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Privacy Terms

BYDFi

2025-11-10 · Updated

Welcome to BYDFi’s Privacy Notice (“Privacy Notice”). Please spend a few minutes reading it carefully before providing us with any information about you or any other person.


Content

1. Introduction

2. Purpose

3. Who we are

4. What data we collect about you

5. How we collect your data

6. How we use your data

7. Disclosures of your data

8. International transfers

9. Data security

10. Data retention

11. Your legal rights


1. Introduction

We respect your privacy, and we are committed to protecting your personal data. We take our data protection responsibilities with utmost seriousness. Details of which are available in Section 3 below in connection with:

2. Purpose

This Privacy Notice describes how we collect and process your personal data why and how we collect and process your personal data, details of which are available in Section 3 below in connection with:

  • use of products, services or applications offered on our Site and App – this may include products, services or applications provided directly by BYDFi or third party service providers whose products, services or applications are integrated/hosted on our Site and App. (collectively, the "Services"),
  • visit or use of our www.bydfi.com websites ("Site") or mobile application ("App").

This Privacy Policy applies to all personal data processing activities carried out by us, across the Services and the App.

This Privacy Notice informs you about your privacy rights and how the data protection principles set out in the applicable privacy legislation protect you.

It is important that you read this Privacy Notice together with any other notice or policy we may provide from time to time when we are collecting or processing personal data about you so that you are fully aware of why and how we are using your data. This Privacy Notice supplements other notices and policies and is not intended to override them. Where any conflict arises between this Privacy Notice and other notices and policies, the terms of this Privacy Notice shall prevail.

Our Services, Site and App are not intended for minors under the age of 18 years, and we do not knowingly collect data relating to minors.

3. Who we are

Data Controller

The controller of your personal data is the legal entity that determines the "means" and the "purposes" of any processing activities that it carries out.

BYDFi Fintech LTD ("BYDFi") is the controller and is responsible for handling of your personal data.

Data Protection

If you have any questions or complaints related to this Privacy Notice or our privacy practices, or if you want to exercise your legal rights, please reach out to cs@bydfi.com.

Our duties and your duties in case of changes

We regularly review our Privacy Notice. This version was last updated on the date above written. Please check from time to time for new versions of the Privacy Notice. We will also additionally notify you of any material changes in this Privacy Notice in a manner which will effectively bring the changes to your attention.

It is important that the personal data we hold about you is accurate and up to date.

Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Site and any applicable web browser, the App or application programming interface required to access the Services ("Applications"), may include links to third-party websites, plug-ins and applications ("Third-Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements and policies. When you leave our Site or Applications, we encourage you to read the privacy notice or policy of every Third-Party Site you visit or use.

4. What data we collect about you

Personal data

Personal data, or personal information means any information that relates to an identified or identifiable living individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.

A "data subject" is an individual who can be identified, directly or indirectly, by personal data. This is usually by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We collect the following types of information from you:

Category of personal dataExamples of specific pieces of personal data
Identity Data• full name
• maiden name
• username or similar identifier
• date of birth
• biometric information, including a visual image of
your face
• national identity card, passport, driving licence or
other form of an identification document
Contact Data• country of residence
• email address or telephone numbers
• proof of address documentation (if applicable)
Financial Data• bank account
• payment card details
• virtual currency accounts
• stored value accounts
Transactional Data• details about transaction to and from you
• other details of any transactions you enter into
using the Services, Site or App
Technical Data• internet connectivity data
• internet protocol (IP) address
• operator and carrier data
• login data
• browser type and version
• device type, category and model
• time zone setting and location data
• language data
• application version and SDK version
• browser plug-in types and versions
• operating system and platform
• diagnostics data such as crash logs and any
other data we collect for the purposes of
measuring technical diagnostics, and
• other information stored on or available regarding
the devices you allow us access to when you visit
the Site, or use the Services or the App
Profile Data• username and password
• identification number as our user
• information on whether you have BYDFi app
account and the email associated with your
accounts
• requests by you for products or services
• your interests, preferences and feedback
• other information generated by you when you
communicate with us, for example when you
address a request to our customer support
Usage Data• information about how you use the Site, the
Services, mobile applications and other offerings
made available by us, including:
• device download time,
• install time,
• interaction type and time,
• event time, name and source
Marketing and
Communications Data		• your preferences in receiving marketing from us
or third parties
• your communication preferences
• your survey responses

As explained above under Identity Data, we will also collect a visual image of your face which we will use, in conjunction with our sub-contractors (See Section Disclosures of Your Data below), to check your identity for onboarding and fraud prevention purposes.

This data falls within the scope of special categories of data.

5. How we collect your data

We use different methods to collect information from and about you, including through:

Direct interactions. You may provide us with your Identity Data, Social Identity Data, Contact Data, Financial Data, Profile Data and Marketing and Communications Data by directly interacting with us, including by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:

  • visit our Site or App;
  • apply for our Services;
  • create an account;
  • make use of any of our Services;
  • request marketing to be sent to you, for example by subscribing to our newsletters;
  • enter a competition, promotion or survey, including through social media channels; or
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other online identifiers. We will also collect Transactional Data and Usage Data. We may also receive Technical Data and Marketing and Communications Data about you if you visit other websites employing our cookies. You may find more information about how we use cookies through the Cookie Preferences.

Social media widgets and similar links. Our Site may contain links, social media plug-ins, "widgets", "tweet", "share" and "like" buttons linked to social media platforms such as Facebook, X (Twitter), Instagram, Threads, Discord, LinkedIn, Reddit and Telegram.

6. How we use your data

Lawful basis

We will only use your personal data when the applicable legislation allows us to. In other words, we must ensure that we have a lawful basis for such use.

Most commonly, we will use your personal data in the following circumstances:

  • performance of a contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract; we use this basis for provision of our Services;
  • legitimate interests: means our interests (or those of a third party), where we make sure we use this basis as far as your interests and individual rights do not override those interests;
  • compliance with a legal obligation: means processing your personal data where we need to comply with a legal obligation we are subject to;
  • consent: means freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signifyagreement to the processing of personal data relating to you; under specific circumstances this consent should be explicit – if this is the case, we will ask for it properly.

Purposes for which we use your personal data

We have set out below, in table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose and/or activity Categories of
personal data		Legal basis for
processing
To register you as a new
customer		• Identity Data
• Contact Data
• Financial Data		• Performance of a
contract
To carry out and comply
with anti-money
laundering requirements		• Identity Data
• Contact Data
• Financial Data
• Transactional Data
• Technical Data
• Profile Data		• Compliance with a legal
obligation
To process and deliver the
Services (including
products offered by third-
party service providers
with whom we work) and
any App features to you,
including to execute,
manage and process any
instructions or orders you
make through the Services		• Identity Data
• Contact Data
• Financial Data
• Transactional Data
• Technical Data		• Performance of a
contract
• Consent, if required
To prevent abuse of our
Services and promotions		• Identity Data
• Contact Data
• Financial Data
• Transactional Data
• Technical Data
• Marketing and
Communications Data		• Legitimate interests:
safeguarding the security
and integrity of our
Services by detecting and
preventing fraud and
unauthorized activities,
thereby protecting both
our business and our
customers
To manage our
relationship with you
which will include asking
you to leave a review,
take a survey or keeping
you informed of our
company's business and
product development		• Identity Data
• Contact Data
• Profile Data
• Transactional Data
• Marketing and
Communications
Data		• Performance of a
contract
• Consent, if required
To keep our records
updated and to study
how customers use our
products/services		• Identity Data
• Contact Data
• Profile Data
• Transactional Data
• Technical Data
• Marketing and
Communications
Data		• Legitimate interests: to
maintain accurate
customer data for effective
service and informed
business decisions, and to
enhance our offerings by
understanding customer
interactions
• Consent, if required
To manage, process,
collect and transfer
payments, fees and
charges		• Identity Data
• Contact Data
• Financial Data
• Transactional Data		• Performance of a
contract
To obey applicable
legislation and handle
complaints, including:
• manage risk and crime
prevention involving
performance of anti-
money laundering,
counter terrorism,
sanction screening, fraud
and other background
checks
• detect, investigate,
report and prevent
financial crime in a broad
sense
and
• ensure your account's
security, in order to honor
requests regarding
information and/or
changes to your account		• Identity Data
• Contact Data
• Financial Data
• Transactional Data
• Technical Data
• Profile Data
• Usage Data
• Sensitive Data
(a.k.a. Special
Categories Data*)
data that you give us
directly or that we
receive from third
parties and/or
publicly available
sources:
- data which might
be revealed by KYC
or other background
checks (for example,
because it has been
reported in the press
or is available in
public registers);
- data collected via
facial scan as part of
identity verification
processes;
- data that is
incidentally revealed
by photographic ID
although we do not
intentionally process
this personal data.		• Compliance with a legal
obligation
• Performance of a
contract
• Legitimate interests:
ensuring that we are not
involved in dealing with
the proceeds of criminal
activities and do not assist
in any other unlawful or
fraudulent activities, as
well as to develop and
improve our internal
systems for dealing with
financial crime and to
ensure effective dealing
with complaints
* Special Categories Data:
where we process such
data we rely on reasons of
substantial public interest
under the Seychelles AML
CFT Act, the EU AML
Directives, the UK AML
framework and so forth.
To enable you to partake
in a prize draw,
competition or complete a
survey		• Identity Data
• Contact Data
• Profile Data
• Usage Data
• Marketing and
Communications
Data		• Performance of a
contract
• Consent, if required
To gather market data for
studying customers'
behavior including their
preference, interest and
how they use our
products/services,
determining our marketing
campaigns and growing
our business		• Identity Data
• Contact Data
• Profile Data
• Usage Data
• Marketing and
Communications
Data		• Legitimate interests:
understanding our
customers and improving
our products and services
To administer and protect
our business, our Site,
App(s) and social media
channels including bans,
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting, hosting of data		• Identity Data
• Contact Data
• Financial Data
• Technical Data
• Transactional Data
• Usage Data		• Legitimate interests: to
run our business,
provision of administration
and IT services, network
security, to prevent fraud
and in the context of a
business reorganization or
group restructuring
exercise
To deliver relevant
website content and
advertisements to you and
measure or understand
the effectiveness of the
advertising we serve to
you		• Identity Data
• Contact Data
• Profile Data
• Usage Data
• Technical Data
• Marketing and
Communications
Data		• Legitimate interests: to
study how customers use
our products/services, to
develop them, to grow our
business and to form our
marketing strategy
• Consent, if required
To use data analytics to
improve our website,
products/services,
marketing, customer/user
relationships and
experiences		• Technical Data
• Usage Data
• Marketing and
Communications
Data		• Legitimate interests: to
define types of
customers/users for our
products and services, to
keep our website updated
and relevant, to develop
our business and to form
our marketing strategy
• Consent, if required
To make suggestions and
recommendations to you
about goods or services
that may be of interest to
you		• Identity Data
• Contact Data
• Technical Data
• Usage Data
• Profile Data
• Marketing and
Communications
Data		• Legitimate interests: to
develop our
products/services and
grow our business
• Consent, if required
To use the services of
social media platforms or
advertising platforms
some of which will use the
personal data they receive
for their own purposes,
including marketing
purposes		• Technical Data
• Usage Data		• Consent
To use the services of and
enter into partnerships
with, financial institutions,
third-party partners whose
products form a part of the
Services offered, crime
and fraud prevention
companies, risk
measuring companies,
which will use the
personal data they receive
for their own purposes in
their capacity of
independent controllers		• Identity Data
• Contact Data
• Financial Data
• Transactional Data
• Technical Data
• Usage Data		• Legitimate interests: to
conduct our business
activities and provide the
Services to you, and to
participate actively in the
prevention of crime and
fraud

Automated Decision Making

What is an automated decision?

Automated decision is usually a decision that may impact you and is made automatically based on software algorithms, without human intervention. As an illustrative example, we use automated decisions to complete the onboarding process of a new customer or to perform anti-fraud monitoring.

Why is an automated decision important to you?

Depending on the particular case, using your personal data may lead to automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.

How do we protect your interests regarding automated decisions?

The rights and interests of individuals whose personal data undergoes automated decision-making is safeguarded through appropriate measures. When an automated decision is made about you, you have the right to oppose the decision. If you need more detailed information or wish to exercise this right, please contact us.

Marketing

We may use your Identity Data, Contact Data, Technical Data, Transactional Data, Usage Data and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us and consented to receive marketing communications, or if you have purchased from us and you have not opted out of receiving such communications. We will use your Marketing and Communications Data for our respective activities.

Third-party marketing

We will obtain your opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You may opt out of marketing communications at any time by following the opt-out links on any marketing message sent to you.

Further, you can login and cancel the marketing messages in Notifications.

Where you opt out of receiving marketing messages, this will not apply to service messages which are directly related to the use of our Services (e.g. maintenance, change in the terms and conditions and so forth).

Cookies

You may set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services or Site may become inaccessible or not function properly. For more information about the cookies we use, please review the Cookie Preferences.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Sale or transfer of business

We may also need to process your data in connection with or during the negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving all or a part of our shares, business or assets. This will be based on our legitimate interests in carrying out such transactions, or to meet our legal obligations.

7. Disclosures of your data

We may share your personal data with our third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates (as described below) in order to complete tasks and provide the Services and use of the App to you on our behalf. When using third party service providers, they are required to respect the security of your personal data and to treat it in accordance with the law.

We pass your personal data to the following entities:

  • companies and organizations that assist us in processing, verifying or refunding transactions/orders you make and in providing any of the Services that you have requested;
  • third-party service providers with whom we work and whose products, services or applications are hosted/integrated on our Site and App;
  • identity verification agencies to undertake required verification checks;
  • fraud or crime prevention agencies to help fight against crimes including fraud, money-laundering and terrorist financing;
  • anyone to whom we lawfully transfer or may transfer our rights and duties under the relevant terms and conditions governing the use of any of the Services;
  • any third party because of any restructure, sale or acquisition of our group or any affiliates, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us; and
  • regulatory and law enforcement authorities, whether they are outside or inside the Republic of Seychelles, where the law allows or requires us to do so.

Specifics regarding the use of the blockchain

The blockchain technology used in the provision of certain Services operates on a decentralized network, where transactions are recorded in an immutable and transparent manner. This characteristic ensures the integrity and security of the data stored on the blockchain. However, it also means that once data is added to the blockchain, it becomes virtually impossible to remove or delete it.

8. International transfers (Cross-border data flows)

Many of our external third parties are based outside the Republic of Seychelles so their processing of your personal data will involve a transfer of data outside the Republic of Seychelles.

Whenever we transfer your personal data out of the Republic of Seychelles, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • the country to which we transfer your personal data has been deemed to provide an adequate level of protection (attention third-party website link) for personal data by the European Commission; and
  • a specific contract approved by the European Commission, the Information Commission or other competent authority which gives safeguards to the processing of personal data, the so-called Standard Contractual Clauses.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the Republic of Seychelles.

9. Data security

While there is an inherent risk in any data being shared over the internet, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Depending on the nature of the risks presented by the proposed processing of your personal data, we will have in place the following appropriate security measures:

  • organisational measures (including but not limited to staff training and policy development);
  • technical measures (including but not limited to physical protection of data, pseudonymization and encryption); and
  • securing ongoing availability, integrity, and accessibility (including but not limited to ensuring appropriate back-ups of personal data are held).

We have put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.

10. Data retention

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Here are some exemplary factors which we usually consider when determining how long we need to retain your personal data:

  • in the event of a complaint;
  • if we reasonably believe there is a prospect of litigation in respect to our relationship with you or if we consider that we need to keep information to defend possible future legal claims (e.g. email addresses and content, chats, letters will be kept up to 10 years following the end of our relationship, depending on the limitation period applicable in your country);
  • to comply with any applicable legal and/or regulatory requirements with respect to certain types of personal data:
    • under the Seychelles AML CFT Act we are obliged to retain your personal data for a period of at least 7 years after the end of the relationship between us as a company and you as a customer; this period may be further extended in certain cases if so provided by and in accordance with the applicable legislation;
    • if information is needed for audit purposes and so forth;
  • in accordance with relevant industry standards or guidelines;
  • in accordance with our legitimate business need to prevent abuse of the promotions that we launch. We will retain a customer’s personal data for the timeof the promotion and for a certain period after its end to prevent the appearance of abusive behavior.

Please note that under certain condition(s), you can ask us to delete your data: see your legal rights below for further information. We will honor your deletion request ONLY if the condition(s) is met.

11. Your legal rights

You have rights we need to make you aware of. The rights available to you depend on our reason for processing your personal data. If you need more detailed information or wish to exercise any of the rights set out below, please contact us.

You may:

  • request access to your personal data;
  • request rectification of your personal data by asking us to rectify information you think is inaccurate and to complete information you think is incomplete (subject to our verification of the accuracy of the new data you provide to us);
  • request erasure (cancellation or deletion) of your personal data; note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you. In addition, please also check sub-section "Specifics regarding the use of the blockchain" above;
  • object to the processing of your personal data, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms; in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms; you also have the right to object where we are processing your personal data for direct marketing purposes;
  • require that decisions be reconsidered if they are made solely by automated means, without human intervention (detailed explanation in Section 6 above);
  • request restriction of processing your personal data, which enables you to request us to suspend the processing of your personal data, if you want us to establish the data accuracy; where our use of the data is unlawful; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, or if you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it;
  • request the transfer of your personal data to you or to a third party, and we will provide to you, or a third party you have chosen (where technically feasible), yourpersonal data in a structured, commonly used, machine-readable format; note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
  • withdraw consent at any time where we are relying on consent to process your personal data; however, this will not affect the lawfulness of any processing carried out before you withdraw your consent; if you withdraw your consent, we may not be able to provide certain products or services to you, but we will advise you if this is the case at the time you withdraw your consent;
  • complain to the Seychelles’ Information Commission, or you may also contact your local competent data protection authority about any perceived violation and to seek compensation for damages in the courts.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Period for replying to a legitimate request

Considering the various requirements of the privacy legislation we are subject to we aim to reply to a legitimate request within one month.

Please note that we may request that you provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.

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