FREX - PRIVACY POLICY
[Last Updated: 03 November, 2025]
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.
i. “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;
ii. “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;
iii. “Plaid” registered as Plaid Inc.; and its various subsidiaries including Plaid
Financial Ltd., Plaid Consumer Reporting Agency, Inc., and Plaid, B.V.;
iv. “Astra” registered as Astra Inc.; and/or its affiliates or subsidiaries; and
v. “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, you also independently agree with the 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 Know Your Customer (KYC), Anti Money Laundering (AML) and
Combating Financing of Terrorism Policy [KYC/AML/CFT Policy] (link)
● Bridge Privacy Policy (link)
● Bridge User Terms (link)
● Plaid Privacy Policy (link)
● Astra Privacy Policy (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
Identifiers
and Online
Usage
When you
interact with Us,
We may collect
online identifiers
such as your
Internet Protocol
address (“IP”),
cookie-ID, etc.,
as well as other
information that
relates to your
activity such as
pages viewed,
click stream data,
login time and
date stamp, etc.
This data might
be collected
directly by Us or
by Our use of
third parties'
(i) Operation,
security and fraud
detection
purposes;
(ii) Internal
statistics and
analysis in order to
enhance and
improve the App or
the Platform and
its content;
(iii) Marketing and
advertising
purposes.
Where required
under applicable
laws, We will obtain
your consent for the
purpose of data
collection through
our use of
third-party Cookies
for analytics
purposes and
marketing
purposes, if
permissible under
applicable law. In
any such case, you
may withdraw
consent or change
your preferences at
any time by using
the cookie settings
tool available on our
Cookies (as
defined
hereinafter).
website.
Contact
Communicat
ions
If you voluntarily
contact Us
through any
means of
communication,
we make
available (e.g.,
through email),
you will be
requested to
provide Us with
your contact
information such
as your name,
phone number
and email
address.
We process your
contact information
solely for the
purpose of
contacting you,
responding to your
inquiries and
providing you with
the support or
information you
have requested.
The
correspondence
with you may be
stored by Us in
order to improve
our internal
operation, or to
handle any dispute
you might have
with Us.
We process such
data subject to Our
legitimate interest.
Electronic
newsletter,
Surveys,
Marketing
communicati
ons,
Updates,
Polling and
Offer
Registration
In the event you
sign up to receive
Our electronic
newsletter or
other promotional
materials,
surveys, polling,
you will be
requested to
provide your
contact details,
such as email
address.
We will use the
information you
provide in order to
include you in Our
mailing list and
send you the
materials you have
signed up to
receive.
In addition, We use
your email address
in order to provide
you with surveys,
polling, marketing
related
You may withdraw
your consent at any
time by clicking the
“unsubscribe” link
which will be
included in the
email we will send
you. You may also
contact Us through
the above means of
contact and request
to unsubscribe.
Note that if you
choose to opt-out,
We will further
communication
such as new
features, additional
offerings, special
opportunities or
any other
information We
think Our
customers will find
valuable. It may
also be used to
respond to your
inquiries,
questions, and/or
other requests.
maintain a
suppression file –
meaning lists of
applicable email
addresses that
have requested to
opt-out. If you
opt-out, Frex may
still send you emails
about your
registered account
or any services you
have requested or
received from Us.
Know Your
Customer
and Account
Information
You will be asked
to submit certain
information as
part of the know
your customer
process (KYC)
such as: full
name, email
address,
telephone
number, IDs,
utility bills and
any other
information
requested to
complete the
KYC process.
We will use your
email and name
as part of the
signing up
process and to
create your
account.
We use the KYC
and account
Information to
register you to Our
services, create
your account,
authentication,
provide account
management
(including billing
and invoices),
customer support
and to provide the
Services.
KYC and Account
Information is
needed to provide
services to you.
At times, we may
even share this
information with the
third party service
providers in order to
enable them to be
compliant with
applicable law
before they are able
to provide the
services.
Usage Data
When you use
We use your
We process your
the App or the
Platform,
information
regarding such
use is
automatically
generated and
collected, which
may include the
click stream
within the
Platform, the time
spent on each
page or feature,
crash data and
analytics, how
often you use the
Service etc.
("Usage Data").
Usage Data to help
Us understand
how you are using
Our services, and
how to better
provide and
improve Our
services to you.
This helps us to
better understand
Our business,
analyse Our
operations,
maintain, improve,
innovate, plan,
design, and
develop the
services and the
App or the
Platform.
Usage Data subject
to Our legitimate
interest.
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. 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.
6. 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. 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.
H. 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. 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.
