- PRIVACY POLICY

At , we're committed to protecting your data. This privacy policy describes what data we process about you, what we do with it and why.
is made up of more than one company. The company you'll have a relationship with is dependent on where you're based and what you're using for. We'll tell you who you have a relationship with when you first apply for or use a product or service.
In short:

• Group
• Corporation (US)
• Subsidiaries

What data do we process about you?
Identity Data:

• Full name
• Date of birth
• ID document details
• Selfie photograph
• Employment status and industry

Financial Data:

• Details of the funding card(s) added to your account
• card data (including card number, expiring date, CVV number, name and billing address)
• Details of your credit history held at credit reference agencies

Contact Data:

• Home address
• Shipping address
• Billing address
• Email address
• Mobile number

Transaction Data:

• Information about your transactions
• Rewards
• Purchases

Device Data:

• Internet Protocol (IP) address
• Model of your phone
• Geo-location

Profile Data:

• Communication preferences
• Social media handles
• Feedback
• Survey / questionnaire responses

How do we get your data?
There are a number of ways in which we obtain your data.
From direct interactions, we have with you, including:

• Creation of an account
• Use of one of our products
• Subscription to marketing
• Contacting
• Providing feedback
• Using Community

From our automatic collection, including:

• Technical data from your electronic devices, browsing actions and patterns. Collected using cookies, server logs and similar technologies.

From third parties or publicly available information, including:

• Analytics providers
• Payment services and e-wallet providers
• Customer service providers
• Electoral register
• Governmental agencies
• Credit reference agencies

What do we use your data for?
We use your data to provide the best experience possible. We always have a lawful basis to process your data. This section provides you with information about our use of your data. We only use your personal data for the purpose we collected it or a similar, connected purpose. If we ever need to use your information for an unrelated purpose, we’ll inform you and explain why. We may also be required by law to process your personal data without your knowledge or consent.

Who do we share your data with and why?
When we share data with third parties, they can only process it for specific purposes and in accordance with our instructions.
Here's who we may share data with and why:
The Group.
We share personal data within the Group of companies in order to provide you with the best service(s) and perform necessary activities, as described above.
Identity checking and fraud prevention partners.
To perform sign-up and verification checks.
When shares data with identity and fraud prevention partners, they will become a joint controller of your data to determine how your data will be used to best provide their services.

IT vendors including cloud storage providers.
Hosting and IT services; IT vendors including cloud storage providers to securely store your personal data.
Social media sites.
Social media sites, for the purposes of conducting market research and running marketing campaigns. When sharing data with these sites, we ensure that your data is only used in accordance with our instructions.
If you don’t want us to use your information in this way, you can contact us at privacyrequests@.com.

Financial services providers.
To facilitate payment processing, we share your data with financial services providers, including card issuers, payment processors and banking partners to facilitate payment transactions.
Our payment processing activities for customers in Europe will be carried out by Europe UAB as it is licensed to provide financial services in Europe in accordance with EU financial regulations.

Support tools.
Support tools include analytics and search engine service providers and customer experience support platforms which we use to optimise and improve our services.
If you contact our customer services line out of hours, our external team will manage your enquiries. We will become joint controllers of your data as they will determine the means of collecting your data on our behalf.
Vendors, Partners and Contractors
To the extent necessary, we may share your information with other vendors and contractors that perform certain services on our behalf / help us to provide our services and products.
What are your rights?
You have rights over your personal data.

• Access the personal data we process about you.
• Rectify your personal data by asking us to correct it for you.
• Delete your data, by asking us to delete it. There are times when we may not be able to delete data for legal purposes.
• Restrict or object to our processing of your data for direct marketing.
• Withdraw any consent you’ve given us to use your personal data in a specific way.
• Request a review of any automated decision made by technology.

If you want to do any of the above, or if you have questions relating to 's data processing please get in touch with us at privacyrequests@.com.
We have one month to respond unless your request is complicated, in which case we may need more time. If that's the case, we'll let you know.
This is almost always free but we’re allowed to charge a reasonable fee or refuse your request if it’s clearly unfounded, repetitive or excessive.

How can you opt-out of marketing?
You can ask us to stop sending you marketing emails at any time by following the "e;unsubscribe"e; links at the bottom of any marketing message. You'll still receive operational emails we need to send you, such as updates to our terms and conditions.
If you would like to stop receiving receipt emails (for each of your payments), you can change your preferences for each of your funding cards on the app.

Do we make automated decisions about you?
Depending on the products or services you use, we may make automated decisions about you.
This means that we may use technology that can evaluate relevant factors about you and your circumstances to predict risks or outcomes. We do this for the efficient running of our services and to make sure that the decisions we make are fair, consistent and based on the correct information.
Where we make an automated decision about you, you have the right to ask that it is manually reviewed by a human.
For example, we may make automated decisions about you that relate to:
Detecting fraud

• Monitoring your account to detect fraud and financial crime

Our legal basis for our use of automated decision making is to enable us to fulfil our contract with you or because we have a legal obligation to do so.

How long do we keep your data?
The period for which we may retain data about you will depend on:

• The purposes for which the data was collected,
• whether you have requested deletion of the data, and;
• whether we have any legal or regulatory obligation to retain the data.

We will not retain data about you for longer than is necessary to fulfil the purposes for which the data was collected. We will typically keep your data for up to 10 years after you last completed onboarding or had an active account or product with us.
We may keep your personal data for a longer period where it is necessary for legal, regulatory or operational purposes.

How can you contact us?
You’re most welcome to drop us an email at privacyrequests@.com to exercise a right, ask a question, lodge a complaint or offer a suggestion.

How can you escalate a complaint?
We encourage you to contact us directly if you aren't happy with how we've handled a request or another data protection matter.
Should you wish to contact our Data Protection Officer, you can email them at privacyrequests@.com.
You also have the right to lodge a complaint with the UK's Information Commissioner's Office depending on which entity is the subject of your complaint.