Privacy Policy of Kodo GmbH

Status: March 2026

1. Data Controller

Kodo LLC
CHE-138.057.351
c/o Malik Bajo, Albertstrasse 10, 8005 Zürich
E-Mail: malik@kodo-pay.com
Phone: +41 78 646 88 76
This Privacy Policy applies to all data processing activities in connection with our money transfer services as well as the website www.kodopay.ch.

2. Personal Data We Process

We process in particular the following categories of personal data:

2.1 Master Data

Name, date of birth, address, contact details.

2.2 Identification Data (KYC)

Data from passport/ID documents, information on the beneficial owner, source of funds, purpose of the transaction.

2.3 Transaction Data

Amount, currency, destination country, payout method, recipient details.

2.4 Communication Data

Emails, telephone inquiries, contact form content.

2.5 Technical Website Data

IP address, browser information, time of access.
Our website is for informational purposes only and does not offer online transactions.

3. Purposes of Data Processing

We process personal data for the following purposes:

Execution of money transfers
Identification (KYC) and compliance with obligations under the Swiss Anti-Money Laundering Act (AMLA)
Prevention of fraud, misuse, and sanctions violations
Compliance with legal and regulatory requirements
Internal analysis and improvement of our services
Communication with you

Where we process data based on your consent (e.g. newsletters), you may withdraw your consent at any time.

4. Disclosure of Data

We only disclose personal data where necessary or legally required, in particular to:

Payment partners in Switzerland and abroad (e.g. mobile money providers, banks, cash pickup locations),
Banks and financial institutions,
IT service providers and technical vendors,
Our self-regulatory organisation (SRO PolyReg),
Supervisory authorities and law enforcement agencies, where legally required

4.1 Sanctions Screening and AML Service Providers

To comply with our legal obligations under the AMLA, personal data may be transmitted to specialised service providers, such as:

Sanctions list screening (e.g. UN/EU/OFAC/SECO),
AML checks and risk assessments,
Fraud prevention tools,
Transaction monitoring systems.

Such providers may be located in Switzerland or abroad.

5. Cross-Border Data Transfers

For the execution of a money transfer, personal data may be transferred to countries that do not provide a level of data protection equivalent to that of Switzerland.
Such transfers take place only if:

they are necessary for the performance of the contract (e.g. payout in the destination country),
appropriate safeguards are in place (e.g. standard contractual clauses), or
a statutory exception applies.

6. Data Retention

Personal data is retained only for as long as necessary or as required by law.
As a financial intermediary, we are subject to statutory retention obligations of up to ten (10) years after the end of the transaction or business relationship.

7. Data Security

We protect personal data through appropriate technical and organisational measures, including:

access restrictions,
secure storage,
encryption where appropriate,
regular backups.

Despite these measures, data transmission over the internet may involve security risks.

8. Your Rights

Under applicable law, you have in particular the right to:

access,
rectification,
deletion (to the extent legally permissible),
restriction of processing,
object to certain processing activities,
receive or request the transfer of certain data,
withdraw any consent given.

To exercise your rights, please contact: malik@kodo-pay.com
You also have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC).

9. Website and External Links

Our website may contain links to third-party websites. The respective operators are solely responsible for their content and data protection practices.

10. Amendments

This Privacy Policy may be amended at any time.
The version published on our website at any given time shall apply.

Contact

Kodo LLC
c/o Malik Bajo, Albertstrasse 10,
8005 Zürich
E-Mail: malik@kodo-pay.com
Phone: +41 78 646 88 76