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Terms & Policies

Privacy Policy

Introduction

At Sinku, protecting your personal data is fundamental to everything we do. This Privacy Policy explains what information we collect, why we collect it, how we use it, and the choices you have.

When we say 'Sinku', 'we', 'us', or 'our', we're referring to MORABI, SOCIEDADE UNIPESSOAL LDA, the financial technology company that develops and operates the Sinku App. Sinku is not a bank. Sinku is a technology platform that provides a user interface enabling access to services offered by independent third-party providers, including Privy (wallet infrastructure) and our licensed financial partner (payment card and financial services). Sinku does not itself offer, hold, or transmit funds or provide regulated financial services.

By using the Sinku app, website, or any of our services, you agree to the collection and use of your information in accordance with this policy. Please also review the privacy policies of our third-party service providers, as they may independently collect and process your data.

What data do we collect?

We collect information you provide directly, information generated by your use of our services, and information from third-party sources. Here's a breakdown:

Information you provide

When you sign up and use Sinku, we ask you for personal details such as your full name, date of birth, nationality, residential address, email address, phone number, and government-issued ID. We also collect a selfie for identity verification purposes. If you contact our support team, we keep a record of that communication to help us resolve your issue and improve our service.

Information we collect automatically

When you use the Sinku app or website, we automatically collect certain technical and usage data. This includes your device type, operating system, IP address, app version, browser type, language preferences, and how you interact with our services (such as pages visited and features used). We also collect transaction data — including amounts, currencies, dates, and recipient details — as part of providing our payment services.

Information from third parties

We may receive information about you from third-party sources such as identity verification providers, credit reference agencies, fraud prevention services, and public databases. This helps us verify your identity, assess risk, and meet our regulatory obligations.

How do we use your data?

We use your personal data for the following purposes:

Providing our services

To open and maintain your account, process transactions, deliver your debit card, facilitate currency exchange, and provide customer support.

Security and fraud prevention

To protect your account and our platform from fraud, money laundering, and other financial crime. This includes monitoring transactions in real-time, verifying your identity, and conducting security checks.

Legal and regulatory compliance

To meet our obligations under applicable laws and regulations, including anti-money laundering (AML) rules, know your customer (KYC) requirements, tax reporting obligations (CRS and FATCA), and requests from regulatory bodies or law enforcement.

Improving our services

To understand how people use Sinku so we can improve the app, fix bugs, develop new features, and make better decisions about our product. We may use aggregated, anonymised data for this purpose.

Communications

To send you important account notifications (such as transaction alerts, security warnings, and regulatory updates). We may also send you marketing communications if you've opted in — you can change your preferences at any time in the app.

Our legal basis for processing

Depending on the type of data and the purpose, we rely on one or more of the following legal grounds to process your personal data:

Contractual necessity — processing that is required to provide you with our services under the terms of your account agreement.

Legal obligation — processing that is necessary to comply with laws and regulations that apply to us and to the third-party financial service providers operating through our platform.

Legitimate interests — processing that serves our business purposes (such as fraud prevention, product improvement, and security) provided it doesn't override your rights and freedoms.

Consent — where you've given us explicit permission, for example to send you marketing communications or to use certain cookies. You can withdraw consent at any time.

Who do we share your data with?

We don't sell your personal data. We may share it with the following categories of recipients when necessary:

Service providers

Third parties that help us run our business and deliver services through our platform — including Privy (non-custodial wallet infrastructure), our licensed financial partner (payment cards and financial services), cloud hosting providers, identity verification services, card networks (Visa and Mastercard), and customer support tools. These providers are contractually bound to protect your data and can only use it for the purposes we specify.

Regulatory and legal authorities

Government bodies, regulators, tax authorities, law enforcement agencies, and courts where we're legally required to share information or where it's necessary to prevent financial crime.

Partner institutions

Banking partners and financial institutions involved in processing your transactions, delivering your card, or providing specific account features.

Within the Sinku group

Other Sinku entities may access your data where necessary to provide services, ensure compliance, or support operations across our group.

International data transfers

Because Sinku operates across multiple countries, your data may be transferred to and processed in countries outside your country of residence. When this happens, we ensure appropriate safeguards are in place — such as standard contractual clauses or equivalent protections — to keep your data secure.

By using Sinku, you acknowledge that your data may be processed in jurisdictions that have different data protection laws from your own.

How long do we keep your data?

We keep your personal data for as long as your account is active and for a period after closure as required by law. The exact retention period depends on the type of data and the legal obligations that apply.

For most financial records, we're required to retain data for at least 5 to 7 years after your account is closed. Some data may be kept longer if needed for ongoing legal proceedings or regulatory investigations.

Once the retention period expires, your data is securely deleted or anonymised so that it can no longer be linked to you.

Your rights

Depending on where you live, you may have some or all of the following rights regarding your personal data:

Right of access

You can request a copy of the personal data we hold about you at any time.

Right to rectification

If any of your data is inaccurate or incomplete, you can ask us to correct it. You can also update most details directly in the app under 'Personal details'.

Right to erasure

You can ask us to delete your personal data in certain circumstances. However, we may need to retain some data to comply with legal obligations.

Right to restrict processing

You can ask us to limit how we use your data in certain situations — for example, while a complaint is being resolved.

Right to data portability

You can request your data in a structured, machine-readable format so you can transfer it to another provider.

Right to object

You can object to certain types of processing, including direct marketing. If you object to marketing, we'll stop immediately.

Right to withdraw consent

Where we process your data based on your consent, you can withdraw it at any time. This won't affect any processing that already took place.

How to exercise your rights

You can exercise most of your data rights directly in the Sinku app by going to your profile and tapping 'Privacy'. You can also contact our support team via the in-app chat or by emailing support@sinku.io.

We'll respond to your request within 30 days. In some cases, we may need to verify your identity before processing your request.

How we protect your data

We take the security of your personal data seriously and use a combination of technical and organisational measures to protect it. These include:

Encryption of data in transit and at rest, strict access controls so that only authorised personnel can access personal data, regular security audits and vulnerability testing, employee training on data protection and security practices, and incident response procedures to handle any data breaches quickly and effectively.

While no system is completely immune to risk, we continuously invest in our security infrastructure to stay ahead of emerging threats.

Applicable data protection laws

Sinku operates across multiple jurisdictions. The processing of your personal data is governed by the data protection laws applicable in the country where you are located at the time of access. We are committed to respecting the principles of applicable data protection frameworks, including the General Data Protection Regulation (GDPR) for users in the European Union and European Economic Area, local data protection laws in PALOP countries and other African nations where we operate, and applicable privacy laws in the Americas and other regions where our services are available.

Regardless of your location, we apply a consistent standard of data protection based on internationally recognised best practices.

Partner data processing

By using Sinku, you acknowledge and accept that the sharing of personal and transactional data between Sinku and its third-party partners is strictly necessary for the delivery of the services you have chosen (such as payment cards, currency exchange, and wallet functionality).

When you use services provided through our partners, your data may be processed by those partners as independent data controllers under their own privacy policies. We encourage you to review the privacy policies of our partners, including our licensed financial partner and Privy, for details on how they handle your data.

We only share the minimum data necessary for each partner to deliver their specific service, and we require all partners to maintain appropriate security and privacy safeguards.

Wallet and blockchain data

Wallet functionality within the Sinku App is powered by Privy, a non-custodial wallet infrastructure provider. You should be aware of the following regarding your data in this context:

On-chain data

Certain transactions made through the Sinku App may be recorded on public blockchains. By design, data recorded on a blockchain — including wallet addresses and transaction values — is immutable, transparent, and public in nature. The exercise of privacy rights such as deletion or rectification is not technically possible for on-chain records.

Wallet credentials

Sinku does not have access to your wallet's private keys or recovery phrases. Any data related to your wallet authentication is processed by Privy under their own privacy and security policies. We do not store or have the ability to retrieve your private wallet credentials.

Wallet address sharing

We may share your wallet address with infrastructure partners and blockchain analytics providers for the purpose of technical integration, asset settlement, and financial crime prevention.

Additional information for users in the European Union

If you are located in the European Union or European Economic Area, the processing of your personal data is subject to the General Data Protection Regulation (GDPR). Our legal bases for processing your data include: (i) your consent for specific purposes such as marketing communications; (ii) contractual necessity to provide you with our services; (iii) compliance with legal obligations; and (iv) our legitimate interests, provided your fundamental rights and freedoms do not override those interests.

Under the GDPR, you have the right to: request access to and obtain a copy of your personal data, request rectification or erasure of your personal data, object to or restrict the processing of your data, request data portability, and withdraw your consent at any time. Please note that we cannot edit or delete information stored on a public blockchain, as such records are beyond our control.

To exercise any of your rights under the GDPR, contact us at support@sinku.io or through the in-app chat. You also have the right to lodge a complaint with your local data protection supervisory authority.

Electronic communications

By creating a Sinku account, you consent to receive all communications, contracts, and legal notices from us electronically. These include service updates, terms changes, security alerts, transaction confirmations, and support communications.

Electronic communications from Sinku satisfy any legal requirement that such communications be made in writing. You are responsible for keeping your email address and phone number up to date to ensure you receive all important notifications.

Business transfers

In the event of a merger, acquisition, reorganisation, or sale of assets involving Sinku, your personal data may be transferred to the acquiring entity. Any such transfer will be conducted under the same privacy standards set out in this policy.

We will notify you of any change in ownership or use of your personal data, as well as any choices you may have regarding your data, before any such transfer takes effect.

Children's privacy

Sinku is currently available only to individuals aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we discover that we've inadvertently collected data from a minor, we'll delete it promptly.

Support for younger users is on our roadmap — when it launches, it will have its own age-appropriate privacy practices.

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make significant changes, we'll notify you via the app or email before they take effect.

We encourage you to review this policy periodically. The date at the bottom of this page tells you when it was last updated.

Contact us

If you have questions about this Privacy Policy or how we handle your data, get in touch:

Email: support@sinku.io

In-app chat: Go to your profile and tap 'Help'

If you're not satisfied with how we've handled a data protection concern, you may have the right to lodge a complaint with your local data protection authority.

Last updated: February 2026