Privacy Policy

Globana (“Globana,” “we,” “ our,” or “us”) is committed to protecting your personal data and maintaining transparency regarding how information is collected, used, processed, and shared when you use our mobile application, website, and related financial services (collectively, the “Services”).

Globana operates as a technology platform that interfaces with licensed financial institutions and regulated service providers. Certain financial services accessible through the platform are provided by third-party partners that act as independent data controllers under applicable law.

By using the Services, you acknowledge and consent to the practices described in this Privacy Policy.

Depending on the activity, Globana may act as:

• Data Controller for account information, communications, and platform usage data
• Data Processor or Intermediary for financial and identity data processed by regulated partners

Licensed banking partners and financial service providers are independently responsible for data required to provide regulated services, including identity verification, transaction monitoring, and regulatory reporting.

We collect the following categories of data:

A. Information You Provide

• Full name
• Date of birth
• Address
• Phone number
• Email address
• Government-issued identification details
• Account credentials

B. Identity Verification Information

To comply with financial regulations, identity verification data (including biometric identifiers such as selfies or liveness checks) may be collected and processed by our regulated verification and banking partners. Globana does not independently store biometric data.

C. Financial Information

Handled primarily by partner financial institutions:

• Transaction records
• Wallet balances
• Payment instructions
• Linked account information

D. Technical and Usage Data

We may collect:

• Device type
• Operating system
• App activity logs
• IP address
• Interaction events
• Cookie or similar tracking data

We collect data through:

• Direct user submission
• Partner integrations
• Automated technologies
• Identity verification workflows
• Transaction processing systems

We process personal data only where permitted under applicable law, including when:

• Necessary to provide requested services
• Required to comply with legal obligations
• Necessary to prevent fraud or misuse
• You provide consent
• Processing is required for legitimate business interests that do not override your rights

We use information to:

• Create and maintain accounts
• Facilitate financial services
• Verify identity
• Prevent fraud and unauthorized activity
• Respond to inquiries
• Improve platform functionality
• Comply with regulatory obligations
• Send service notifications and updates
• Deliver optional promotional communications (where permitted)

Financial services accessed through Globana may involve automated systems operated by our partners to:

• verify identity
• detect fraud
• screen against sanctions lists
• monitor transactions for suspicious activity

These processes are required for regulatory compliance and fraud prevention.

We do not sell personal data.

We may share data with:

Service Providers

Technology vendors, analytics providers, and infrastructure partners.

Financial Institutions & Compliance Providers

Licensed banks, payment processors, KYC vendors, and regulatory compliance partners.

Authorities

Where disclosure is required by law, regulation, court order, or lawful governmental request.

Business Transfers

If Globana undergoes merger, acquisition, or restructuring.

All third-party providers are contractually required to safeguard personal data.

Your information may be processed outside your country of residence, including jurisdictions where our partners operate. When transfers occur, appropriate safeguards are used to ensure compliance with applicable data protection laws.

Globana retains personal data only for as long as necessary to:

• provide services
• comply with legal obligations
• resolve disputes
• enforce agreements

Financial and identity records may be retained by regulated partners for legally mandated retention periods, which may extend for several years after account closure.

We implement administrative, technical, and organizational safeguards designed to protect personal data against unauthorized access, disclosure, or misuse. These include:

• encryption in transit and at rest
• access control restrictions
• monitoring systems
• vendor due diligence
• periodic security reviews

No system is completely secure; users are responsible for safeguarding login credentials.

Subject to applicable law, you may have the right to:

• access your data
• request correction
• request deletion of platform-held data
• restrict processing
• withdraw consent
• request a copy of your information

Requests may be submitted using the contact information below.

Note: Certain financial records must be retained by regulated partners for compliance purposes and may not be deletable upon request.

Globana does not provide services to individuals under the age of 18 and does not knowingly collect data from minors.

The Services may contain links or integrations with third-party platforms. Globana is not responsible for the privacy practices of external services.

We may update this Privacy Policy periodically. Material updates will be communicated through in-app notifications, email, or website notice. Continued use of the Services constitutes acceptance of the updated Terms.

For privacy-related questions or requests:

Globana Privacy Team
admin@encoholdings.com