SwirlPay Ltd. is dedicated to safeguarding the privacy and confidentiality of personal information within our possession and control. This Privacy Policy outlines the steps we take to honor these commitments and elucidates how SwirlPay collects, utilizes, maintains, discloses, and manages personal information of users ("Users") of our website at www.swirlpay.net and the SwirlPay mobile application (collectively with all subpages and successor pages, the "Site"), as well as through other products and services offered by SwirlPay (collectively the "Services") and other interactions with our clients and prospective clients.

Your Consent: By utilizing the Site, registering for or acquiring a Service, and/or providing us with personal information, you agree to the collection, use, and disclosure of your personal information as detailed in this Privacy Policy. Capitalized terms used but not defined in this Privacy Policy have the meanings given to those terms in the SwirlPay User Terms.

To exercise any of your rights described herein, you can contact us using the details in the "Contacting Us" page of the website or using the support@swirlpay.net email.

Personal Information We Collect: We collect personal information from Users directly, through their interactions with the Site and the Services, and from third parties, as described below.

We gather personal information in various ways, including when Users visit or use our Site, register for or use a Service, and in connection with other activities, services, features, or resources available on or through our Site. Users may be required to provide, as appropriate, name, address, email address, telephone number, date of birth, government ID information, passport number, payroll provider, occupation, employer or other related organization, and banking or other account information.

Users may also furnish us with additional personal information when contacting us with questions, inquiries, complaints, or suggestions. Information about how Users use our Site and Services is also collected.

We also collect information about your use of our Services, including details about your transactions using your Card (such as transaction date, amount, and location).

We may obtain personal information from third-party partners with User consent, such as credit scores and related information from credit bureaus.

If you create an account, you agree that we may verify your name, address, phone number, and other account details using information about you held by third parties or publicly available sources (such as identity verification providers, fraud prevention services, government registries, and your mobile service provider) to verify your identity and prevent potential fraud. Your personal information will not be shared with these third parties for any other purpose.

Information We Collect Automatically through our Site:

We may collect information about Users whenever they interact with our Site, including browser name, type of computer, and technical information about Users' means of connection to our Site (such as operating system and Internet service providers). This information is used to understand how Users interact with our Sites and to make improvements.

Cookies and Similar Technologies: Our Site uses "cookies," which are tiny data elements that the Site can send to your browser for storage on your hard drive. We use cookies to enhance User experience, deliver personalized recommendations, products, and services, and to provide information to us and our service providers about your use of the Site and other websites. You can set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you choose not to accept cookies from the Site, some features may not be available to you.

Tracer Tags & Web Beacons: The Site may use "tracer tags" or "Web Beacons" to understand which pages Users visit. These tags help optimize and tailor the Site for Users and future visitors.

Online Advertising: Third parties may serve advertisements on our Site or other websites. These companies may use cookies, tracer tags, or web beacons to report information about your visits to measure marketing campaign effectiveness and deliver more relevant ads on and off our Site.

How We Use Collected Information: SwirlPay may collect and use Users' personal information for the following purposes:

To provide Services: Information is used to register Users for a Service, provide and administer our Services, and address any issues related to a Service.

To process Card applications (including identity verification) and, if a Card is issued, to provide Card-related services (including administering the Card and processing Card transactions).

To respond to inquiries and improve customer service: Information is used to respond to User inquiries, questions, and requests, enhancing efficiency in customer service.

To personalize user experience: Collected information may be used to personalize Users' experiences when using the Site or Services.

To improve our Site: Information, including User feedback, is used to enhance our Site and Services.

To run promotions, contests, surveys, or other Site features: Information is used to administer contests, promotions, surveys, and other Site features.

For marketing purposes: Personal information may be used to understand Users' needs and preferences, providing information and offers believed to be of interest. Users can opt out of this use of personal information.

For research and analytics: Information collected may be used to generate aggregate or de-identified data for research and analytics purposes.

For other reasonable business purposes: Information may be used to detect and prevent fraud, for legal compliance, to enforce agreements with Users, and for other purposes with User consent or as permitted or required by law.

How We Protect Your Information: We employ appropriate data collection, storage, and processing practices and security measures to guard against unauthorized access, alteration, disclosure, or destruction of Users' personal information. Personal information is stored on our servers or those of our service providers, accessible only to authorized personnel who need access for their job responsibilities.

Your online access to certain personal information is protected with a password of your choosing. We advise against disclosing your password to anyone. In the event of a breach, we will notify you and the relevant authorities in accordance with applicable law.

Sharing Your Personal Information: We may disclose personal information to third parties (including outside of Bulgaria) as necessary to provide requested Services.

Personal information may be disclosed to third parties, such as identity verification providers, fraud prevention services, government agencies, and mobile service providers, to verify identity, contact information, and account details.

Personal information and payment history may be disclosed to credit bureaus for updating and maintaining information in their records.

Service providers may be used to perform specialized services on our behalf, such as data hosting, processing services, banking, payment processing, research, marketing, analytics, customer service, digital support, or mail distribution. Service providers are given only the necessary information to perform the service, and we require them to protect the information in line with our Privacy Policy and security practices.

Personal information may be disclosed in connection with proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of SwirlPay or our business or assets for evaluation and/or execution of the proposed transaction. Assignees or successors of SwirlPay may use and disclose personal information for purposes similar to those outlined in this Privacy Policy.

Personal information may be disclosed in other circumstances with User consent or as permitted or required by law, including foreign laws applicable to us, our affiliates, and service providers.

Generic aggregated demographic information not linked to personal identification information may be shared with business partners, trusted affiliates, and advertisers.

Personal information we collect may be transferred to jurisdictions other than the one in which the information was originally collected, and processing and storage may occur outside your jurisdiction of residence, including outside Bulgaria. These jurisdictions may not have the same data protection laws as your jurisdiction of residence, and your personal information may be subject to applicable foreign laws. If we transfer your personal information to other jurisdictions, we will protect it as described in this Privacy Policy.

Your Choices: You may withdraw your consent to our collection, use, and disclosure of personal information at any time by contacting us as described in the "Contacting Us" section below. Withdrawal of consent is subject to contractual and legal restrictions and reasonable notice. Certain Site functionality may be unavailable if you withdraw your consent.

You can request account closure using the "Cancel Account" button in our mobile application. Refer to the User Terms for additional information on account cancellation.

You may request that we not use your personal information for marketing purposes by contacting us as described in the "Contacting Us" section or by using an unsubscribe feature in our marketing communications. Note that you may still see certain types of ads (e.g., online) even if you ask us not to use your personal information for marketing purposes.

Subject to applicable law, you may ask us to erase your personal information. A request for erasure should be made via email by contacting us as described in the "Contacting Us" section below. If a request is refused, we will notify you and provide reasons for the refusal.

Children's Privacy: Our Site is not intended for children under sixteen, and we do not knowingly collect information from children under sixteen on our Site. If we learn that we have received information from a visitor under sixteen on our Site, we will delete the information.

User Submitted Content: Users may submit reviews, content, and other information through our Site and third-party social media platforms. Opinions expressed in user-submitted content are solely those of the users submitting the content and do not necessarily reflect SwirlPay's opinions, policy, or position. Users assume all risks associated with such content. Users also agree that SwirlPay has no responsibility or liability for such activities and that user content is not sponsored or endorsed by SwirlPay.

Third-Party Websites: Our Site may contain links to websites we do not own or operate. Links to our Site may be featured on third-party websites on which we advertise. We provide links as a user convenience, and these links are not endorsements of or referrals to the linked websites. Linked websites have separate privacy policies, notices, and terms of use, and we recommend reading them carefully. We have no control over such websites and no responsibility or liability for how organizations operating them collect, use, disclose, secure, and otherwise treat personal information.

Safeguarding Credit Card Information: We protect personal and credit card information from loss, theft, alteration, and misuse. Safeguards depend on the sensitivity, amount, distribution, format, and storage of personal information. While we take precautions, no system or security measure is completely secure. Transmission of personal and credit card information is at your own risk, and we expect you to take appropriate measures to protect this information.

Retaining Your Personal Information: We will retain personal information as long as necessary to perform requested Services, protect our Site and Services from fraud or unlawful activity, meet legal obligations, and protect and enforce legal rights. If you withdraw consent or cancel your account, we will no longer use or disclose your personal information for Services but may retain it as necessary for the noted purposes.

Changes to Our Privacy Policy: SwirlPay may update or change this Privacy Policy at any time. The revised date will be shown at the bottom of this page. Users are encouraged to check this page frequently for changes and acknowledge that continued use of the Site or Services after changes are posted indicates acceptance of those changes.

Contacting Us: You can request access to, correction, or erasure of your personal information by writing to the address below, attention Senior Counsel for Privacy. Verification of identity may be required.

If you have questions about this Privacy Policy or our personal information handling practices, contact us at:

SwirlPay Inc.
www.swirlpay.net 
support@swirlpay.net
 

This document was last updated on November 14, 2024.