2. PRIVACY POLICY

1. Introduction

Colibri values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share information when you use our Services, and outlines your rights under applicable data protection regulations, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act

(CCPA).

2. Data We Collect

1. Personal Data: Includes your name, email address, phone number, payment details, and other identifiers (e.g., government-issued ID) if required by law for AML/KYC.

2. Usage Data: We collect data about how you interact with our platform, such as pages visited, timestamps, device type, browser, and IP address.

3. Cookies and Tracking: We use cookies and similar technologies to enhance user experience, analyze trends, and track usage.

3. How We Use Your Data

1. Service Provision: We process your data to facilitate international money transfers, payroll management, multi-currency transactions, and financial analytics.

2. Security and Fraud Prevention: We verify user identity, detect suspicious activities, and maintain secure transactions in compliance with regulatory obligations.

3. Communication: We may send notifications about changes to our Services, Terms, or other relevant updates.

4. Platform Improvement: We analyze usage data to optimize and personalize our Services.

4. Third-Party Services

To provide our Services, we share certain data with or collect certain data via trusted third-party providers, such as:

● Plaid: For secure bank account connectivity and verification.

● Pockyt: For additional payment and digital wallet services. We have agreements in place with these providers to ensure they process data in compliance with applicable privacy laws.

5. Data Storage and Security

1. Security Measures: We use encryption, firewalls, and other technical and

organizational measures to protect your data.

2. Data Location: Your data may be stored on servers located in or outside your

country of residence, in compliance with relevant data protection laws.

6. Your Rights

1. Access and Rectification: You have the right to request access to or correction of your personal data.

2. Erasure (Right to Be Forgotten): You may request the deletion of your personal data, subject to legal retention requirements.

3. Data Portability: Where applicable, you can request the transfer of your personal data to another service provider.

4. Objection: You can object to certain processing activities, such as direct marketing. To exercise these rights, please contact our support channels provided on our platform.

7. Cookies Policy

We use cookies to:

● Remember user preferences (language, region, etc.).

● Analyze traffic and user engagement.

● Provide personalized content or advertisements (if applicable).

You can disable cookies in your browser settings, but this may affect some functionalities of our Services.

8. GDPR and CCPA Compliance

● GDPR: Colibri acts as a “Data Controller” for personal data collected within the European Economic Area (EEA).

● CCPA: We respect the privacy rights of California residents, including the right to know, delete, and opt-out of the sale of personal information.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Any material changes will be posted on

our platform with an updated “Last Revised” date. If you continue to use our Services after

these changes take effect, you agree to the revised policy.