
3. Who we share it with
We share information only where necessary to provide the Service or where the law requires it: with payment processors and mobile money operators to complete your deposits and withdrawals; with our SMS provider to deliver verification codes; with regulators, tax authorities, or law enforcement where required by law or a valid legal request; and with professional advisors (auditors, lawyers) under confidentiality obligations. We do not sell your personal information.
4. How long we keep it
We retain account and transaction records for as long as your account is active and afterward for the period required by financial recordkeeping and anti-money-laundering laws in your country, which is often several years after an account closes. KYC documents are retained on the same basis.
5. Security
Passwords and transaction PINs are stored as one-way cryptographic hashes, never in plain text. We use industry-standard measures to protect your information, but no system is completely secure — please also protect your own device, password, and PIN, and tell us immediately if you suspect unauthorized access to your account.
6. Your rights
Depending on your country's data protection law, you may have the right to access, correct, or request deletion of your personal information, or to object to certain uses of it. Where a right to deletion applies, it doesn't override our obligation to retain financial records for the periods required by law. You can reach us through the Support section of the app to exercise these rights.
7. Cross-border transfers
As ThirdMoney operates and expands across multiple countries, your information may be processed in a country other than the one you're in, including where our servers or payment partners are located. Where required, we take steps to ensure an adequate level of protection for information transferred this way.
8. Children's privacy
ThirdMoney is not directed at children and is not intended for use by anyone below the legal age of majority in their country. We don't knowingly collect information from children.
9. Changes to this policy
We may update this Privacy Policy from time to time. If we make a material change, we'll notify you in the app or by another reasonable means before it takes effect.
10. Contact
Questions about this Privacy Policy, or requests relating to your personal information, can be sent through the Support section of the app, or to the contact details published on our website.