Privacy Policy

This Policy applies to personal information processed through the Trove public website, registration process, identity-verification process, customer account, transaction features, support channels, and related services.

It does not necessarily apply to a third party’s independent website, service, application, or privacy practices, even when that third party supports a Trove transaction.

A. Registration and account information

We may collect:

• Full legal name
• Date of birth
• Email address
• Telephone number
• Residential address
• Mailing address
• Country of residence
• Nationality or citizenship
• Preferred language
• Username or account identifier
• Authentication and account-recovery information
• Account preferences
• Account type
• Occupation or employment information
• Business information where applicable
• Tax-related information where required

B. Identity-verification information

We may collect:

• Passport information
• National identity card information
• Driver’s licence information
• Copies or images of identity documents
• Document number, issue and expiry dates, issuing country or authority
• Photograph shown on an identity document
• Proof-of-address documents
• Selfie photographs or video
• Verification results and liveness-check results
• Information concerning document authenticity
• Additional verification responses

Depending on the verification technology used, facial comparison data or another biometric identifier or template may be generated from an identity-document photograph, selfie, or video. Trove will confirm its actual technology and data flow before launch and provide any consent or additional notice required by applicable law.

C. Financial and transaction information

We may collect:

• Currency balances
• Transaction amounts
• Source and destination currencies
• Exchange-rate information
• Fees
• Funding method
• Payment-account details
• Recipient and sender details
• Bank or payment-provider information
• Transaction purpose and reference
• Transaction status
• Refund, return, reversal, chargeback, or dispute information
• Source-of-funds and source-of-wealth information where required
• Supporting transaction documents
• Information about the relationship between transaction parties
• Information provided by payment and banking partners

E. Device, website, and technical information

• Internet Protocol address, device and browser identifiers
• Device type, operating system, language
• Approximate location derived from an IP address
• Login dates and times, session information
• Pages viewed, links selected, referring pages
• Error logs, performance information, security events
• Cookie and similar-technology information
• Fraud and risk signals

F. Communications and support information

• Contact-form submissions, support messages, and complaint information
• Call or chat records where applicable
• Survey responses and feedback
• Records of notices sent
• Communication preferences
• Enquiry and case references
• Information provided during an account or transaction review

G. Risk, fraud-prevention, and compliance information

• Identity-verification outcomes
• Fraud indicators
• Device and account risk signals
• Transaction-monitoring results
• Sanctions-screening results
• Politically exposed person screening results where applicable
• Adverse-media screening results where lawful and appropriate
• Internal risk classifications
• Account or transaction review notes
• Suspicious-activity indicators
• Records of decisions, restrictions, or escalations
• Information received from fraud-prevention, identity, banking, and payment partners

H. Information about other people

You may provide information about recipients, senders, beneficial owners, directors, representatives, employees, contractors, or other individuals. You must have a lawful reason to provide that information and should inform the relevant person where required.

We may collect personal information:

• Directly from you
• Through your Trove account
• Through transaction forms
• Through identity-verification processes
• Through the Contact page
• Through cookies and similar technologies
• From banks and payment providers
• From recipients, senders, or counterparties
• From identity-verification providers
• From fraud-prevention and risk providers
• From business customers or authorized representatives
• From public records or official sources
• From sanctions, politically exposed person, or compliance databases
• From service providers supporting account or transaction operations
• From other lawful sources

We may process personal information to:

• Provide the services and create and maintain accounts
• Authenticate users and display balances and transaction information
• Process payments, transfers, receipts, and conversions
• Calculate rates and fees and communicate transaction status
• Provide customer support and handle refunds, returns, reversals, and disputes
• Verify identity and eligibility, review documents, and compare a selfie with an identity-document photograph
• Confirm residential or business information, assess account eligibility, and complete required customer checks
• Detect and prevent fraud, protect accounts, and investigate suspicious access
• Monitor transactions, enforce limits and restrictions, and maintain service security
• Meet legal and compliance obligations, conduct customer due diligence, and screen against sanctions and other required lists
• Respond to lawful requests, maintain required records, and support audits, investigations, and regulatory reviews
• Enforce legal rights and agreements
• Send essential account notices, verification requests, transaction information, security alerts, and material policy updates
• Diagnose errors, measure performance, improve user experience, and develop or test features
• Conduct internal analytics, train staff, and maintain business records

Where legally permitted, Trove may send information about relevant features or services. Consent will be obtained where required, and available preference or unsubscribe controls will be provided. Declining marketing does not prevent essential service, account, transaction, security, or legal communications.

The legal grounds available to Trove depend on the applicable jurisdiction and the specific processing activity. These may include:

• Performing a contract with you
• Taking steps at your request before entering a contract
• Meeting a legal obligation
• Pursuing legitimate interests that are not overridden by your rights
• Protecting vital interests
• Establishing, exercising, or defending legal claims
• Performing tasks in the public interest where legally applicable
• Obtaining your consent

Where special-category or biometric data is processed, Trove will identify and document the additional legal condition required in each applicable jurisdiction.

Trove and its providers may use automated tools to support identity verification, fraud detection, transaction monitoring, sanctions screening, account security, eligibility assessment, and risk management.

Automated tools may flag an account or transaction for additional review, request further information, apply a temporary restriction, or contribute to another decision.

Where applicable law grants rights concerning a decision based solely on automated processing that produces legal or similarly significant effects, Trove will provide the required information and a method for exercising those rights.

We may share relevant personal information with:

Trove service providers

• Cloud hosting and data storage
• Identity verification, facial comparison, or liveness checks
• Fraud prevention and cybersecurity
• Customer support and communications
• Analytics, document processing, and professional services

Financial and transaction partners

• Banks, payment processors, card and payment networks
• Correspondent institutions, recipient institutions, funding providers
• Currency and liquidity providers
• Other organizations required to complete or investigate a transaction

Compliance and risk partners

• Sanctions-screening and politically exposed person screening providers
• Fraud-prevention networks
• Identity-verification and transaction-monitoring providers
• Professional advisers and auditors

Authorities and legal recipients

We may disclose information:

• To comply with law or a valid legal process
• To regulators, supervisory authorities, courts, tax authorities, and financial-intelligence units
• To protect rights, safety, property, customers, or the public
• To investigate or prevent unlawful activity

Corporate transactions

Information may be disclosed as part of a proposed or completed financing, investment, restructuring, merger, acquisition, sale, insolvency, or transfer of all or part of the business, subject to appropriate protections and applicable law.

With your direction or consent

We may share information where you instruct us to do so or provide legally valid consent.

Trove does not sell personal information in the ordinary meaning of exchanging it for money. Any jurisdiction-specific definition of “sale,” “sharing,” or targeted advertising will be reviewed separately before this statement is published in a market where broader definitions apply.

Trove may use service providers, transaction partners, and infrastructure located in countries other than the country where you live. As a result, personal information may be transferred internationally.

Where required, Trove will use an approved transfer mechanism and appropriate safeguards. These may include contractual protections, adequacy decisions, or another legally recognized mechanism.

Trove retains personal information only for as long as reasonably necessary for the purposes described in this Policy, including providing services, maintaining transaction records, meeting legal and regulatory obligations, preventing fraud, resolving disputes, and enforcing agreements.

Retention periods may depend on:

• The type of information
• The nature of the account or transaction
• Legal and regulatory requirements
• Limitation periods
• Fraud and security risks
• Complaint or dispute status
• Litigation or investigation holds
• Partner requirements
• Whether an account remains active

Some information may be retained after an account is closed or a transaction is completed. When information is no longer required, Trove will delete, anonymize, or securely dispose of it in accordance with applicable requirements and internal retention procedures.

Trove uses administrative, technical, and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, loss, or misuse.

Measures may include:

• Access controls and authentication controls
• Encryption where appropriate
• Activity monitoring and logging
• Provider assessments
• Staff training
• Incident-response procedures
• Secure development practices
• Data-minimization controls
• Backup and recovery procedures

No system or method of transmission is completely secure. Customers must protect their credentials and notify Trove promptly if they suspect unauthorized access.

Privacy rights vary depending on your location. Subject to applicable law and available exceptions, you may have the right to:

• Request access to personal information
• Request correction of inaccurate information
• Request deletion
• Request restriction of processing
• Object to certain processing
• Withdraw consent where processing relies on consent
• Request data portability
• Opt out of certain marketing
• Ask about automated decision-making
• Lodge a complaint with an applicable privacy authority
• Appeal the outcome of a privacy request where required

Trove may need to verify your identity before completing a request. A request may be limited or refused where permitted or required by law, including when information must be retained for legal, fraud-prevention, transaction, security, or recordkeeping purposes.

To submit a privacy request, visit the Contact page and select Privacy request.

Trove may use cookies and similar technologies to:

• Operate essential website functions
• Maintain sessions
• Support authentication
• Remember preferences
• Protect against fraud
• Understand website performance
• Diagnose errors and measure usage
• Improve the website
• Support optional analytics or marketing where permitted

Necessary cookies

Necessary cookies support website operation, account access, security, and requested services. They may not be optional where they are essential to provide the website or service.

Optional cookies

Optional analytics, preference, or marketing cookies will be used only in accordance with applicable consent requirements.

Privacy choices

Where required, users can accept, reject, or manage optional cookies through the website’s consent interface. Rejecting optional cookies will not prevent essential website functions.

Where Trove sends marketing communications, you may use the unsubscribe method included in the message or an available account preference.

It may take a reasonable period to process a preference change. Trove may continue sending essential operational, transaction, verification, legal, and security communications.

Trove services are not intended for children or anyone below the minimum age displayed during registration. Unless expressly stated otherwise, users must be at least 18 years old.

If Trove learns that it collected personal information from an ineligible child, it will take appropriate steps in accordance with applicable law.

The website or services may contain links to third-party websites or rely on third-party providers. Their privacy practices are governed by their own notices where they act independently.

Review a third party’s privacy information before providing personal information directly to that third party.

Trove may update this Policy to reflect changes in services, technology, legal requirements, providers, or data practices.

The updated Policy will display a revised effective date. Where required, Trove will provide additional notice or obtain consent before a material change takes effect.

To ask a question about this Privacy Policy or submit an available privacy request, use the Trove Contact page or email support@trovein.com. We may need to verify your identity before responding to a request involving personal information.

Do not send identity documents, passwords, security codes, or complete payment-card information through an ordinary email unless Trove has specifically instructed you to use an approved secure process.