FREX - PRIVACY POLICY  
‍[Last Updated: January 29, 2026]  
FREX TECHNOLOGIES PRIVATE LIMITED (“Frex”, or “Our”, or “We”, or “Us”)  
respects your privacy and is committed to protecting it through Our compliance with  
this Privacy Policy (“Policy”). This Policy describes:  
i.  
The types of information We may collect or that you may provide when you  
download and register with, access or use, or transact with the Frex  
Application (“App”), or associated website, any associated content, material,  
interactive features, applications, widgets, blogs, social networks and social  
network pages, and other online or wireless offerings that post a link to this  
Policy, whether accessed via computer, mobile device or other technology  
(“Platform”).  
ii.  
Our practices for collecting, using, maintaining, processing, accessing, storing,  
protecting and disclosing that information.  
iii.  
Your rights under applicable law.  
This Policy applies only to personal information you provide or We collect via App  
and Platform. This Policy does not apply to information that we collect through  
websites not under Our control, including websites you may access through our App,  
or information that you provide to or is collected by any third party. These third  
parties may have their own privacy policies, which We encourage you to read before  
providing information on or through them.  
PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING AND USING  
OUR APP, SERVICES AND PLATFORM. BY ACCESSING OR USING OUR  
SERVICES OR APP OR PLATFORM YOU ARE ACCEPTING THE PRACTICES  
DESCRIBED IN THIS POLICY. IF YOU DISAGREE TO ANY TERM PROVIDED  
HEREIN, YOU MAY NOT ACCESS OR USE THE SERVICES OR THE WEBSITE.  
‍If you have any question, inquiry, request or concern related to this Privacy Policy,  
you may contact Us, and Our privacy team at: legal@frexpay.com  
In terms of the Information Technology (Intermediaries Guidelines) Rules, 2011 and  
the Information Technology (Reasonable Security Practices and Procedures and  
Sensitive Personal Data or Information) Rules, 2011, any grievance or complaint  
may be intimated to Himanshu Arora, Grievance Officer, who may be reached at +91  
9888253353 or legal@frexpay.com. The complaint shall be redressed within a period  
of 1 (one) month.  
A.  
SERVICE PROVIDERS  
Frex has relationships with certain service providers, as mentioned below, in  
order to provide its services to you.  
● “Mudrex”, registered in India as RPFAS Technologies Private Limited, holding  
license number VA00031079, registered in Italy as a Virtual Asset Service  
Provider (VASP) with the Organismo Agenti e Mediatori (OAM) holding  
license number 0099827/23, and registered as Mudrex TR Holdings UAB as a  
Virtual Asset Service Provider (VASP) by the Bank of Lithuania with license  
number 306070243;  
● “Bridge”, registered as Bridge Ventures LLC; registered Bridge Building Inc  
NMLS # 2450917 and licensed for Money transmission services, registered as  
Bridge Building Sp. Z.o.o., KRS: 0001039515, RDWW-794;  
● “Plaid” registered as Plaid Inc.; and its various subsidiaries including Plaid  
Financial Ltd., Plaid Consumer Reporting Agency, Inc., and Plaid, B.V.;  
● “Astra” registered as Astra Inc.; and/or its affiliates or subsidiaries; and  
● “Coins”, registered as Betur, Inc., a virtual asset service provider (VASP) duly  
registered with the Bangko Sentral ng Pilipinas (BSP) as a Remittance &  
Transfer Company (RTC) with Money Changing (MC)/ Foreign Exchange  
Dealing (FXD) & Virtual Currency Exchange (VC) service; and as DCPay  
Philippines Inc., a company that is duly registered with the BSP as an  
Electronic Money Issuer.  
Frex is a technology platform which facilitates the delivery of services by these  
third party service providers, i.e. Mudrex, Bridge, Plaid, Astra, and Coins. By  
agreeing to Frex’s Policy and Terms of Use, you also independently agree with  
the end user terms and policies of the above-mentioned service providers as  
well. You may refer to these terms and policies in the links mentioned below -  
● Mudrex Terms of Use of Services (link)  
● Mudrex Privacy Policy (link)  
● Mudrex KYC/AML/CFT Policy (link)  
● Bridge Privacy Policy (link)  
● Bridge User Terms (link)  
● Plaid Privacy Policy (link)  
● Astra Privacy Policy (link)  
● Astra Terms of Use (link)  
● Coins Legal & Privacy User Agreement (link)  
B.  
‍USERS UNDER THE AGE OF 18  
We are not intended for individuals under the age of eighteen (18). Accordingly, We  
do not knowingly solicit Personal Data (as defined hereinafter) from or market to  
children as defined under applicable law. We request that such individuals not  
provide Personal Data. If you become aware or have any reason to believe that a  
child has shared any Personal Data with us, please contact Us through the means of  
contact detailed herein.  
C.  
DATA WE COLLECT  
We may collect data from and about users of the App directly from you when you  
provide it to Us and/or automatically when you use the App or Our Platform. We may  
also collect and retain the Personal Data to achieve the purposes for which the  
Personal Data was collected. In certain cases, we may need to retain Personal Data  
for purposes required under applicable law, for tax, accounting, or audit purposes, or  
for other purposes permitted or required under law.  
Depending on your interaction with Us, We collect two types of data:  
1.  
Non-Personal Data  
Non-Personal Data (as defined hereinafter), means information which does  
not identify a specific natural person and cannot reasonably be used for such  
identification. We collect Non-Personal Data regarding use of the App or the  
Platform, such as the scope, frequency, latency, pages accessed and viewed,  
time and date stamp, interactions with content and materials displayed on the  
App or the Platform, language preference, and other technical information  
regarding the device used to access the App or the Platform , for example  
type of device, type of browser, operating system, etc. This data is considered  
as Non-Personal Data when collected on an aggregate basis, or otherwise not  
combined with online identifiers (“Non-Personal Data”).  
Also, We may sometimes process and anonymize or aggregate Personal  
Data and identifiable information in a manner that shall create a new set of  
data that will be Non-Personal Data. Such a new data set can no longer be  
associated with any identified natural person.  
Non-Personal Data may be used by Us without limitation and for any purpose,  
including for commercial, research, or statistical purposes, in order to maintain  
and develop the App or the Platform, including among others, for ensuring the  
technical functioning of the App or the Platform, to help prevent fraudulent use  
of the App or the Platform.  
2.  
Personal Data  
Personal Data means, individually identifiable information, namely information  
that identifies an individual or may with reasonable effort be used to identify  
an individual. This may include but not limited to online identifiers, first and  
last name, email address, telephone number, geolocation, mobile device  
identification number, etc. as well as information and documents you provide  
for completion of KYC checks as required under applicable law (“Personal  
Data”).  
This also includes information provided when posting material and requesting  
information on the App or the Platform. We may also ask you for information  
when you report a problem with the App. We may also collect records and  
copies of your correspondence (including email addresses and phone  
numbers), if you contact Us; or details of transactions you carry out through  
the App or the Platform; or your search queries on the App or the Platform.  
The table below summarizes Our collection, use and disclosure of personal  
information:  
Type of  
Data  
Detail  
Use  
Disclosure  
Device  
When  
you (i)  
Operation, Where  
required  
Identifiers  
and Online  
Usage  
interact with Us, security and fraud under  
applicable  
We may collect detection  
laws, We will obtain  
your consent for the  
online  
such  
identifiers purposes;  
as your  
purpose  
of  
data  
Internet Protocol  
address (“IP”),  
cookie-ID, etc., as  
collection  
our use of third-  
party Cookies for  
analytics  
and  
purposes,  
permissible  
applicable law.  
any such case, you  
may withdraw  
consent or change  
your preferences at  
any time by using  
the cookie settings  
tool available on our  
website.  
through  
(ii)  
statistics  
Internal  
and  
analysis in order to  
enhance and  
improve the App or  
the Platform and its  
content;  
well  
information  
relates to  
as  
other  
that  
your  
purposes  
marketing  
if  
activity such as  
pages viewed,  
click stream data,  
login time and  
date stamp, etc.  
This data might  
under  
In  
(iii) Marketing and  
advertising  
purposes.  
be  
collected  
directly by Us or  
by Our use of  
third  
parties'  
Cookies  
defined  
(as  
hereinafter).  
Contact  
Communicat contact  
If you voluntarily We process your We process such  
Us contact information data subject to Our  
ions  
through  
means  
any solely  
of purpose  
for  
the legitimate interest.  
of  
communication,  
we  
available  
contacting  
make responding to your  
(e.g., inquiries and  
you,  
through  
you  
email), providing you with  
will  
be the  
support  
or  
requested  
to information  
you  
provide Us with have requested.  
your contact  
information such  
The  
as  
phone  
and  
your  
name,  
number  
email  
correspondence  
with you may be  
stored by Us in  
order to improve  
address.  
our  
operation,  
internal  
or to  
handle any dispute  
you might have  
with Us.  
Electronic  
newsletter,  
Surveys,  
In the event you We will use the You may withdraw  
sign up to receive information you your consent at any  
Our electronic provide in order to time by clicking the  
newsletter  
Marketing  
or include you in Our “unsubscribe”  
link  
be  
communicati other promotional mailing  
ons,  
Updates,  
list  
you  
and which  
the included  
will  
in  
materials,  
surveys,  
send  
the  
polling, materials you have email we will send  
Polling and you  
will  
be signed  
to receive.  
your  
up  
to you. You may also  
contact Us through  
the above means of  
contact and request  
Offer  
requested  
Registration  
provide  
contact  
such  
details,  
email  
In addition, We use  
your email address  
in order to provide  
as  
to unsubscribe.  
address.  
you with surveys, Note  
that  
if  
you  
polling,  
marketing choose to opt-out,  
related  
communication  
We  
maintain  
will  
further  
a
such  
as  
new suppression file –  
lists of  
special applicable email  
or addresses that have  
other requested to opt-  
We out. If you opt-out,  
Our Frex may still send  
features, additional meaning  
offerings,  
opportunities  
any  
information  
think  
customers will find you emails about  
valuable. It may your registered  
also be used to account or any  
your services you have  
respond  
to  
inquiries,  
questions,  
requested  
and/or received from Us.  
or  
other requests.  
Know Your You will be asked We use the KYC KYC and Account  
Customer  
and Account information  
Information part of the know register you to Our services to you.  
to submit certain and  
account Information  
is  
as Information  
to needed to provide  
your  
process  
such  
customer services,  
(KYC) your  
create  
account,  
At times, we may  
even share this  
as:  
full authentication,  
name,  
email provide  
account  
information with the  
third party service  
providers in order to  
enable them to be  
address,  
telephone  
number,  
management  
(including  
IDs, and  
and customer  
billing  
invoices),  
support  
utility  
bills  
compliant  
applicable  
with  
law  
any  
other and to provide the  
information  
requested  
complete  
Services.  
before they are able  
to  
the  
to  
provide  
the  
services.  
KYC process.  
We will use your  
email and name  
as part of the  
signing  
up  
process and to  
create  
your  
account.  
Usage Data  
When  
you  
use We  
use  
your We  
process  
your  
the App or the Usage Data to help Usage Data subject  
Platform,  
information  
regarding  
use  
automatically  
generated  
Us understand how to  
you are using Our interest.  
such services, and how  
Our  
legitimate  
is to better provide  
and improve Our  
and services  
to  
you.  
collected,  
may include the better  
which This helps us to  
understand  
business,  
Our  
click  
stream Our  
the analyse  
within  
Platform, the time operations,  
spent on each maintain, improve,  
page or feature, innovate,  
crash data and design,  
plan,  
and  
the  
analytics,  
how develop  
often you use the services and the  
Service etc. App or the  
("Usage Data").  
Platform.  
From time to time, Frex may use personal information for new and  
unanticipated uses not previously disclosed in the Policy. If Our information  
practices change regarding information previously collected, Frex shall make  
reasonable efforts to provide notice and obtain consent of any such uses as  
may be required by law.  
D.  
HOW WE COLLECT DATA  
Depending on the nature of your interaction with Us through the App or the Platform,  
We may collect information as follows:  
1.  
Automatically – We may use Cookies (as defined hereinafter) or similar  
tracking technologies (such as pixels, tags, agent, etc.) to gather certain  
information automatically such as your browser type, your ISP or operating  
system, your domain name, your access time, the URL of the previous  
website you visited, your page views, your IP address, and the type of device  
that you use. We also track how frequently you visit the Website. We use this  
information (including the information collected by Our third party service  
providers) for analytics of the App or Platform (including to determine which  
portions of the App or Platform are used most frequently, what Our users  
like/do not like), to assist us in determining relevant advertising (both on and  
off the Website), to evaluate the success of Our advertising campaigns, and  
as otherwise described in this Policy.  
2.  
Provided by you or about you voluntarily – We will collect information if and  
when you choose to provide Us with the information, for example, when you  
register and create an account or correspond with Us including your name,  
username, gender, birth date, email address, phone number, address.  
Cookies  
A Cookie is a small text file containing a string of alphanumeric characters stored on  
user’s computer hard drive containing information about the user (“Cookies”).  
Cookies help Us analyze web traffic or informs you about your use of a particular  
website. Cookies allow web applications to respond to you as an individual, tailoring  
its operations to your needs, likes and dislikes by gathering and remembering  
information about your preferences. When you visit the App or Platform, We may  
send one or more Cookies to your computer that identifies your browser.  
Some of these Cookies may be connected to third-party companies or websites or  
third party service providers. The terms of use of such Cookies are governed by this  
Policy and the privacy policy of the relevant third-party company or website.  
For example, Google measures the performance of advertisements by placing  
Cookies on your computer when you click on ads. If you visit the App or the Platform  
when you have such cookies on your device, the Company and Google will be able  
to tell that you saw the ad delivered by Google. The terms of use of these cookies  
are governed by this Policy and Google’s Privacy Policy.  
You  
can  
find  
more  
information  
about  
our  
use  
of  
cookies  
here:  
www.allaboutcookies.org.  
Disabling Cookies  
You can manage your Cookies preferences through your browser settings. You can  
choose to accept or decline Cookies. Most web browsers automatically accept  
Cookies, but you can usually modify your browser setting to decline Cookies if you  
prefer. If you disable Cookies, you may be prevented from taking full advantage of  
the App or the Platform because it may not function properly if the ability to accept  
Cookies is disabled.  
Web Beacons  
Pages of the App or the Platform may contain small electronic files known as web  
beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Us,  
for example, to count users who have visited those pages and for other related app  
statistics (for example, recording the popularity of certain app content and verifying  
system and server integrity).  
E.  
THIRD-PARTY INFORMATION COLLECTION  
Apart from sharing your information with third party service providers for KYC  
compliance, We may also use and disclose non-personal information We collect with  
third parties. We may also share it with third parties to develop and deliver targeted  
advertising on the App and the Platform and on websites or applications of third  
parties, and to analyze and report on advertising you see. We may combine non-  
personal information we collect with additional non-personal information collected  
from other sources. We also may share aggregated, non-personal information, or  
personal information in hashed, non-human readable form, with third parties,  
including advisors, advertisers and investors, for the purpose of conducting general  
business analysis or other business purposes. For example, We may engage a data  
provider who may collect web log data from you (including IP address and  
information about your browser or operating system), or place or recognize a unique  
cookie on your browser to enable you to receive customized ads or content. The  
Cookies may reflect de-identified demographic or other data linked to data you  
voluntarily have submitted to Us (such as your email address), that We may share  
with a data provider solely in hashed, non-human readable form. To opt-out of  
cookies that may be set by third party data or advertising partners, please go to  
www.aboutads.info/choices/.  
When you use the App or the Platform, certain third parties may use automatic  
information collection technologies to collect information about you or your device.  
These third parties may include but are not limited to: Advertisers, ad networks and  
ad servers; Analytics (including marketing analytics) and digital platform  
management companies; your mobile device manufacturer; your mobile service  
provider; your card issuer or other financial services provider.  
These third parties may use tracking technologies to collect information about you.  
The information they collect may be associated with your personal information or  
they may collect information, including personal information, about your online  
activities over time and across different websites, apps and other online services  
websites. They may use this information to provide you with interest-based  
(behavioral) advertising or other targeted content.  
F.  
DATA SHARING/ DISCLOSURE  
We share your Personal Data with third parties, including with trusted partners or  
service providers that help Us to manage Our business operation, the App or the  
Platform . We may disclose aggregated information that does not constitute personal  
information about Our users without restriction.  
Further, We may disclose personal information that We collect or you provide, to  
third parties such as, but not limited to, the following –  
1.  
INFORMATION DISCLOSED TO PROTECT US AND OTHERS  
We may disclose your information including personal information if: (i) Frex  
reasonably believes that disclosure is necessary in order to comply with a  
legal process (such as a court order, search warrant, etc.) or other legal  
requirement of any governmental authority, (ii) disclosure would potentially  
mitigate Our liability in an actual or potential lawsuit, (iii) reasonably necessary  
to enforce this Policy, Our terms of use of Frex etc. (iv) disclosure is intended  
to help investigate or prevent unauthorized transactions or other illegal  
activities, or (v) necessary or appropriate to protect Our rights or property, or  
the rights or property of any person or entity.  
2.  
INFORMATION DISCLOSED TO THIRD PARTY SERVICE PROVIDERS  
AND BUSINESS PARTNERS  
Frex may contract with various third parties for the provision of services such  
as third party service providers mentioned hereinabove and maintenance of  
App or the Platform and its business operations, and may need to share your  
personal information and data generated by Cookies and aggregate  
information with these vendors and service agencies. For example, Frex may  
provide your information to a credit card processing company to process your  
payment. The vendors and service agencies will not receive any right to use  
your personal information beyond what is necessary to perform its obligations  
to provide the services to you. If you complete a survey, Frex also may share  
your information with the survey provider; if Frex offers a survey in conjunction  
with another entity, it also will disclose the results to that entity.  
3.  
INFORMATION DISCLOSED TO LAW ENFORCEMENT OR GOVERNMENT  
OFFICIALS  
Frex shall disclose your information, including, without limitation, your name,  
city, state, telephone number, email address, user ID history, and fraud  
complaints, to law enforcement or other government officials if We are  
required to do so by law, regulation or other government authority or  
otherwise in cooperation with an investigation of a governmental authority.  
4.  
IN THE EVENT OF A CHANGE OF CONTROL OR BANKRUPTCY  
In the event that Frex undergoes a change in control, including, without  
limitation, a merger or sale of all or substantially all of the Frex’s assets to  
which the website relates or other corporate reorganization in which the Frex  
participates, and is thus merged with or acquired by a third party entity (a  
“Successor”), Frex hereby reserves the right to transfer the information We  
have collected from the users of its website to such Successor. In addition, in  
the event of Frex’s bankruptcy, reorganization, receivership, or assignment for  
the benefit of creditors, or the application or laws or equitable principles  
affecting creditors’ rights generally, Frex may not be able to control how your  
information is transferred, used, or treated and reserves the right to transfer  
the information it has collected from the users of the App or the Platform to  
non-affiliated third parties in such event.  
5.  
6.  
INFORMATION DISCLOSED AT YOUR REQUEST  
Frex may share your personal information with other users to whom you  
explicitly ask Us to send your information or if you explicitly consent to such  
disclosure upon receipt of a specific service.  
LICENSED MONEY TANSFER VENDEOR  
Frex may share your information such as bank account or credit card or debit  
card or other payment instrument details to Our licensed money transfer  
vendor, Stripe (“Stripe”), in the event that you direct Us to transfer funds  
internationally, in which case Stripe’s privacy policy will apply.  
7.  
KNOW YOUR CUSTOMER (KYC) AND BACKGROUND VERIFICATION  
We may share your personal information and documents with our service  
providers for the sole purpose of processing transactions, conducting KYC,  
and complying with applicable legal requirements. We may also engage third-  
party agencies to conduct background verification or Frex itself may conduct  
such verifications, if required.  
By using Our services, you expressly consent to (i) such background  
verifications and (ii) the sharing of your personal information and documents  
with service providers and third-party verification agencies for the purposes of  
KYC, identity verification, and compliance.  
8.  
CROSS-BORDER DATA TRANSFER  
Due to Our global business operation, We may store or process your  
Personal Data in several territories, including, for example in India, UAE, US,  
Philippines, or in other countries. Thus, your Personal Data may be  
transferred to and processed in countries other than the country from which  
you accessed the App or the Platform or otherwise the country of your  
jurisdiction.  
In addition, some of the third parties may store and process data globally,  
including in the US (e.g., Google Analytics servers). When granting consent  
for such Cookies through the Cookies tool in the website, you hereby  
acknowledge and approve such cross-border transfer, in accordance with  
such third party’s privacy practices.  
G.  
H.  
USER GENERATED CONTENT  
If you post content on the App or the Platform such as comments, feedbacks, etc., all  
of the information that you post will be available to all visitors to App or the Platform  
and your posting may become public and Frex cannot prevent such information from  
being used in a manner that may violate this Policy, the law, or your personal privacy.  
DATA RETENTION  
We retain the Personal Data We collect as long as it remains necessary for the  
purposes set forth above, all in accordance with applicable laws, or until an individual  
expresses a preference to opt-out.  
In certain circumstances, We will retain your Personal Data for longer periods of time  
and mainly:  
●
●
●
Where We are required to retain Personal Data in accordance with legal,  
regulatory, tax, or accounting requirements;  
Where We deem retention is necessary to obtain an accurate record of your  
dealings with Us in the event of any complaints or challenges; or  
If We reasonably believe there is a prospect of litigation relating to your  
Personal Data.  
Notwithstanding the above, you acknowledge that even post (i) your request to  
delete your data as held by Us and/or Our service providers, and/or (ii) you stopping  
the usage of Our App and/or Platform, We shall continue to retain the information  
and/or transaction details, if We are required under applicable law to do so.  
We may at Our sole discretion, delete or amend information from our systems,  
without notice to you, once We deem it is no longer necessary for such purposes.‍  
I.  
ACCOUNT PROTECTION  
Your password is the key to your registered account, if any, on the App and/ or the  
Platform. When creating your password you should use unique numbers, letters,  
special characters, and combinations thereof. In addition, DO NOT disclose your  
password to anyone. If you do share your password or your personal information  
with others, you are solely responsible for all actions taken via your registered  
account. If you lose control of your password, you may lose substantial control over  
your personal information and be subject to legally binding actions taken on your  
behalf. Thus, IF YOUR PASSWORD HAS BEEN COMPROMISED FOR ANY  
REASON, YOU MUST IMMEDIATELY NOTIFY FREX TO CHANGE YOUR  
PASSWORD.  
J.  
SECURITY  
We implement industry-standard security measures to protect your personal  
information from unauthorized access, disclosure, alteration, and destruction.  
Payment transactions are processed through secure channels to ensure the  
confidentiality of your financial information. Frex may use encryption, passwords,  
and physical security measures to help protect your personal information against  
unauthorized access and disclosure. No security measures, however, are 100%  
complete. Therefore, We do not promise and cannot guarantee, and thus you should  
not expect, that your personal information or private communications will not be  
collected and used by others. You are required to be careful to avoid “phishing”  
scams, where someone may send you an e-mail that looks like it is from Frex asking  
for your personal information.  
K.  
PRIVACY RIGHTS  
We acknowledge that different people have different privacy concerns and  
preferences. Our goal is to be clear about what information We collect, so that you  
can make meaningful choices about how it is used. We provide you with the ability to  
exercise certain choices, rights and controls in connection with your Personal Data.  
Depending on your relationship with Us (e.g., if you are a visitor of App or the  
Platform), your jurisdiction and the applicable data protection laws that apply to you,  
you have the right to control and request certain limitations or rights to be executed.  
L.  
MOBILE NUMBER AND SMS COMMUNICATIONS  
Collection of Mobile Number  
We may collect your mobile phone number when you create an account, use the  
App, or otherwise interact with the Services. Providing your mobile number is  
voluntary; however, certain features of the Services may require mobile number  
verification for security, authentication, and regulatory compliance purposes.  
Use of Mobile Number for SMS Communications  
We use your mobile phone number to send transactional and service-related SMS  
messages, including but not limited to one-time passwords (OTPs), verification  
codes, account alerts, login confirmations, and other security or operational  
notifications. We do not use SMS communications for marketing or promotional  
purposes.  
Consent and Opt-Out  
By providing your mobile phone number, you consent to receive such SMS  
communications from us. Message frequency may vary. Message and data rates  
may apply as per your mobile carrier. You may opt out of receiving SMS messages  
at any time by replying STOP to any message. For assistance, reply HELP or  
contact us at support@frexpay.com. Please note that opting out of SMS  
communications may limit or prevent access to certain features of the Services that  
rely on SMS-based authentication.  
Sharing of Mobile Information  
We do not sell, rent, or share your mobile phone number or SMS opt-in information  
with third parties or affiliates for marketing or advertising purposes. We may share  
your mobile number with trusted service providers solely to facilitate SMS delivery  
and messaging operations, in accordance with this Privacy Policy and applicable law.  
Data Retention and Security  
We retain mobile phone numbers and related messaging data only for as long as  
necessary to provide the Services, comply with legal obligations, and enforce our  
agreements. We implement reasonable administrative, technical, and physical  
safeguards to protect your mobile information from unauthorized access, disclosure,  
or misuse.  
M.  
CHANGES AND UPDATES  
This Policy is current as of the effective date set forth above. Frex may, in its sole  
and absolute discretion, change this Policy from time to time by updating this  
document. You are advised to visit the App or the Platform frequently. In the event of  
any substantial change of this Policy, We will make reasonable efforts to post a clear  
notice on the website, and obtain your consent where required under applicable.  
Changes to this Policy are effective as of the stated “Last Updated” date and your  
continued use of the App or the Platform, thereafter, will constitute acceptance of,  
and agreement to be bound by, those changes.  
You may contact us at: legal@frexpay.com, if you have any questions.