This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

TPML is committed to safeguarding the privacy of your information. By “your data”, "your personal data”, and “your information” we mean any personal data about you which you or third parties provide to us.

We may change this Policy from time to time so please check this page regularly to ensure that you’re happy with any changes.

1. Who are we

Transact Payments Malta Limited (“TPML”, “we”, “our” or “us”) is the issuer of your card and is the Data Controller for the personal data which you provide to us in relation to the card only. TPML is not the Data Controller in relation to any use of your personal data to send marketing or promotional material to you. TPML is an e-money institution, authorised and regulated by the Malta Financial Services Authority. Our registered office address is Vault 14, Level 2, Valletta Waterfront, Floriana, FRN 1914, Malta and our registered company number is C91879.

Enfuce is the Program Manager of your card and is a Data Processor of the personal data which you provide to us in relation to the card.

2. How do we collect your personal data?

We collect information from you when you apply for a payments card which is issued by us and when you use your card to make transactions. We also obtain information from third parties (such as fraud prevention agencies) who may check your personal data against any information listed on an electoral register and/or other databases.

3. On what legal basis do we process your personal data?

Contract

Your provision of your personal data and our processing of that data is necessary for each of us to carry out our obligations under the contract (known as the Card Terms and Conditions or similar) which we enter into when you sign up for our payment services. At times, the processing may be necessary so that we can take certain steps, at your request, prior to entering into that contract, such as verifying your details or eligibility for the payment services. If you fail to provide the personal data which we request, we cannot enter into a contract to provide payment services to you or will take steps to terminate any contract which we have entered into with you.

Legal/Regulatory

We may also process your personal data to comply with our legal or regulatory obligations.

Legitimate Interests

We, or a third party, may have a legitimate interest to process your personal data, for example: