Network Bank Group — Privacy Policy

Last updated: July 23, 2026
Version: 1.1 (Partner FI absorb)

Geographic Scope

This Privacy Policy applies to customers and users of The Network Bank Ltd. Co. and The Network Labs Ltd. Co. (the Network Bank Group) and related platform services for non-U.S. customer relationships.

U.S. customers of Network Capital LLC should review the separate Network Capital Privacy Policy.

When you accept the Agent of Payee Services Agreement, Network Pay LLC and Network Clearing LLC may process payment-related data as your agents and as affiliates under this Policy and that Agreement. No separate Network Pay or Network Clearing privacy policy acceptance is required for onboarding.

Partner Financial Institutions. Banks, correspondent banks, program banks, sponsor banks, custodians, payment processors, and other licensed financial institution service providers (“Partner Financial Institutions”) that support standard platform rails receive and use information as described in this Policy and in Parts H and I of the Network Bank Group Terms, Conditions, and Disclosures. For those standard rails, you are not required to accept a separate Partner Financial Institution privacy pack at onboarding. Specialty products that legally require issuer-specific notices may still present a limited product notice for that product only.

1. Introduction

1.1 Our Commitment to Privacy

The Network Bank Group (The Network Bank Ltd. Co. and The Network Labs Ltd. Co.) respects your privacy and is committed to protecting your personal information. The Network Bank Group comprises:

• The Network Bank (The Network Bank Ltd. Co.) - International banking services (Próspera ZEDE)
• The Network Labs Ltd. Co. - Brokerage and custody services (Próspera ZEDE)

(Collectively, the “Companies,” “we,” “us,” “our,” or the “Group” for purposes of this Privacy Policy.)

This Privacy Policy describes:

• What information we collect about you
• How we use your information
• When and with whom we share your information
• How we protect your information
• Your rights and choices regarding your information
• How to contact us with privacy questions

1.2 Scope

This Privacy Policy applies to:

• Our websites and mobile applications
• Banking services provided by The Network Bank (The Network Bank Ltd. Co.)
• Brokerage, custody, and exchange services provided by The Network Labs Ltd. Co.
• Related Network Bank Group platform services for non-U.S. customers
• Payment-related data processed by Network Pay LLC or Network Clearing LLC when you accept the Agent of Payee Services Agreement, as described in that Agreement and this Policy

1.3 Acceptance

By using our services, creating an account, or providing us with your information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

1.4 Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other reasons.

We will notify you of material changes by:

• Posting the updated policy on our website with a new “Last Updated” date
• Sending notice to your registered email address
• Displaying a notice on our Platform.

Your continued use of our services after changes become effective constitutes your acceptance of the updated Privacy Policy.

2. Information We Collect

2.1 Information You Provide to Us

We collect information you provide directly to us, including:

2.1.1 Account Registration Information

• Full legal name
• Date of birth
• Gender
• Nationality and citizenship
• Country of residence
• Email address
• Phone number
• Mailing address
• Tax identification number or equivalent
• Employment information (occupation, employer name)
• For entities: legal name, registration number, formation documents, beneficial owners, authorized representatives

2.1.2 Identity Verification Information

• Government-issued identification documents (passport, national ID, driver’s license)
• Proof of address documents (utility bills, bank statements)
• Photographs or biometric information (facial recognition, fingerprints)
• Video verification recordings

2.1.3 Financial Information

• Bank account details (account numbers, routing numbers, IBAN, SWIFT/BIC codes)
• Payment card information (card numbers, expiration dates, CVV)
• Cryptocurrency wallet addresses
• Source of funds and source of wealth information
• Financial statements, tax returns, or other financial documentation
• Income, net worth, assets, and liabilities
• Credit history or credit reports (if applicable)

2.1.4 Transaction Information

• Details of deposits, withdrawals, transfers, and trades
• Order history and execution details
• Payment instructions and beneficiary information
• Blockchain transaction hashes and addresses

2.1.5 Communication Information

• Customer support inquiries and correspondence
• Feedback, reviews, or survey responses
• Messages sent through our Platform
• Phone call recordings (with your consent where required)

2.1.6 Profile and Preference Information

• Investment experience and objectives
• Risk tolerance and preferences
• Communication preferences
• Language preferences
• Profile settings and customizations

2.2 Information We Collect Automatically

When you use our services, we automatically collect certain information:

2.2.1 Device and Usage Information

• Device type, model, and operating system
• Browser type and version
• IP address and geolocation data
• Device identifiers (UDID, advertising ID)
• Mobile network information
• Time zone and language settings

2.2.2 Platform Usage Information

• Pages viewed and features used
• Time spent on pages or features
• Click paths and navigation patterns
• Search queries
• Login dates and times
• Session duration and frequency

2.2.3 Cookies and Tracking Technologies

• Cookies (small text files stored on your device)
• Web beacons and pixel tags
• Local storage objects
• Session replay data For more information about cookies, please see our Cookies Policy.

2.3 Information from Third Parties

We may collect information about you from third parties, including:

2.3.1 Identity Verification Services

• Background checks and identity verification services
• Credit bureaus or credit reporting agencies
• Sanctions lists and watchlists
• Politically Exposed Person (PEP) databases
• Adverse media screening services

2.3.2 Blockchain and Public Sources

• Publicly available blockchain transaction data
• Wallet address activity and balances
• Public records and business registries
• Social media profiles (if you link them)

2.3.3 Service Providers

• Payment processors
• Sub-custodians and brokers
• Market data providers
• Analytics providers

2.3.4 Affiliates and Partners

• The Network Bank shares information with The Network Labs and vice versa
• Affiliated companies within our corporate group
• Business partners with whom we offer co-branded services

2.4 Inferences and Derived Information

We may create inferences or derived data based on the information we collect, including:

• Risk profiles and scores
• Investment preferences and patterns
• Behavior analysis and predictions
• Credit or suitability assessments

3. How We Use Your Information

3.1 Service Delivery

We use your information to provide, operate, and maintain our services, including:

• Opening and managing your account
• Verifying your identity and eligibility
• Processing transactions and orders
• Executing trades and transfers
• Providing custody and safekeeping of assets
• Calculating and collecting fees
• Providing customer support
• Communicating with you about your account and transactions
• Generating account statements and tax documents

3.2 Compliance and Legal Obligations

We use your information to comply with legal and regulatory requirements, including:

• Anti-money laundering (AML) and know-your-customer (KYC) compliance
• Sanctions screening and monitoring
• Suspicious activity detection and reporting
• Tax reporting and withholding
• Responding to legal process (subpoenas, court orders)
• Regulatory reporting and audits
• Record-keeping requirements

3.3 Risk Management and Security

We use your information to protect our services and users, including:

• Detecting and preventing fraud, money laundering, and illegal activity
• Monitoring transactions for suspicious patterns
• Verifying the authenticity of transactions
• Preventing unauthorized access
• Investigating security incidents
• Enforcing our terms and conditions
• Recovering debts or resolving disputes

3.4 Product Development and Improvement

We use your information to improve and develop our services, including:

• Analyzing usage patterns and trends
• Improving Platform features and functionality
• Developing new products or services
• Conducting research and data analysis
• Testing and quality assurance

3.5 Marketing and Communications

With your consent where required, we use your information to:

• Send promotional offers and product announcements
• Provide personalized recommendations
• Conduct market research and surveys
• Inform you of events, webinars, or educational content

You may opt out of marketing communications at any time by following the unsubscribe instructions in emails or updating your preferences in your account settings.

3.6 Corporate Transactions

We may use your information in connection with:

• Mergers, acquisitions, or sales of assets
• Financing or investment transactions
• Corporate restructuring
• Due diligence processes

3.7 Legal Purposes

We may use your information for legal purposes, including:

• Establishing, exercising, or defending legal claims
• Protecting our rights and property
• Enforcing agreements
• Complying with court orders or legal obligations

4. How We Share Your Information

4.1 Within The Network Bank Group

We may share information between The Network Bank Ltd. Co. and The Network Labs Ltd. Co., and with other affiliates (including Network Capital LLC, Network Pay LLC, and Network Clearing LLC) as needed to provide services you request or as described in the applicable privacy notices, for:

• Providing integrated services across multiple entities
• Compliance and risk management
• Operational efficiency
• Product development
• Analytics and reporting
• Customer support and service delivery
• Fraud prevention and security

If you have accounts or services with multiple entities within The Network Bank Group, all entities will have access to your information as necessary to provide services.

4.2 Service Providers and Partner Financial Institutions

We share information with third-party service providers and Partner Financial Institutions who perform services on our behalf or support platform rails, including:

• Identity verification and KYC providers
• Payment processors, correspondent banks, program banks, sponsor banks, and other Partner Financial Institutions
• Sub-custodians and brokers
• Technology infrastructure providers (cloud hosting, data centers)
• Customer support platforms
• Analytics and data processing services
• Marketing and communication platforms
• Legal, accounting, and auditing services

Partner reliance. Information you provide to the Network Bank Group (including through the platform) may be shared with Partner Financial Institutions and may be relied on by them to provide Bank Services, verify identity, comply with applicable law, or respond to valid legal process, as described in Part I of the Network Bank Group Terms, Conditions, and Disclosures.

Service providers and Partner Financial Institutions are contractually required to protect your information and use it only for permitted purposes (or as required by law or Payment Network Rules).

4.3 Regulatory Authorities and Law Enforcement

We may disclose information to:

• Regulatory authorities supervising our activities
• Law enforcement agencies investigating crimes
• Tax authorities for tax reporting and compliance
• Government agencies pursuant to legal obligations
• Courts or tribunals in response to legal process We disclose only the information required by law or legal process.

4.4 Fraud Prevention and Security

We may share information with:

• Fraud prevention services and databases
• Cybersecurity providers
• Other financial institutions to prevent and detect fraud

4.5 Blockchain Networks

When you conduct transactions involving Digital Assets:

• Transaction details are publicly visible on the blockchain, including transaction amounts, sender and recipient addresses, and timestamps
• While addresses are pseudonymous, it may be possible to link them to your identity
• We have no control over blockchain transparency or data visibility

4.6 Business Transfers

If we are involved in a merger, acquisition, sale of assets, bankruptcy, or other corporate transaction:

• We may transfer your information to the successor entity
• Your information may be disclosed during due diligence
• The successor entity will be bound by this Privacy Policy (or will notify you of changes)

4.7 With Your Consent

We may share your information with third parties when you provide express consent, such as:

• Linking your account to third-party services
• Participating in co-branded offers or partnerships
• Authorizing specific disclosures

4.8 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that does not identify you personally, including:

• Statistical information about Platform usage
• Market research data
• Industry reports and analysis

4.9 No Sale of Personal Information

We do not sell your personal information to third parties for their marketing purposes.

5. International Data Transfers

5.1 Global Operations

Our operations are international, and your information may be transferred to, stored in, and processed in countries other than your country of residence, including:

• Próspera ZEDE
• Countries where our service providers are located
• Countries where our servers or data centers are located
• Countries where our affiliates operate

5.2 Data Protection Standards

We implement appropriate safeguards to protect your information during international transfers, including:

• Standard contractual clauses
• Data processing agreements with service providers
• Security measures and encryption
• Compliance with applicable data protection laws

5.3 Consent to Transfer

By using our services, you consent to the transfer of your information to countries that may have different data protection laws than your country of residence. Some countries may not provide the same level of data protection as your home country. We take reasonable steps to ensure your information receives adequate protection wherever it is processed.

6. Data Security

6.1 Security Measures

We implement industry-standard security measures to protect your information, including:

• Encryption: Data is encrypted in transit (TLS/SSL) and at rest
• Access Controls: Restricted access to information on a need-to-know basis
• Multi-Factor Authentication: Required for account access and sensitive operations
• Firewalls and Network Security: Protection against unauthorized access
• Monitoring and Logging: Continuous monitoring for security incidents
• Regular Security Audits: Periodic assessments and penetration testing
• Employee Training: Security awareness and data protection training
• Incident Response Plan: Procedures for detecting and responding to breaches

6.2 Your Responsibilities

You play a critical role in protecting your information:

• Use strong, unique passwords for your account
• Enable multi-factor authentication when available
• Keep your login credentials confidential and do not share them
• Be vigilant against phishing and social engineering attacks
• Monitor your account regularly for unauthorized activity
• Report suspicious activity to us immediately

6.3 No Absolute Security

No security system is impenetrable. Despite our efforts, we cannot guarantee absolute security of your information. You acknowledge and accept the risk of unauthorized access, data breaches, or other security incidents.

6.4 Data Breach Notification

In the event of a data breach that compromises your information, we will:

• Investigate the breach and take remedial action
• Notify affected individuals as required by applicable law
• Notify relevant regulatory authorities if required
• Provide information about the breach and steps you can take to protect yourself

7. Data Retention

7.1 Retention Period

We retain your information for as long as:

• Your account is active
• Necessary to provide services to you
• Required by law or regulation (typically 7+ years for financial records)
• Necessary for legitimate business purposes (compliance, dispute resolution, enforcement)

7.2 Deletion After Retention Period

After the retention period expires, we will:

• Securely delete or anonymize your information
• Destroy physical records
• Remove your information from active systems Some information may be retained in backup systems for a limited period before permanent deletion.

7.3 Legal Holds

If your information is subject to legal proceedings, investigations, or disputes, we may retain it beyond the standard retention period until the matter is resolved.

8. Your Rights and Choices

8.1 Access to Your Information

You have the right to:

• Access your personal information we hold
• Request a copy of your information in a portable format
• Verify the accuracy of your information

To request access, contact us at privacy@thenetworkbank.com.

8.2 Correction and Updates

You have the right to:

• Correct inaccurate information
• Update outdated information
• Complete incomplete information

You can update most information directly in your account settings. For other changes, contact us at privacy@thenetworkbank.com.

8.3 Deletion Requests

You may request deletion of your information, subject to:

• Legal retention requirements: We cannot delete information we are required to retain by law
• Ongoing obligations: We cannot delete information necessary for open transactions or obligations
• Legitimate business purposes: We may retain information for fraud prevention, dispute resolution, or legal compliance

To request deletion, close your account and contact us at privacy@thenetworkbank.com.

8.4 Objection and Restriction

You may object to or request restriction of certain processing activities, such as:

• Marketing communications (you may opt out at any time)
• Automated decision-making (if applicable and to the extent permitted by law)
• Certain data processing activities (subject to legal or contractual requirements)

To exercise these rights, contact us at privacy@thenetworkbank.com.

8.5 Marketing Opt-Out

You may opt out of marketing communications by:

• Clicking “unsubscribe” in marketing emails
• Updating your communication preferences in your account settings
• Contacting us at privacy@thenetworkbank.com

Note: Even if you opt out of marketing, we will still send transactional and account-related communications.

8.6 Cookie Choices

You can control cookies through your browser settings. See our Cookies Policy for details.

8.7 Limitations on Your Rights

Your rights may be limited by:

• Legal or regulatory obligations that require us to retain or process information
• Overriding legitimate business interests
• The rights and freedoms of others
• Technical feasibility

8.8 Response Timeframe

We will respond to your requests within a reasonable timeframe, typically within 30 days. If we need more time, we will notify you of the delay.

8.9 Verification

To protect your privacy, we will verify your identity before fulfilling requests.

We may request additional information or documentation to confirm your identity.

8.10 No Fee

We do not charge a fee for processing requests, except in cases of excessive or repetitive requests, in which case we may charge a reasonable administrative fee.

9. Children’s Privacy

9.1 Age Restrictions

Our services are not directed to individuals under the age of 18 (or the age of majority in their jurisdiction).

We do not knowingly collect information from minors. If you are under 18, do not use our services or provide any information to us.

9.2 Parental Notice

If we become aware that we have collected information from a minor without proper consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, please contact us immediately at privacy@thenetworkbank.com.

10. Third-Party Links and Services

10.1 External Websites

Our Platform may contain links to third-party websites or services.

This Privacy Policy does not apply to those third-party sites.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party sites you visit.

10.2 Third-Party Services

If you link your account to third-party services (e.g., social media, external wallets, analytics tools), those third parties may collect information about you. Review the privacy policies of third-party services to understand their data practices.

11. Do Not Track Signals

11.1 DNT Disclosure

Some browsers support “Do Not Track” (DNT) signals. Our Platform does not currently respond to DNT signals, as there is no industry consensus on how to handle them.

11.2 Cookie Controls

You can control cookies through your browser settings or by using cookie management tools. See our Cookies Policy for more information.

12. Automated Decision-Making

12.1 Use of Automated Systems

We may use automated systems and algorithms to:

• Assess your risk profile
• Detect fraud or suspicious activity
• Determine suitability for certain products
• Personalize your experience
• Make credit or account decisions

12.2 Human Review

Significant decisions (such as account closure or denial of services) involving automated processing may be subject to human review.

12.3 Right to Object

If you are subject to automated decision-making with significant effects, you may have the right to:

• Request human intervention
• Express your point of view
• Contest the decision

Contact us at privacy@thenetworkbank.com to exercise this right.

13. Entity-Specific Provisions

13.1 Banking Services (The Network Bank)

For banking services provided by The Network Bank (The Network Bank Ltd. Co.):

• Your banking information is protected according to financial privacy standards
• We do not share your banking information with third parties except as necessary for service delivery, compliance, or as required by law
• Account information is subject to banking regulations and confidentiality requirements
• Banking records are retained for at least 7 years

13.2 Brokerage and Custody Services (The Network Labs)

For brokerage and custody services provided by The Network Labs (The Network Labs Ltd. Co.):

• Your trading and investment information is protected according to securities regulations
• We may share information with sub-custodians, brokers, and exchanges as necessary to provide services
• Transaction data may be visible on public blockchains (for Digital Assets)
• Brokerage records are retained for at least 7 years

13.3 Network Clearing and Network Pay

When you accept the Agent of Payee Services Agreement, Network Clearing LLC and Network Pay LLC may process payment-related data as your agents and as affiliates under this Privacy Policy and that Agreement. No separate Network Pay or Network Clearing privacy policy acceptance is required for onboarding.

13.4 Information Sharing Among Group Entities

Information may be shared among entities within The Network Bank Group to provide integrated services, manage risk, ensure compliance, and improve customer experience. By using services from multiple Group entities, you consent to this information sharing.

14. Complaints and Dispute Resolution

14.1 Privacy Concerns

If you have concerns about our privacy practices, please contact us at privacy@thenetworkbank.com.

We will investigate and respond promptly.

14.2 Supervisory Authority

If you are not satisfied with our response, you may have the right to lodge a complaint with:

• The supervisory authority in Próspera ZEDE
• The data protection authority in your jurisdiction (if applicable)

14.3 Dispute Resolution

Privacy disputes are subject to the dispute resolution provisions in our Master Terms and Conditions.

15. Contact Us

15.1 Privacy Officer

For privacy-related questions, requests, or concerns, contact our Privacy Officer: The Network Bank Group Attn: Privacy Officer Email: privacy@thenetworkbank.com

15.2 Response Time

We will respond to privacy inquiries within 30 days. If we need additional time, we will notify you.

16. Changes to This Privacy Policy

16.1 Updates

We may update this Privacy Policy from time to time.

We will notify you of material changes by:

• Posting the updated policy with a new “Last Updated” date
• Sending email notification
• Displaying a notice on our Platform

16.2 Review

We encourage you to review this Privacy Policy periodically to stay informed about our privacy practices.

16.3 Continued Use

Your continued use of our services after changes become effective constitutes your acceptance of the updated Privacy Policy.

17. Additional Information

17.1 Language

This Privacy Policy is written in English. Translations are provided for convenience only. In case of inconsistency, the English version prevails.

17.2 Entire Agreement

This Privacy Policy, together with our Master Terms and Conditions and other applicable policies, constitutes the complete agreement regarding privacy.

17.3 Jurisdiction-Specific Provisions

Depending on your location, additional privacy rights or disclosures may apply.

We will provide supplemental information as required by local law.

Acknowledgment

By using our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.