Privacy Policy for SFX

Sora Financial Technologies Inc. United States 1111B S Governors Ave STE 26538 Dover, DE 19904 Reg:20244413314

Turkiye Turkiye, Samsun, YENIMAHALLE MAH. 3142 SK. SHT. ASB. ÖMER HALISDEMIR APT. NO: 3 IÇ KAPI Tax ID: 4651507062

Privacy Policy

Effective Date: 6th December, 2024

Applicable Law: This Privacy Policy is governed by and constructed in accordance with the laws and regulations of the Republic of Turkey and the Delaware, United states of America.

At SFX, we are dedicated to protecting your privacy and ensuring the security of your personal information. This Privacy Policy outlines how we collect, use, and safeguard your data. Please take a moment to review this policy and understand your rights and responsibilities regarding your personal information.

1. Introduction

SFX is a digital fintech company providing payment, savings, and spending services tailored to African expats in Turkey and the Turkish Republic of Northern Cyprus (TRNC). Our robust Customer Identification Program (CIP) complies with the laws of your home country and domiciled countries, incorporating advanced Know Your Customer (KYC) processes through Smile ID for rigorous identity verification and to prevent money laundering and terrorist financing activities.

1. Information We Collect

As part of our comprehensive CIP and KYC processes, we collect the following necessary customer information:

• Full Name: First name and last name as per official documents.

• Date of Birth: To verify the customer's age.

• Nationality: To establish the customer's legal status.

• Address: Residential address, including P.O. Box.

• Government-Issued Identification: Valid government-issued identification with a photograph, such as a Turkish driver’s license, designated payment countries' passport, or valid short Term or Long Term residence permit, BVN (Bank Verification Number) for users with bank accounts in Nigeria.

1. Customer Refusal to Provide Information

SFX maintains a strict policy of verifying the identity of all customers to comply with Anti-Money Laundering (AML) regulations and ensure platform security. Customers who refuse to provide required information will not be allowed to open an account with SFX.

1. Verification Process

We utilize Smile ID for customer authentication, which includes:

• Input of KYC Details: Users provide name, date of birth, nationality, address, and P.O. Box during registration.

• Live Passport Upload: Customers upload their international passport live through Smile ID for identity verification. Smile ID conducts automated screening for AML compliance by cross-referencing customer data against global and African sanctions lists, PEP lists, and adverse media watchlists.

1. Comparison with Government Lists

In collaboration with Smile ID, SFX verifies users against government databases across Turkey, Africa, and other jurisdictions, enhancing fraud mitigation and compliance with regulatory requirements. List include but are not limited to: OFAC, South African Financial Intelligence Center (FIC) list, Nigeria Economic and Financial Crimes Commission (EFCC), MASAK FIU list

1. Notice to Customers

Customers are promptly informed of the requirement to verify their identity as part of our AML and KYC procedures immediately upon registration on our platform.

1. How We Use Your Information

We use the information you provide to:

• Verify your identity and maintain platform security.

• Comply with AML regulations.

• Enhance fraud mitigation.

• Ensure the safety of your account and our platform.

1. Data Security: We employ stringent security measures to protect your personal information and prevent unauthorized access or disclosure. Our databases are kept in a secure password protected and 2FA protected environment only accessible to Authorized senior executives. Record of Login, and actions taken are monitored while in use. Our security protocols include encryption, secure socket layer (SSL) technology, access controls, and regular, compliance and security audits.

2. 🛡️ Biometric Authentication (Face ID / TrueDepth API) We offer biometric authentication (such as Face ID) as a convenient and secure method for users to access the app after they have logged in at least once.

   When enabled, Apple’s TrueDepth API is used solely for the purpose of verifying the user's identity through Face ID. This biometric authentication replaces the need to manually enter a PIN when re-opening the app.

   We do not:

   Collect, store, or transmit any data captured by the TrueDepth camera.

   Share biometric data with any third parties.

   Use biometric data for marketing, analytics, or any other purposes.

   All Face ID processing is handled securely by the device's operating system and remains entirely on the user's device. Our app does not have access to raw facial mapping data.

   This use of Face ID complies with Apple’s guidelines and prioritizes user privacy and security at all times.

3. Access to Your Information

You have the right to access your personal information held by SFX. To view, update, or delete your data, please contact our customer support team.

1. Changes to Our Privacy Policy

We may update our Privacy Policy periodically to reflect changes in practices and for legal or regulatory reasons. Updates will be posted on our website, and the revised policy will be effective immediately.

1. Contact Us

If you have questions or concerns about our Privacy Policy or how we handle your data, please contact us at [e-mail].