Information we receive and collect is strictly related to the service we provide. Information is collected from you when you register with us, or when you order a card off our website. This information we collect is clearly set out on the web page on which we collect it.

This information allows us to provide you with our service and keep you up to date on any changes or additions made to the product/service that may interest or affect you.

When you visit our website or App we collect your IP address and other information such as domain and host from which you access the internet, the browser and browser version, the operating system and type of device. We do so in order to administer our services and optimise our websites and applications for you.

We want to make sure you are kept up to date on all information relevant to your card. You can opt out of receiving any Marketing communications from us by using the “opt out” function on the respective channels or from within your online account. You cannot opt out of receiving messages related to the usage of your card or general service notifications.

We do not share your personal data with any third parties for marketing or promotional purposes. We would have to obtain your explicit opt in consent before sharing your personal data with any company outside of Smart Transfer Ltd for this type of processing.

We will only pass on information about you as an individual to third partiest to enable us to perform the service. If a processing activity is outsourced to an external processor, the relevant DPAs (Data Processing Agreements) will be put in place to ensure the external processor fulfils their obligations under the GDPR.

In certain circumstances we may need to disclose information about you if you breach this privacy notice of if you breach the Terms and Conditions. We may also disclose or access your account if required to to do so by law or by any Governmental body. We do not sell or rent your personal data to any third parties for marketing purposes.

Keeping information about you secure is very important to us and certain sections of the website may encrypt data using SSL or a comparable standard. We will take appropriate measures to ensure confidentiality of all information, both paper and electronic required for the operation of our business. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

You have the right to the following:

• Access to the personal information we have about you.
• Ask us to correct information which is inaccurate, incomplete or out of date.
• To restrict the processing of your personal data or to object to such processing. To erase your personal data unless certain conditions apply including that processing is necessary for compliance with a legal obligation.
• To data portability whereby your personal data can be transmitted directly from one controller to another where technically feasible.

EML Money DAC must comply with a number of statutory and regulatory requirements in relation to the retention of data. As Smart Transfer processes data on behalf of EML Money DAC we are bound by the same obligations in relation to the retention of your data. When personal data is no longer needed to meet those obligations it will be deleted or unidentified. You can view the privacy policy of EML Money DAC at https://perfectpass.com/Help/PrivacyPolicy and the privacy policy of EML Payments Europe Limited at https://www.emlpayments.com/privacy.

Personal data shall not be transferred to a country or territory outside the European Economic Area (EEA) unless that country or territory ensures an adequate level of protection and the relevant Data Protection Agreements (DPAs) are in place.

If you have any questions or complaints relating to this Privacy Policy or how we use the personal information we have about you, please contact us at info@swirlcard.com. We will endeavour to respond to you promptly.