Privacy Policy
This policy explains when and why we collect personal information about you, how we use it,
the conditions under which we may disclose it to others and how we keep it secure.
TPL is committed to safeguarding the privacy of your information. By “your data”, "your
personal data”, and “your information” we mean any personal data about you which you or
third parties provide to us.
We may change this Policy from time to time so please check this page regularly to ensure
that you’re happy with any changes.
Who are we?
Transact Payments Limited (“TPL”, “we”, “our” or “us”) is the issuer of your card and is the
Data Controller for the personal data which you provide to us in relation to your application
for and use of the card only. TPL is an e-money institution, authorised and regulated by the
Gibraltar Financial Services Commission. Our registered office address is 6.20 World Trade
Center, 6 Bayside Road, Gibraltar, GX11 1AA and our registered company number is 108217.
In relation to the matters listed in the Brightwell Privacy Policy for which your personal data
is processed, the Data Controller is Brightwell Payments, Inc., whose registered office address
is at P.O. Box 724026, Atlanta, Georgia 31139, USA and that processing is governed by the
Brightwell Privacy Policy which you can view here.
How do we collect your personal data?
We collect information from you when you apply online, in person or via a mobile application
for a payments card which is issued by us. We also collect information when you use your
card to make transactions. We also obtain information from third parties (such as employers,
joint account holders, credit reference agencies and fraud prevention agencies) who may
check your personal data against any information listed on an Electoral Register and/or other
databases.
On what legal basis do we process your personal data?
Contract
Your provision of your personal data and our processing of that data is necessary for each of
us to carry out our obligations under the contract (known as the Cardholder Agreement or
Cardholder Terms & Conditions or similar) which we enter into when you sign up for our
payment services. At times, the processing may be necessary so that we can take certain
steps, at your request, prior to entering into that contract, such as verifying your details or
eligibility for the payment services. If you fail to provide the personal data which we request,
we cannot enter into a contract to provide payment services to you or will take steps to
terminate any contract which we have entered into with you.
Legal/Regulatory
We may also process your personal data to comply with our legal or regulatory obligations.
Legitimate Interests
On occasion we may have a legitimate interest or those of a third party to process your
personal data.
What type of personal data is collected from you?
When you apply for a card, we, or our partners on our behalf, collect the following
information from you: full name, date of birth, street address, passport number, passport
country, passport issue and expiry dates and bank account details.
When you use your card to make transactions, we store that transactional information. This
includes the date, amount, currency, card number, account balances and name of the
merchant or supplier (for example a supermarket or retailer). We also collect information
relating to the payments which are made to/from your account.
How is your personal data used?
We use your personal data to:
- set up your account, including processing your application for a card, creating your account,
verifying your identity and printing your card.
- maintain and administer your account, including processing your financial payments,
processing the correspondence between us, providing general customer services, monitoring
your account for fraud and providing a secure internet environment for the transmission of
our services.
Who do we share your information with?
We pass your information to our third party service providers, agents, subcontractors,
program managers and other associated organisations for the purposes of completing tasks,
managing your account and providing services to you on our behalf, as detailed above. When
we use third party service providers, we have a contract in place that requires them to keep
your information secure and confidential.
We pass your information to the following categories of entity:
- companies and organisations that assist us in processing transactions you make (including
but not limited to payment processing service providers) and in providing services that you
have requested;
- companies and organisations that run and manage the card program;
- identity verification agencies to undertake required verification, regulatory and fraud
prevention checks;
- payment card manufacturers;
- information security services organisations, web application hosting providers, network
backup service providers and software/platform developers;
- document destruction providers;
- anyone to whom we lawfully transfer or may transfer our rights and duties under this
agreement;
- any third party as a result of any restructure, sale or acquisition of TPL or any associated
entity, provided that any recipient uses your information for the same purposes as it was
originally supplied to us and/or used by us.
- regulatory and law enforcement authorities, whether they are outside or inside of the EEA,
where the law requires us to do so.
Sending personal data overseas
To deliver services to you, it is sometimes necessary for us to share your personal information
outside the European Economic Area (EEA), e.g.:
with service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and Gibraltar data protection law.
These non-EEA countries do not have the same data protection laws as Gibraltar and EEA. We
will, however, ensure the transfer complies with data protection law and all personal
information will be secure. We will send your data to countries where the European
Commission has made an adequacy decision, meaning that it has ruled that the legislative
framework in the country provides an adequate level of data protection for your personal
information. You can find out more about this here.
Where we send your data to a country where the European Commission has not made an
adequacy decision, our standard practice is to use standard data protection contract clauses
that have been approved by the European Commission. To obtain a copy of those clauses,
please go to the European Commission’s website.
We transfer your data to the United States of America. Please go to the Privacy Shield website
in order to find out more about the EU Commission-approved safeguards in place for that
data transfer.
If you would like further information please contact our Data Protection Officer.
How long do we store your personal data?
We will store your information for a period of 5 years after our business relationship ends in
order that we can comply with our obligations under applicable legislation such as anti-money
laundering and anti-fraud regulations. If any changes to applicable legislation require us to
retain your data for a longer period of time, we shall retain it for that period. We will not
retain your data for longer than is necessary.
Your rights regarding your personal data?
You have certain rights regarding the personal data which we process:
- You may request a copy of some or all of it.
- You may ask us to rectify any data which we hold which you believe to be inaccurate.
- You may ask us to erase your personal data.
- You may ask us to restrict the processing of your personal data.
- You may object to the processing of your personal data.
- You may ask for the right to data portability.
- If you would like us to carry out any of the above, please email the Data Protection Officer
at DPO@transactpaymentsltd.com.
How is your information protected?
We implement security policies and technical measures in order to secure your personal data
and take steps to protect it from unauthorised access, use or disclosure.
While we strive to protect your personal information, we cannot guarantee the security of
any information you transmit to us, and you do so at your own risk. Once we receive your
information, we make our best effort to ensure its security on our systems. Where we have
given (or where you have chosen) a password which enables you to access certain parts of
our websites, you are responsible for keeping this password confidential. We ask you not to
share your password with anyone.
Complaints
We hope that our Data Protection Officer can resolve any query or concern you may raise about our
use of your personal information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory
authority, in particular in the European Union (or European Economic Area) state where you work,
normally live or where any alleged infringement of data protection laws occurred. The supervisory
authority in Gibraltar is the Gibraltar Regulatory Authority. Their contact details are as follows:
Gibraltar Regulatory Authority,
2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar.
(+350) 20074636/(+350) 20072166 info@gra.gi
Other websites
Our website may contain links to other websites. This privacy policy applies only to our
website‚ so we encourage you to read the privacy statements on the other websites you visit.
We cannot be responsible for the privacy policies and practices of other sites even if you
access them using links from our website.
Changes to our Privacy Policy
We keep our Privacy Policy under review and we regularly update it to keep up with business
demands and privacy regulation. We will inform you about any such changes. This Privacy
Policy was last updated on 25th May 2018.
How to contact us
If you have any questions about our Privacy Policy or the personal information which we hold
about you or, please send an email to our Data Protection Officer at
DPO@transactpaymentsltd.com.
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