Bitrefill Global Privacy Policy

We care about your privacy

As a business headquartered in Europe, we are subject to certain regulations (among which, the European General Data Protection Regulation) that require us to comply with a number of obligations regarding your data.

In this document, you can learn everything about how we use your data: that we collect it from you and your actions, that we process only what we need in order to perform what you have asked or consented to (or what the law requires us to…), that we protect with appropriate technology and that we will not share it with anyone, including law enforcement, unless we are forced to by laws and regulations.

The right to privacy is a basic human right. We will fight for yours.

0. Introduction

The “Bitrefill Group”, comprising the entities mentioned below as well as their parent companies, subsidiaries and affiliates, is committed to protecting the privacy of our Customers.

This privacy policy is issued on behalf of AIRFILL PREPAID AB, a limited company incorporated under the laws of Sweden and registration no. 559001-6035 (“Airfill”). Airfill is a data controller of the personal data collected through our websites www.bitrefill.com and www.airfill.com (“Websites”), or through our mobile application Bitrefill, available on Apple and Android app stores (“App”).

This policy also applies to the following entities, to the extent personal data is collected on transactions involving them:

• for personal data collected in the context of the Bill Payment Services from El Salvador, Bitrefill, Sociedad Anónima de Capital Variable and with registration number 2021103271 (“Bitrefill ES”) is a joint data controller.
• for personal data collected in the context of the Bill Payment Services from any other jurisdiction, Airfill US LLC, a Delaware company with file number 5817333 (“Airfill US”) is a joint data controller.

When creating an account, or before acquiring a Product, we will ask you to review this Policy and accept its contents before proceeding. You should read this policy in full before proceeding.

If you don't want us to collect, use or share your personal information as outlined in this Privacy Policy, or if you are under 18 years old and unsupervised by parents or legal guardians, please stop using our Websites or App.

In this policy you can find about:

1. What personal data do we collect;
2. Why do we process your personal data;
3. When do we share your personal data;
4. How do we protect your personal data;
5. How can you exercise your data subjects rights; and
6. How long do we keep your data?
7. Minors
8. International Transfers

1. What personal data do we collect?

Bitrefill may collect your personal data directly from you, indirectly from third parties or through automated technologies, provided Bitrefill will only collect your personal data where it has a legitimate interest or your express, specific and unequivocal consent to do so in accordance with this Privacy Policy and for the purposes described herein, all under applicable standards.

Bitrefill does not collect any data on your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetics or biometrics, other than as described in this Privacy Policy.

To purchase some Products or use some services, you may be required to provide Bitrefill some personal data. In those cases, Bitrefill will only be able to offer the Products or provide the services if you provide Bitrefill with that information, and Bitrefill retains the ability to terminate your account if Bitrefill can no longer process the personal data necessary to offer you the Products or provide you the Services.

Please find below an outline of the types of data that we may collect and how we collect it.

1.1. Personal data obtained directly from you

To ensure that the person submitting the identification documents is the owner of such documents, Bitrefill may collect biometric data in the context of an identification verification procedure. Provided you have given your consent, your biometric data will be collected and processed in accordance with this Privacy Policy solely for the purpose of identification verification.

With your prior consent, SumSub, a trusted partner, will collect a live selfie that is compared to the picture of the identification document provided by you. Bitrefill does not process or store biometric data. SumSub processes and stores this data.

Bitrefill may have access to personal data related to your purchases with the Bitrefill Card, which could qualify as special categories of personal data under Article 9, GDPR.

1.2. Personal data obtained indirectly from you

If you provide our affiliates, service providers, counterparties or advertising, analytics or other partners with (or if they otherwise obtain from you) personal data in the context of your use of the Products, Websites and/or App, then your personal data may be shared with Bitrefill for the purposes outlined in this Privacy Policy.

Bitrefill may also receive your personal data from a person who has submitted it for our referral program.

1.3. Personal data automatically obtained from you

For more information on cookies, pixels and similar trackers, please refer to our Cookie Policy below.

2. Why do we process your personal data?

2.1. We use your personal data for different purposes, better stated below:

3. When do we share your information?

3.1. General

Bitrefill works with multiple partners, providers and other third parties to enable the Products and provide Customers with the Bitrefill service. For that end, Bitrefill shares certain information with third parties, as explained below.

3.2. Specifically: Cooperation with law enforcement

Bitrefill may receive requests for personal data from law enforcement authorities, regulators, tax authorities or other public entities. Such requests may be binding orders valid in the jurisdiction whose data is sought, and others may be requested by legitimate public entities that do not bind Bitrefill, because these do not constitute binding orders valid in the jurisdiction whose data is sought.

Bitrefill will comply with such requests if Bitrefill is legally required to on the basis of compliance with a legal obligation under Article 6(1)(c), GDPR. Bitrefill may comply with certain requests even if not legally required to on the basis of legitimate interests under Article 6(1)(f), GDPR, namely for the purpose of preventing or detecting fraud and financial crime, protecting Bitrefill and its customers, and cooperating with legitimate requests from authorities acting within their remit.

Any disclosure of personal data based on legitimate interests only occurs after Bitrefill has completed an assessment of those interests, and never if those interests are overridden by your rights and freedoms as data subject. Bitrefill keeps a record of that assessment. You have the right to object to this processing at any time pursuant to Article 21, GDPR, and Bitrefill will cease processing your personal data on this basis unless Bitrefill has compelling and legitimate grounds to continue.

Requests from any public entities outside the EU/EEA do not bind Bitrefill unless they reach Bitrefill through appropriate domestic channels based on an applicable international agreement in accordance with Article 48, GDPR.

In exceptional circumstances, to protect someone's life or prevent serious harm, Bitrefill may disclose on the basis of vital interests pursuant to Article 6(1)(d), GDPR, or other applicable grounds, to the extent permitted by law.

Law enforcement authorities should submit the appropriate request via this form.

3.3. Specifically: Bitrefill Card

Certain Products may be offered, from time to time, together with third-party providers that may require Bitrefill to process your personal data in order to provide it.

This is the case, for example, of the personal data collected in the context of the Bitrefill Card, offered together with Lightspark Payments Europe AS and Wallester AS.

The joint data controllers for personal data connected with this product, which may include Basic information data, KYC customer data, Business and professional data, Financial data, Wallet data, Transaction data, and Customer Support data, are Lightspark Payments Europe AS and Wallester AS.

From January 1, 2026, certain Bitrefill Card activity may be subject to reporting requirements under the European Directive on Administrative Cooperation (known as "DAC8"). Such reporting requirements include the obligation for Lightspark Payments Europe AS to collect and send certain data (which may include Basic information data, KYC customer data, Transaction data and Wallet data) to the Estonian Tax Authority. Learn more here.

You can contact Lightspark Payments Europe AS for data protection purposes by emailing dpo.eu@lightspark.com.

As a rule, Bitrefill processes such data only upon the instructions of Lightspark Payments Europe AS and Wallester AS and acts as a data processor. This includes, specifically, data on the purchases you make with the Bitrefill Card. This information is passed to Bitrefill from the joint data controllers for the sole purpose of showing it to you on your transaction history and is not processed for any other purpose.

However, Bitrefill also acts as a data controller with respect to some of the data processed in connection with the Bitrefill Cards, e.g., where Bitrefill processes personal data that is not processed by third-party data controllers (such as the password of your account) or where Bitrefill processes personal data for the functions entirely handled by Bitrefill (such as customer support, or to provide you with account management tools).

These are the relevant details for the processing of data in the context of the Bitrefill Card:

3.4. Specifically: the US Visa Card

Another product offered together with third-party providers that may require access to information collected by Bitrefill from you in order to provide is the US Visa Card, which is issued by Sutton Bank®, Member FDIC, pursuant to a license from Visa U.S.A. Inc, and fulfilled by Perfect Gift, LLC.

In relation to this product, Bitrefill collects the data identified below, but does not have access to any of the information related to how you spend the funds in the card.

These are the relevant details for the processing of data in the context of the US Visa Card:

3.5 Specifically: AI

Artificial Intelligence ("AI") is a resource that we use to improve our product and provide our services to you. We use AI tools for certain purposes identified in this section. When processing your data through AI tools, we are a data controller of your data.

We use the AI tools identified in this section to analyse your data that you submitted to us pursuant to this Privacy Policy, as well as other information (including usage information) as indicated in this section. We do not develop our own AI tools using your data. We use off-the-shelf AI tools where the respective Large Language Models ("LLMs") are not updated by us and don't retain your data once we request them not to. No automated individual decisions are made resulting from the processing of your data through any such AI tools. All decisions related to you are made with the intervention of a natural person.

As of this date, we use Claude (https://claude.ai/) for the purpose of screening certain actions from customers as part of our enhanced monitoring controls, and building and running AI artifacts that improve internal anti-money laundering and terrorism financing (AML) monitoring and reporting processes, such as investigations and reporting based on our own red flags, KYC levels and account limits, investigation practices, and follow-up actions ("Purpose"). Data processed using Claude may be shared with Anthropic Ireland, Limited ("Anthropic"), the provider of the platform. You can access Anthropic's Privacy Policy at https://www.anthropic.com/legal/privacy. Anthropic can only access the data that we decide to process through Claude for the Purpose. This means that, by default, your personal data is secure and can only be accessed by us.

We abide by a transparent and responsible use of AI. Our selection and use of AI tools is subject to the following principles:

• Selection. When selecting an AI tool, we conduct due diligence to ensure the AI tool is suitable to its intended uses, namely whether the AI tool has been tested for such uses, how human oversight can be embedded into processes, the potential privacy and security risks, as well as who will have access to our data inputs or the system's data outputs. We only engage AI tools whose terms of service include data retention periods that are equal or shorter (or can be made equal or shorter upon request) than the retention periods included in this Privacy Policy.

• Lawful basis. We only process your data through an AI tool if all of the following conditions are met: (i) there is a legitimate interest of ours, as controller; (ii) the processing is necessary to pursue our legitimate interest; and (iii) our legitimate interest is not overridden by your interests or fundamental rights and freedoms. In particular, we only process your data through an AI tool for the Purpose, if and when necessary. The Purpose is related to the detection of fraudulent content or behaviour, which is a lawful, clear, articulated and present interest of ours, and, therefore, constitutes a legitimate interest of ours, as controller. Considering the current volume data and complexity of fraud controls and detection mechanisms, the pursuit of the Purpose is not only enabled with recourse to AI tools, but would not be possible without it. To the extent that datasets are not stripped of their usefulness, they are pre-processed by Bitrefill to redact personal data, where personal identifiers are removed prior to input.

• Monitoring. We monitor the performance of selected AI tools to ensure the system remains fit for the Purpose, and that its use is appropriate and complies with our privacy obligations under this Privacy Policy and applicable law.

• Purpose-specific channels. Only authorised staff can use AI tools licensed to us and access any resulting data outputs. Use of AI for the Purpose is limited to purpose-specific input channels, where access to the AI tool is limited to authorised personnel and governed by internal data handling protocols.

4. How do we protect your personal data?

We are committed to protecting the privacy and confidentiality of your personal data. Access to your data is limited only to authorized Bitrefill officers, employees, contractors or others who may require access to it in order to perform the services requested by you.

More specifically, we have implemented the following security measures:

• Staff dedicated to cyber and physical security, that designs, implements and provides oversight to our information security program;
• The use of specialized technology such as host-based security tools, network defence monitors, and intrusion detection systems;
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
• Internal and external reviews of our Internet website and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting information during transmission through various means including, where appropriate, encryption; and
• Providing Bitrefill personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

4.1. Specifically: your password

Customers are responsible for ensuring that their password is not shared or accessed by any other person, as well as for keeping their devices safe.

Bitrefill highly recommends its customers to use the 2FA (two-factor authentication) feature made available to them.

We have in place the following security measures for your password:

To ensure the safety of your password, we have implemented a series of security measures.

Our password strength validator checks for a minimum length, as well as the presence of uppercase and lowercase letters, numbers, and special characters. By hashing passwords, we ensure that even if a potential breach occurs, actual passwords will remain undisclosed.

To further protect your account, we confirm the password reset token before allowing a password change. Finally, we notify users whenever their password is changed to ensure they are aware of any unauthorized modifications.

5. How can you exercise your data subject rights?

Under certain circumstances, you have the following rights under the data protection laws in relation to your personal data:

• Right to access, correct or erase your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it, correct any inaccuracies or request (to the extent permitted by law) the deletion of your data.
• 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 that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • 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.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us in writing to support@bitrefill.com.

Please note that when applicable exceptions apply, some or all of these rights may not be enforceable. This will be the case, for example, if we have reason to suspect you may have been using our platform for unlawful purposes. In these cases, we can either refuse to, for example, erase your personal data and transactions record, or agree to do it within a certain reasonable time period that would allow us to confirm or waive our suspicions.

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 unreasonable, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We retain your data only as long as is necessary and only for the purpose for which we obtained it. Our retention periods are based on business needs or legal obligations and your information that is no longer needed is either irreversibly anonymized or destroyed securely. We will keep your data related to the exercise of any rights set out above for a period of 12 months from the relevant exercise of rights.

6. How long do we keep your personal data?

We will keep your personal data for the time needed to fulfil the purpose for which it was collected, be it selling you Products, complying with legal obligations, or protecting ours, yours or other’s interests.

If you have an account with us, we will keep your data collected in relation to your account activity for as long as the account exists.

We will keep information that is collected and processed for compliance purposes (namely information connected with ongoing investigations, or processed in the context of our anti-money laundering policy), for a minimum of 5 years, in accordance with applicable legislation and our internal money laundering process. This includes basic information data, KYC customer data, financial data, wallet data, transaction data, and certain device, browser and app data. We keep this information regardless of your request to delete it, if you have purchased Products that require KYC or if you have engaged in certain types of behaviour with Bitrefill that are considered by us as high risk.

We will keep information that is relevant for tax purposes for a minimum of 7 years.

We will keep information about your application for a job at Bitrefill until the moment we fill out the position, and unless you authorize us to keep that information further for consideration for new job openings, we will delete it and you will need to resubmit it again if you want to reapply.

If you request us to delete your personal data, we will comply with that request to the extent possible. In certain circumstances, we may be forced by tax, anti-money laundering or other compliance regulations and policies, to keep your data despite of your request. We will inform you of that circumstance.

7. Minors

Our website and services are not intended for children under 16 years of age.

We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information to us without parental consent. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

8. International transfers

To enable our platform and services, we may need to transfer and process your personal data in countries outside the EEA, where Bitrefill is based. Although we strive to ensure that your personal data remains within the EEA whenever possible, certain third-party providers are located abroad and therefore in certain circumstances transferring your personal data internationally is unavoidable.

When that happens, we rely on adequacy decisions from the European Commission, whenever possible, and on the European Commission’s Standard Contractual Clauses to enable the transfer of data to third countries.

We also rely on exemptions provided by the GDPR (article 49), for example in order to share personal information when requested by law enforcement authorities, or to connect with our suppliers in order to fulfil your order.

9. Miscellaneous

9.1 If you have questions about this Privacy Policy and how we handle your data, please send an email to support@bitrefill.com with your question.

9.2. As our platform evolves, we may need to modify our Privacy Policy from time to time. Those changes will be made in this page, and when significant, we will inform you.

If you wish to contact us for any matter related with the Bitrefill Global Privacy Policy or with how we process your personal data, please contact us at support@bitrefill.com.

10. Cookie Policy

When you visit the Website, the Website asks your browser to store a small piece of data (text file) called a cookie on your device in order to remember information about you, such as your language preference or login information. Cookies ensure a consistent and efficient experience for you, and perform essential functions such as allowing you to register and remain logged in.

These cookies are set by Bitrefill and called first-party cookies. Bitrefill also uses third-party cookies, which are cookies from a domain different from the domain of the Website, for our advertising and marketing efforts.

Other similar tracking technologies used by Bitrefill may include web beacons or tracking pixels. These are typically small transparent images that provide Bitrefill with statistics, for similar purposes as cookies, and are often used in conjunction with cookies. Web beacons are not stored on your device in the same way as cookies, and, as a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.

Bitrefill uses cookies and other tracking technologies for the purposes described in this Cookie Policy.

All capitalized terms used in this Cookie Policy and not defined herein shall have the meaning attributed to it under the Privacy Policy. For the purposes of this Cookie Policy, unless the context otherwise requires, the term ‘cookies’ refers to all of cookies, web beacons and tracking pixels.

10.1. Strictly-necessary cookies

Some cookies are strictly necessary for the Website to function and cannot be switched off in our systems. These cookies are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but that will cause some parts of the Website to not work. These cookies do not store any personally identifiable information.

10.2. Performance cookies

Bitrefill uses third-party performance cookies. Performance cookies collect information on how you interact with the Website, including visits, time spent, as well as other analytical data. Bitrefill uses this information to improve how the Website functions and to understand how you interact with it, and also to improve our advertising strategies. This is known as digital analytics and enables Bitrefill to know what content on the Website is the most and least popular, and how you move around and interact with the Website overall. The data collected through performance cookies is not associated by Bitrefill with any individual person.

To view an overview of your Google Analytics cookie please go here.

You may install a Google Analytics opt-out browser add-on by going here.

If you give consent for the use of cookies, Bitrefill will deploy a single cookie for the single purpose of remembering such consent.

10.3. Advertising cookies

Bitrefill may use advertising cookies for the purpose of providing you with access to content and information that you may be interested in.

10.4. Email engagement and deliverability trackers

Bitrefill emails may contain a tracking pixel, which is a small invisible image that tells when you opened an email from Bitrefill. Where this is used to measure engagement, personalize content, or inform marketing decisions, Bitrefill only does this with your consent.

You can give or withdraw consent at any time via the “Unsubscribe” link in any email you have received from Bitrefill or in your account preferences. Declining does not affect your ability to receive transactional emails (such as order confirmations or account notifications) or exercise your rights under our Terms.

Where a pixel is used solely to keep the mailing list accurate, Bitrefill does not treat this as requiring separate consent, consistent with applicable standards. Pixels in transactional emails, including, for example, welcome emails, account alerts, order confirmations and purchase invoices, reminders and password resets, responses to requests sent to Customer Support, or payment notifications also do not require prior consent from you, pursuant to applicable law and standards. This is without prejudice to Bitrefill complying with the principle of data minimisation under Article 5(1)(b), GDPR, and recording only the minimum information to successfully complete the service requested by you.

Bitrefill does not use tracking pixels to build profiles about you for use outside of email, unless you have separately consented to that use.

10.5. Third-party website cookies

When using the Website, you may be directed to other websites for such activities as surveys, to make payments, and to view content hosted on those websites. These websites are hosted, owned and/or operated by third parties and may use their own cookies. Bitrefill does not have control over the placement of cookies by any websites other than the Website, even if you are directed to them from the Website.

10.6. How to control and delete cookies?

A cookie notice popped-up when you accessed the Website, requesting your consent for the use of cookies. If you provide consent, you can always opt-out at any time as described below.

Cookie consent tool

You can customize your cookie preferences in Bitrefill’s cookie consent tool available in the menu in the Website. The cookie consent tool will record when you have consented to this Cookie Policy and will ask for consent once a year to ensure you stay up to date with changes to our Cookie Policy and Privacy Policy.

Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from the Website. You can access Bitrefill’s cookie consent tool anytime from the preferences link in the Website footer.

Using your browser

Many of the cookies used on the Website and through emails can be enabled or disabled, at any time, through Bitrefill’s cookie consent tool or by disabling the cookies through your browser.

To disable cookies through your browser, follow the instructions usually located within the “Help,” “Tools” or “Edit” menus in your browser. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually completed through your browser function.

Cookies set in the past

Collection of your data from our cookies can be deleted. If cookies are deleted, the information collected prior to the preference change may still be used. However, Bitrefill will stop using the disabled cookie to collect any further information from your user experience.

10.7. Help

You may need to refresh the page before any changes to your cookie settings take effect.

If you have any questions about our use of cookies or other related questions, please refer to our Privacy Policy. For any further questions, please contact us at help.bitrefill.com.