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This policy explains what personal information Bluechain collects, why we use it, who we share it with and your rights. It applies to our customers, people who use Bluechain for a business, the people and businesses our customers pay, Rewards Members, and visitors to our website. How our services work is explained in our Bluechain Terms and Bluechain Pay Terms.
1.1 Bluechain Payments Limited is a company registered in England and Wales (company number 10646000), with its registered office at Building 4, Foundation Park, Maidenhead, SL6 3UD ("Bluechain", "we", "us"). We are the controller of the personal information described in this policy. You can contact us about it at info@bluechain.com.
2.1 Some firms we work with decide for themselves how they use your information, and their own privacy notices apply to that use:
(a) Modulr FS Limited, which provides the Bluechain Balance, makes payments from it, and holds the account we use to pay suppliers after a card payment. As Modulr's distributor, we also carry out identity and financial crime checks on its behalf;
(b) Tink Financial Services Limited, which sends your payment instruction to your bank when you pay by bank;
(c) your bank and your card issuer;
(d) the card payment processors and card schemes that process card payments made to us; and
(e) our rewards partners, if you switch on rewards.
(a) Identity and contact details: name, email address, phone number, address, date of birth and identity documents.
(b) Business details: company number, addresses, directors, shareholders, beneficial owners and the nature of the business.
(c) Payment details: for card payments, a secure token and the last four digits of your card (full card details are handled by our card payment processor, not stored by us); for bank payments, the name on the account you pay from, partial account details and the payment status. We never see your online banking login.
(d) Details of who you pay: supplier names, bank details, invoices and references. If a supplier is an individual or sole trader, this is their personal information.
(e) Transactions: amounts, dates, references, approvals and status, including each payment in a Bulk Payment.
(f) Rewards: the Rewards Member's name, contact details and membership number.
(g) Technical information: IP address, device and browser details, how you use our website and Platform, and cookies.
(h) Support: messages, questions and complaints you send us.
4.1 Mostly from you. We also receive information from identity verification and business information providers, Companies House, sanctions and fraud screening services, Tink, Modulr, your bank and our card payment processors. If a business nominates you as a user or Rewards Member, we receive your details from that business.
5.1 We use your information for these purposes, relying on the lawful basis shown:
(a) opening and running your account and making the payments you ask for: to perform our contract with you;
(b) checking suppliers' bank details before you pay them: our legitimate interest in preventing fraud and misdirected payments;
(c) verifying identity, sanctions screening and preventing financial crime, including checks on Modulr's behalf: our legitimate interest in preventing financial crime and helping Modulr meet its legal duties, and legal obligation where the law applies to us directly;
(d) handling disputes, chargebacks and complaints: to perform our contract, and our legitimate interest in resolving them;
(e) running rewards you switch on: to perform our contract with you, or our legitimate interest in running the programme your business chose where the Rewards Member is not our customer;
(f) keeping tax and accounting records: legal obligation;
(g) improving our services and website: our legitimate interest in running a better service; and
(h) sending you marketing: your consent or, if you are an existing customer, our legitimate interest in telling you about similar services. You can opt out at any time.
5.2 Our checks may reveal information about criminal offences or sanctions. We use it only to prevent fraud and financial crime, as UK data protection law allows.
5.3 If you do not give us the information we need for our checks, we cannot open or keep your account.
5.4 Our systems score payments for fraud risk automatically. A person reviews any decision to refuse a payment, or to restrict or close an account, before it takes effect.
6.1 We share information only as needed to provide our services, meet legal requirements or protect against fraud:
(a) Modulr, Tink, your bank, our card payment processors, card schemes and card issuers, to make and evidence payments;
(b) the bank of the supplier you pay. After a card payment, your supplier is paid by Bluechain with your reference. A bank payment or Bulk Payment is made in your name;
(c) identity verification, screening and fraud prevention providers;
(d) our rewards partners, if you switch on rewards (see section 7);
(e) service providers who work for us under contract, such as hosting, IT and email providers;
(f) our professional advisers, auditors and insurers;
(g) law enforcement, regulators and tax authorities, where the law requires or allows it; and
(h) a buyer of or investor in our business, under confidentiality.
6.2 We do not sell your personal information.
7.1 If you switch on rewards, we send the partner the Rewards Member's name, contact details and membership number, and the amount and date of each Qualifying Payment and the rewards earned. By linking their membership with a partner, the Rewards Member consents to us sending this information to that partner, including where the partner is outside the UK.
7.2 Some partners may be based outside the UK. Their country's law may not protect the information to the same standard as UK law. The Rewards Member can withdraw consent by unlinking their membership, which stops rewards with that partner.
8.1 We store information in the UK and the European Economic Area. Some of it is accessed from outside these areas, by our group company in Australia, by our engineers in India, and by our rewards partners (see section 7). Where the UK has not found a country's data protection law adequate, we use the safeguards UK law requires, such as the UK International Data Transfer Agreement. You can ask us for details.
(a) Identity, financial crime and transaction records: 5 years after our relationship ends.
(b) Accounting and tax records: 6 years.
(c) Records we may need for legal claims: normally 6 years after our relationship ends.
(d) Marketing preferences: as long as we need them to respect your choice.
9.1 After that, we delete or anonymise the information.
10.1 We protect your information with measures such as encryption, access controls and multi-factor authentication. No internet transmission is completely secure, but if a breach puts your information at high risk, we will tell you.
11.1 Our website uses cookies. Cookies that are strictly necessary to run the website and keep the Platform secure are set automatically. We set all other cookies, such as analytics cookies, only if you agree through our cookie banner, and you can change your choice at any time.
12.1 You have the right to access your information, have it corrected, have it deleted, restrict or object to how we use it, receive it in a portable format, withdraw consent, and ask for a person to review an automated decision. These rights are free to use. We will respond within one month, or tell you if we need up to two more months.
12.2 Some rights have limits. For example, we must keep certain records for as long as the law requires, and we cannot tell you about reports to the authorities where the law prevents it.
12.3 If you are unhappy with how we handle your information, please tell us first. You can also complain to the Information Commissioner's Office at www.ico.org.uk or on 0303 123 1113.
13.1 We may update this policy. The date at the top shows when it last changed, and we will tell you about significant changes.
14.1 Email info@bluechain.com, or write to Bluechain Payments Limited, Building 4, Foundation Park, Maidenhead, SL6 3UD.