This Privacy Policy explains how personal data is collected, used, stored, and shared when you access or use the MULTIBANQ website, platform, dashboards, tools, and related services (collectively, the “Platform”).

For the purposes of this Privacy Policy, “MULTIBANQ”, “we”, “us”, or “our” refers to the MULTIBANQ platform operated through affiliated entities, including GTECHSPRO S.A., and where applicable, affiliated entities and partners supporting contracting, compliance, and service delivery, including Switzerland.

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1. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed in connection with:

• Visits to MULTIBANQ websites and portals

• Use of dashboards, platforms, and payment or onboarding panels

• Use of software, including web, desktop, or mobile applications

• Communications with MULTIBANQ, including email, messaging, telephone, or web chat

• Business onboarding, verification, and compliance-related interactions

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2. Layered Privacy Approach

MULTIBANQ follows a layered privacy approach in line with regulatory guidance. This Privacy Policy provides high-level information about how personal data is handled. More specific notices may be provided during onboarding, verification, or when using particular services.

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3. Personal Data We May Collect

Depending on how you interact with the Platform, we may collect or receive the following categories of personal data:

• Identification data (e.g. name, date of birth, nationality)

• Contact details (e.g. email address, telephone number, business address)

• Business and corporate data (e.g. company name, registration details, beneficial ownership)

• Verification and compliance data (e.g. identity documents, screening results)

• Technical data (e.g. IP address, browser type, device identifiers)

• Usage data (e.g. platform activity, logs, access timestamps)

• Communications data (e.g. emails, support requests, messages)

• Marketing preferences, where applicable

We may collect data directly from you, automatically through use of the Platform (including cookies), or from third parties such as verification providers, screening services, or regulated partners.

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4. How We Use Personal Data

Personal data is processed for the following purposes:

• To provide, operate, and maintain the Platform

• To support onboarding, verification, and compliance processes

• To communicate with you regarding services, updates, and support

• To manage security, risk, and fraud prevention

• To improve platform functionality and user experience

• To comply with legal, regulatory, and contractual obligations

• To respond to lawful requests from authorities

Marketing communications are sent only where permitted by law and in accordance with your preferences.

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5. Legal Basis for Processing

We process personal data on one or more of the following legal bases, as applicable:

• Performance of a contract or steps taken prior to entering into a contract

• Compliance with legal or regulatory obligations

• Legitimate interests (such as platform security, risk management, and service improvement), where those interests do not override your rights

• Consent, where required (e.g. marketing communications)

• Protection of vital interests or public interest obligations

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6. Disclosure of Personal Data

We may share personal data with:

• Regulated and professional third-party service providers (e.g. verification, compliance, payment, banking, custody, or technology providers)

• Affiliates and partners supporting service delivery and compliance

• Law enforcement, regulators, or authorities where required by law

• Professional advisers (e.g. legal, audit, compliance)

Personal data is shared only to the extent necessary and subject to appropriate safeguards.

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7. International Data Transfers

Personal data may be transferred to, stored, or processed in jurisdictions outside your country of residence, including outside the European Economic Area (EEA).

Where such transfers occur, MULTIBANQ applies appropriate safeguards, such as contractual protections or reliance on regulatory adequacy mechanisms, to ensure personal data remains protected.

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8. Data Security

MULTIBANQ implements technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, or alteration.

You are responsible for maintaining the confidentiality of any access credentials and must not share login details with third parties.

While reasonable measures are taken to protect data, no method of transmission over the internet is entirely secure.

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9. Data Retention

Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting, or reporting obligations.

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10. Your Rights

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

• Access your personal data

• Correct or update inaccurate data

• Request deletion of personal data

• Object to or restrict certain processing

• Request data portability

• Withdraw consent where processing is based on consent

Some rights may be limited where processing is required for legal, regulatory, or compliance purposes.

Requests may be submitted using the contact details below.

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11. Automated Decision-Making

Certain processes may involve automated decision-making, including compliance screening and risk assessment. Where required by law, you may request human review of such decisions.

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12. Cookies

The Platform uses cookies and similar technologies. Further information is available in the Cookies Statement.

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13. Changes to This Privacy Policy

This Privacy Policy may be updated periodically. The most current version will be published on the MULTIBANQ website.

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14. Contact & Data Protection

For questions, requests, or concerns regarding this Privacy Policy or personal data processing, please contact us via the contact form available on the MULTIBANQ website.

Where applicable, data protection matters are overseen by a designated data protection function.