Privacy Policy

1. Introduction

Welcome to Beynaa.

Beynaa is a financial technology platform designed to provide modern digital financial services through mobile applications, websites, payment technologies, wallets, cards, banking infrastructure integrations, and related financial products.

This Privacy Policy explains how Beynaa collects, uses, stores, processes, transfers, protects, and discloses personal information when individuals interact with Beynaa services.

This Privacy Policy applies to:

The Beynaa mobile application
The Beynaa website
Digital wallet services
Payment services
Virtual card services
Physical card services
Identity verification services
Customer support services
Promotional and marketing communications
Future financial products and services offered under the Beynaa brand

By accessing or using Beynaa, you acknowledge that you have read, understood, and accepted this Privacy Policy.

2. Who We Are

Beynaa is a financial technology product operated by NovaSky Sàrl. \

Data Controller

For the purposes of applicable data protection laws, NovaSky Sàrl acts as the primary data controller for personal data processed through Beynaa unless otherwise specified by applicable law or contractual arrangements with regulated financial partners. Transparency regarding the controller and processing purposes is a core requirement of Swiss data protection law. (FDPIC)

NovaSky Sàrl

Route de la Maison Neuve 14

1753 Matran

Fribourg

Switzerland

Email: support@beynaa.com

Website: beynaa.com

3. Regulatory and Financial Partners

Beynaa is a technology platform and is not necessarily the direct provider of all financial services available through the platform.

Certain services may be provided through regulated financial institutions, including:

Banking-as-a-Service (BaaS) providers
Licensed banks
Electronic money institutions
Payment institutions
Card issuers
Money transfer providers
Identity verification providers
Compliance service providers
Fraud prevention providers
Other authorized financial infrastructure partners

Depending on your country, regulatory status, and the services used, certain functionalities may be offered through one or more regulated financial partners.

These services may include:

Payment accounts
Wallet services
IBAN issuance
Virtual cards
Physical cards
International transfers
Payment processing
Merchant services
Future financial products

3A. Service Availability

Beynaa services may not be available in all countries or territories.

Availability depends on:

Regulatory approvals
Licensing restrictions
Financial partner capabilities
Local laws
Risk assessments
Compliance requirements

Beynaa reserves the right to restrict, suspend, limit, or refuse access to services in specific jurisdictions.

3B. Financial Infrastructure Partners

Beynaa may rely on one or more regulated financial infrastructure providers to deliver services.

These providers may change over time.

Changes to financial infrastructure providers shall not affect the validity of this Privacy Policy.

Certain services may be subject to additional:

Regulatory disclosures
Partner-specific requirements
Terms and conditions
Compliance procedures

4. Privacy by Design and Privacy by Default

Beynaa is committed to implementing privacy protections from the earliest stages of product design and development.

Personal data processing is designed to respect applicable privacy laws and principles.

Where possible, Beynaa seeks to:

Minimize data collection
Limit access to authorized personnel
Reduce unnecessary processing
Apply privacy safeguards by default
Limit data retention where appropriate

These principles reflect internationally recognized privacy standards and Swiss data protection requirements regarding Privacy by Design and Privacy by Default. (odat)

5. Information We Collect

5.1 Personal Information

We may collect:

Full legal name
Date of birth
Gender
Nationality
Residential address
Mailing address
Email address
Telephone number
Occupation
Tax residency information
Citizenship information

5.2 Identity Verification Information

We may collect:

Passport
National ID card
Residence permit
Driver's license
Selfie photographs
Face identification
Proof of address
Utility bills
Tax documentation
Supporting verification documents

5.3 Financial Information

We may collect:

Account information
Wallet information
Payment information
Card information
Transaction history
Beneficiary information
Funding source information
Spending activity
Account balances

5.4 Technical Information

We may collect:

IP addresses
Device identifiers
Browser information
Device models
Operating systems
Language settings
Application versions
Login activity
Security logs
Device fingerprints

5.5 Communications

We may collect information contained in:

Emails
Support tickets
Contact forms
Surveys
Chat conversations
Feedback submissions

6. How We Use Your Information

We may use information to:

Create accounts
Verify identities
Provide services
Issue cards
Process transactions
Prevent fraud
Conduct compliance checks
Meet legal obligations
Improve products
Provide support
Deliver notifications
Manage disputes
Investigate suspicious activity
Protect users
Protect financial partners
Protect the integrity of the platform

7. Legal Basis for Processing

For users located in Switzerland, personal data is processed in accordance with applicable Swiss data protection laws.

For users located within the European Union and European Economic Area, personal data is processed in accordance with the General Data Protection Regulation (GDPR).

For users located in other jurisdictions, personal data may be processed in accordance with applicable local privacy laws where required.

Processing may be based on:

Consent
Contractual necessity
Legal obligations
Legitimate interests
Regulatory compliance

The duty to provide transparent information regarding processing activities, purposes, recipients, and transfers is a core requirement of Swiss data protection law. (FDPIC)

8. KYC, AML and Compliance Monitoring

Beynaa and its partners may perform:

KYC verification
KYB verification
AML screening
Fraud reviews
Sanctions screening
PEP screening
Source-of-funds verification
Source-of-wealth verification
Ongoing monitoring
Periodic re-verification

Failure to provide required information may result in:

Service limitations
Account restrictions
Suspension
Termination

9. Automated Decision-Making

Certain compliance, fraud prevention, security, sanctions screening, and risk management processes may involve automated systems.

These systems may assist in:

Fraud detection
Transaction monitoring
Security monitoring
AML reviews
Risk assessments

Where required by applicable law, users may have the right to:

Be informed of certain automated decisions
Request information regarding the decision
Express their point of view
Request review by a qualified human reviewer

Swiss law specifically provides rights relating to certain automated individual decisions and review by a natural person. (FDPIC)

10. Sharing Your Information

Information may be shared with:

Financial Partners
BaaS Providers
Identity Verification Providers
Card Networks
Payment Processors
Compliance Providers
Cloud Service Providers
Security Providers
Auditors
Legal Advisors
Regulatory Authorities
Law Enforcement Agencies

Where legally required.

11. International Data Transfers

Personal data may be processed or stored in:

Switzerland
European Union countries
European Economic Area countries
Other countries where authorized service providers operate

Where transfers occur, Beynaa seeks to implement appropriate safeguards consistent with applicable legal requirements.

Swiss law requires transparency regarding cross-border disclosures and destination countries. (odat)

12. Data Retention

Personal data is retained only for as long as necessary.

Account Data

Retained while accounts remain active.

Compliance Data

Retained according to legal and regulatory requirements.

Transaction Data

Retained according to financial recordkeeping obligations.

Communication Data

Retained for support and dispute resolution purposes.

Security Logs

Retained for security, fraud prevention, and audit purposes.

13. Security Measures

Beynaa implements technical and organizational security measures designed to protect personal data.

These measures may include:

Encryption in transit
Encryption at rest
Access controls
Role-based permissions
Security monitoring
Threat detection
Security audits
Incident response procedures
Business continuity planning

The level of protection is designed to be appropriate to the risks involved. (odat)

Fraud Prevention

Beynaa may use:

Automated monitoring
Machine learning systems
Behavioral analytics
Risk assessment tools
Transaction monitoring systems

to detect:

Fraud
Financial crime
Account abuse
Money laundering
Sanctions violations
Security threats

14. Cookies and Analytics

Beynaa may use:

Essential cookies
Security cookies
Analytics cookies
Performance cookies

Users may manage cookie preferences where applicable.

15. Your Rights

Subject to applicable laws, users may have the right to:

Access personal data
Correct inaccurate data
Request deletion
Restrict processing
Object to processing
Withdraw consent
Request portability
Request human review of certain automated decisions

Swiss law provides rights including access, rectification, portability, and protections relating to automated decisions. (FDPIC)

Requests may be sent to:

support@beynaa.com

16. Account Closure

Users may request closure of their account.

Certain information may continue to be retained where required for:

Legal obligations
Regulatory requirements
Fraud prevention
Dispute resolution
Security investigations

Beynaa reserves the right to restrict, suspend, or terminate accounts where required by law, compliance obligations, sanctions requirements, security concerns, or violations of applicable terms.

17. Age Restriction

Beynaa services are intended exclusively for individuals who are at least eighteen (18) years old.

By using Beynaa, users represent and warrant that they meet the applicable minimum age requirements.

18. Third-Party Services and Future Services

Beynaa may integrate with:

Banking-as-a-Service providers
Banks
Card networks
Payment processors
Identity verification providers
Analytics providers
Security providers

Beynaa may expand its services over time, including:

Payment accounts
Wallet services
Virtual cards
Physical cards
International payments
Savings products
Budgeting tools
Financial insights
Business financial services
Additional financial products and services

Additional services may be subject to supplementary terms and regulatory requirements.

19. Complaints and Supervisory Authorities

If you believe your privacy rights have been violated, you may contact Beynaa using the contact information below.

Where permitted by applicable law, you may also have the right to lodge a complaint with a competent data protection authority or supervisory authority in your jurisdiction.

20. Changes to This Privacy Policy

Beynaa may update this Privacy Policy periodically.

Material changes may be communicated through:

Email notifications
In-app notifications
Website notices

The latest version will always be available through Beynaa services.

21. Contact Us

Beynaa

Operated by NovaSky Sàrl

Route de la Maison Neuve 14

1753 Matran

Fribourg

Switzerland

Email: support@beynaa.com

Website: beynaa.com