Privacy Policy

  1. Scope of Policy
    1. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. We process your personal data in accordance with the General Data Protection Regulation (GDPR) and will always keep your data safe and private and never sell your data to third-parties.

    2. Please read this carefully as this policy is legally binding when you use our services. This policy together with the Terms and Conditions apply to your use of:

      1. Our website at www.bitsafe.com and my.bitsafe.com (the "Site");

      2. The Bitsafe App ("App") once you have downloaded a copy of the App onto your mobile telephone or handheld device ("Device"); and

      3. Any of the services accessible through the App or the Site (the "Services").

    3. The authority responsible for the collection, processing and use of personal data is:

      Bitsafe Payments B.V.
      Danzigerkade 23D
      1013 AP Amsterdam
      Netherlands

      We have appointed a Data Protection Officer ("DPO"), who is accessible via dataprotection@bitsafe.com The DPO has a number of important responsibilities including:

      1. Monitoring Bitsafe's compliance with the GDPR and other data protection laws;

      2. Raising awareness of data protection issues, training Bitsafe staff and conducting internal audits; and

      3. Cooperating with supervisory authorities on our behalf

      If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO at dataprotection@bitsafe.com.

  2. Cookies
    1. We use cookies to distinguish you from other users of the App or the Site. This helps us to provide you with a good experience when you use the App or browse our Site and also allows us to improve the App and our Site.

  3. How do we protect your personal information
    1. We are serious about guarding the security of your personal information and use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using Transport Layer Security technology.

    2. As you will know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

    3. We restrict access of your personal information to those employees of Bitsafe who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from unauthorized access.

  4. Information we may collect from you
    1. Information you give us:

      1. You may give us information about you when you sign up to use our service, e.g. when you provide us with your personal details, such as your name and email address. This also includes information you provide through your continued use of our Services on our Site or App. The information you give us may include your name, address, e-mail address, phone number, financial information, payment reason, geographical location, social security number, personal description and photograph.

      2. We may also need additional commercial and/or identification information from your e.g. if you send or receive certain high-value or high volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.

      3. In providing the personal data of any individual (other than yourself) to us during your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy.

    2. Information we collect about you:

      1. Details of the transactions you carry out when using our Services, including details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

      2. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

      3. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.

    3. Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them.

      For example:

      • the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;

      • business partners may provide us with your name and address, as well as financial information, such as card payment information;

      • advertising networks, analytics providers and search information providers may provide us with pseudonymized information about you, such as confirming how you found our website;

      • credit reference agencies do not provide us with any personal information about yourself, but may be used to corroborate the information you have provided to us.

    4. In our current activity, we will transfer the information you have provided to us, and information collected and/or received from other sources (your "personal data") to other countries / international / foreign organizations only if that country or international / foreign organization has a Personal Data Protection standard equivalent to this data protection policy and in line with GDPR and Dutch AVG provisions.

  5. Uses made of the information
    1. Data protection legislation requires us to collect and process your personal data legally and correctly in relation to you in order to protect your individual rights. Your personal data will only be collected for determined, explicit and legitimate purposes, defined below. The purpose of the processing of your personal data should have a legal basis. Subsequent changes to this purpose is possible but only to a limited extent and requires a solid legal foundation. We may use your information in the following ways:

      1. to carry out our obligations relating to your contract with us and to provide you with the information, products and services;

      2. to comply with any applicable legal and/or regulatory requirements;

        You give us the right to share your personal data to the payment Card Networks pursuant to the requirements of the network rules under the applicable payment facilitation contracts, card issuing agreements or with third-party service providers who help with certain parts of our business operations, including payment processing, fraud prevention, validation of user credentials, secure data storage and other similar services. We ensure that these parties only use personal information in connection with the services they perform for us.

      3. to notify you about changes to our Services;

      4. as part of our efforts to keep our Services safe and secure;

          Therefore you give us the right to share your personal data further with:

        • to our management board, on a need-to-know basis, with the implementation of appropriate safeguards in relation to them, in order to ensure the integrity and security of your personal data;

        • to companies providing money laundering and other fraud prevention and crime prevention services and companies providing similar services, including financial institutions, credit bureaux and regulatory authorities with which data are shared;

        • to card issuing company with whom we have a contracted relationships, including PayrNet (UK) Limited, PayrNet UAB and/or Railsbank Technology (UK) Limited (jointly "PayrNet");

        • to counter parties in any payment transaction, where such personal information may be limited to your name or names, and your account number;

        • to courts of law, law enforcement authorities, regulators or lawyers or other persons, if it proves to be justly necessary to establish, exercise or defend a right to a fair hearing.

      5. to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

      6. to improve our Services and to ensure that they are presented in the most effective manner;

      7. to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;

      8. to allow you to participate in interactive features of our Services, when you choose to do so;

      9. to provide you with information about other similar goods and services we offer;

      10. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or

      11. to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

  6. Data retention
    1. As a regulated financial institution, Bitsafe is required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.

    2. We will always delete data that is not longer required by a relevant law or jurisdiction in which we operate.

  7. Rights
    1. You have the following rights concerning your personal data: right of access according to Art. 15 GDPR, right of rectification according to Art. 16 GDPR, right to erasure according to Art. 17 GDPR, right to restriction of the processing according to Art. 18 GDPR, right if revocation to according to 21 GDPR, aw swell as the right to data portability according Art. 20 GDPR. Please note, that the restrictions of sec. 45, 35 BDSG apply to the right of access and the right to erasure.

    2. You have the right to request information about the way Bitsafe handles your personal information (DSAR). The type of DSAR may be a request of what personal data is collected in general, what personal data is collected on you, a DSAR to delete your personal data or a DSAR to take your personal data somewhere else. You may request a DSAR via email to dataprotection@bitsafe.com. Bitsafe first needs to verify your identity and existence within Bitsafe's ecosystem and track the request through to resolution in 30 working days.

    3. Any DSAR of Bitsafe Account holders that relate to the Bitsafe Debit Card are also shared with the card issuer financial institution, unless we are not allowed to do so under applicable laws.

  8. Changes to our privacy policy
    1. Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

  9. Contact
    1. Questions, comments and request regarding this privacy policy are welcomed and should be addressed to privacy@bitsafe.com