Privacy Policy

The Prudential Bank, trading as Pruvanta, is responsible for the personal information described in this Policy, except where another entity is expressly identified as responsible for a particular product or processing activity.

This Policy applies to information collected through Pruvanta websites, applications and interfaces, Early Access or contact forms, account onboarding, customer support, banking and payment services, supported digital-asset services and other interactions with us.

It does not govern third-party websites or services that we do not own or control. Those providers may have their own privacy policies.

The information we collect depends on your relationship with us and the products you use. It may include:

• Identity and contact information: name, date and place of birth, nationality, residential and business address, email, telephone number, signature and similar identifiers.

• Application and profile information: occupation, employer, business activity, expected account use, countries of operation, currencies, anticipated transaction volumes, product interests and information submitted in Early Access or account applications.

• KYC/KYB information: government identification, corporate records, ownership and control information, directors, authorised persons, ultimate beneficial owners, tax information and verification results.

• Financial and compliance information: source of funds, source of wealth, bank account details, financial standing, payment instruments, sanctions/PEP screening results and information reasonably required to assess financial-crime or regulatory risk.

• Transaction information: amounts, dates, currencies, counterparties, beneficiaries, merchants, payment routes, references and other data associated with transactions or attempted transactions.

• Digital-asset information: wallet addresses, blockchain transaction identifiers and related public-chain or service information where digital assets are used.

• Technical information: IP address, device and browser information, operating system, identifiers, login and security events, pages visited, usage information, approximate location and diagnostic data.

• Communications: emails, support enquiries, complaints, call or meeting records and other communications with us, where lawfully recorded or retained.

Our websites and services are not designed for children and we do not knowingly seek to collect personal information from children.

We may obtain personal information:

• directly from you or from persons acting on your behalf;

• from your employer, business, authorised representatives, directors, shareholders or beneficial owners;

• from counterparties, merchants, beneficiaries and other transaction participants;

• from banks, correspondent banks, payment providers, card networks, digital-asset or blockchain infrastructure providers and other financial-service partners;

• from identity-verification, fraud-prevention, sanctions, PEP, adverse-media, credit or other risk-information providers;

• from public records, registries, blockchain data and other lawfully available sources; and

• automatically from your device or browser when you use our Sites or Services.

We may process personal information to:

• review Early Access and account applications and assess product eligibility;

• open, administer and secure accounts and provide requested banking, payment, card, foreign-exchange, digital-asset or other services;

• authenticate users and protect accounts, systems and transactions;

• process, reconcile and investigate transactions;

• communicate with you about your application, account, transactions and services;

• comply with legal, regulatory, tax, sanctions, AML/CFT and other obligations;

• detect, investigate and prevent fraud, money laundering, misuse, cyber incidents and other prohibited activity;

• manage credit, liquidity, operational, financial-crime and other risks;

• maintain, analyse, test, improve and develop our websites, products, security and customer experience;

• establish, exercise or defend legal rights and respond to lawful requests from authorities; and

• send service information and, where permitted, relevant marketing communications.

The legal basis for processing may vary by jurisdiction and may include performance of a contract, steps taken at your request before entering into a contract, compliance with legal obligations, legitimate interests, consent, or another basis recognised by applicable law.

Legal basis for each purpose

The table below shows the legal basis we generally rely on for each main purpose. Where the law that applies to you requires a different basis, we rely on the basis that law recognises.

These activities may involve specialised third-party providers and, where permitted by law, automated tools or risk indicators. An application may be declined, restricted or referred for additional review based on compliance, eligibility or risk considerations.

We may be legally restricted from informing you about certain financial-crime reports, investigations, monitoring activities or disclosures to authorities.

We may disclose personal information where reasonably necessary to provide services, operate the Bank or meet legal and regulatory obligations, including to:

• affiliates and companies supporting Pruvanta technology or operations;

• correspondent banks, partner banks, payment processors, card schemes, acquirers, liquidity providers and other financial institutions involved in providing or processing a service;

• KYC/KYB, identity, sanctions, fraud, cybersecurity, cloud, communications, customer-support and other service providers acting for or with us;

• transaction counterparties and their service providers where necessary to complete or investigate a transaction;

• digital-asset, wallet or blockchain service providers where relevant to a supported digital-asset service;

• regulators, supervisory authorities, courts, law-enforcement, tax authorities and other public authorities where required or permitted by law;

• auditors, lawyers, accountants, insurers and other professional advisers; and

• a purchaser, investor, successor or other party in connection with an actual or proposed corporate transaction, subject to appropriate safeguards.

We do not disclose personal information to unrelated third parties for their own direct marketing unless you have consented or applicable law otherwise permits it.

Pruvanta operates internationally and the services we provide may require information to be processed in countries other than the country where you live or where the Bank is established. This may occur when we work with international banks, payment networks, technology providers, compliance providers or other service partners.

Privacy and data-protection laws differ between jurisdictions. Where applicable law requires specific safeguards for an international transfer, we will seek to use an appropriate transfer mechanism or contractual, organisational or technical protection.

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide services, maintain business and transaction records, comply with banking, AML/CFT, tax and other regulatory requirements, resolve disputes, prevent fraud and enforce agreements.

Financial institutions may be required to retain identification, account, transaction and compliance records after an account is closed or an application is declined. Retention periods vary by record type and applicable legal or regulatory requirement. We may de-identify or securely delete information when it is no longer required.

We use administrative, organisational and technical measures designed to protect personal information against unauthorised access, disclosure, alteration, loss or misuse. These measures may include access controls, authentication, monitoring, encryption or similar security controls where appropriate.

No website, network, communication or storage system can be guaranteed to be completely secure. You are responsible for protecting your passwords, authentication devices and account credentials and should contact us promptly if you suspect unauthorised access or fraud.

Your rights depend on the law that applies to you. Subject to applicable exceptions and verification requirements, you may have rights to request access to personal information, correction of inaccurate information, deletion, restriction or objection to certain processing, withdrawal of consent, portability, or information about how data is used or shared.

You may opt out of non-essential marketing communications using the unsubscribe method provided in the communication or by contacting us. Service, security, legal and account communications may still be sent where required.

Some information is necessary for us to satisfy banking, compliance or security obligations. If you do not provide required information, we may be unable to open or maintain an account or provide a service.

We and our service providers may use cookies and similar technologies to keep our Sites secure, recognise devices or sessions, remember preferences, understand how our Sites are used, measure performance and, where permitted, support relevant communications or advertising.

For more information, including available controls, please read the Pruvanta Cookie Policy.

Pruvanta services are not intended for children. We do not knowingly solicit or collect personal information from children through the Site. If you believe a child has provided personal information to us without appropriate authorisation, please contact us.

Our Sites and Services may link to or integrate with third-party services. If you authorise an account connection or use a third-party service, information may be exchanged with that provider as necessary for the connection or transaction.

Third parties process information under their own privacy practices. You should review the relevant privacy policy before connecting an external service or providing information to it.

We may update this Privacy Policy to reflect changes in our products, technologies, service providers, legal obligations or privacy practices. We will publish the updated version on the Site and update the date shown at the top of the page. Where required by law, we may provide additional notice.

To ask a privacy question or make a request concerning your personal information, contact The Prudential Bank using the details below. We may need to verify your identity before acting on a request.