Privacy Policy
1. Who We Are
This Privacy Policy (“Policy”) sets out how Bullswipe Limited, a company incorporated in Hong Kong with its registered office at 9/F Wui Tat Centre, No. 55 Connaught Road West, Sheung Wan, Hong Kong (“Bullswipe”, “Company”, “we”, “us” or “our”), collects, uses, discloses, and protects your personal data when you access or use our services, applications, and websites (the “Services”).
By using our Services, you agree to the practices described in this Policy. If you do not agree, you must not use our Services.
We may amend this Policy at any time by posting the updated version on our website or mobile application, or by notifying you directly. Your continued use of the Services after such updates constitutes your acceptance of the revised Policy.
For privacy-related inquiries, please contact our Data Protection Officer (DPO) at: dpo@bullswipe.com
2. What Personal Data We Collect
We may collect the following categories of personal data from you and, where applicable, from related persons such as beneficial owners, directors, or authorised signatories (“Relevant Persons”):
- Account Information: Email, username, password, referral code.
- Identity Verification (KYC): Full legal name, passport or ID details, nationality, facial recognition data, address, phone number, occupation, and beneficial ownership details.
- Transaction Data: Wallet balances, deposit and withdrawal history, transfers, and payment records.
- Technical Data: IP address, device identifiers, operating system, browser type, usage logs.
- Marketing Preferences: Language, campaign interaction, opt-in/opt-out records.
- Emergency Contact Information: For issuance of physical cards or in compliance with regulations.
- Other Information: Information you voluntarily provide, such as feedback, surveys, or when contacting support.
3. How We Collect Your Data
- Directly from You: During sign-up, KYC procedures, or when using the Services.
- Automatically: Through cookies, analytics, and device data.
- Third Parties: Verification providers, payment processors, compliance partners, and public databases.
4. How We Use Your Data
We use your personal data for purposes including:
- To operate, manage, and secure your account.
- To perform KYC/AML checks and comply with regulatory requirements.
- To process transactions, provide statements, invoices, and receipts.
- To prevent, detect, and investigate fraud or suspicious activity.
- To improve, personalise, and optimise our Services.
- To send operational and service-related communications (mandatory).
- To send marketing communications to which you have opted in.
- To comply with laws, regulations, and court orders.
- To enforce our Terms & Conditions and protect the rights of Bullswipe, our users, and partners.
5. Data Sharing and Processors
We do not sell your personal data. We may share your data with:
- Service Providers: Authentication, card issuance, cloud hosting, telecom, analytics, and payment processors.
- Affiliates: Within Bullswipe group entities, subject to confidentiality.
- Professional Advisers: Auditors, legal counsel, or compliance consultants.
- Regulators & Law Enforcement: Where required by applicable law.
- Business Transfers: In case of mergers, acquisitions, or restructuring.
- Authorised Parties: Persons you instruct us to share your data with.
All third parties are bound by data protection obligations.
6. International Data Transfers
Your personal data may be transferred to and stored outside of Hong Kong, including in the EU, the US, and other jurisdictions. Such transfers will only be carried out with appropriate safeguards in line with applicable data protection laws.
7. Data Retention
We will retain your data only as long as necessary for the purposes outlined in this Policy, including to:
- Comply with legal obligations (e.g., AML record retention).
- Resolve disputes and enforce agreements.
- Maintain accurate business records.
Typically, financial and KYC records are retained for at least 5 years after account closure.
8. Marketing Communications
- You may receive updates, promotions, or service-related notifications.
- Marketing communications require your explicit consent.
- You may withdraw consent at any time by contacting support@bullswipe.com with the subject line “OPT-OUT”.
Note: You cannot opt out of operational notices, such as changes to Terms or security alerts.
9. Cookies and Tracking
We use cookies and similar technologies for:
- Authentication and session management.
- Analytics and performance (e.g., Google Analytics).
- Security and fraud detection.
You may disable cookies in your browser, but this may affect service functionality.
10. Data Security
We employ industry-standard measures such as encryption, firewalls, SSL, and access controls. However, no system is 100% secure, and we cannot guarantee absolute security.
11. Children’s Privacy
Bullswipe does not knowingly provide Services to individuals under 18 years old. If we discover that a minor has submitted data, we will delete it promptly. Parents/guardians may contact us if they believe their child has provided personal data.
12. Your Rights
Depending on your jurisdiction, you may have the following rights:
- GDPR (EU/EEA Residents): Access, rectification, deletion, restriction, objection, data portability, withdraw consent.
- CCPA & US State Laws: Right to know, request deletion or correction, opt out of certain uses, and non-discrimination.
Requests should be sent to dpo@bullswipe.com. Identity verification may be required.
13. Links to Third Parties
Our Services may contain links to third-party websites or integrations. We are not responsible for their content, privacy practices, or security. Please review their policies separately.
14. Changes to This Policy
We may update this Policy periodically. Significant changes will be communicated via email or app notifications. Continued use of our Services after changes indicates acceptance.
15. Contact Us
If you have questions, concerns, or requests regarding this Policy or your personal data:
- dpo@bullswipe.com
- Bullswipe Limited 9/F Wui Tat Centre, No. 55 Connaught Road West, Sheung Wan, Hong Kong
Last Updated: 1 October 2025