Who are we?

We are Bottlepay Ltd, referred to in this document as “we”, “our”, “us”. Our product trades under the name of Bottlepay. Our registered business address is MX307, Hoults Yard, Walker Road, Newcastle upon Tyne, NE6 2HL.

Our registration at the Information Commissioner's Office (ICO) is under ZA751312.

This document explains how we collect, use and process your data when using the Bottlepay App ‘App’ or Bottlepay.com ‘website’ hereinafter referred to as ‘services’ and is a legally binding document in combination with our

Customer Agreement.

Data we collect about you and how we use it

Information you provide to us

You can instruct us in the Bottlepay App to purchase a supported cryptocurrency using your fiat balance. This should be done following the process in the App whereby you will be asked to enter the amount of cryptocurrency to be purchased and we will show you what will be deducted from your fiat balance. We aim to load your cryptocurrency to your wallet within one business day following receipt of your instructions.

• 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.

• When signing up to use our service as a business you will need to provide us with personal details through the app or by email of shareholders (beneficial owners), directors, partners and signatories. You commit to having gained consent from the individual to disclose their personal data prior to disclosure to us and have informed them of the use and disclosure of their personal data pertaining to this Privacy Policy.

• 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.

• You may provide us with personal data about a third party in situations for instance where you are making a payment to them as a payee. You commit to having gained consent from the individual to disclose their personal data prior to disclosure to us and have informed them of the use and disclosure of their personal data pertaining to this Privacy Policy.

• You may provide us with personal data about a third party via Social media accounts (such as Twitter) for the purpose of initiating a payment. You commit to having gained consent from that individual to disclose their social media information and to initiate a payment on social media, which is publicly viewable, prior to initiating the payment and have informed them of the use and disclosure of their personal data pertaining to this Privacy Policy.

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 for example response times, tabs you view, error messages incurred.

Information we receive from third parties

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

• Identity verification and financial crime prevention services in order to meet our Anti-Money Laundering obligations.

• Publicly available sources such as Companies House, information published by press.

• Financial Institutions, for example when you send money to us your financial institution will provide us with your name, sort code and bank account number.

Social Media

If you choose to link your social media account to us the relevant social media network will provide us with the relevant information in order to verify it’s you, such as your name, profile picture and email address. If you choose to connect to others using your social media account we will use, store and access this information in accordance with this notice.

Use of your Personal Data

We use your personal data to:

• consider your application for a Bottlepay wallet

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

• to comply with all legal and regulatory requirements

• prevent illegal activities, such as fraud, money laundering, terrorist financing

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

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

• investigate complaints you have raised with us

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

• to ensure we are delivering the best possible service and customer experience

Where we disclose your personal data

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

• to our partners and suppliers in order to operate and execute the terms of our agreement and our services to you.

• where we are under a legal obligation to disclose your data in order to prevent or detect financial crime, this includes fraud prevention agencies, law enforcement and identity verification companies.

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

• analytics providers in providing us with information on improvements of our services.

• to recover debt or insolvency.

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

We will never sell your data or disclose your data to marketing agencies or companies without your prior explicit consent.

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 and transfer data in the European Economic Area (‘EEA’) in the first instance. However there may be situations where some suppliers require the transfer and storage of data we collect from you outside the EEA. When we do this, we make sure that your data is protected and that:

• the European Commission says the country or organisation has adequate data protection, or

• we have agreed to standard data protection clauses approved by the European Commission with the organisation.

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

As a Custodian wallet business we are required to retain your data whilst you are a Customer and for six years after that, in accordance with legal obligations. Where we believe that there have been instances of Money Laundering or Fraud we may keep some information for longer than this, where it is in our legitimate interests.

We will always delete data that is no longer required by law.

Automated Decisions

We sometimes use technology to perform automated decisions about you:

• for acceptance of your application when you are opening a Bottlepay wallet in order to verify your identity

• to help fight financial crime, our technology decides this based on patterns in our data

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.

Legal basis for Processing

The lawful basis we use for collecting and processing your information in Europe are as follows:

• where it is necessary for entering into or performing a contract with you;

• where we have a legitimate interest to do so, provided your rights do not override those interests;

• where you have consented to its uses;

• where our colleagues believe it is in your vital interests to share your personal details;

• where required to comply with our legal obligations.

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

To contact us about any of the above rights please email us [email protected]

Changes to our 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.

Complaints

If you have a complaint about how we use your personal information, we will do our best to try and put it right. Just drop us an email [email protected] and we 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 any supervisory authority or other public body with responsibility for enforcing privacy laws. In the United Kingdom this is the Information Commissioner’s Office, you can see their contact details via the ICO website.