Privacy Policy

MRL Group Ltd.
Company No.: 514288588
Address: 2 Menorat Hamaor St., Tel Aviv, Israel
Email for privacy inquiries: business@finholy.com

1. Introduction

1.1. This Privacy Policy (“Policy”) explains how MRL Group Ltd. (“the Company”, “we”, “us”) collects, uses, stores, protects, and shares personal information of users (“User”, “you”) using our digital wallet and related financial services (“the Service”, “the Wallet”).

1.2. By using the Service, you consent to the practices described in this Policy.

1.3. The Company may update this Policy at any time. Updated versions will be published through the app or website.

2. Information We Collect

We collect two types of information: personal information and technical/operational information.

2.1. Personal Information Required to Use the Service

  • Full name
  • Identification number (ID/Passport)
  • Date of birth
  • Address
  • Phone number
  • Email address
  • Government-issued ID documents for verification (KYC)
  • Proof of address (if required)
  • Source of funds documentation (if required for AML/CTF)
  • Selfie or biometric verification (if required)
  • Bank account information
  • Tokenized credit/debit card information
(We do not store full card numbers; we use tokenization methods.)


2.2. Technical and Usage Information

  • IP address
  • Device type, operating system, browser type
  • Geolocation data (only with user consent)
  • Device identifiers and session tokens
  • Log data and user activity within the app
  • Security metadata used for fraud detection


2.3. Financial Information

  • Wallet balance
  • Transaction history
  • Transfer history with other users
  • Deposit and withdrawal activity
  • Card transactions (if card is used)
  • Verification status and compliance checks


3. Purpose of Data Processing

We collect and process information for the following purposes:

3.1. To Provide and Operate the Service

  • Creating and managing user accounts
  • Identity verification (KYC)
  • Processing deposits, withdrawals, and transfers
  • Enabling card transactions
  • Providing customer support
  • Sending notifications and updates


3.2. Legal and Regulatory Requirements

  • Compliance with AML (Anti-Money Laundering) laws
  • Compliance with CTF (Counter-Terrorism Financing) laws
  • Fraud detection and prevention
  • Transaction monitoring
  • Reporting obligations to authorities when required


3.3. Security

  • Protecting the integrity of the platform
  • Detecting unauthorized access
  • Preventing misuse or fraudulent activity


3.4. Service Improvement

  • Analyzing user behavior
  • Improving functionality and features
  • Enhancing user experience
  • Fixing bugs and technical issues


4. Sharing Personal Information

We may share user information only in the following situations:

4.1. With Third-Party Service Providers

For operation of the Wallet:

  • Payment processors and card networks
  • Banks and financial institutions
  • Identity verification (KYC) providers
  • Fraud detection and risk management systems
  • Cloud hosting providers
  • SMS/Email communication providers

All service providers are contractually obligated to maintain confidentiality and adequate data protection.

4.2. With Financial Institutions

When required for:

  • Processing transactions
  • Issuing payment cards
  • Performing compliance checks


4.3. With Law Enforcement or Regulators

We may disclose information where required:

  • By law
  • By court order
  • To comply with AML/CTF obligations
  • To report criminal or fraudulent activity


4.4. Anonymized and Aggregated Data

We may use anonymized data (with all identifiers removed) for:

  • Analytics
  • Research
  • Improving service performance

This data does not identify any individual user.

5. International Data Transfers

The Company may store or process information on servers located outside Israel, including in the EU, US, or other jurisdictions.

Transfers will follow:

  • Applicable privacy laws
  • GDPR safeguards (when required)
  • Standard Contractual Clauses (SCCs) where relevant


6. Data Retention

6.1. Data is stored as long as your account is active.

6.2. After account closure, data may be stored for an additional period as required by:

  • AML regulations
  • Financial reporting laws
  • Legal obligations


6.3. When no longer required, data will be deleted or anonymized.

7. Data Security

The Company uses advanced security measures, including:

  • Encryption (in transit and at rest)
  • Multi-factor authentication (2FA)
  • Secure access controls
  • Firewalls and intrusion detection
  • Real-time fraud monitoring
  • Regular security audits

Users are responsible for maintaining the confidentiality of their login information.

8. Your Rights

Depending on jurisdiction, users may have the right to:

  • Access personal data we hold
  • Request correction of inaccurate data
  • Request deletion (subject to legal obligations)
  • Restrict processing of certain data
  • Withdraw consent (for optional data like geolocation)
  • Request a copy of their data (data portability)

To exercise rights:
📧 Email: business@finholy.com

9. Cookies and Tracking Technologies

We use cookies and similar technologies for:

  • Security
  • Authentication
  • User session management
  • Analytics
  • Improving user experience

Users can control cookie settings through their browser or device.

10. Marketing Communications

10.1. Marketing messages are sent only with explicit user consent.

10.2. Users may unsubscribe at any time.

11. Children’s Privacy

The Service is not intended for individuals under 18 years of age.
We do not knowingly collect data from minors.

12. Policy Changes

We may update this Policy from time to time.
Changes will be communicated via the app or website.
Continued use of the Service constitutes acceptance of the updated Policy.

13. Contact Information

For any privacy questions or requests:
📧 business@finholy.com
🏢 MRL Group Ltd., 2 Menorat Hamaor St., Tel Aviv, Israel

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