Privacy Policy

Global Financial Solutions MSB LLC ("GFS MSB LLC") is a U.S. Money Services Business that supports international payment services, digital asset settlement, foreign exchange transactions, and stablecoin-enabled payment solutions.

As part of our services, we collect and process personal information to onboard customers, verify identities, facilitate lawful payment transactions, comply with applicable financial crime regulations, and protect our customers and business from fraud and other illegal activities.

We are committed to protecting your personal information and handling it responsibly in accordance with applicable U.S. federal and state privacy laws, including the Gramm-Leach-Bliley Act (GLBA), the Bank Secrecy Act (BSA), the USA PATRIOT Act, and other applicable financial crime, sanctions, and data protection laws.

This Privacy Policy explains what personal information we collect, how we use it, with whom we share it, and the rights available to you when you use our website, mobile applications, onboarding platform, or any of our services.

We collect personal information directly from you, from trusted third-party verification providers, from financial institutions, and from publicly available sources where permitted by law.

Depending on the services you use, we may collect the following categories of personal information:

Identity Information: full name, date of birth, nationality, government-issued identification documents, passport or national ID number, and identity verification information, including selfie, biometric data, liveness checks, and verification results.

Contact Information: residential address, email address, and telephone number.

Financial Information: bank account details, payment instructions, transaction history, source of funds, and source of wealth.

Digital Asset Information: blockchain wallet addresses, wallet ownership verification, blockchain transaction identifiers (transaction hashes), and digital asset transaction history necessary to provide our services.

Business Information (for corporate customers): legal entity information, beneficial ownership information, corporate documentation, and authorised representatives.

Technical Information: IP address, browser type, operating system, device identifiers, geolocation data, website usage information, and cookies and similar technologies.

Cookies and Tracking Technologies: Cookies may be used to personalize your experience and deliver relevant information. These include:

Necessary cookies: Required for basic website functionality.

Analytical cookies: To analyze usage and improve our services.

Marketing cookies: To deliver personalized ads.

You can manage your cookie preferences directly through your browser settings.

If applicable, in compliance with the Fair Credit Reporting Act (FCRA), we may collect credit information from credit bureaus to evaluate your eligibility for our services.

We will use your personal information for legitimate business purposes, including:

• establish and verify your identity through Know Your Customer (KYC), Know Your Business (KYB), Customer Identification Program (CIP), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) procedures;
• comply with the Bank Secrecy Act, USA PATRIOT Act, OFAC sanctions requirements, anti-money laundering (AML) and counter-terrorist financing (CTF) obligations;
• perform sanctions screening, politically exposed person (PEP) screening, adverse media screening, fraud prevention and ongoing transaction monitoring;
• facilitate international payment processing, digital asset settlement, stablecoin transactions and OTC trading services;
• communicate with customers regarding their accounts and transactions;
• improve our products, services and security controls;
• detect, investigate and prevent fraud, financial crime, cybercrime and other unlawful activities;
• comply with legal obligations and regulatory reporting requirements;
• establish, exercise or defend legal claims.

Where applicable, we process personal information under one or more of the following legal bases:

• performance of a contract;
• compliance with legal and regulatory obligations;
• legitimate business interests, including fraud prevention and information security;
• protection of vital interests;
• consent, where required by applicable law.

We may disclose personal information to:

• our employees and authorised personnel;
• affiliated companies within our corporate group;
• identity verification providers;
• KYC, KYB and AML service providers;
• sanctions screening and fraud prevention providers;
• blockchain analytics providers;
• payment service providers;
• correspondent financial institutions;
• liquidity providers;
• digital asset settlement partners;
• cloud hosting and technology service providers;
• auditors, legal advisers and professional consultants;
• courts, regulators, law enforcement agencies and government authorities where required by law.

We only share the minimum amount of personal information necessary for the relevant purpose and require our service providers to implement appropriate confidentiality and security measures.

GFS MSB LLC maintains physical, electronic, and procedural safeguards to protect your personal information. This includes:

Encryption of sensitive data to ensure protection during transmission and storage

Regular updates to security protocols

Strict access control to your information, limiting it to authorized personnel only

Regular staff training on privacy management

In compliance with the Gramm-Leach-Bliley Act (GLBA), we ensure that any third parties handling your personal information maintain adequate safeguards to protect it.

If you have been provided with a password to access specific areas on our platform, it is your responsibility to keep this information confidential. We will not be responsible for any losses incurred due to unauthorized access resulting from the disclosure of your password.

We will store and retain your data for as long as is necessary for the purposes it was collected. This includes storing data in compliance with legal requirements set forth by the BSA, GLBA, and other applicable laws. Storage is also determined by legal, regulatory, and operational needs.

We retain your personal data based on the type of information:

Transactional data: Retained for at least seven years to comply with the Bank Secrecy Act (BSA).

Personal identification data: Retained for as long as you maintain an account with us and up to five years after account closure.

You have the following rights regarding your personal information:

Right to access: You can request details of the personal information we hold about you.

Right to rectification: You can request that we correct any inaccurate information.

Right to deletion: You can request that we delete your information where legally permissible.

Right to withdraw consent: You may withdraw consent for the processing of your data at any time, though this may affect your ability to use certain services.

Right to data portability: You can request that we transfer your data to a third party.

Right to object: You can object to how we process your personal information.

These rights are in line with the privacy obligations set forth by the Gramm-Leach-Bliley Act (GLBA) and the Fair Credit Reporting Act (FCRA).

Because we provide international payment and settlement services, your personal information may be transferred to, processed or accessed in countries other than your country of residence, including the United States, Brazil, the European Economic Area and other jurisdictions where our affiliates, payment partners, service providers or technology providers operate.

Where required by applicable law, we implement appropriate safeguards for international data transfers, including Standard Contractual Clauses, adequacy decisions or other legally recognised transfer mechanisms.

GFS MSB LLC may interact with you through social media platforms, but we will never ask you to share personal or security information via these channels. Your activity on social media is subject to the platform’s privacy policies and GFS MSB LLC’s privacy policy does not apply to third-party platforms or external websites.

We may contact you with product information and promotions that we believe you may find valuable. You can opt out of these communications at any time by contacting admin@mippo.io or selecting the “Unsubscribe” links included in all promotional emails.

We may revise this Privacy Policy as necessary to remain compliant with new laws and regulations, including updates to the Bank Secrecy Act or Gramm-Leach-Bliley Act. Revisions will take effect upon posting to this page. Continued use of our services signifies your acceptance of any updated policies.

In the event of a data breach that affects your personal information, we will notify you in accordance with applicable laws and take the necessary steps to mitigate any risks.

If you have any questions or comments about this Privacy Policy or wish to exercise any of your rights, please contact us through our help center at admin@mippo.io.