Privacy Policy

Updated 5/19/2026

CSH DIREK (“Company,” “we,” “us,” or “our”) processes personal information in

connection with its website, mobile application, and related interfaces (collectively, the “Interface”).

The Interface provides access to services powered by MoneyTrans and its financial institution and

service provider partners (collectively, the “Underlying Services”). As a result, the collection, use,

and disclosure of information may occur across an integrated system involving the Company,

MoneyTrans, and such partners.

This Privacy Policy describes how information is collected, used, disclosed, and safeguarded in

connection with the Interface.

The services accessible through the Interface operate within a regulated financial environment.

Certain data collection, processing, retention, and disclosure activities are required by law, regulatory

obligation, or financial institution requirements and may not be limited where such obligations apply.

1. Information We Collect

The Company may collect information necessary to operate the Interface, facilitate access to the

Underlying Services, and support compliance obligations. This may include identifying information

such as name, address, email address, telephone number, date of birth, and account identifiers. It

may also include information submitted in connection with identity verification, account registration,

or transaction initiation.

In addition, technical and usage information may be collected, including device identifiers, IP

address, access logs, and information reflecting how the Interface is accessed and used. Information

relating to transactions, recipients, or counterparties may also be collected in connection with use of

the Underlying Services. The scope of information collected may vary depending on the nature of

the activity, the services accessed, and applicable legal or regulatory requirements.

2. How Information is Collected

Information is collected directly from users when interacting with the Interface, including during

account registration, submission of information, or use of available functionality. Information may

also be collected automatically through system processes, including cookies, device identification

technologies, and server-side logging mechanisms.

In addition, information may be obtained from MoneyTrans, financial institutions, payment

processors, identity verification providers, compliance vendors, and other service providers involved

in delivering the Underlying Services. Such information may be used to support identity verification,

transaction processing, risk assessment, and compliance with applicable obligations.

3. Use of Information

The Company uses information as necessary to operate the Interface and facilitate access to the

Underlying Services. This includes enabling account access, supporting user interactions,

communicating with users, and maintaining system functionality.

Information may also be used to support security monitoring, detect and prevent unauthorized

activity, and comply with applicable legal and regulatory requirements.

To the extent necessary, information is shared with and used by MoneyTrans and its partners in

connection with transaction processing, identity verification, fraud detection, sanctions screening,

and other compliance-related functions. Where permitted, information may be used to improve

system performance and enhance the operation of the Interface.

4. Automated Processing and Risk Controls

The Interface operates in conjunction with systems used by MoneyTrans and its partners to evaluate

activity and manage risk. These systems may assess identity, analyze transaction activity, and

determine whether to permit, delay, restrict, or reject transactions or account access.

Such determinations may be made without prior notice where required to comply with legal

obligations or to protect the integrity of the system. The Company does not control these

determinations but may enforce or reflect them within the Interface.

5. Sharing and Disclosure of Information

The Company does not sell personal information. Information may be disclosed to MoneyTrans and

to financial institutions, payment processors, identity verification providers, compliance vendors, and

other service providers as necessary to operate the Interface and facilitate the Underlying Services.

Information may also be disclosed in connection with legal process, regulatory inquiry, or lawful

request, or where necessary to protect the rights, property, or safety of the Company, its users, or

others. Certain processing, restrictions, or disclosures may be determined or required by

MoneyTrans or by financial institution partners independent of the Company.

6. Data Security

The Company implements administrative and technical safeguards designed to protect information

within its control. These measures may include access controls, system monitoring, and other

protections designed to prevent unauthorized access or misuse.

At the same time, users acknowledge that information may pass through systems operated by

MoneyTrans and its partners, and no system operating across multiple integrated environments can

guarantee absolute security. Users remain responsible for maintaining the confidentiality of their

account credentials and access to their devices.

7. Data Retention

The Company retains information for as long as necessary to operate the Interface and fulfill

applicable obligations. Information may also be retained by MoneyTrans and its partners in

accordance with their own legal, regulatory, and operational requirements, including retention

periods that extend beyond account closure.

8. International Data Processing

Information may be transferred to, stored in, or processed in jurisdictions outside the user’s location,

including jurisdictions where MoneyTrans or its partners operate. Such transfers may be necessary to

provide the Underlying Services and to comply with applicable obligations.

9. Third-Party Services

The Interface relies on and integrates with third-party systems and services, including those operated

by MoneyTrans and its partners. These third parties operate under their own policies and are not

controlled by the Company. The Company is not responsible for the independent practices of such

third parties. Users are responsible for reviewing applicable terms where they interact with external

services.

10. Changes to this Policy

The Company may update this Privacy Policy from time to time to reflect changes in operations,

legal requirements, or system functionality. Updates become effective upon posting. Continued use

of the Interface constitutes acceptance of the revised Policy.