Last Revised: 9 October, 2019

In accordance with European Union Data Protection Regulation (GDPR), has recently updated its Privacy Policy., owned and operated by CF Technologies Ltd. (“”, “the Company” “we” or “us”), respects the privacy of the users of our platform (the “Platform”) and/or our website at (the “Site”), and is committed to protect the personal information that users share with us in connection with the use of our Platform and/or Site (collectively – the “Service”).

This Privacy Policy (the “Privacy Policy”), together with our Terms of Services (the “TOS") is intended to describe our practices regarding the information we collect from you (the “User” or “you”) when you use the Service (or any part thereof), the manners in which we may use your personal information, and the options and rights available to you.

The purpose of this Privacy Policy is to inform you of:

  1. Your Consent
  2. What information we collect on our users
  3. How do we collect information on our users
  4. What are the purposes of the collection of Personal Information
  5. Sharing Information with Third Parties
  6. Retention of Personal Information
  7. Minors Policy
  8. Use of Cookies
  9. Your Rights
  10. Security
  11. Third Party Websites
  12. Changes to the Privacy Policy
  13. Questions


1. Your Consent

By entering to, connecting to, accessing or using the Service (or any part thereof), you agree to the terms and conditions set forth in this Privacy Policy, including to the collection and processing of your personal information (as defined below). If you disagree to any term provided herein, you may not access and/or use the Service in any manner whatsoever.


2. Which information may we collect on our users?

We collect two types of information from our Users:

Non-personal information

  1. The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Service and/or the transactions carried out in connection with the Service, as applicable (“Non-Personal Information”). We are not aware of the identity of the User from which the Non-personal Information was collected.
  2. Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ on the Service and activities on the Service, the period of time the User visited the Service and related timestamps, etc.
  3. Non-Personal Information shall be gathered by us in order to perform preliminary examinations of the users’ transactions before enabling such users to use the Service.
  4. For the avoidance of doubt, any Non-personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

Personal Information 

  1. The second type of information is information that identifies or may identify an individual with reasonable efforts (“Personal Information”). Personal Information which is being gathered may consist of the following:


Please note that the Personal Information we collect is required in order for us to contractually provide the Services, as well as for us to meet our regulatory requirements (such as Anti-Money Laundering and Know-Your-Customer regulations), and to safeguard our legitimate interests. In the event that you will not provide such information, we may not be able to provide our Services.


3. How Do We Collect Information on Our Users?

We use the following methods of collection:

  1. We collect Non-Personal Information through your use of the Service and/or the transactions carried out in connection with the Service. In other words, when you are using the Service, we may be aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below.
  2. We collect Non-Personal Information and Personal Information through publicly available sources. For example, we collect certain information about you through your publicly available SN Account(s) information, publicly available credit card blacklists and official limited bank account lists, and other online public information.
  3. We obtain Personal Information from third-party services. For example, we use third-party services to receive and enhance the User’s information.
  4. We collect Personal Information which you provide us voluntarily. For example, we collect Personal Information required to use the Service by completing the registration form and/or contacting us directly.

We store the Personal Information either independently or through the help of our authorized third-party service providers as detailed below.


4. What are the Purposes of the Collection of Information?

We collect Non-Personal Information and Personal Information in order to:

  1. Provide and operate the Service, including for risk analysis, billing, and other aspects relating to carrying out the transactions performed by the Users (such as identity authentication, payment processing, and charge-backs);
  2. Analytics, statistical and research purposes;
  3. Detect, prevent, or otherwise address fraud, security or technical issues (such as identity theft or financial fraud);
  4. Meet our regulatory requirements, such as Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements.
  5. Enable us to further develop, customize and improve the Service based on Users’ common preferences and uses;
  6. Create and provide our business partners and affiliates with aggregated statistical data;
  7. Direct marketing purposes – we may use the contact details you provided us to send you promotional offers or communications; you may withdraw your consent via sending a written notice to by email to the following address [email protected] or in the same manner as the advertising was transmitted to you (e.g. via email or SMS messaging), or by following the unsubscribe instructions included within the promotional offer or communication.
  8. Respond to User’s support requests;
  9. Satisfy any applicable law, regulation, legal process, subpoena or governmental requests;
  10. Enable us to provide our Users with a better user experience, with more relevant Content, features, and functionalities, and with technical assistance and support; and
  11. Protect the rights, property, or personal safety of the Company, any of its Users, or the general public;
  12. Enforce this Privacy Policy and/or the TOS, including investigation of potential violations thereof;
  13. Abide by any applicable law.


5. Sharing Information with Third Parties

The Company discloses Personal Information in the following cases:

  1. With acquiring and card issuing banks;
  2. With third-party authentication vendors (such as identity verification vendors) and other data sources (such as geolocation services);
  3. With our service providers (such as cloud computing companies);
  4. In order to fulfill the purposes stated above, including to satisfy any applicable law, regulation, legal process, subpoena or governmental request;
  5. Respond to claims that any content available on the Service violates the rights of third-parties;
  6. When the Company, or any of its affiliates is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets.

Please note that our businesses, as well as our trusted partners and service providers, are located around the world. Any information that we collect (including your Personal Information) is stored and processed in various jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy Policy.

We use best efforts to ensure that your Personal Information is protected in accordance with our privacy policy, through contractual means (such as by using the contractual clauses approved by the relevant regulators for data transfer) or other means (such as ensuring that the jurisdiction imposes adequate safeguards for data protection).


6. Retention of Personal Information

The Company will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations, such as for KYC (Know Your Customer) and AML (Anti-Money Laundering) purposes.

If for any reason you wish to delete your Personal Information stored with us and identifying to you, please send us an e-mail to [email protected] and we will make reasonable efforts to address your request.


7. Minors

To use the Service, you must be over the age of eighteen (18). The Company does not knowingly collect Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Service. In the event that it comes to our knowledge that a person under the age of eighteen (18) is using the Service, we will prohibit and block such User from accessing the Service and will make all efforts to promptly delete or effectively anonymize any Personal Information stored with us with regard to such a user.


8. Cookies

When you access or use the Service, we may use industry-wide technologies such as “cookies” or similar technologies, which stores certain information on your computer and which will allow us to enable automatic activation of certain features, and make your Service experience much more convenient and effortless.

We may also use certain third-party tracking technologies like Google Analytics. These are a different kind of cookies, stored on your computer by third parties, rather than by us. This kind of tracking technology is deployed or used each time you visit the Service, and also when you visit certain websites or applications that use similar cookies.


How to manage your cookie settings

Please note that we do not recognize or respond to automated browser signals regarding Tracking Technologies, including “Do Not Track” requests. However, there are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.



9. Your Rights

If you reside in the EU or in another location that affords you with the below rights, you may contact us at any time at [email protected] and request:


  1. To access (including asking for supplementary information), delete, change or update any Personal Information relating to you (for example, if you believe that your personal information is incorrect, you may ask to have it corrected or deleted);
  2. That we will restrict or cease any further use of your Personal Information;
  3. That we will provide the Personal Information you volunteered to us in a machine-readable format.

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations (such as KYC and AML regulations).

If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at [email protected].


10. Security

We take a great care in implementing and maintaining the security of the Service, and our Users’ Personal Information. The Personal Information is hosted on Amazon Web Services, which provides advanced security features. The Company employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. In addition, in order to safeguard the privacy expectation of the Users, Our Merchant Processing Partner is Payment Card Industry Data Security Standards (“PCI DSS”) certified. Please note that while we take reasonable measures to safeguard your personal data, we cannot fully guarantee its security.


11. Third-Party Websites

While using the Service you may encounter links to third party websites and/or services. Please be advised that such third party websites and/or services are independent of the Company, and may use cookies and other web-tracking technologies to collect non-personal and/or personal information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties.


12. Changes to the Privacy Policy

The Company reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently. We will provide notice of substantial changes to this Privacy Policy on the Service and/or we will send you an email regarding such changes to the e-mail address that you volunteered. All changes to this Privacy Policy are effective as of the stated “Last Revised” date, and your continued use of the Service after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.


13. Have Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to contact us at [email protected] or via postal mail at the address listed below.

This service is supplied by CF Technologies Ltd.

CF Technologies
48 Stella Maris Street
Sliema SLM1765

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