Consumer Privacy Policy

TeleGiro, Inc.

Effective Date: March 2026

Our Privacy Commitment

TeleGiro, Inc. ("We," "Us" and "Our") is committed to respecting and protecting the privacy of Our consumers across all our digital financial services, including payments and remittances.

This privacy policy applies to personal information We collect about consumers when they:

• Use our digital wallet and payment services
• Initiate domestic or international payment transactions
• Access our services through mobile applications or Our website
• Otherwise provide personal information to Us

Privacy Statement

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires Us to tell You how we collect, share and protect your personal information. Please read this notice carefully to understand what we do.

The Types of Personal Information We Collect and Share

The types of personal information we collect and share depend on the product or service you have with us. This information can include (but is not limited to):

Contact Information:

• Name, address, mobile and home telephone numbers
• Email address
• Emergency contact information

Identification Information:

• Social Security Number
• Driver's license number, passport number or other government identification number
• Date of birth
• Citizenship and residency status

Financial Information:

• Bank account information (including FBO accounts)
• Debit and credit card information
• Digital wallet account details
• Payment history and preferences

Transaction Information:

• Transaction dates, amounts, and types
• Sender and recipient information
• Payment method details
• International remittance details

Identity Verification and Biometric Information:

• Government-issued identity documents
• Facial images used for liveness detection and document matching (retained only for the duration of the verification session and deleted immediately upon completion)
• BSA/AML screening results and risk assessment data

Technical Information:

• Computer and mobile device information
• IP address and geolocation data
• Browser and operating system information
• Cookie data and similar technologies

Reasons We Can Share Your Personal Information

For our everyday business purposes:

• Process your transactions including remittances, ACH transfers, checks, and wire transfers
• Maintain your digital wallet and payment accounts
• Provide access to FBO accounts through our banking partners
• Validate your identity and comply with KYC/AML requirements
• Enable payment processing through Checkbook Inc.

Legal and Regulatory Compliance:

• Cooperate with criminal or government investigations
• Detect and prevent fraud, money laundering, and other illegal activities
• Respond to court orders, subpoenas, and regulatory inquiries
• Report to regulatory agencies including FinCEN as required under the Bank Secrecy Act
• Comply with state money transmitter laws in Florida and New Jersey
• Meet requirements under the Gramm-Leach-Bliley Act and USA PATRIOT Act

Business Operations:

• Share with service providers including: Checkbook Inc. (payment processing), White Wings Technologies / IDM Global (identity verification), Plaid Inc. (bank account verification), OpenSanctions Datenbanken GmbH (sanctions screening), Banking Partners (FBO account services)
• In connection with a merger, acquisition or any form of sale of some or all of business
• As otherwise permitted or required by law

How Does TeleGiro Protect My Personal Information?

To help protect your personal information from unauthorized access and use, we use security measures that comply with federal law and industry best practices:

• Employee training and access controls
• Encryption of data in transit and at rest
• Multi-factor authentication
• Secure API connections with partners
• Regular security assessments and incident response procedures

In accordance with the FTC Safeguards Rule under the Gramm-Leach-Bliley Act, we maintain a comprehensive information security program that includes administrative, technical, and physical safeguards to protect customer information.

International Data Storage

Some data processed on your behalf by our service providers may be stored on secure cloud infrastructure located within the European Union. All such data transfers are subject to appropriate contractual safeguards and handled in compliance with applicable law.

How Does TeleGiro Collect My Personal Information?

We collect your personal information, for example, when you:

• Open a digital wallet or payment account
• Submit information on applications and forms
• Link bank accounts or payment methods
• Send or receive money domestically or internationally
• Complete identity verification processes
• Use our online sites or mobile apps

We also collect information from third-party sources including Checkbook Inc., banking partners, consumer reporting agencies, and identity verification services.

How Long Does TeleGiro Keep My Personal Information?

We retain your personal data for the period of time necessary to satisfy the purposes outlined in this Privacy Policy, comply with our record retention policies, and meet legal and regulatory requirements.

• Transaction records: Up to 5 years from date of transaction as required by BSA (31 C.F.R. §1022.410); longer periods may apply
• Identity verification records: 5 years after account closure
• Suspicious activity reports: 5 years
• Other records as required by the Bank Secrecy Act, USA PATRIOT Act, and state regulations

State-Specific Privacy Rights

California Residents

Under the California Consumer Privacy Act (CCPA), you have rights to know what personal information we collect, request deletion (subject to legal requirements), opt-out of the sale of personal information (we do not sell personal information), and non-discrimination for exercising privacy rights. Contact us at privacy@telegiro.com.

New Jersey Residents

New Jersey residents may request information about categories of personal information collected, how we use and disclose information, and your rights regarding your information. Contact: New Jersey Department of Banking and Insurance, 20 West State Street, PO Box 040, Trenton, NJ 08625-0040, Phone: (609) 292-7272

Florida Residents

Florida law requires us to inform you that we do not sell your personal information. Contact: Florida Office of Financial Regulation, 200 East Gaines Street, Tallahassee, FL 32399, Phone: (850) 487-9687

Because TeleGiro operates as a regulated financial institution, certain information may be retained or shared as required by federal and state financial regulations, even if you request deletion or opt out of sharing. This includes records required under the Bank Secrecy Act, USA PATRIOT Act, and applicable state money transmitter laws.

Cookies and Similar Technologies

We use cookies and similar technologies to maintain secure sessions, remember your preferences, process transactions safely, comply with regulatory requirements, and improve our services. For detailed information, please see our separate Cookie Policy available at www.telegiro.com/cookie-policy.

Changes

TeleGiro reserves the right to modify this Privacy Statement. When we make material changes, we will update the effective date and notify you through our website or app.

You can always access the current Privacy Statement at www.telegiro.com/privacy.

Questions

Phone: (323) 546-9392

Email: info@telegiro.com

TeleGiro, Inc.

5201 Waterford District Drive, 9th Floor

Miami, Florida 33126

Data Protection Officer: compliance@telegiro.com

TeleGiro, Inc. — Licensed Money Transmitter | Not a Bank

Florida License #FT230000431 | New Jersey License #2305779 | FinCEN MSB Registration #31000298380846

5201 Waterford District Drive, 9th Floor, Miami, Florida 33126 | (323) 546-9392