Privacy Policy

Effective date: 2 October 2026

1. Who we are

Grogoo FZ-LLC ("Grogoo", "we") is a company registered in Ras Al Khaimah Economic Zone, United Arab Emirates, Licence No. 47035672, with its registered address at VUNE2495, Compass Building, Al Hulaila, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates. We are the controller of the personal data described in this Policy. Contact: privacy@grogoo.io.

2. Scope

This Policy applies to the website grogoo.io, the waitlist, our customer support and the Grogoo mobile app once it is released. The app is not yet available; sections that describe app data apply from the moment you create a Grogoo account.

3. Data we collect

• Website and waitlist: your email address when you join the waitlist, and basic technical data such as IP address and browser type.
• Account data: email address, phone number where provided, password and payment-password hashes, two-factor authentication settings.
• Identity verification data: full name, date of birth, nationality, residential address, identity document images and numbers, a selfie or liveness check, verification results, sanctions and politically-exposed-person screening results.
• Financial data: wallet addresses we assign to you, balances, deposits, withdrawals, card top-ups, card transactions, marketplace purchases and QR payments.
• Card data: card status, masked card number and the delivery address for physical cards. Full card details are generated and held by the card issuer.
• Device and technical data: device model, operating system, app version, IP address, device identifiers, push notification token, log and crash data.
• Support data: messages and attachments you send us.

We do not collect your contacts, precise location or advertising identifiers, and we do not use your data for third-party advertising or tracking.

4. Why we use it

To operate the waitlist and tell you when the app is available; to open and operate your account; to hold and transfer digital assets on your instruction; to issue and service cards; to verify your identity and meet anti-money-laundering, counter-terrorist-financing and sanctions obligations; to prevent fraud and secure accounts; to provide support; to fix errors and improve the service; and to comply with law and respond to lawful requests.

5. Legal bases

Performance of our contract with you, compliance with legal obligations, our legitimate interests in security and fraud prevention, and your consent where it is required.

6. Who receives your data

We share data only as needed with: our identity verification and screening provider; the card issuer and card programme partners; payment providers that process QR payments; blockchain infrastructure providers (blockchain transactions are public by nature); hosting, email, form and push notification providers; professional advisers; and authorities where the law requires. The providers used for your account are named in the app. These parties are bound to protect your data to a standard equal to this Policy. We do not sell personal data.

7. International transfers

Your data may be processed outside your country of residence, including in the countries where we and our providers operate. We use contractual safeguards where the law requires them.

8. Retention

Waitlist emails are kept until you unsubscribe or until the waitlist is closed. Account and transaction data are kept while your account is open. After closure we keep identity verification and transaction records for at least five years, or longer where the law requires, and then delete or anonymise them. Technical logs are kept for up to twelve months.

9. Your rights and account deletion

You may request access to, correction of, deletion of, restriction of and a copy of your data, and you may object to processing or withdraw consent at any time. To remove your email from the waitlist or to delete your account, see grogoo.io/delete-account. Some records must be retained after deletion as described in section 8.

10. Security

We use encryption in transit, encrypted storage of sensitive data, role-based access for staff, two-factor authentication and a separate payment password. No system is fully secure. If you suspect unauthorised access, write to security@grogoo.io at once.

11. Children

Grogoo is for people aged 18 and over. We do not knowingly collect data from minors.

12. Changes

We will post changes on this page and, once the app is available, notify you in the app when they are material.

13. Contact

Privacy requests: privacy@grogoo.io. Complaints: complaints@grogoo.io. Grogoo FZ-LLC, VUNE2495, Compass Building, Al Hulaila, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates.