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Draft — pending counsel review, not yet in forcePrivacy
What we collect, and why
- Waitlist: your email, country, and browser language — nothing else. Email is encrypted at rest; country tells us where to launch next.
- Account: email, country, phone number, wallet addresses, and your source-of-funds declaration — the minimum needed to operate your card.
- Card events: the card issuer's transaction events can include your name and address; we store them encrypted, minimize what we keep, and delete them on a fixed retention schedule.
- Identity verification (KYC): performed by Sumsub on behalf of Gnosis Pay, as required by card regulation. We store the verification status, not your documents.
- Card activity: transaction events needed to run your buffer and show your history, stored encrypted and deleted on a fixed retention schedule.
How we protect it
Personal data is encrypted at rest with per-column encryption; systems that only write data cannot read it back. Logs are automatically scrubbed of emails, wallet addresses, phone numbers, and tokens. We run no third-party marketing pixels.
Who else touches your data
Gnosis Pay and its issuing partner (card operation, regulatory obligations), Sumsub (identity verification), and our infrastructure providers under data-processing agreements. We never sell personal data.
Your rights
EEA residents have GDPR rights: access, rectification, erasure, portability, and objection. Write to privacy@tengo.finance — the binding wording of this policy lands with counsel review.