Effective as of 26.07.2019
Last Updated: 17.02.2020
For the purposes of this documents GiftCard Products consist of products, services, content, features, technologies, or functions, and all related websites, applications offered to you by us or mobile apps, online platform, official social media platforms, or other online properties through which we provide payment and e-money services.
GiftCard Product is also designed for business purposes and may be used both by individuals or entities. In case you are registering for and/or using our GiftCard Product on behalf of an entity we will treat you as authorized person 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
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.
We may ask for and collect from you the following personal information when you use the GiftCard Product.
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 GiftCard Product.
And other data which we may choose to collect in our enrol forms on our Website, which is necessary for your identification and verification.
And other data which we may choose to collect at our Front offices and Agents.
• 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):
- color copy of ID Card of natural persons, including persons opening the account (in case of entities)
- Verification of permanent address through sending GiftCards at said address
- Declaration for Ultimate beneficial owners, in case of entities.
- Information regarding corporate structure and ownership, representatives and other similar data, in case of entities.
• Tax information. In order to comply with FATCA regulations, we are 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 Product 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 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.
• Payment Card-related information. We 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 (PAN), 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 GiftCard Website, even if you have not created a GiftCard Account or logged in. That information includes, among other things: details about how you’ve used the GiftCard 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 GiftCard 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 GiftCard Product 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 GiftCard Product.
You may choose to provide us with additional personal information in order to obtain a better user experience when using GiftCard. This additional information will be processed based on your consent.
• Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your GiftCard Account, respond to surveys, participate in promotions, or use other features of the GiftCard Product.
When you use the GiftCard Product, we may collect information, including personal information, about the Products 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 GiftCard Product.
• Geo-location Information. When you use certain features of the GiftCard Website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location Products for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions. The legitimate interests that we pursue with this processing is the identification of location-specific problems (i.e. coverage problems for SMS-sending purposes) and other statistical information, which helps us improve our Products.
• Usage Information. We collect information about your interactions with GiftCard Product such as your usage of any Website Functionalities, and other interactions with GiftCard Product. The legitimate interests that we pursue with this processing is collection of reports and other statistical information, which helps us improve our Products.
Please be advised that when you use GiftCard Product, we automatically collect some of the personal information described in the sections above such as Geo-location Information, Log Data and Device Information, Cookies and Similar Technologies, Payment Transaction Information.
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop GiftCard Product, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
We process this information given our legitimate interest in improving the GiftCard Product and our clients’ experience with it, and where it is necessary for the adequate performance of the contract with you as well as to comply with applicable laws.
We process this information given our legitimate interest in improving the GiftCard Product, and where it is necessary for the adequate performance of the contract with you.
We process this information given our legitimate interest in protecting GiftCard Product, to measure the adequate performance of our contract with you, and to comply with applicable laws.
We will process your personal information for the purposes listed in this section given our legitimate interests in relation to the products we have already offered you and your consent in undertaking marketing activities to offer you products or Products that may be of your interest. You have the right to object or opt-out from processing your personal information for the purposes described above by withdrawing your consent at any time and free of charge.
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 Products 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 Products and communications.
3.2. With third part Product providers: We may share personal information with third party Product providers that support us in providing GiftCard Product, and/or Website with functions at our decision and our behalf.
These third-party Product 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 GiftCard Products, 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 Product providers when you use the Products to pay for goods or Products. 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:
With your consent: We also will share your Personal Data and other information with your consent or direction.
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 and Products. This data will not personally identify you or provide information about your use of GiftCard Product. 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.
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.
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 GiftCard Product 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.
You have the right to obtain the following:
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 GiftCard Account).
You have the right to:
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.
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 GiftCard Product to you, you can request that we erase your personal information and close your GiftCard 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 Product. 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:
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 (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.
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 GiftCard Products.
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.
4.7.1. You should in first place try to resolve the matter by sending an e-mail to
4.7.2 In case you are not satisfied with the reply or resolution of the Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.
You have the right to file a complaint with the Data Controller’s lead supervisory authority, the Commission for Protection of Personal Data, Bulgaria:
2 Prof. Tsvetan Lazarov blvd.
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.
In case personal information is shared with corporate affiliates or third-party Product providers outside the EEA in absence of an adequacy decision, we have - prior to sharing your information with such corporate affiliate or third-party Product 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.
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 Products to you.
If you know or have reason to believe that your GiftCard Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your GiftCard Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Products, 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.
GiftCard Products 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 GiftCard Products. 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.