We collect your personal data in order to provide services to you or those you represent. Personal data could be collected directly or indirectly when you either enter or express an intent to enter into a legal relationship with us and, therefore, use our services. Subsequently, your personal data could be collected from other external sources (e.g. private or public databases). Personal data could also be collected by recording calls, images or saving any other type of correspondence maintained with the Client throughout the course of business relations.

Personal data is being collected when you:

• register to use Bilderlings app;
• correspond with us;
• complete our forms;
• apply for opening/open an account at Bilderlings or use any of our services;
• use our services;
• communicate with a member of our social media or customer support either by phone or online chat;
• contact us for other reasons.

Categories of personal data that may be collected:

Identification data such as name, surname, date of birth, personal identification number, photo in submitted personal identification document, and other personal identification documents provided.

Contact information data such as your email address, phone number, country of residence.

Demographic data such as location, citizenship and other demographic information.

Biographical data such as current professional or work activity, education, professional certificates, information concerning other people (such as joint account holder, your spouse or family member, and other family related data), whether or not the Client is a Politically Exposed Person (PEP).

Financial data such as source of funds, data about transactions, financial liabilities, debts and other information, financial experience in investment/trading in financial instruments, ownership of financial assets and other property; details of your bank account, including the card number, expiration date and Card Verification Code (CVC). We may collect data from third parties (e.g. credit or financial institutions, databases, fraud prevention agencies, partners etc.) in order to verify and check your identity and obtain necessary information with regard to your transactions.

Location and system data (whenever you use our website or Bilderlings app) such as technical information about your internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone settings, operating system and platform, the type of device you use, unique device identifier your mobile operating system and the type of mobile browser you use; information about your visit, including the links you have clicked on, through and from our website or the app (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages.

Data concerning reliability and due diligence such as payment history and behaviour, other data that is critical for execution due diligence measures concerning prevention of money laundering and terrorist financing, compliance with international sanctions, determining the account opening purpose, and data with regard to the client’s business partners and business activities.

Data deriving from usage of Bilderlings services such as what kind of services you use in Bilderlings; your assets stored at Bilderlings account/s; your obligations to Bilderlings; your account and card number issued by Bilderlings; correspondence with Bilderlings; internet banking system data; data that is reflected in your concluded contract/s with Bilderlings; information on transactions and your use of Bilderlings products (e.g. incoming/outgoing payments on Bilderlings account), including date and time, amount, currency, exchange rate, beneficiary details, details of a merchant, receiver’s name and registration information, messages sent or received or any other communications between you and Bilderlings, details of device used to arrange the payment and the payment method. If you provide us personal data of another person (e.g. joint account holder, your spouse or family member), or you ask us to share their personal data with third parties, you confirm that you have brought this notice to their attention beforehand.

Video and audio data such as records of phone calls or other Internet based remote communication means chosen by you or us to interact.

Other data could be publicly available information about you from selected social media websites, online registers, directories, or apps to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be provided to us when we conduct general searches on you (e.g. to fulfil requirements of anti-money laundering or sanctions screening obligations and KYC purposes).

Special category data is biometrical data (e.g. physical or behavioural features) deriving from a specific technical processing executed within the confines of a remote identification in order to confirm the identity of a person. Bilderlings could also process special category personal data upon the necessity to exercise a legal claim.

Our services use cookies that are considered to be personal data when used in order to distinguish you from other users. This helps us to provide you with a valuable experience of our services as well as to allow us to improve our services.

Sources of personal data collection:

Directly from you:
• Online forms on the website or mobile applications;
• Communication via email, phone, or in-person interactions;
• Submission of ID documents for compliance purposes.

From third parties:
• Payment service providers, payment systems, payment service initiators, including financial institutions with which Bilderlings may or may bot have direct contractual relations;
• Data obtained through AML/KYC and risk management service providers;
• Information shared by authorised business partners or contractors.

Automatically:
• Cookies and tracking technologies on our website (subject to the Cookies Policy);
• IP addresses, device information, and geolocation data during interactions with Bilderlings’ digital platforms.

Legal basis for processing

Concluding and keeping our contracts and agreements with you (contractual necessity) – we need to collect your personal data in order to be able to provide you with our services to a full extent. Please note that you could refuse or withdraw your consent for data processing where we have asked you to provide one. In circumstances, where you are not willing to consent or have withdrawn your consent, we will provide you with an alternative.

Legal obligation – upon particular circumstances we are bound by the Applicable Laws to collect, store and retain your personal information (e.g. check and verify Client’s identity, detect, prevent and report money laundering, terrorism financing, proliferation financing, breaching/avoiding sanctions regime; investigate suspicious transactions, detect market abuse, manage incidents and other conditions).

Consent – your freely given consent to your personal data processing in circumstances where we have asked you to provide one. Consent can always be managed and withdrawn.

Legitimate interest – in some cases Bilderlings processes your personal data based on the legitimate interest as legal ground for processing. It includes constantly examining, developing and improving our services to strengthen Client’s satisfaction and loyalty; advertising of Bilderlings services (e.g. advertising our services of a general nature and is not personalised based on the profiling of your personal data).

Upon the necessity, your personal data could also be processed in order to fulfil legal obligations outlined within the UK GDPR Article 6 (d), (e) (to protect the vital interests of you or another person or for the performance of a task carried out in the public interest)

Personal data sharing

We do not disclose your personal data to the public and treat it confidentially. However, we sometimes need to disclose your personal data to third parties:
We may disclose your personal data to third parties:
• due to any legal obligation
• to protect the rights, property, or safety of Bilderlings, our customers, or others; This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
• to develop customer relationships, services and systems;
• to our suppliers assisting us in the provision of our service who need to know your personal data (e.g. card manufacturing, personalisation and delivery undertakings, to create and deliver your personalised credit card; to our banking and financial services partners and payment networks, such as Mastercard; to analytics providers and search information providers in order to help us in improving our website or app; to communications services providers for the purpose to distribute commercial offers and marketing materials and proving multi-factor authorisation and signature; to professional advisors and partners providing AML KYC and risk management systems, for maintaining compliance with the law and the regulatory requirements; and to suppliers who provide us IT, outsource and other services in order to help us to provide the services to you).

The list of third parties and disclosure purposes may vary from time to time.