Revolut Technologies Singapore Pte. Ltd. (“we” or “us”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. We strive to ensure that our practices regarding personal data of our users comply with the various personal data protection and privacy laws applicable to us.
By using any of the Services, you accept our practices and processes as set out in this policy. If you do not agree to any part of this policy, please do not use any of the Services.
We have appointed a data protection officer (“DPO”). Our DPO is based in Singapore and may be contacted directly via email (firstname.lastname@example.org) or through Customer Support using the in-App support. When contacting the DPO, please provide as much information as possible that is specific to your enquiry (including geographical or location information where relevant).
Our DPO has a number of important responsibilities, including:
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO via email@example.com or our in-App support.
You have the right to make a complaint at any time to the PDPC in Singapore. We would, however, appreciate the chance to deal with your concerns before you approach the PDPC, so please contact us in the first instance.
So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
a) Information you give us - “Submitted Information”: This is information you give us about you by filling in forms on the App and/or the Site, or by corresponding with us (for example, by e-mail or via the chat functions on the App and/or the Site). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our services, enter into any transaction on the App or the Site (such as a Top Up, Instant Transfer, Revolut Bank Transfer, Electronic Money Exchange), participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your names (including aliases), address, date of birth, e-mail address, phone number, the Device's phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, identification card, work permit, residency permit, driving license and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
b) Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:
c) Location Information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in the UK but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the Revolut App within your device settings – “Location Information”
(d) Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Revolut Services), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions. Please see the ‘Disclosure of your Information’ section for more information.
(e) If you allow us to, we will collect friends lists from Facebook and similar information from other third parties such as Twitter and Google – the App will periodically re-collect this information in order to stay up-to-date. You will always have the opportunity to opt-out later through our in-app chat.
4.1 Below is a summary of the key types of data that we make use of as part of the Revolut Services. For more information on how these types of data are used and for which purposes then please see the table below.
4.2 We use information held about you in the following ways:
a) Submitted Information: We will use this information:
b) Device Information: We will use this information:
c) Location Information: We will use this information:
d) Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
for the purposes set out above (depending on the types of information we receive).
4.3 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
4.4 If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in a particular geographical location). In some instances, we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
4.5 We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so.
4.6 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via in-App support if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|What we use your information for||Type of Information||Legal Bases|
|To provide the Revolut Services: To provide the Revolut Services: To carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, Revolut Bank Transfers, Electronic Money Exchanges, ATM Withdrawals and Revolut Card Purchases and to provide you with the information, products and services that you request from us.||Submitted Information||
Fulfilling contracts: Being efficient about how we fulfill our legal and contractual duties.
Our legal obligation: Complying with regulations that apply to us.
|To combat against fraud: To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services; and To help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Revolut Account.||Submitted Information
Third Party Information
|Our legal obligation: (i) Developing and improving how we deal with financial crime and complying with our legal duties in this respect; and (ii) Complying with regulations that apply to us.|
|To help market and provide new products and services to engage you and acquire new users: To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; To make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them; and To process applications for products and services available through us, including making decisions about whether to agree to approve any applications.||Submitted Information
Third Party Information
|Your opt-in consent, so that we may: (i) Develop products and services for existing customers and any applicable fees in relation to them; and (ii) Define types of customers for new products or services.
Fulfilling a contract: Being efficient about how we fulfill our legal and contractual duties.
|To keep the Revolut Services up and running: To administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer; To allow you to participate in interactive features of our service, when you choose to do so; To notify you about changes to our service; and As part of our efforts to keep our Site and the App safe and secure.||Submitted Information
|Fulfilling a contract: being efficient about how we fulfill our legal and contractual duties.
Our legal obligation: Complying with regulations that apply to us.
|Facilitate social interactions: To facilitate social interactions through our services and to make you aware if any of your contacts who are Revolut Users and have location services enabled, are in the same area as you; and To make you aware if any of your contacts who are Revolut Users have utilised any of Revolut’s products or features.||Submitted Information
Information Location Information
|Fulfilling a contract: Being efficient about how we fulfill our legal and contractual duties.|
|To provide location-based Services: To deliver relevant advertising to you, for example, information on nearby merchants; To protect against fraud; and To make you aware if any of your contacts, who are Revolut Users and have location services enabled, are in the same area as you.||Location Information||Fulfilling a contract: Developing products and services
Our legal obligation: Complying with regulations that apply to us.
What do we mean when we say:
5.1 We want to make it crystal clear how we use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want.
5.2 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a ‘Privacy’ section within the ‘Profile’ section of the App where you can view and make certain decisions about your personal data use in relation to marketing emails and push notifications. Please see the ‘Privacy’ section within the ‘Profile’ section of the App for more details.
5.3 When we use social media for marketing purposes, your information may be shared with the social-media platforms so that they can check if you hold an account with them. If you do, we may ask the advertising partner or social-media provider to:
The legal basis for such marketing would be opt-in consent.
5.4 We may use your personal data (such as your Submitted Information, Location Information or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
5.5 You will receive marketing communications from us if you have signed up to and/or utilise the Revolut Services and, in each case, you have not opted out of receiving marketing notifications.
5.6 We will obtain your express opt-in consent before we share your personal data with any company outside the Revolut group of companies for marketing or promotional purposes.
5.7 You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences via ‘Privacy’ section found within the ‘Profile’ tab of the App or by following the unsubscribe links on any marketing message sent to you.
6.1 We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Revolut.
6.2 We send personal data to the following sets of data processors in order to perform the Revolut Services:
a) Fraud prevention agencies
b) Cloud storage providers
c) Banking and financial services partners
d) Credit reference agencies
e) Card manufacturing/personalisation and delivery companies
f) Advertisers and analytics providers
g) Companies within the Revolut group
In order to provide a unified service across all of our products and services, we may disclose your personal information to any member of the Revolut group, which means any of Revolut Ltd’s subsidiaries or our related entities. Companies in the Revolut group will be acting as joint controllers or processors in order to provide the Revolut Services. For example, we may share your data with our parent company Revolut Ltd, an FCA authorised and regulated entity, in order to provide foreign exchange related services to you.
6.3 We may also disclose your personal information in the following circumstances:
(i) enforce or apply the General Terms of Service and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or
(ii) protect the rights, property or safety of Revolut, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.5 From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any company outside the Revolut group of companies for these purposes.
6.6 You can withdraw your consent at any time after giving your explicit opt-in consent by contacting support via in-App chat and letting us know.
7.1 The data that we collect from you may be transferred to, processed, and stored at, a destination outside Singapore. As we provide an international service, your data also may be processed outside Singapore in order for us to fulfill our contract with you to provide the Revolut Services. We will need to process your personal data in order for us, for example, to action a request made by you to execute an international payment, process your payment details, provide global anti-money laundering and counter terrorist financing solutions and provide ongoing support services. We will take all steps to ensure that your data is treated securely and in accordance with the PDPA.
7.2 All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and/or our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
Revolut is obligated under the PDPA to retain personal data about you and your Revolut Transactions for such time until the retention of your personal data is no longer necessary for any business or legal purpose. In particular, we are required, as an entity subject to the regulatory supervision of the Monetary Authority of Singapore (“MAS”), to retain data, documents and information we collect as part of complying with our anti-money laundering and countering the financing of terrorism (“AML/CFT”) obligations (which may include your personal data, documents and information) for at least five years after the termination of business relations with you or the completion of transactions you undertake with or through us.
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via the in-App chat function. Please note that Singapore law allows us to refuse your request for access for various reasons, including where the burden or expense of providing such access would be unreasonable to us or disproportionate to your interests.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via the in-App chat function. Please note that Singapore law allows us to refuse your request for correction for various reasons, including where your personal data is contained in a document that is related to a prosecution if all proceedings related to the prosecution have not been completed.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request. As an MAS-regulated entity, we are required to retain data, documents and information we collect as part of complying with our AML/CFT obligations (which may include your personal data) for at least five years after we terminate business relations with you or the completion of transactions you undertake with or through us. Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling grounds to process your information which override your rights. As an MAS-regulated firm, Revolut is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Revolut Services and it is likely we will have to terminate your account.
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:
a) if you want us to establish the data's accuracy;
b) where our use of the data is unlawful but you do not want us to erase it; or
c) 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. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Revolut Services). In this case, we may have to cancel your use of the Revolut Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via the in-App chat function.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Revolut Services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required 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 clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Revolut Services). In this case, we may have to cancel your use of the Revolut Services but we will notify you if this is the case at the time.