Privacy Policy
Last Updated: 17 March 2026
MOOZARS LTD ("we," "our," or "us") operates satellite-resilient stablecoin settlement infrastructure for global petroleum, energy, and commodity markets. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services.
Please read this Privacy Policy carefully. By accessing or using our services, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.
International Compliance: This Privacy Policy complies with data protection regulations in multiple jurisdictions, including GDPR (EU), UK GDPR, HKMA requirements (Hong Kong), CCPA (California/US), PIPL (China), and applicable Asia-Pacific data protection laws.
1. Information We Collect
1.1 Information You Provide
We collect information that you voluntarily provide to us when you:
- Register for an account
- Use our stablecoin settlement services
- Execute commodity trade settlements
- Contact us for support
- Complete identity verification (KYC/AML)
This information may include:
- Name and contact information (email address, phone number, postal address)
- Account credentials (username, password)
- Identity verification information (government-issued ID, proof of address)
- Financial information (bank details, wallet addresses, transaction history)
- Source of funds documentation
- Communications you send to us
1.2 Automatically Collected Information
When you access our services, we automatically collect certain information, including:
- Device information (device type, operating system, unique device identifiers)
- Usage data (features accessed, time spent, interaction patterns)
- Location data (with your permission)
- Satellite connectivity data (connection status, signal quality)
- Log data (IP address, browser type, access times)
- Cookies and similar tracking technologies
2. How We Use Your Information
We use the information we collect for the following purposes:
2.1 Service Provision
- To create and manage your account
- To provide stablecoin settlement services
- To process petroleum and commodity trade settlements
- To facilitate satellite-connected payment processing
- To provide customer support
2.2 Compliance and Regulatory Requirements
- To comply with KYC/AML regulations in UK, Hong Kong, and other jurisdictions
- To meet HKMA licensing and regulatory requirements
- To conduct sanctions screening and anti-money laundering checks
- To report to financial regulators as required by law
- To maintain audit trails and transaction records
2.3 Communication
- To send you technical notices and updates
- To respond to your inquiries and requests
- To provide regulatory notices and compliance communications
- To send you news about our services (with your consent)
2.4 Security and Fraud Prevention
- To verify your identity and prevent fraud
- To detect and prevent money laundering
- To monitor for suspicious transactions
- To protect the rights, property, and safety of MOOZARS LTD and our users
2.5 Service Improvement
- To analyze usage patterns and improve our services
- To develop new features and functionality
- To optimize satellite connectivity performance
3. How We Share Your Information
We may share your information in the following circumstances:
3.1 Regulators and Authorities
We share information with regulatory bodies and authorities as required, including:
- Hong Kong Monetary Authority (HKMA)
- Financial Conduct Authority (FCA) - United Kingdom
- European financial regulators (for EU operations)
- US regulatory authorities (for US operations)
- Chinese regulatory authorities (for China operations)
- Law enforcement agencies when required by law
3.2 Financial and Service Partners
We may share your information with:
- Banking partners and liquidity providers
- Settlement network participants
- Payment processors and custody providers
- KYC/AML verification service providers
- Satellite connectivity infrastructure providers
- Cloud storage and hosting providers
3.3 Legal Requirements
We may disclose your information if required to do so by law or in response to:
- Valid legal processes (subpoenas, court orders)
- Regulatory inquiries or investigations
- Requests from law enforcement or government authorities
- Protection of our rights or the rights of others
3.4 Business Transfers
In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction.
3.5 With Your Consent
We may share your information for any other purpose with your explicit consent.
Important: We do not sell your personal data to third parties.
4. International Data Transfers
As a global stablecoin settlement infrastructure provider operating across multiple jurisdictions, we transfer personal data internationally, including between our operations in the United Kingdom, Hong Kong, and other countries.
We ensure appropriate safeguards for international transfers through:
- EU Standard Contractual Clauses (SCCs)
- UK International Data Transfer Agreements (IDTAs)
- HKMA-approved cross-border data transfer mechanisms
- Adequacy decisions where applicable
- Encryption and security measures during transfer
5. Data Security
We implement appropriate technical and organizational measures to protect your information, including:
- End-to-end encryption of data in transit and at rest
- Secure satellite communication protocols
- Bank-grade security infrastructure
- Multi-factor authentication
- Regular security assessments and audits
- Access controls and authentication mechanisms
- Employee training on data protection
- Compliance with HKMA technology risk management guidelines
However, no method of transmission over the Internet or satellite network is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.
6. Data Retention
We retain your information for as long as necessary to:
- Provide our services to you
- Comply with legal, regulatory, or contractual obligations
- Meet financial services record-keeping requirements (typically 7 years)
- Satisfy HKMA, FCA, and other regulatory retention obligations
- Resolve disputes and enforce our agreements
When your information is no longer needed, we will securely delete or anonymize it in accordance with applicable laws and regulations.
7. Your Rights
7.1 EU/UK Users (GDPR/UK GDPR)
You have the right to:
- Access your personal data
- Rectify inaccurate data
- Request erasure (subject to regulatory retention requirements)
- Restrict or object to processing
- Data portability
- Withdraw consent
- Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk
7.2 Hong Kong Users (PDPO)
You have the right to:
- Request access to and correction of your personal data
- Object to the use of personal data for direct marketing
- Lodge a complaint with the Privacy Commissioner for Personal Data at pcpd.org.hk
7.3 California/US Users (CCPA)
California residents have the right to:
- Know what personal information is collected
- Know whether personal information is sold or disclosed
- Opt-out of the sale of personal information (we do not sell data)
- Request deletion of personal information
- Non-discrimination for exercising CCPA rights
7.4 China Users (PIPL)
Users in China have the right to:
- Access and copy your personal information
- Request correction or supplementation
- Request deletion under certain circumstances
- Withdraw consent for processing based on consent
7.5 Exercising Your Rights
To exercise any of these rights, please contact us using the information provided in the Contact Us section below.
8. Legal Basis for Processing
We process your personal data based on the following legal grounds:
- Contractual Necessity: Processing necessary to provide stablecoin settlement services
- Legal Obligation: Processing required to comply with KYC/AML, HKMA, FCA, and other regulatory requirements
- Legitimate Interests: Processing necessary for fraud prevention, security, and service improvement
- Consent: Processing based on your explicit consent (which you can withdraw at any time)
9. Children's Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete such information promptly.
10. Cookies and Tracking Technologies
We use essential cookies for platform functionality and analytics cookies to improve our services. You may control cookies through your browser settings. However, disabling cookies may affect the functionality of our services.
11. Third-Party Links and Services
Our services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party services you access.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons. We will notify you of any material changes by:
- Posting the updated Privacy Policy on our website
- Updating the "Last Updated" date at the top of this policy
- Sending you an email notification (for significant changes)
Your continued use of our services after any changes indicates your acceptance of the updated Privacy Policy.