Who we are

We are Bottlepay (Bottlepay Ltd and its subsidiaries), referred to in this document as “we”, “our”, or “us”.

The registered business address for our UK establishment  is MX307, Hoults Yard, Walker Road, Newcastle upon Tyne, NE6 2HL and our registered number is 11266919

The registered address for our French establishment is 128 rue La Boétie, 75008, Paris, France and our registered number is 899 113 831.

This document explains how we collect, use and process your personal data (your 'information') when using the Bottlepay app (the ‘app’), Bottlepay.com (the ‘website’), or any other Bottlepay service.

Information we collect about you

We collect the following information about you:

Information you provide to us

• When signing up to use our service you will need to provide us with personal details through the app, such as your name, date of birth, email address, photo of a government issued document, selfie and financial information such as your sort code and bank account number.

• Your profile picture (if you choose to upload one).

• When processing your application or certain transactions we may request further information or documentation from you in order to meet our Anti Money Laundering regulatory obligations.

Information we collect about you when using our services

When you use our services, we collect information from you in order to provide a safe, lawful and to ensure we are continually giving you the best experience:

• Details of transactions undertaken by you, including financial information of the transaction such as amounts, payees, geographical location.

• Technical information such as the Internet Protocol (IP) address from which you send us an instruction, Device ID, your login information, including any biometrics used.

• Details about your usage of our app such as response times, tabs you view, and error messages incurred.

Information we receive from third parties

We may receive information about you from third parties, such as:

• One of our customers.  Our customers (both businesses and individuals) may provide your social media or payment details to us in order to allow us to make payments to you. Individuals (but not businesses) can also upload our contact details in order to check if you’re on the service

• Identity verification services. These services provide confirmation that you are who you say you are. We use this information in order to meet our anti-money laundering obligations.

• Financial crime prevention services. These services may provide us with additional financial information to help us identify suspicious activity.

• Businesses that  use, or that wish to use, our services.  If you are a shareholder, partner, director or signatory of a business,  your information may be provided to us by that business as part of its onboarding process, or as part of our due diligence prior to that process. If you are an employee of that business, your information may be provided to us as part of the delivery of the service.

• Publicly available sources. We may verify your information against publicly available registers, such as company registers and sanctions lists, as part of our due diligence and anti-money laundering processes.

• Business partners. If we’re working with another business to provide or explore new services, they may share your information with us. We’ll let you know which business provided the data on first making contact with you.

Social media

If you choose to link your Bottlepay account to your social media profile, the relevant social media network will provide us with information in order to verify it’s you, such as your name, profile picture and email address.

Linking your social media profile will allow you to post instructions to Bottlepay - such as trading sats or paying a friend - on your social media account, and have those instructions carried out automatically by Bottlepay.

You can unlink your social media profile from your Bottlepay account at any time. If you have used your social media account to make or receive payments

Use of your information

Under UK and European data protection laws, we can only use your information where we have a lawful  basis for doing so. You can read more about these here. We use your information on the following lawful bases:

In order to perform our contract with you, or enter into a contract with you.

We need to process certain sorts of information to provide our services. We may use your information to:

• consider your application for a Bottlepay wallet.

• provide you with our services in accordance with our terms and conditions.

• send you messages about your wallet or changes to our services.

• investigate and resolve complaints you have raised with us.

• allow other Bottlepay customers to send or request funds from you when matching details of your Bottlepay wallet.

In order to comply with the law.

We may use your information to:

• adhere to banking laws and regulations.

• keep records as required by law.

Where we, or a third party, have a legitimate interest.

This means we must use your information for a reason that is in our, or a third party’s, interests, that the use of the information must be necessary for this purpose, and that your privacy rights must not be unduly affected (e.g. because the use is unexpected or affects you adversely). We may use your information to:

• keep our services safe, secure and up to date.

• monitor your interaction with our services and decide how they could be improved.

• administer and protect our business, and to enforce our rights.

• create anonymous datasets.

• conduct market research.

• send marketing emails, texts and push notifications related to our products and services if you are a business user.

You have a right to object to these uses.

Where you have given your consent.

For as long as you provide your consent, we will use your data to:

• send marketing emails, texts and push notifications to you if you are a consumer.

• show your profile picture if you add one.

• link your social media profile to your Bottlepay account.

• access information on your device for trouble-shooting purposes.

• enable login security features that rely on biometric information like fingerprints.

You can withdraw your consent to any of these uses at any time.

For reasons of substantial public interest

The law requires us to conduct due diligence on our customers and to monitor transactions for the purposes of preventing money laundering and terrorist financing, and provides that this is a substantial public interest. We may therefore:

• confirm your identity, including by using facial recognition to match your identity documents to your selfie.

• monitor your transactions for suspicious activity.

• disclose your information to fraud prevention agencies and to our business partners as outlined below.

Who we share your information with

We may disclose your personal data to third parties in the following situations:

• where you have asked us to do so.

• to anyone to whom you make a payment via Bottlepay.

• within the group of companies of which Bottlepay is a part. If you want to get information about how any of these companies process your data, or make a rights request from them, you can contact your local Bottlepay entity.

• to individual Bottlepay users who search for you on our app.

• to our fiat partner Modulr, who provides fiat custody services in the UK. Modulr will hold your information on their own account, and process it in accordance with their own privacy policy, which may be updated from time to time. You can read Modulr’s privacy policy here.

• to fraud prevention agencies and identity verification companies in order to comply with our obligations to prevent or detect financial crime.

• where we need to enforce terms of our agreement with you and need to disclose your information in order to do so.

• to recover debt or in the event of insolvency.

• in response to a legal warrant, court order or as otherwise requested by law.

• to analytics providers, who provide us with information on improvements to our services.

• to business partners who have provided your details to us in order to explore new services. We’ll share feedback from you with these organisations.

• to our suppliers, in order to operate and execute the terms of our agreement and our services to you. Our contracts with these suppliers prevent them from using your information for their own purposes, and require them to provide a high standard of security.

The following are the types of suppliers we will usually share your personal data with:

Type of Supplier	Why we share your Personal Data
Suppliers who provide us with IT, infrastructure and delivery services	To help us provide our service to you
Banking and Financial Services partners	To help us provide our fiat custody service to you
Identity Verification and Financial Crime Prevention services	To help us meet our regulatory obligations and keep our service secure
Analytics providers and search information providers	To help us improve our website and app
Communications service providers	To help us send you push notifications, emails and text messages
Customer service providers	To help us support you to get the most out of our service
Project management providers	To gather feedback from you for feature requests or to improve our services.

How we store and share your data

Where possible we always try to store data in the European Economic Area (‘EEA’), or in a country that the European Commission says has adequate standards of data protection. However, some of our suppliers do store data outside the this area. In addition to the security measures we require of all suppliers, when we transfer data to one of these supplier we ensure that there are sufficient safeguards in place to ensure that your rights are protected and that you have a legal remedy if they are infringed.

Direct marketing communication

If you have chosen to opt-in to our direct marketing communications, we will use your information to tell you about products and services available from us which may be of interest to you. We may also use your information to tell you about products and services which we can introduce from selected businesses.

To help make our emails more interesting and relevant, we often receive a confirmation when you open an email from Bottlepay if your computer supports such capabilities.

You have a right to opt-out of our direct marketing communications at any time. You can opt-out by following the Unsubscribe instructions at the bottom of the communication or by emailing [email protected]

How long we keep your information

We keep your information only for as long as is reasonably necessary for the purposes we have told you about.

As a custodian wallet business we are legally obliged to retain certain information about you whilst you are a customer, and for six years after that. Where we believe that there have been instances of money laundering or fraud we may have to keep some information for longer than this.

Automated decisions

We sometimes use technology to perform automated decisions about you:

• in order to verify your identity for the purposes of securing your account and preventing financial crime;

• in order to detect and take action on money laundering, fraud or other financial crime.

Cookies

Like most services we collect small files, known as cookies in order to help remember your preferences and improve our services. Please see our cookie policy for more information.

Your rights

In accordance with the relevant data protection legislation, you have the right to (where appropriate in accordance with law):

• access the information we hold about you or obtain a copy of it.

• update any incorrect, out of date or inaccurate information about you.

• ask us to block, delete or suppress your data.

• where processing is based on your consent, to withdraw that consent.

• ask an employee to review an automated decision made about you.

• refuse us to market directly to you by updating your marketing preferences.

• object to processing that is based on legitimate interests.

Verification

You can exercise your rights in any way you want, but we may need to check to ensure it’s you. You can minimise the amount of time we spend in verification by using the app, or communicating with us via a number and/or email address that we’ve already associated with you.

In many cases we will provide tools for you to exercise your rights, such as unsubscribe links in marketing emails. If you can’t find these or don’t want to use them, the best way to exercise your rights is to contact us via the help function in the app. If you haven’t installed the app, or can’t access it for some other reason, please email us [email protected].

For rights requests related to fiat services, please contact our fiat partner Modulr. You can read Modulr’s privacy policy here.

Changes to this Privacy Policy

We may from time to time update our Privacy Policy in accordance with changes of legislation, best practice or changes to our products and services. Please check back periodically for updates. Where changes are significant we will notify you by email.

Contact us

If  you have a complaint about how we use your information, we will do our best to try and put it right. Just drop an email to our Data Protection Officer at [email protected] and they will look into it for you.

If you feel that we have not addressed your questions or concerns adequately, or you believe that your data protection or privacy rights have been infringed, you can complain to the supervisory authority or other public body with responsibility for enforcing data protection laws in your country. In the United Kingdom this is the Information Commissioner’s Office. In France this is the Commission nationale de l'informatique et des libertés.