This policy explains how Mosaic ("Mosaic", "we", "us") handles personal data when you use this website, contact us, apply for or use our services, or otherwise interact with us. Mosaic processes personal data in accordance with the Cayman Islands Data Protection Act (2021 Revision) and, where applicable, other data protection laws.
Who we are
The data controller is Mosaic Technologies, an exempted company incorporated in the Cayman Islands, which operates the Mosaic platform. Contact details for data protection matters are set out at the end of this policy.
Cayman Islands Data Protection Act
Mosaic is the data controller of personal data collected through the platform for the purposes of the Cayman Islands Data Protection Act (2021 Revision). We collect identity, contact, beneficial ownership and transaction data to open and operate your account, to meet our and our providers' legal obligations, and to provide the services. We share personal data with Dakota Ridge, Inc. and its partner bank Lead Bank, Rain and Third National as card program manager and issuer, Mosaic Capital Inc., and our service providers, including providers in the United States, under contracts that require them to protect it. You have rights of access, rectification, erasure and objection, and to complain to the Cayman Islands Ombudsman. Email support@mosaic.ky.
What we collect
- Contact details you give us: name, work email address, company, role and message content when you contact us or request information.
- Onboarding and verification information for entities and their directors, signatories and beneficial owners, including identity documents, proof of address, source of funds and wealth, and tax residency, as required by anti-money-laundering and counter-terrorist-financing law.
- Account and transaction information generated when you use our services, including payments, conversions, card activity and approvals.
- Technical information: IP address, browser and device type, pages visited and the referring page, collected through server logs and any analytics we use.
Why we use it and on what basis
- To respond to enquiries and provide information you have asked for, on the basis of your request.
- To assess applications, verify identity, screen against sanctions and politically exposed person lists, and monitor transactions, to comply with our legal obligations.
- To provide, operate, secure and improve our services under our contract with the customer.
- To send service communications and, where you have not objected, information about our products, on the basis of our legitimate interests.
- To establish, exercise or defend legal claims.
Who we share it with
- Service partners that provide accounts, payment rails, card issuing, custody and treasury products on our platform, to the extent needed to deliver the service.
- Identity verification, screening, fraud prevention and analytics providers acting on our instructions.
- Professional advisers, auditors and insurers.
- Regulators, law enforcement and courts where required by law or to protect our rights.
- A buyer or successor in the event of a merger, acquisition or reorganisation.
We do not sell personal data.
International transfers
Our partners and providers may be located outside the Cayman Islands, including in the United States and the European Union. Where personal data is transferred internationally we rely on safeguards permitted by the Data Protection Act, such as contractual protections and the adequacy of the destination's law.
How long we keep it
We keep personal data for as long as needed for the purposes above. Records collected for anti-money-laundering purposes are retained for at least five years after the end of the business relationship or the transaction, as Cayman law requires. Enquiry data is kept for as long as needed to respond and for a reasonable period afterwards.
Security
We apply technical and organisational measures appropriate to the sensitivity of the data, including encryption in transit, access controls, logging and staff training. No system is perfectly secure, and we will notify you and the Ombudsman of a personal data breach where the law requires it.
Your rights
Subject to the Act, you may ask us to confirm whether we process your personal data, to give you access to it, to correct or erase it, to stop or restrict processing, and to stop direct marketing at any time. You may also complain to the Office of the Ombudsman of the Cayman Islands, which supervises data protection.
Cookies and analytics
This website uses only the cookies and local storage needed for it to function. If we add analytics or marketing cookies we will update this policy and, where required, ask for your consent.
Changes
We may update this policy. The date at the top shows when it last changed. Material changes will be highlighted on this page.
Contact
For any question or request about personal data, email support@mosaic.ky, marking your message for the attention of the data protection contact.