Effective as of: 25.05.2018
Last update: 28.07.2019This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of PremioCard Service.
If you see an undefined term in this Privacy Policy (such as “E-money” or “PremioCard”), it has the same definition as in our PremioCard Terms & Conditions, PremioCard Business Terms & Conditions, Acquiring Service Terms & Conditions, regulating the all aspects of PremioCard Service for individual and business clients to all of which this Privacy Policy is inseparable part.
When this policy mentions “we,” “us,” or “our,” it refers to iCard AD, Company number 175325806, Registered office Business Park Varna, building B1, Varna 9009, Bulgaria, that is responsible for your information under this Privacy Policy (the “Data Controller”).
For the purposes of this documents PremioCard Service consist of products, services, content, features, technologies, or functions, and all related websites, applications (if any) offered to you by us or mobile apps, online platform, official social media platforms or other online properties, or POS terminals or other physical devices through which we provide payment and e-money services (referred to as “PremioCard Service” or “Service”).
We give utmost importance to the protection of personal data of our customers. In the following Privacy Policy, we inform the Client about the collection, use and processing of your personal data when you apply, register or use our PremioCard Service and all functionalities, including our website https://www.premiocard.com (hereinafter: "Website"), E-money account, Cards and POS devices.
PremioCard Service is also designed for business purposes and may be used both by individuals or entities (“company”). In case you are registering for and/or using our PremioCard Service on behalf of an entity we will treat you as authorized person on behalf of the company and you may be obliged to disclose to us personal data of the legal representatives, the employees, the agents, the beneficial owners or any other third-party related to the entity pursuant to the rules described below. You certify that where you have provided information regarding any third person beside yourself you have received prior consent from that other person to provide their personal information to us.
Please see Section 4.7 for contact details of the Data Controller
Not a Framework Contract: For the avoidance of doubt, this Privacy Policy does not constitute a "framework contract" for the purpose of the EU Payment Services Directive 2 (EU) 2015/2366 or any implementation of that directive in the European Union or EEA (including, without limitation any national laws implementing the EU PSD).
1. WHAT INFORMATION WE COLLECT
You are informed that there are three general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.
1.1 Information That We Collect In Order To Perform Our Legal Obligations and In Order To Provide PremioCard Service As Part Of Our Contract With You
We may ask for and collect from you the following personal information when you use the PremioCard Service.
This information is necessary for us to comply with our regulatory obligations and for the adequate performance of the contract between you and us.
Without it, we may not be able to provide you effectively with the PremioCard Service.
Identity Verification Information. In accordance with our legal obligations under the relevant Anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the Account (in case of company or other entity, referred to as “user opening the Account”).
We comply with this legal obligation by any means permissible and in compliance with applicable AML laws. Anti-money laundering and anti-terrorism financing measures that we may apply are (non-exhaustively):
- copy of ID Card of natural persons, including persons authorized for opening and managing the account (in case of companies)
- Verification of permanent address
- Declaration for Ultimate beneficial owners and collection of their personal details (as described above), in case of company.
- Information regarding corporate structure and ownership, representatives and other similar data, in case of entities.
Tax information. In order to comply with CRS/FATCA regulations, we may be required to collect your Tax Identification Number (“TIN”), Country of Tax Residence and status (active or passive business). We might be required to disclose this information to its supervising tax authorities.
Risk and Fraud related information. In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations we collect personal data regarding you, such as demographic data or fraud detection information, from third-party service providers and/or partners, and combine it with information we have about you.
Source of income, annual estimate over the account, business activity details. In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations we may collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorism financing.
Card-related information. We may collect information about your payment cards, which we have issued to you. The information may be as follows: address of delivery of card, card number (masked PAN), emboss name, issue date, expiry date, IBAN or other payment account identifier to which card is linked to, currency, card transaction data, spending limits, expired cards’ details, SMS or other communication which the cardholder has received or has initiated with us, card status history, date of activation.
Log data and device information. We automatically collect log data and device information when you access and use the PremioCard Website, even if you have not created a PremioCard Account or logged in. That information includes, among other things: details about how you’ve used the PremioCard Website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the PremioCard Website. We collect this information in relation to our legal obligation to provide you with secure methods of controlling your financial assets and your personal data.
Payment Transaction Information.
We collect information related to your payment transactions under PremioCard Service for example when you make purchases from merchants, or you receive payments or in case we process payments executed by you.
The payment transaction information may include the payment instrument’s details used, date and time of transactions performed by you, amount of payment transaction, payment instrument expiration date and billing postcode, email address, IBAN or other account identifier information, your address and other related transaction details.
This information is necessary for the adequate performance of the contract between you and us and to allow us to provide you effectively the PremioCard Service.
Participant information - When you use our PremioCard Service, we collect Personal Data you provide us about the other participants associated with the transaction. Particular payment transaction information may include:
1.2 Information That We Collect with Your Consent
You may choose to provide us with additional personal information in order to obtain a better user experience when using PremioCard.
This additional information will be processed based on your consent.
1.3 Information We Collect from Your Use of the PremioCard Service.
When you use the PremioCard Service, we may collect information, including personal information, about the Service you use and how you use them.
This information is necessary given our legitimate interest in being able to provide and improve the functionalities of the PremioCard Service.
2. HOW WE USE INFORMATION WE COLLECT
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop PremioCard Service, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
2.1 Providing e-money and payment Service.
2.3 Create and Maintain a Secure Environment.
2.4. Provide, Personalize, Measure, and Improve our Advertising and Marketing.
3. WITH WHOM DO WE SHARE PERSONAL DATA
3.1. With other members of iCard corporate family: We may share your Personal Data with members of the iCard Group of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the Service you have requested or authorised or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of our Service and communications.
3.2. With third-party service providers: We may share personal information with third-party service providers that support us in providing PremioCard Service, and/or Website with functions at our decision and our behalf.
These third-party service providers may for example:
3.3. With other financial institutions that we have contracted to enable us to provide effectively Payment Services to our customers: These financial institutions may only use this information in order for us to provide you with the wider scope of payment features. Such may be:
3.4. With the other parties to transactions when you use PremioCard Service, merchants and their providers: We may share information with the other participants to your transactions, including other clients or payers/payees you are sending or receiving funds from, and merchants or their service providers when you use the Service to pay for goods or services. The information includes:
3.5. With other third parties for our legitimate interest or as permitted or required by law: We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:
In addition, we may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our Website for the Service. This data will not personally identify you or provide information about your use of PremioCard Service. We do not share your Personal Data with third parties for their marketing purposes without your consent.
3.5. Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
3.6 Monitoring We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer support or training purposes. When visiting our or our Agent’s offices, CCTV, access control systems and/or other monitoring systems may be in operation.
3.7 Business Transfers. If any of the companies that provides PremioCard Service is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy.
4. YOUR RIGHTS
You may exercise any of the rights described in this section before the Data Controller by sending an email from your e-mail registered for PremioCard Service to iCard. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.
4.1 Managing Your Information.
You have the right to obtain the following:
4.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to PremioCard Account).
4.3 Data Access and Portability.
You have the right to:
4.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations.
If you no longer want us to use your information to provide PremioCard Service to you, you can request that we erase your personal information and close your PremioCard Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service.
Since the Data Controller is a regulated E-money institution, Data Controller is obliged under PSD and AML laws to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you.
Please note that if you request the erasure of your personal information:
4.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing.
Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where:
4.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest.
If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Please note that the Data Controller is a regulated E-money institution and is obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason.
In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the functionalities of the PremioCard Service.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.
4.7 Lodging Complaints.
4.7.1. You should in first place try to resolve the matter by sending an e-mail to
5. OPERATING GLOBALLY
To facilitate our global operations we may transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America.
Laws in these countries may differ from the laws applicable to your Country of Residence.
For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy.
Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.
6. INTERNATIONAL TRANSFERS
6.1 EU-US & Swiss-US Privacy Shield.
Where we disclose any of your collected personal information outside EEA to USA (if applicable), we shall comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework and any other adequacy decision.
6.2 Other Means to Ensure an Adequate Level of Data Protection.
In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have - prior to sharing your information with such corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection.
We will provide further information on the means to ensure an adequate level of data protection on request.
7. SECURITY
We take the responsibility to ensure that your personal information is secure, kept in an encrypted from on servers, collocated in Special data centres in Class A jurisdictions in Europe.
To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information.
Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology with High-grade security Encryption (AES-256, 256 bit keys, certified by StartCom Ltd).
We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.
If you know or have reason to believe that your PremioCard Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your PremioCard Account, please contact us following the instructions in the Contact Us section below.
While we are dedicated to securing our systems and Service, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.
8. Can Children Use Our Service?
PremioCard Service are not designed to individuals under the age of 18.
We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use PremioCard Service.
If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data.
Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.
9. CHANGES TO THIS PRIVACY POLICY
We reserve the right to modify this Privacy Policy at any time in accordance with this provision.
If we make changes to this Privacy Policy, we will post the revised Privacy Policy on PremioCard Website.
If you disagree with the revised Privacy Policy, you may cancel your Account.
If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of PremioCard Service will be subject to the revised Privacy Policy.
10. CONTACT US
If you have any questions or complaints about this Privacy Policy or our information handling practices, you may email us from your registered e-mail for the Service to the e-mails stated above in Section 4.
