Privacy Policy

1. INTRODUCTION

Morwen Payment Solutions – FZCO (“Morwen” or the “Company”) respects the privacy and confidentiality of client information and is committed to handling personal and corporate information responsibly and in accordance with applicable United Arab Emirates data protection requirements.
This Privacy Policy describes how Morwen may collect, use, store, process, and disclose information obtained in connection with its payment facilitation and operational support services.

2. INFORMATION COLLECTED

Morwen may collect and process information including:

• Identification documents
• Corporate records and ownership information
• Contact information
• Transaction-related information
• Source-of-funds documentation
• Payment instructions and supporting commercial documentation
• Communications exchanged with clients or counterparties
• Information obtained during compliance, sanctions, or adverse media reviews

3. PURPOSE OF PROCESSING

Information may be collected, reviewed, processed, and retained for purposes including:

• Client onboarding and KYC/KYB procedures
• Transaction review and execution support
• Sanctions screening and compliance procedures
• Fraud prevention and risk management
• Compliance with legal, banking, operational, or regulatory requirements
• Maintenance of internal operational records

4. SHARING OF INFORMATION

Where reasonably necessary, information may be shared with:

• Banking institutions
• Correspondent banks
• Payment processors and financial infrastructure providers
• Compliance service providers
• Professional advisors
• Competent authorities or regulatory bodies where legally required

Information is shared only where reasonably necessary for transaction execution, operational support, compliance review, legal obligations, or risk management purposes.

5. COMPLIANCE AND SCREENING

Morwen may conduct compliance reviews, sanctions screening, adverse media searches, and transaction validation procedures using publicly available information, commercially available compliance resources, and supporting documentation provided by clients.

6. DATA RETENTION

Morwen maintains onboarding, transaction-related, and compliance-related records for a minimum period of five (5) years following completion of the transaction or termination of the business relationship, or longer where reasonably required by applicable legal, banking, operational, or compliance considerations.

7. DATA SECURITY

Morwen applies commercially reasonable administrative and operational measures designed to protect information against unauthorized access, misuse, disclosure, alteration, or loss.
However, no method of electronic transmission or storage can be guaranteed to be completely secure.

8. INTERNATIONAL PROCESSING

Certain information may be processed, transmitted, or accessed by international banking institutions, payment processors, correspondent banks, or service providers involved in the execution of transactions or compliance-related procedures.

9. MARKETING COMMUNICATIONS

Morwen does not sell client information to unrelated third parties.
Clients may opt out of non-essential marketing communications at any time by contacting Morwen directly or by using available unsubscribe mechanisms where applicable.

10. CLIENT RIGHTS

Subject to applicable legal and operational limitations, clients may request reasonable access to personal information held by Morwen or request correction of inaccurate information.

11. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates.

12. CONTACT INFORMATION

Questions relating to this Privacy Policy or requests relating to personal information may be directed to Morwen Payment Solutions – FZCO through the contact details published on the Company’s website.