Privacy Notice

Last update: March, 2022

Card Blanch, Inc. (“we”) welcomes you. We created this Privacy Notice (“Privacy Notice”) to ensure your right to information. It describes how your personal data is processed and informs you about who processes it for what purpose and how.

Privacy Notice applies to our mobile application (“App”), available in AppStore and Google Play Market available via the link:

________________ on Google Play Market;

________________ on AppStore.


Please, read our Terms of Service to ensure you understand the essential information about your legal rights and obligations related to your use of our App.

About us

Name
Card Blanch, Inc.
Employer identification number (EIN)
87-0999936
Address
8 The Green, Ste 7869, Dover, Delaware 19901, United States
Email

[email protected] – for privacy issues

[email protected] — for any other issues

About you

When you use our App, you become our user (“User”):

Type of User
Description
Type of User
Customer
Description
User who registered in the App and successfully conducted KYC procedure.
Please note! We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please, contact us.

Personal data

Sources of data

We receive data when you use our App. The amount of data collected depends on the settings and features you use.

We may also receive data from third parties. Read more below.

Legal basis for processing

To process your personal data, we rely on the following lawful basis:

  • performance of the contract — for the processing of personal data necessary for the conclusion and performance of a contract;
  • legal obligation — for the processing necessary to comply with the law;
  • legitimate interest — for the processing necessary for the development of our services and reasonable for you;
  • consent — for additional processing for specific purposes (read more below).

Customer data

When you download the App, we collect some data automatically. We need technical data to operate, support, and improve the App’s functionality.

We collect data when
Type of data
Reasons for processing
Legal basis
We collect data when
You use our App
Type of data
  • device type;
  • device ID;
  • phone model;
  • device OS;
  • OS version;
  • session ID;
  • APNs token.
Reasons for processing
Analytics;
Statistics;
Smooth operation of the App.
Legal basis
Legitimate interest
Data storage
Data that is processed based on legitimate interest
Stored during the use of the App + 2 years
We collect data when
Type of data
Reasons for processing
Legal basis
We collect data when
You create an account
Type of data
  • phone number;
  • email.
Reasons for processing
Registration and verification
Legal basis
Performance of a contract
We collect data when
You undergo KYC procedure
Type of data
  • first and last name;
  • date of birth;
  • type of ID and its number;
  • photo of ID;
  • your selfie;
  • address (country, city, state, ZIP code, line 1 and 2).
Reasons for processing
To verify you
Legal basis
Legal obligation
We collect data when
You log in
Type of data
  • PIN code;
Reasons for processing
To enter the App
Legal basis
Performance of a contract
We collect data when
You create or change a PIN for entering the App
Type of data
  • PIN code;
  • old PIN code;
  • new PIN code;
Reasons for processing
To set up or update a PIN
Legal basis
Performance of a contract
We collect data when
You enable Face ID, Biometrics or Touch ID
Type of data
  • face ID;
  • biometrics;
  • touch ID.
Reasons for processing
To enable Face ID, Biometrics or Touch ID for entering App
Legal basis
Consent
We collect data when
You enable email notifications
Type of data
  • email.
Reasons for processing
To set up email notifications
Legal basis
Consent
We collect data when
You create or update a name for the card added
Type of data
  • type of card;
  • name.
Reasons for processing
To name the card in the App
Legal basis
Performance of a contract
We collect data when
You block or unblock your Card Blanch card
Type of data
  • СardBlanch card status.
Reasons for processing
To block or unblock your CardBlanch card
Legal basis
Performance of a contract
We collect data when
You restore your PIN to enter the App
Type of data
  • phone number;
  • phone number confirmation code;
  • new PIN code (it is ciphered).
Reasons for processing
To restore an Apps’ PIN
Legal basis
Performance of a contract
We collect data when
You get virtual CardBlanch card
Type of data
  • KYC data.
Reasons for processing
To create a CardBlanch virtual card
Legal basis
Performance of a contract
We collect data when
You set up limits for your card
Type of data
  • limits.
Reasons for processing
To set up spending limits
Legal basis
Performance of a contract
We collect data when
You click “Get bank statement”

Please note! We do not store this data, we only process it to make it available for you.

Type of data
  • period of time for which statement is needed;
  • transaction information on selected period;
Reasons for processing
To receive a bank statement for Card Blanch card
Legal basis
Legal obligation
We collect data when
You click “Export”
Type of data
  • copy of the invoice;
  • copy of the bank statement;
Reasons for processing
To export receipt
Legal basis
Legal obligation
We collect data when
You contact Customer support
Type of data
  • first and last name;
  • phone number;
  • email;
  • other data needed to resolve your issue.
Reasons for processing
Support
Legal basis
Legal obligation
We collect data when
You order an emission of physical Card Blanch card
Type of data
  • first and last name;
  • phone number
  • delivery address.
Reasons for processing
To deliver you physical card
Legal basis
Legal obligation
We collect data when
Credit limit is set up

Please note! When setting up your credit limit, our specialists use your data.

Type of data
  • credit report on you.
Reasons for processing
To generate your credit score
Legal basis
Legal obligation
Data storage
Data that is processed based on the performance of a contract
Stored during the use of the App + 7 years
Data that is processed based on consent
Stored during the use of the App + 7 years or until consent withdrawal
Data that is processed based on legal obligation
Stored during the use of the App + 7 years
Data of the Customers that not completed registration
Data of the Customers that failed the KYC process or who have been rejected
Stored for 1 year

Data that is shown in the App but which we do not store

We do not store or have any access to this data. It is processed on your device only.

We collect data when
Type of data
Reasons for processing
Legal basis
We collect data when
You add a Card Blanch card to Apple Wallet or Google Pay
Type of data
  • your Card Blanch card.
Reasons for processing
To add the card to Apple Wallet or Google Pay
Legal basis
Consent
We collect data when
You create an account and confirm it via phone number and email
Type of data
  • phone number verification number;
  • email verification number.
Reasons for processing
To complete the verification
Legal basis
Performance of a contract
We collect data when
You add your card
Type of data
  • card number;
  • expiry date;
  • CVC code;
  • country of issue;
  • ZIP code.
Reasons for processing
To display the card in the App
Legal basis
Performance of a contract

Data received from third parties

We may receive some personal data from third parties.

We use various tools to understand and promote our business. To get a detailed list of it, contact us.

We also may receive your credit information (credit report) from Consumer Reporting Agencies to generate a credit score.

The amount of data collected, the purposes, and the legal basis for processing is determined by the respective privacy documents of third parties.

Data sharing with third parties

We share your personal data with our contractors in the scope we need to provide services and technical or customer support.

General

We share your data on the following grounds:

1. Performance of a contract. We may transfer your data to our contractors and partners for contractual purposes.

2. Consent. We may transfer your personal data based on your explicit consent.

3. Compliance with the law. We may disclose your personal data to third parties to the extent that it is necessary:

  • to comply with a government request, court order, or applicable law;
  • to prevent unlawful use of our App or policies;
  • to protect against claims of third parties;
  • to help prevent or investigate fraud.

4. Transfer to third parties. We may transfer your personal data to third parties based on a data processing agreement, subject to applying technical and organizational measures to protect your personal data. We may share data with certain companies, consultants and contractors hired to provide certain services on our behalf.

Please note! We will ask for your consent if data transfer is not part of the contract.

Details

We may share some of your data with our partners and consumer reporting agencies.

For example, our partners help us to complete transactions or to conduct KYC.

We share the following amount of your personal data with Consumer Reporting Agencies to achieve your credit score: Social Security Number (SSN), first and last name, date of birth, age, address and phone number.

Consumer Reporting Agencies help us to generate your credit limits.

Data protection

We apply a variety of security measures appropriate to the risks.

Organizational measures
Non-disclosure agreements (NDA)
Internal policies and instructions
Technical measures
Two-factor authentication
Backups
Firewalls
Encryption technologies

Data subjects rights

United States residents

You, as data subjects have some special privacy rights. To use them, please contact us.

Please note! Depending on the state and legislative requirements, we have from 30 to 60 days to exercise your request, with the right to postpone it for 30 days more.

Your rights vary depending on the laws that apply to you, but may include:

Right
Description
Area
Right
Right to access.
Description
You can request an explanation of the processing of your personal data.
Area
  • California;
  • Virginia;
  • Ohio;
  • Colorado;
  • Nevada;
  • Massachusetts;
  • Minnesota;
  • New York;
  • North Carolina;
  • Pennsylvania;
  • Delaware;
  • Utah.
Right
Right to rectification.
Description
You can change the data if it is inaccurate or incomplete.
Area
  • California;
  • Virginia;
  • Colorado;
  • Nevada;
  • Delaware;
  • Massachusetts;
  • Minnesota;
  • New York;
  • North Carolina.
Right
Right to deletion.
Description
You can send us a request to delete your personal data from our systems.
Area
  • California;
  • Virginia;
  • Ohio;
  • Colorado;
  • Nevada;
  • Massachusetts;
  • Minnesota;
  • New York;
  • North Carolina;
  • Pennsylvania;
  • Delaware;
  • Utah.
Right
Right to restriction.
Description
You may partially or completely prohibit us from processing your personal data.
Area
  • California;
  • Massachusetts;
  • New York.
Right
Right to portability.
Description
You can request all the data you provided to us and request to transfer data to another controller.
Area
  • California;
  • Virginia;
  • Ohio;
  • Colorado;
  • Massachusetts;
  • Utah;
  • Minnesota;
  • New York;
  • North Carolina.
Right
Right to opt out.
Description
The right to prohibit the sharing or selling of your data.
Area
  • California;
  • Virginia;
  • Ohio;
  • Colorado;
  • Nevada;
  • Massachusetts;
  • Minnesota;
  • New York;
  • North Carolina;
  • Pennsylvania;
  • Delaware;
  • Utah.
Right
Right against automated decision-making.
Description
You have the right not to be subject to a decision based solely on automated means if the decision produces legal effects concerning you or significantly similarly affects you.
Area
  • California;
  • Massachusett;
  • Virginia;
  • Colorado;
  • Minnesota;
  • New York;
  • North Carolina.
Right
Right to lodge a complaint.
Description
If your request was not satisfied, you can file a complaint with the regulatory body.
Area
By default.
Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us.

If your complaint was not satisfied, you can file a complaint with the Federal Trade Commission.

California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by the CCPA.

Card Blanch, Inc. does not sell your personal information to anyone nor use your data as a business model.

However, we support the CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us at: [email protected].

Privacy Notice updating

The Privacy Notice and the relationships falling under its effect is regulated by US privacy laws.

Existing laws and requirements for processing personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on our App.

If significant material changes are made to our App that may affect your privacy and confidentiality, we will notify you by displaying information on the main page of our App and ask for your consent if necessary.