1. Scope of Application

This Privacy Policy applies to websites, mobile applications, and related services that are directly operated and provided by MOA (the “Services”).

Services, websites, or platforms operated or controlled by third parties or MOA’s partners are governed by their own privacy policies, and this Privacy Policy does not apply to such third-party services.

2. Personal Information We Collect

2.1 Personal Information Collected Directly by MOA

MOA collects only the minimum information necessary to provide its Services.

Currently, the only personal information collected directly by MOA is:

• Email address

MOA does not directly collect, store, or process the following types of personal information:

• Name, phone number, or date of birth

• Government-issued identification (passport, national ID, driver’s license, etc.)

• Financial or payment information

• Address or location information

2.2 Personal Information Processed by Third-Party Partners

Personal information required for card issuance, payment processing, KYC/AML, or regulatory compliance is collected and processed independently by MOA’s third-party partners (such as card issuers, payment service providers, or KYC providers) in accordance with their own privacy policies.

• MOA does not access or store such personal information.

• MOA is not the data controller for personal information processed by these partners.

• Responsibility for the collection, storage, processing, and deletion of such personal information rests solely with the relevant third-party partner.

3. Purposes of Use

MOA uses the collected email address solely for the following purposes:

• Account creation and management

• Provision and operation of the Services

• Customer support and inquiry handling

• Delivery of essential service-related notices and operational communications

• Delivery of information regarding MOA services, events, benefits, updates, promotions, and marketing communications

Marketing and promotional emails are sent based on user consent, in accordance with applicable laws and international standards.

Users may opt out of such communications at any time.

4. Retention Period

Email addresses are retained only for the period necessary to provide the Services and to fulfill the purposes specified in this Privacy Policy.

If a user requests account deletion or deletion of personal information, such information shall be deleted without undue delay, unless retention is required under applicable laws and regulations.

The Company retains and uses users’ personal information only for the period necessary to provide the Services and to fulfill the purposes of collection and use, and shall promptly delete such information once those purposes have been achieved, except where retention is required or permitted by applicable laws and regulations.

In principle, upon deletion of a user’s account or upon fulfillment of the purposes for which personal information was collected and used, the Company shall delete such personal information without undue delay.

Account deletion requests are processed within seven (7) business days following internal verification, and personal information that is not required to be retained under applicable laws shall be permanently deleted in a non-recoverable manner within such period.

Notwithstanding the foregoing, where retention of personal information is required under applicable laws and regulations, the Company shall retain such information as follows, and such retained information shall not be used for any purpose other than those prescribed by law:

• Records related to contracts or withdrawal of consent: retained for the period required under applicable laws

• Records related to payment and transaction history: retained for the period required under applicable laws

• Records related to customer inquiries and dispute resolution: retained for the period required under applicable laws

• Other personal information required to be retained under applicable laws and regulations

Upon expiration of the applicable retention period, personal information shall be securely deleted in a manner that prevents recovery or reproduction.

Where personal information must be retained after account deletion pursuant to applicable laws and regulations, such information shall be stored separately and securely, and shall not be used for any purpose other than legal compliance.

5. Disclosure to Third Parties

MOA does not disclose users’ email addresses to third parties as a general rule.

Exceptions may apply in the following cases:

• Where disclosure is required by law or by a lawful request from a government authority, court, or regulator

• Where the user has provided explicit prior consent

  
  

6. International Data Transfers

MOA’s servers and infrastructure may be located outside the user’s country of residence.

Accordingly, email addresses may be transferred to, stored, and processed in other jurisdictions.

By using the Services, users consent to such international transfers.

7. Security Measures

MOA implements reasonable technical and organizational measures to protect personal information, including:

• Limiting access to personal information

• Operating internal management and access control procedures

• Implementing administrative safeguards to prevent security incidents

However, due to the nature of the internet and network environments, MOA cannot guarantee absolute security.

8. User Rights

Users may exercise the following rights at any time:

• Request access to personal information

• Request correction of personal information

• Request deletion of personal information

• Request restriction of processing or withdrawal of consent

Requests may be submitted through the contact details provided below.

9. Age Restriction

MOA’s Services are intended only for users aged 18 or older.

MOA does not knowingly collect personal information from individuals under the age of 18.

If such information is identified, MOA will promptly delete it and restrict access to the Services.

10. Tracking and Advertising Policy

MOA does not collect advertising identifiers (such as IDFA) or engage in user behavior tracking through third-party advertising networks.

However, communications based on the user’s email address for MOA’s own services, updates, and promotional purposesmay be conducted in accordance with this Privacy Policy.

11. Changes to This Privacy Policy

This Privacy Policy may be updated to reflect changes in applicable laws, Services, or internal policies.

Where material changes occur, MOA will provide notice within a reasonable period through the website or application.

12. Contact Information

For inquiries regarding this Privacy Policy or to exercise your rights, please contact us at:

📧 support@moaglobal.io

13. Governing Law

This Privacy Policy is governed by the laws of the British Virgin Islands (BVI)