Privacy Policy on Revolut for kids and Teens (6-17)
REVOLUT TECHNOLOGIES JAPAN, Inc.( "We", “our”, “us” or "Revolut") complies with the applicable personal data protection laws and regulations of Japan and foreign countries regarding the personal information related to Sub-Account Users, as defined in the Revolut for Kids and Teens (6 - 17) Account Terms (the "Terms"), in connection with the Revolut for Kids and Teens (6 - 17) Account and related services ( collectively or individually referred to as the "Service"). We handle such personal information in accordance with the following Privacy Policy on Revolut (6-17) (the "Policy").
Unless otherwise specified in this Policy, the personal information of Sub-Account Users is also subject to our Privacy Policy (hereinafter the Privacy Policy and the Policy shall be collectively referred to as the "Revolut Privacy Policy").
For details regarding the content of the Service, please refer to these Terms.
Unless otherwise defined, terms used in this Policy shall have the same meanings as defined in these Terms.
Collection of Personal Information
To provide the Service, we need to collect information about Sub-Account Users. We are a "Business Operator Handling Personal Information" as defined by the Act on the Protection of Personal Information. By starting to use the Service, the Lead Parent and the Sub-Account User grant us permission to collect, process, entrust, and store their personal information in accordance with the Revolut Privacy Policy.
The personal information obtained from Sub-Account Users includes, but is not limited to, name, date of birth, the relationship between the Sub-Account User and the Lead Parent or Co-Parent (such as a parent-child relationship), email address, and phone number.
When Sub-Account Users use the Sub-Account, we collect additional information, including:
- Transaction details when a Sub-Account User makes payments using their Card (date, location, transaction amount, etc.).
- Usage data from our website, which we track using cookies, as well as data on how the Sub-Account User interacts with the app.
To verify the identity of Sub-Account Users, we may request the Lead Parent or Co-Parent to submit identification documents such as My Number Card (front side only), Residence Card, or a Certificate of Residence (without My Number). Additionally, we may collect photos and other information the Sub-Account User, Lead Parent, or Co-Parent decided to give us.
If the Sub-Account User has any questions regarding how we use Sub-Account Users' data, please contact [email protected]. For other inquiries, please contact us through the Lead Parent.
If a Sub-Account User contacts us via email, they may be asked a few questions to confirm their identity. Be mindful of the information included in emails, avoiding unnecessary details or information that could be misused. If we need any specific information, we will request it clearly.
Usage of Sub-Account Data
The Lead Parent or Co-Parent can view how the Sub-Account User uses their Sub-Account, what they spend money on, and the balance of the account. We also have access to this data. In other words, the Lead Parent and the Co-Parent can view data related to the Sub-Account of the Sub-Account User. Additionally, we can also view data related to the Sub-Account of the Sub-Account User.
Purpose of Using Sub-Account User Data
In addition to the purposes outlined in our Privacy Policy, Sub-Account User data is used for the following purposes:
- Opening the Sub-Account, or identity verification when opening or maintaining a Sub-Account.
- Allowing other Sub-Account Users to search for the Sub-Account User (provided that the Sub-account user has enabled search permission in the App settings).*1
- Enabling Sub-Account Users to find other users by using shared contact lists (provided that the other sub-account user has enabled search permission in the App settings).*2
- Informing users about services offered by us, our group companies (Revolut Ltd, its affiliates, and subsidiaries of its parent company), and our partners. Such notifications are sent only with the Lead Parent’s consent or the Sub-Account User’s consent if they are 16 years or older. However, essential updates, such as changes to our terms and conditions, will be sent regardless of the consent.
- Protecting the Sub-Account.
- Responding to inquiries from Sub-Account Users or Lead Parents regarding the Service. However, Co-Parents cannot contact us regarding the Sub-Account User’s account.
*1 This search function is only available if both the Sub-Account User and the other Sub-Account User are 13 years or older.
*2 If a Sub-Account User is 13 years or older, they can share their contact list (name, phone number, email address, date of birth, etc.) registered on the Sub Account user’s mobile device with us for the Sub-Account User to find friends with the contact list using Sub-Account. The Sub-Account User can choose to stop sharing your location or syncing the Sub-Account User’s contacts list at any time through the App.
Data Security and Notifications
Only the Sub-Account User knows the password for the Sub-Account. Please make sure that no one else knows it. When entering the password, ensure that no one is watching.
We will do our best to protect the Sub-Account User’s data. To keep the Sub-Account User’s data secure, we will comply with legal requirements. Unfortunately, even with our best efforts, information on the internet can never be completely secure. We cannot guarantee that the Sub-Account User’s data will always be fully protected.
If someone gains unauthorized access to our office, computers, or databases and obtains the Sub-Account User’s data, we will notify the Sub-Account User and the Lead Parent as soon as possible.
Rights of Sub-Account Users
If the Sub-Account User (or if the Sub-Account User is under 16 years old, the Lead Parent) requests disclosure, correction, suspension of use, deletion, or cessation of third-party provision of their personal data, or requests disclosure of the presence or absence of personal data held by us, we will confirm that the request is made by the Sub-Account User (or the Lead Parent if the Sub-Account User is under 16 years old), and will respond based on our established procedures, unless there are special reasons, such as those defined by the Act on the Protection of Personal Information or other applicable laws, that prevent us from doing so. If the Sub-Account User (or if the Sub-Account User is under 16 years old, the Lead Parent) requests specific disclosure, correction, etc., we will charge the Sub-Account User or the Lead Parent the prescribed fees for processing.
- Additionally, the Sub-Account User can check their personal data, such as their name and contact information, held by us through the profile screen of the App. They can also correct their phone number or email address.
- If the Sub-Account User requests something that indicates they wish to stop using the Sub-Account, we will notify the Lead Parent. Similarly, if the Sub-Account User requests a copy of their data, we will inform the Lead Parent. This is because there may not be a direct method for sending the Sub-Account User’s data to them. Please note that we will only contact the Lead Parent and will not contact the Co-Parent.
Contact Information
For requests for disclosure, correction etc., suspension of use, deletion or suspension of provision to third parties of Personal Data etc. or complaints, consultations or other questions concerning the handling of personal data, please contact us using the information below.
The Lead Parent may also contact us regarding the Sub-Account User’s account.