Privacy Policy
tiun has developed this privacy statement to explain how tiun, as a data controller, may collect, retain, process, share and transfer your personal data when you visit our sites or use our services. This Privacy Statement applies to your Personal Data when you visit sites or use services, and does not apply to online websites or services that we do not own or control, including websites or services of other tiun users.
This privacy statement is designed to help you obtain information about our privacy practices and understand your privacy choices when you use our sites and services. Please note that our service offerings may vary by region.
We have defined some terms that we use throughout the privacy statement. You can find the meaning of a capitalised term in the definitions section.
Please contact us if you have questions about our privacy practices that are not addressed in this privacy statement.
We collect personal data about you when you visit our sites or use our services, including the following:
- Registration and use information – When you register to use our services by establishing an account, we will collect personal data as necessary to offer and fulfil the services you request. Depending on the services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an account. We may require you to provide us with additional personal data as you use our services.
- Transaction and experience information – When you use our services or access our sites, for example, to make purchases from merchants, to receive money, or process payments, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, device information, technical usage data, and geolocation information.
- Participant personal data – When you use our services or access our sites, we collect personal data you provide us about the other participants associated with the transaction.
- Add value to your accounts – If you use our services to add value to your account, we may collect personal data to facilitate the request.
- Personal data that you choose to provide us to obtain additional services or specific online services – If you request or participate in an optional site feature, or request enhanced services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that personal data differs from the uses disclosed in this privacy statement.
- Personal data about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
- Other information we collect related to your use of our sites or services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.
We retain personal data to fulfil our legal or regulatory obligations and for our business purposes. We may retain personal data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your account is closed, we may take steps to mask personal data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such personal data in accordance with this privacy statement.
We may process your personal data. Depending on the circumstances, we may rely on your consent or the fact that processing is necessary to fulfil a contract with you, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights and expectations.
The provision of services necessary for the performance of our agreement with you, including:
- To operate the sites and provide the services, including to:
- Perform any pre-contractual obligation;
- Initiate a payment, send or request money, or add value to an account;
- Authenticate your access to an account;
- Communicate with you about your account, the sites, the services, or tiun in general;
- Create an account connection between your account and a third-party account or platform;
- Starting and maintaining a session.
- Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes
- Keep your account and financial information up to date
- To manage our business needs, such as monitoring, analysing, and improving the services and the sites’ performance and functionality. For example, we analyse User behaviour and perform research about the way you use our services.
- To comply with our obligations and to enforce the terms of our sites and services, including to comply with all applicable laws and regulations.
- For our legitimate interests, including to:
- enforce the terms of our sites and services;
- manage our everyday business needs, such as monitoring, analysing;
- manage risk, fraud, and abuse of tiun services;
- anonymise personal data in order to provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why users visit our sites and use our services;
- conduct business to business marketing; and
- provide personalised Services (also called interest-based marketing) offered by tiun on third-party websites and online services. We may use your personal data and other information collected in accordance with this privacy statement to provide a targeted display, feature or offer to you on third-party websites.
- With your consent, including to:
- To market tiun products and services and the products and services of unaffiliated businesses. We may also process your personal data to tailor the marketing content and certain services or site experiences to better match your interests on tiun and other third-party websites.
- To use cookies and other tracking technologies to provide a targeted display, feature, service or offer to you and/or to work with other third-parties such as merchants, advertising or analytics companies to provide these personalised services (also called interest-based marketing).
- To provide you with location-specific options, functionality or offers. We will use this information to enhance the security of the sites and services and provide you with location-based services, such as advertising, search results, and other personalised (also called interest-based marketing) content.
- To respond to your requests, for example to contact you about a question you submitted to our customer service team.
We may share your personal data or other information about you with others in a variety of ways as described in this section of the privacy statement. We may share your personal data or other information for the following reasons:
With other members of the tiun corporate family: We may share your personal data with members of the tiun AG family of entities to, among other things, provide the services you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of tiun products, services, and communications.
With other companies that provide services to us: We share personal data with third-party service providers (business partners) that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with services, send you advertisements for products and services, or provide customer support.
With other financial institutions: We share personal data with other financial institutions that we have partnered with to jointly create and offer our product. These financial institutions may only use this information to market and offer tiun-related products, unless you have given consent for other uses. We may also share personal data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.
With the other parties to transactions when you use the services, such as other users, merchants, and their service providers: We may share information about you and your account with the other parties involved in processing your transactions. This includes merchants you are sending funds to. The information might include:
- Personal data and account information necessary to facilitate the transaction
- Personal data to help other participant(s) resolve disputes and detect and prevent fraud
- Anonymous data and performance analytics to help merchants better understand the uses of our services and to help merchants enhance users’ experiences.
With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for tiun’s business purposes or as permitted or required by law, including:
- if we need to do so to comply with a law, legal process or regulations;
- to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to tiun or tiun’s corporate family;
- if we believe, in our sole discretion, that the disclosure of personal data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
- to protect the vital interests of a person;
- with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes;
- to investigate violations of or enforce a user agreement or other legal terms applicable to any service;
- to protect our property, services and legal rights;
- to facilitate a purchase or sale of all or part of tiun’s business;
- in connection with shipping and related services for purchases made using a service;
- to banking partners as required by card association rules for inclusion on their list of terminated merchants;
- to credit reporting and collection agencies;
- to companies that we plan to merge with or be acquired by; and
- to support our audit, compliance, and corporate governance functions.
With your consent: We also will share your personal data and other information with your consent or direction, including if you authorise an account connection (start session) with a third-party account or platform.
In addition, tiun may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users visit our sites and use our services. This data will not personally identify you or provide information about your use of the sites or services. We do not share your personal data with third parties for their marketing purposes without your consent.
A significant benefit and innovation of tiun’s services is that you can connect your account with a third-party account or platform. For the purposes of this privacy statement, an “account connection” with such a third-party is a connection you authorise or enable between your account and a business tiun account, and business partner platform. When you authorise such a connection, tiun and the third-party will exchange your personal data and other information directly.
If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your account to that of one of our business partners in media, we will receive personal data from the media provider via the account connection. If you connect your account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases, funds transfers, and payment information that we may store.
Information that we share with a third-party based on an account connection will be used in accordance with the third-party’s privacy practices. Before authorising an account connection, you should review the privacy notice of any third-party that you authorised to have an account connection that will gain access to your personal data as part of the account connection.
When you visit our sites, use our services, or visit a third-party website for which we provide online services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “cookies”) to recognise you as a user and to customise your online experiences, the services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our sites and services. Certain aspects and features of our services and sites are only available through the use of cookies, so if you choose to disable or decline cookies, your use of the sites and services may be limited or not possible.
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals.
You have choices when it comes to the privacy practices and communications described in this privacy statement. Many of your choices may be explained at the time you sign up for or use a service or in the context of your use of a site. You may be provided with instructions and prompts within the experiences as you navigate the services.
- Choices relating to the personal data we collect
- Personal data. You may decline to provide personal data when it is requested by tiun, but certain services or all of the services may be unavailable to you.
- Location and other device-level information. The device you use to access the sites or services may collect information about you, including geolocation information and user usage data that tiun may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device.
- Choices relating to cookies
- Online tracking and Interest-based marketing. We work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt-out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third party websites.
- You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a service or site.
- You may have an option regarding the use of cookies and other tracking technologies when you use a service or visit parts of a site. For example, you may be asked if you want the service or site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.
- Choices relating to your registration and account information
If you have an account, you generally may review and edit personal data by logging in and updating the information directly or by contacting us. Contact us if you do not have an account or if you have questions about your account information or other personal data.
- Choices relating to communication
- Promotional Marketing: We may send you marketing content about our sites, services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of the tiun corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications we send by following the instructions in the communications you receive. If you have an account with us, you may also adjust your communication preferences in your account settings. For notifications, you may manage your preferences in your device.
- Informational and Other: We will send communications to you that are required or necessary to send to users of our services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices.
Please contact us if you require more information on automated-decision making.
We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your personal data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to data centres, and information access authorisation controls. While we are dedicated to securing our systems and services, you are responsible for securing and maintaining the privacy of your password(s) and account/profile registration information and verifying that the personal data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party based on an account connection that you have authorised.
The sites and services are not directed to children under the age of 16. We do not knowingly collect information, including personal data, from children or other individuals who are not legally able to use our sites and services. If we obtain actual knowledge that we have collected personal data from a child under the age of 16, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 16.
Changes to this privacy statement.
We may revise this privacy statement from time to time to reflect changes to our business, the sites or services, or applicable laws. The revised privacy statement will be effective as of the published effective date.
If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.
- Account means a tiun account.
- Device Information means data that can be automatically collected from any device used to access the site or services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the site or services; geolocation information; information about apps downloaded to your device; and biometric data.
- Geolocation Information means information that identifies, with reasonable specificity, your location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation.
- Checkout without a tiun Account means a person’s use of the services without logging into and/or establishing an account.
- tiun means tiun AG and subsidiaries or affiliates. In this privacy statement, tiun is sometimes referred to as “we,” “us,” or “our,” depending on the context.
- Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person. “personal data” can include, but is not limited to, name, telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport number).
- Process means any method or way that we handle personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.
- Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by tiun AG.
- Sites means the websites, mobile apps, official social media platforms, or other online properties through which tiun offers the services and which has posted or linked to this privacy statement.
- Technical Usage Data means information we collect from your phone, computer or other device that you use to access the sites or services. Technical usage data tells us how you use the sites and services, such as what you have searched for and viewed on the sites and the way you use our services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the sites and other usage and browsing information collected through cookies.
- User means an individual who uses the services or accesses the sites and has established a relationship with tiun (for example, by opening an account and agreeing to the tiun user Agreement) or otherwise uses the services as a merchant, business or other type of participant to a transaction.