Revision of
Privacy Policy
This Policy describes what data the RELOC Service collects when issuing and servicing virtual cards, why it is processed, who it is shared with and how long it is kept. The Service does not request passport data, document scans or photographs for basic limits.
01General provisions
- 1.1
This Privacy Policy (the “Policy”) describes how information is processed when using the RELOC service (the “Service”) — the Telegram bot, the mini app and the website reloc.finance.
- 1.2
Processing is carried out by the Service Administration (the “Administration”).
- 1.3
By starting to use the Service, the User agrees to this Policy. A User who disagrees should stop using the Service.
- 1.4
This Policy applies together with the Terms of Service.
- 1.1
02What data is processed
- 2.1
Telegram account identifiers: numeric ID, name and username. These are passed to the Service by the messenger itself on first contact with the bot.
- 2.2
Technical data: request timestamps, device and application type, IP address, interface language.
- 2.3
Transaction data: the number of cards issued, transaction amounts and currencies, merchant category codes (MCC) and payment statuses.
- 2.4
Top-up data: amount, time, status and the transaction identifier received from the payment provider.
- 2.5
A service email address created by the Service for the account: it is needed to deliver one-time confirmation codes during payment (OTP and 3-D Secure).
- 2.6
Correspondence with support and any materials attached to it.
- 2.7
Full card details (number, expiry date, verification code) are issued and stored by the issuer. The Service displays them to the User in the mini app and does not pass them to third parties.
- 2.8
To issue a card, cardholder information is passed to the issuer to the extent required by payment system rules.
- 2.9
The Service does not request passport data, document scans or photographs for basic limits. Higher limits require identity verification, and the User is notified separately about what is required before providing it.
- 2.1
03Why data is processed
- 3.1
To issue a card and keep it serviced.
- 3.2
To accept a top-up, calculate fees and lock the conversion rate.
- 3.3
To deliver one-time confirmation codes during payment.
- 3.4
To answer support enquiries and investigate disputed transactions.
- 3.5
To detect fraud, abuse and breaches of the Terms of Service.
- 3.6
To comply with legal requirements and international payment system rules.
- 3.7
To compile anonymised usage statistics.
- 3.8
Data is not used for advertising profiling and is not shared with advertising networks.
- 3.1
04Who data is shared with
- 4.1
The partner issuer that issues the cards — to the extent necessary to issue a card and process transactions on it.
- 4.2
The payment provider that accepts top-ups — to the extent necessary to process and reconcile the payment.
- 4.3
Telegram — in the part that arises from the Service operating inside the messenger and is governed by Telegram's own rules.
- 4.4
Competent state authorities — upon a lawful request and to the extent required by law.
- 4.5
In all other cases data is not shared. Personal data is not sold and is not made available for advertising mailings.
- 4.1
05Storage and protection
- 5.1
Data is stored on servers with access limited by technical and organisational measures.
- 5.2
Access is granted only to those people who need it to perform duties related to running the Service.
- 5.3
Data is transmitted between the User and the Service over a secure connection.
- 5.4
Absolute security of transmission over the internet cannot be guaranteed; the User accepts the associated risks.
- 5.5
The Administration is not liable for data loss caused by third parties or by the User's own actions, including loss of access to their Telegram account.
- 5.1
06Retention periods
- 6.1
Account data is kept for as long as the account is used with the Service.
- 6.2
Transaction and top-up data is kept for the period required by law and by payment system rules, including after the User stops using the Service.
- 6.3
Support correspondence is kept for up to one year from the last message.
- 6.4
Once these periods expire, data is deleted or anonymised.
- 6.1
07User rights
- 7.1
The User may request information about what data of theirs is processed.
- 7.2
The User may request correction of inaccurate data.
- 7.3
The User may request deletion of data — except data whose retention is mandatory under law or payment system rules.
- 7.4
The User may withdraw consent to processing. Since issuing and servicing a card is impossible without processing, withdrawing consent means ceasing to use the Service; the remaining balance is returned.
- 7.5
Requests concerning these rights are sent to support and answered within no more than 30 days.
- 7.1
08Website and cookies
- 8.1
The website reloc.finance requires no registration, contains no forms and collects no personal data from visitors.
- 8.2
The website uses a single technical cookie — the chosen interface language. It exists so that someone who switched language by hand is not sent back to their browser language on the next visit.
- 8.3
There are no advertising or analytics trackers, pixels or third-party statistics systems on the website.
- 8.1
09Changes to this Policy
- 9.1
The Administration may amend this Policy.
- 9.2
The current revision is always available at reloc.finance/en/privacy; the revision date is stated at the top of the document.
- 9.3
Continuing to use the Service after a new revision is published constitutes acceptance of it.
- 9.1
10Contacts
- 10.1
Questions about data processing are sent to Telegram support: @reloc_support.
- 10.2
The Service is available at reloc.finance. This document is permanently published at reloc.finance/en/privacy.
- 10.1