Privacy Policy
Updated: 1 January 2023
Who We Are
The Rapyd group of companies, which includes Rapyd Financial Network (2016) Ltd., CashDash UK Limited, Neat Limited, Rapyd Holdings Pte Ltd, Valitor hf., Valitor Ltd. and Rapyd Europe hf. (together with certain other Rapyd group companies – “Rapyd”, “we”, “our” or “us”) provides a fintech-as-a-service platform (“Platform”) and operates the world’s largest local payment network. The Platform allows for the integration of local payments methods into digital applications from one single API, the effective performance of cross-jurisdictional transactions, company registration and incorporation, card issuing, and other financial-related services (“Services”).
Our Platform and Services are operated through the Rapyd API and business portals (the “Portals”).
Application of this Privacy Policy
The Privacy Policy applies whenever you visit, interact with us or otherwise access or use any of our Services. We are strongly committed to making our practices regarding our use and processing of your personal data transparent and fair, and we respect your privacy as:
- a visitor of any of our websites (“Site”) or a participant at our events (“Visitor”). Our Visitors may include customers, partners and any prospective customers, partners who visits or otherwise interacts with any of our Sites (“Prospects”), online ads and content, emails or other communications under our control.
- a member of the Rapyd Developer Community (available at: https://community.rapyd.net/ – “Community Members”).
- a merchant or corporate customers (“Merchants”). You are a Merchant if you are an individual or business that collects from, disburses to or otherwise facilitates payments for your End-Users with the use of the Services or Platform, and includes your employees, directors, shareholders and ultimate beneficial owners (whenever applicable)).
- a personnel of our infrastructure partners and third party processors, including payment processors and gateways (“Gateways”), being financial entities which process payments between End-Users and Merchants on Rapyd’s behalf or with its assistance.
- a third party individual transacting with a Merchant through the use of the Services, individuals who are issued payment cards by our banking partners or individuals who are provided consumer loans (“End-User”)
Specifically, this Privacy Policy describes our practices regarding:
- Data Collection
- Data Uses
- Data Location and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Communications
- Data Security
- Data Subject Rights
- Data Controller/Processor
- Automated Decision Making
- Additional Notices
Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services.
You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.
1. Data Collection
We collect Personal Data regarding our Visitors, Community Members, End-Users, Gateways and Merchants. We also collect Personal Data of individuals on Merchants’ or Gateway’s behalf as they and their End-Users use our Services through various Gateways and through the Portals. Such data is typically collected and generated through the End-User’s and the Merchant’s interaction with our Services, through automatic means, directly from such Merchant, Gateway or End-User, or from other third parties.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed “Personal Data”):
(i) End-User Data: we collect the following information relating to End-Users:
- Contact information: such as first and last name, email address, home address, date of
- birth, (mobile) phone number, and in some instances a photo and national identity number (such as a social security number).
- KYC (Know Your Customer) Information: In certain circumstances, Rapyd may process a copy of an End-User’s current ID (such as a national ID or passport), nationality, driver’s license, a frontal facial picture, and/or a recent utility bill.
- Financial Information: such as bank and billing account details, bank statements, payment card information, employment status, employer’s name and other relevant employment information, consumer credit report and credit history and any additional information which may be required to process transactions.
- Transaction Information: information regarding the End-User’s transaction with the Merchant and additional financial information which may be required to process or support transactions.
- Digital Wallet Information: such as digital wallet number and information regarding digital wallet transactions.
- Usage Information: such as connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data (such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on the device.
We process “End-User Data” on behalf of Merchants as their “Data Processor”. For more information on this distinction see section 9 below.
(ii) Merchant Data: we collect the following information regarding Merchants who are individuals, or information regarding the directors, shareholders and ultimate beneficial owners if the Merchant is a corporate entity:
- Contact information: such as first and last name, email address, home address, date of birth, (mobile) phone number and in some instances national identity number (such as a social security number).
- KYC or KYB (Know your Business) Information: In certain circumstances, Rapyd may process a copy of a Merchant’s current ID (such as a national ID or passport), driver’s license, a frontal facial picture, nationality, credit history, tax information and/or a recent utility bill.
- Account Data: such as company name and position, account login credentials (usernames and hashed passwords), as well as any other data you choose to provide when you use our Services, create a user account or contact us.
- Financial Information: such as bank and billing account details and payment card information.
- Transaction Information: information regarding the Merchant’s transaction with an End-User such as bank and billing account details, bank statements, payment card information and any additional information which may be required to process transactions).
- Digital Wallet information: such as digital wallet number and information regarding digital wallet transactions.
- Usage Information: such as connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data (such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on the device.
(iii) Community Member Data: we collect the following information regarding members of the Rapyd Developer Community:
- Contact information: such as first and last name, social media handles, email address.
- Account Data: such as account login credentials (usernames and hashed passwords), profile photograph, achievements and badges, other activity within the community, as well as any other data you choose to provide(such as posts, photos or videos you upload to the community), create a user account or contact us.
- Usage Information: such as connectivity, technical and aggregated usage data and activity logs, log-in and log-out time, IP addresses, device and mobile app data (such as type, OS, device ID, app version, browser version, locale, time-zone and language settings used), session recordings and analytics, and the cookies and pixels installed or utilized on the device.
(iv) Gateway Data: we collect full name, email address, job title and other contact information regarding Gateway personnel.
(v) Sites Usage, CRM & Prospect Data: we may collect and generate the following types of information from our Visitors, Merchants and Prospects (collectively, “Non-Services Related Data”).
- Sites Usage Data: connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like device type, OS, device ID, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on our Sites and/or a user’s device;
- Business Account Data: contact details, contractual and billing details relating to Merchants and our partners, which may also contain the details of their internal focal persons who directly engage with Rapyd on behalf of their organization (e.g. the account administrators, billing contacts and authorized signatories on behalf of Merchants or our partners, as well as the needs and preferences of Merchants or our partners, as identified to us or recognized via our engagement with them);
(vi) CRM and Prospective Customer Data: contact and business details, our communications with Merchants and Prospects (correspondences, call and video recordings, call transcripts, and analyses thereof), as well as any needs, preferences, attributes and insights relevant to our potential engagement.
2. Data Uses
We use Personal Data as necessary for the performance of our Services and in reliance on the following legal bases:
| End-User, Merchant, Gateway, Sites, CRM, Community Member & Prospect Data | |
| Purpose | Legal basis for processing |
| To facilitate, operate, and provide our Service |
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| To authenticate the identity of Merchants, Gateways, Community Members and End-Users, and to allow them access to our Services |
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| To provide our Visitors, Community Members, Merchants and End-Users with assistance and support |
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| To evaluate and develop new features, technologies, and improvements to the Service |
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| To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications |
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| To contact our Visitors, Community Members Gateways and Merchants with general or personalized messages and communications, as further described under Section 6 below |
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| To comply with our contractual and legal obligation and requirements, and maintain our compliance with applicable laws, regulations and standards |
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| To facilitate, sponsor and offer certain events, contests and promotions. |
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| To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity. |
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| De-identified End-User Data & Merchant Data | |
| Purpose | Legal basis for processing |
| To support and enhance our data security measures, including for preventing and mitigating the risks of fraud, error or any illegal or prohibited activity. |
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| To create aggregated data, inferred non-Personal Data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose. |
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If you reside or are using the Services (i) in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for processing Personal Data (in general, or specifically with respect to the types of Personal Data you choose to share via the Service), your acceptance of our Terms of Service and of this Privacy Policy will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy. We may also obtain express consent from you separately (e.g. for the purpose of sending direct marketing), in which case we will proceed to process your Personal Data on the basis of such express consent. If you wish to revoke such consent, please contact us by email at privacy@rapyd.net.
When you onboard as a new merchant to our platform, we are required to collect information and documentation in order to comply with anti-money laundering laws. After you provide this information, our system evaluates, based on preset criteria, whether we can approve your application to be registered as a merchant and either accepts or rejects your application, or otherwise sends it for further review. The types of factors involved in this decision are the type of establishment you have, whether you are on any AML blacklists, your country of origin and other relevant criteria. If you have any questions about this process or a decision that was applied to you, you can contact us via privacy@rapyd.net
3. Data Location and Retention
Data Location: Given the global nature of our Services, your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America (U.S.), the State of Israel, Singapore, the European Union, Iceland, the United Kingdom and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law. Rapyd is headquartered in Israel, and for data transfers from the EEA, Switzerland or the UK to countries which are not considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). You can obtain a copy by contacting us as indicated in Section 10 below.
Data Retention: We will retain your Personal Data for as long as we deem it as reasonably necessary on order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.
We retain a Merchant personnel’s Account Data in accordance with the instructions of their organization (the Merchant), or for as long as their account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.
We retain Visitors’ and Community Members’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship with them and to provide them with our Services.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at privacy@rapyd.net.
4. Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own, namely – hosting, data analytics, consulting, support, marketing and advertising, data and cyber security, user engagement, instant messaging, company registration and incorporation; as well as our business, financial, compliance and legal advisors (collectively, “Service Providers”). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
Sharing Personal Data with Merchants and Gateways: We may share the Personal Data of a Merchant and/or its End-Users with such Merchant or the Gateway(s) to which they are related or which are involved in their transactions; or share a Gateway’s End-Users’ Personal Data with such Gateway. Rapyd is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Merchant or Gateway, that themselves may act as the “Data Controller” of such data (as further described in Section 9 below).
Rapyd Developer Community: When you post in the Rapyd Community, your posts will be publicly available to other community members and Site Visitors. You may also choose to share your Personal Data with other community members by sending them a direct message, in which case the content of the message and your Personal Data will be shared with the community member with whom you chose to interact.
Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your Personal Data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your Personal Data will be subject to the sponsors’ privacy statements. If you do not wish for your Personal Data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 8 below;
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Rapyd, any of the Merchants, Gateways, End-Users, or any members of the general public.
Rapyd Subsidiaries and Affiliated Companies: We may share Personal Data internally within Rapyd’s group of subsidiaries and affiliates for the purposes described in this Privacy Policy. In addition, should Rapyd or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of all or part of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, Rapyd may share your Personal Data in additional manners, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
A cookie is a small text file that is placed, for example, to collect data about activity on our Site. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated by the Visitor.
While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend the use of cookies for an optimal user experience of our Services, most browsers allow you to control cookies, including whether to accept them or to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. You can read the complete Rapyd Cookie Policy here.
We also use analytics tools such as Google Analytics. These tools help us understand your behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our google analytics is available at: www.google.com/policies/privacy/partners/;
Further information about your option to opt-out of google analytics services is available at: https://tools.google.com/dlpage/gaoptout.
Please note that if you get a new computer or device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
6. Communications
Service Communications: We may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-reset notices, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may also contact you with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to privacy@rapyd.net, changing your communications preferences in your account, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
8. Data Subject Rights
If you wish to exercise your rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to know/request access to your Personal Data, to request rectification or erasure of your Personal Data held with Rapyd, or to restrict or object to such Personal Data’s processing (including the right to direct us not to sell your Personal Data to third parties and the right to limit the use and sharing of your sensitive Personal Data), or to port such Personal Data or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by email at privacy@rapyd.net.
To the extent provided by law, you also have the right to lodge a complaint with the relevant supervisory authority in your local jurisdiction.
Rapyd requires all Merchants and Gateways provide adequate notice (for example through a privacy policy) to their End-Users of their use of Rapyd’s Services and of their and our processing of Personal Data for such purposes, and that such notice comply with all applicable laws.
If you would like to make any requests or queries regarding Personal Data which we process on a Gateway or Merchant’s behalf, please contact such Merchant or Gateway directly.
Please note that once you contact us by e-mail regarding your data subject rights, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
9. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (or the “business” under the CCPA), who determines the purposes and means of processing; and the “Data Processor” (or the “service provider” under the CCPA), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Rapyd is the “Data Controller” of the following types of Personal Data:
- End-User Data, where Rapyd offers its Services directly to End-Users (via an agreement or the applicable terms and conditions);
- Merchant Data;
- Non-Services Related Data;
- Community Member Data;
- KYC or KYB Information, where: (i) Rapyd has a legal obligation to carry out its own KYC/KYB checks, or (ii) Rapyd has a legal requirement to process Personal Data when carrying out a KYC/KYB check on behalf of a Merchant.
and assumes responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
For the avoidance of doubt, Rapyd and the Gateways will be independent Data Controllers of Personal Data shared by Rapyd in order to facilitate the payment process.
Rapyd is the “Data Processor” of End-User Data (except where Services are offered by Rapyd directly to End-Users as set out above), which we process on behalf of our Merchants acting as Data Controller, as well as processing KYC/KYB data to the extent that the legal obligation to process Personal Data is placed on our Merchant, and collected by Rapyd as part of the Service provided to the Merchant or corporate customer in accordance with its reasonable instructions, subject to our Data Processing Addendum with such Merchant (to the extent applicable) and other commercial agreements. The Merchant will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
If you would like to make any requests or queries regarding your Personal Data (see Section 8), we encourage you to also contact such Merchants and Gateways involved in your transaction(s) directly and independently from your contacting of Rapyd. Rapyd may, but is in no way obligated to, forward you requests or queries to such Merchants and Gateways we believe to be involved in the processing of your Personal Data.
10. Automated Decision Making
According to privacy laws such as the EU & UK GDPR, Automated Decision-Making (ADM) relates to a decision that has a legal impact on an individual, and that is based solely on automated means, without any meaningful human intervention.
In certain circumstances Rapyd is required to carry out KYC/KYB checks on Merchants, and Merchants are required to carry out KYC/KYB checks on End-Users or to consider whether End Use is entitled to a loan. These checks are mandated by law and are designed to comply with anti-money laundering and anti-terror supporting laws.
The “Rapyd Verify” solution allows Rapyd and its Merchants to carry out these checks. The solution collects Personal Data (as detailed above in Section 1), analyzes it for authenticity and checks it against publicly available sources or against our partners’ databases (such as company registration information). If everything checks out, the application will be automatically approved by the system. If the system determines that KYC/KYB checks are unsuccessful, it will reject the application and a notice will be delivered to the Merchant/End-User. If the application is neither fully approved nor fully denied, it will be sent for human review by Rapyd’s expert compliance team, who will make a final determination regarding the application.
For more information about how “Rapyd Verify” works, please visit the product page here. If you think that a decision to reject your application was made in error you can contact Rapyd support at support@rapyd.net.
11. Additional Notices
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
California Notice: This policy describes the categories of personal information we may collect and the sources of such information (in Section 1 above), and our retention and deletion (Section 3) practices. We also included information about how we may process your information (in Sections 2 through 7), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We share Personal Data with third parties for the purpose of cross-context behavioral advertising, via the cookies we place on your browser when you visit our website. In order to see the full list of cookies we use, including those used for cross-context behavioral advertising and understand how to opt-out of such usage, please visit Rapyd’s Cookie Policy here. We may disclose personal data to third parties or allow them to collect personal data from our Services as described in Section 4 above, if those third parties are authorized Service Providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Services, or direct us to disclose your personal data to third parties, or as otherwise described in Section 4 above.
If you have any questions or would like to exercise your rights under the CCPA, you can contact us at privacy@rapyd.net or our DPO at DPO@rapyd.net.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website or service you visit. This Privacy Policy applies only to our Services.
Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at privacy@rapyd.net.
DPO, Questions, Concerns or Complaints: Rapyd has appointed PrivacyTeam Ltd. as its data protection officer for matters relating to privacy and data protection. If you have any comments or questions about this Policy or if you have any concerns regarding your Personal Data, please contact Rapyd’s appointed DPO by email by sending a message to dpo@rapyd.net.
Rapyd’s UK and Rapyd’s Iceland offices have been designated as Rapyd’s representatives in the United Kingdom (“UK”) and in the European Union, respectively. Our representatives may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to privacy@rapyd.net.