Privacy policy
1. Who is responsible for your data
KereX Technologies L.L.C-FZ, Meydan Free Zone, Dubai, United Arab Emirates (“KereX”, “we”) is the controller of personal data processed through the Moduwi website, Telegram Mini App and apps. Our licensed partners process your data as independent controllers for the regulated services they provide, under their own privacy policies. Our identity verification provider processes verification data on behalf of the party carrying out the checks. The current list of partners is in the Terms. We process data in line with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and, where it applies to you, the EU and UK GDPR.
2. What we collect
Waitlist: your email, the moment or platform you chose, language, the page and campaign you came from, IP address and browser type. Account: name, date of birth, phone, Telegram ID, country of residence. Identity verification: ID document, selfie and liveness check (biometric data used only to confirm it is you), address and results of sanctions and politically-exposed-person screening. Service data: your modus, roles, participants, top-ups, payments, transfers, card operations and exchange. Technical data: device, app version, IP address, security logs. Communications with support.
3. Why we use it
To provide Moduwi and perform our contract with you; to meet legal obligations, including anti-money-laundering, counter-terrorist-financing and sanctions rules; for our legitimate interests in keeping the service secure, preventing fraud and improving the product; and, with your consent, to send you the launch email and product news. You can withdraw consent at any time. We do not sell personal data and do not use it for third-party advertising.
4. Who we share it with
Participants of your modu see its shared history and the roles in it. Our licensed partners receive the data they need to open accounts, issue cards and execute payments. Our identity verification provider receives the data needed to verify you. Hosting, email and communication providers process data on our instructions under contract. We disclose data to regulators, law enforcement or courts when the law requires it.
5. International transfers
Your data may be processed in the United Arab Emirates and in other countries where our licensed partners and service providers operate. Where the law requires it, we protect such transfers with contractual safeguards.
6. How long we keep it
Waitlist data: until 12 months after launch in your market, or until you ask us to delete it. Account data: while your account is open. Identity verification and transaction records: for the period required by anti-money-laundering laws, usually at least 5 years after the relationship ends. Security logs: up to 12 months.
7. Security
Data is encrypted in transit, access is limited to staff who need it, and we review our security regularly. No system is completely secure; if a breach affects you, we will inform you and the authorities as the law requires.
8. Your rights
You can ask to access, correct or delete your data, restrict or object to its processing, receive a copy in a portable format and withdraw consent. Write to privacy@moduwi.com; we reply within 30 days. We may refuse deletion where the law requires us to keep records. You can also complain to the UAE Data Office or, if you live in the EU or UK, to your local data protection authority.
9. Cookies and local storage
The website stores your language choice in a cookie and in your browser. We do not use advertising trackers. If we add analytics, it will run only with your consent and will be listed here.
10. Children
Moduwi accounts are for adults. A parent or guardian can give a child a card inside their own modu; in that case we process only the data needed for the card, on the parent’s or guardian’s instructions.
11. Changes and contact
We will post updates on this page and notify you of material changes. Questions: privacy@moduwi.com, or KereX Technologies L.L.C-FZ, Meydan Free Zone, Dubai, United Arab Emirates, legal@kerex.io.