EEA Privacy Policy

Last updated: August 14, 2016

This Privacy Policy describes how Embedded Downloads Limited  trading as Swiss Bank in your pocket (“SBIYP”) collects, uses, stores, shares and protects your information whenever you use SBIYP through the website (www.swissbankinyourpocket.com) or SBIYP’s applications.

We know how important privacy is to our users, which is why we only collect the information we need and will not share your personal information with any third parties unless it is necessary. Even within SBIYP access to your personal information is limited to only those employees who require such information to handle matters relating to compliance, identity verification, fraud prevention and customer support.

For the purpose of data protection legislation, the data controller is Embedded Downloads Ltd trading as Swiss Bank in your pocket, (SBIYP)  of 22 Wenlock Rd, London, United Kingdom. When we refer to SBIYP” in this policy, we refer to this entity. 

We may change this Privacy Policy from time to time. When we do make updates, we’ll let you know by changing the date above. If it is a big update, we’ll send you a notification or post a notice on our website. If you ever have any questions about changes made to the Privacy Policy, just reach out to support.

By using SBIYP’s website or other apps, you consent to the practices contained in this Privacy Policy.

1. Information We Collect

What You Directly Provide Us

When you create a SBIYP account, we’ll collect some important details about you such as your name, address, phone number, email, birth date, password, etc.

 As SBIYP adds additional features, you may also be prompted to provide additional information.

Sometimes we need to request more information to verify your identity or to meet legal and regulatory obligations. When that is necessary, you will be prompted to provide such information.

What is Automatically Collected

There is some information that is automatically collected as you use SBIYP. This information allows us to deliver cool new features, more easily handle your customer support issues and better protect your account. This information includes:

  • Device Information. We collect information about your device, including the type of device (Computer vs. iPhone vs. Android), operating system, mobile phone number, browser type and language, and device identifiers (such as IMEI and MAC address).
  • Location Information. With your permission, we collect your device location so that we can offer you location-based features such as the ability to send funds etc,
  • Contacts. To make it easier to send money to your contacts, we will – with your permission – collect information from your computer or  phone’s address book.
  • Photos, Videos & Other Media. If you want to attach photos, videos or other media to your payments, payment requests or other communication using SBIYP we require access to the photos on your device. Any photos, videos or other media you attach will be stored and accessible to SBIYP, but we will never download or store any photos, videos or other media from your phone that aren’t attached to payments, payment requests or other communications using SBIYP.
  • Message Content. If you include a message with your payments, the content of that message is stored and accessible to SBIYP
  • Transactions. We collect information about your payment activity such as the amount, date, time, recipient for each transaction.
  • Cookies. Like most mobile apps and websites, we use cookies. Cookies are small data files that we place on your device that allow us to identify you as a SBIYP user and provide a customized SBIYP experience. We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Longer lasting cookies, known as persistent cookies, remain on your browser until you erase them or they expire. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of SBIYP. The help section of most browsers or browser add-ons provides instructions on blocking, deleting or disabling cookies.

 

2. Protecting Your Information

Throughout this policy, we use the term “personal information” to describe information that is associated with you or can be used to identify you. We do not consider personal information to include information that has been anonymised.

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorisation controls. All of our physical, electronic and procedural safeguards are designed to comply with applicable laws and regulations.

The data that we collect from you will be transferred to, and stored at, a destination in the UK. and may be transferred and/or stored to other places outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. These staff may be engaged in the fulfilment of our Services and/or the processing of your details and the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Third parties may be located in other countries where the laws on processing personal information may be less stringent than in your country.

 

3. How We Use Your Information

We collect all of this information so that we can provide you with a safe and seamless way to make and receive payments. The information we collect allows us to:

  • Deliver the full range of payments and functionality of the SBIYP product;
  • Keep in touch with you – whether it be for providing customer service, notifying you of cool new features that have been added to the mobile apps, or providing security notices or information;
  • Verify your identity so that we can prevent fraud or unauthorised activity;
  • Improve SBIYP or add new product features by analysing usage trends;
  • Personalise the SBIYP experience by matching product features to things that we think you specifically might be interested in; and
  • Fulfill any other purpose for which the information was collected.

We will never sell or rent your personal information to third parties. We may combine your information with information we collect from other companies and use it to improve and personalise the Services, as well as our content and advertising.

4. How We Share Your Information

Sharing With Third Parties

In order to provide you with the SBIYP product and meet our legal and regulatory obligations, we may share the information we collect as detailed below:

  • If you link a debit card, credit card or current account, we will share your account information with our banking partners so that we can process payments. . We also may need to share your information with your own banking institution in order to verify and complete payment transactions.

 

  • In order to prevent fraud, we will sometimes need to share your information with third party identity verification services. This lets us make sure you are who you say you are, by comparing the information you provide us to public records and other third party databases. This may include searches through electronic services such as credit bureaus, but we will not do so in a manner that would have an adverse impact on your credit or credit score.
  • In order to improve SBIYP’s functionality, we will sometimes share information with service providers that help us analyse how people are using the app. This allows us to refine popular features and improve or eliminate features people don’t use.
  • In order to complete third party financial, technical and legal audits of SBIYP’s operations, we may need to share information about your account as part of such review.
  • If SBIYP merges with or gets acquired by another Company, they will have access to the information you have provided to us. If this happens, we will require that the new entity follows this Privacy Policy and will notify you of any such change.
  • SBIYP will share your information with Embedded Downloads Ltd. and other SBIYP affiliated entities as necessary in order to provide you with the best possible product and customer support.
  • We will share your information with other third parties if you specifically authorise us to do so.

 

Sharing With Other SBIYP Users

In order to make SBIYP payments about more than just sending money from A to B, we will share additional information with other SBIYP users, but only to the extent that you give us permission to do so. This information includes:

  • Transaction Details. At the risk of stating the obvious, when you send someone a payment or payment request, they will be provided with the details of that transaction if necessary.
  • Messages & Photos. If you attach a message or photo, video or other media to a payment, payment request or other communication using SBIYP, that information will be visible to the person(s) receiving the payment. You should know that the recipient of a message or photo (or other media) can always save them – so don’t send anything you wouldn’t want shared publicly.

 

  • Status as a SBIYP User. Other SBIYP users may be able to see that you have a SBIYP account. This lets them know they can send you a payment and you will receive it instantly without having to first set up a SBIYP account.  

 

  • Other Information. As we add new product features, there may be additional information that is shared with other SBIYP users. If those new features require sharing any personal information, we’ll always get your permission first and will do our best to allow you to disable such features in your account settings. We’ll also provide information to other SBIYP users if you specifically request that we share such information.

 

5. How To Change or Delete Your Information

If you need to add or change any information, just reach out to support and we’ll take care of it.

If you want to know what information we’re keeping on you, check out the categories listed above. We can also provide you with a copy of this information, but we won’t include any sensitive financial information.

If you want to close your SBIYP account, know we may be legally required to retain certain information you have provided for a number of years.

 

6. Children’s Privacy

Unfortunately, if you’re under 16, you can’t use SBIYP. So we don’t knowingly solicit or collect information from anyone under 16. If we become aware that a child under the age of 16 has provided us with personal information, we’ll delete it immediately.

7. Questions?

If you have any questions about this Privacy Policy, feel free to reach out to support.