Last updated: 30/10/2026
Processing your personal data in a safe and fair manner is a cornerstone principle of Bilderlings Pay Limited.
This privacy notice explains how we, as a data controller, process your personal data. The notice is designed to provide information on what personal data we collect and for what purposes as well as to outline your rights concerning your personal data. We may update this notice from time to time. We will publish updates on our website and, where required by law, notify you of significant changes.
Bilderlings Pay Limited is authorised and regulated as a UK financial institution and processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018) as amended by the Data Use and Access Act (2025) (DUAA) from time to time.
We, us, our or Bilder - Bilderlings Pay Limited.
Data controller is an entity (e.g. a person, organisation, agency), which alone or jointly with others, determines the purposes and means of processing personal data. In the context of this document Bilderlings acts as the data controller when it provides its services.
Data processor is an entity (e.g. a person, organisation, service provider) which processes personal data on behalf of Bilder. Bilder engages data processors for processing personal data and undertakes necessary steps to ensure that personal data processing by data processors takes place under a contract or the applicable law and according to Bilder documented instructions.
Customer or you is any natural person who has used, uses or has expressed a wish to use our services and/or has any other relationship with us.
Corporate customer means any legal entity that uses, has used or has expressed a wish to use the services.
Data subject any identifiable living natural person whose personal data is processed by Bilder. Bilder processes personal data of data subjects such as customers, legal representatives, authorized persons, contact persons, counterparties, payers, board members, ultimate beneficial owners, as well as personal data of other data subjects provided for in this notice. Categories of data subjects referred to in this definition are included in the definition of the customer.
Applicable legislation means the DPA 2018 and the UK GDPR as amended from time to time by the DUAA. It could also mean other legislation that Bilder is subject to, for instance, anti-money laundering, prevention of terrorism and proliferation financing, enforcement of sanctions, taxes, accounting, payment services, litigation (procedural) law and others.
Special category data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for unique identification purposes, data concerning health, or data concerning a person’s sex life or sexual orientation.
EU/EEA is the European Union/European Economic Area.
Personal data is any type of information that could directly or indirectly define a living individual.
Processing is any manipulation (e.g. collecting, storing, modifying, erasing, etc.) with personal data disregarding whether or not executed by automated means.
Services means a wide range of financial products and services provided by Bilder to you.
Bilder ensures the confidentiality of personal data in compliance with the applicable legislation by having adopted sustainable technical and organisational tools that are designed to maintain a high standard of safeguarding personal data against unauthorised access, accidental loss or destruction, unlawful disclosure or processing.
In cases where Bilder uses services of data processors, we undertake all necessary measures to ensure that data processors act in the confines of our written instructions as well as comply with standards laid out by the applicable legislation and follow required security measures.
We may collect your personal data and this notice applies when you:
We apply the principles of lawfulness, fairness and transparency, data minimisation, purpose limitation, accuracy, storage limitation, integrity and confidentiality, and accountability when processing personal data.
Our registration number with the Information Commission’s UK (ICO) is ZA187012. Our registered office is 13 Regent Street, London, United Kingdom, SW1Y 4LR. Company No. 09908958.
We collect your personal data in order to provide services to you or those you represent. Personal data could be collected directly or indirectly when you either enter or express an intent to enter into a business relationship with us and, therefore, use our services. Subsequently, personal data could be collected about you from other external sources (e.g. private or public databases). Personal data could also be collected by recording calls, images or saving any other type of correspondence maintained with the customer throughout the course of business relations with us.
Where we are required by law, or need certain personal data to enter into or perform our agreement with you, we will indicate where the provision of such information is mandatory. If you do not provide the required information, we may be unable to open or maintain your account, provide certain services, process transactions or otherwise establish or continue our business relationship with you. Therefore, the following categories of personal data may be processed:
Identification data such as name, surname, date of birth, personal identification number, photo in submitted personal identification document, and other personal identification documents provided.
Contact information data such as your email address, phone number, country of residence.
Personal data such as country of residence, location data, and citizenship.
Biographical data such as current professional or work activity, education, professional certificates, information concerning other people (such as joint account holder, your spouse or family member, and other family related data).
Account data such as bank account number, card number.
Financial data such as transactions, ownerships, income, liabilities, assets.
Tax information: your country or countries of tax residence and your tax identification number (s).
Location and system data (whenever you use our website or Bilderlings app) such as technical information about your internet protocol (IP) address used to connect your terminal equipment to the internet, your login information, browser type and version, time zone settings, operating system and platform, the type of device you use, unique device identifier your mobile operating system and the type of mobile browser you use; information about your visit, including the links you have clicked on, through and from our website or the app (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages.
Data concerning reliability and due diligence such as payment history and behaviour, other data that is critical for execution due diligence measures concerning prevention of money laundering and terrorist financing, compliance with international sanctions, determining the account opening purpose, and data with regard to the customer’s business partners and business activities.
Data related to your use of Bilder’s services, including the types of services you use, or expressed a wish to use (for instance personal data you have provided within account opening process), assets held in your Bilder account(s), your obligations to Bilder, your account and card numbers issued by Bilder, correspondence with Bilder, internet banking and system usage data, data contained in contracts concluded with Bilder, and information about transactions and your use of Bilder products (for example, incoming and outgoing payments), including the date and time, amount, currency, exchange rate, beneficiary details, merchant details, receiver’s name and registration information, messages sent or received, other communications between you and Bilder, details of the device used to arrange the payment, and the payment method. If you provide us with personal data relating to another person (for example, a joint account holder, your spouse, or a family member), or ask us to share their personal data with third parties, you confirm that you are authorised to do so and that you have provided them with this notice in advance.
Video and audio data such as records of phone calls or other Internet based remote communication means chosen by you or us to interact. Such recordings are used for quality assurance purposes.
Other data could be publicly available information about you from selected social media websites, online registers, directories, or apps where necessary to carry out enhanced due diligence checks. Publicly available information from social media websites or apps may also be obtained by us when we conduct proportionate searches on you (e.g. to fulfil requirements of anti-money laundering or sanctions screening obligations and KYC purposes in accordance with applicable legal and regulatory requirements).
We may process biometric data, such as facial images and facial recognition data, to verify your identity when you apply for the account opening. We use this data in order to:
We may use specialist identity-verification providers to carry out these checks on our behalf. Biometric data is retained only for as long as necessary to comply with legal and regulatory requirements and is subject to appropriate technical and organisational safeguards.
Our services use cookies that are considered to be personal data when used in order to distinguish you from other users. This helps us to provide you with a valuable experience of our services as well as to allow us to improve our services.
Concluding and keeping our contracts and agreements with you (contractual necessity) - we need to collect your personal data in order to be able to provide you with our services.
Legal obligation - we are bound by the applicable legislation to process your personal data (e.g. to check and verify customer’s identity, detect, prevent and report money laundering, terrorism financing, proliferation financing, breaches or circumvention sanctions regimes, investigate suspicious transactions, prevent fraud, manage incidents and fulfil other statutory and regulatory obligations; including, but not limited to, for tax reporting - we use your tax information to identify whether you are a tax resident outside the UK and, if so, meet our reporting obligations under Common Reporting Standards).
Consent - your freely given, specific, informed and unambiguous indication of your wishes by which you agree to the processing of your personal data for a particular purpose (for example, direct marketing). Where we rely on your consent, you have the right to withdraw it at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal. Please note that if you do not provide or withdraw your consent, we may not be able to provide certain services (for example, direct marketing) that rely on that consent. We do not rely on your consent to process personal data where the processing is necessary to provide our services, maintain our systems, comply with legal obligations, or protect against fraud and security risks.
Legitimate interest - includes examining, developing and improving our services to strengthen customer satisfaction and loyalty; providing information about Bilder services of a general nature, where such communications are not personalised through profiling of your personal data and are permitted under the applicable legislation.
We do not disclose your personal data to the public and treat it confidentially. However, we sometimes need to disclose your personal data to third parties where necessary and in accordance with the applicable legislation.
We may share your personal data with regulated contractual partners or other third parties:
Normally your personal data is processed within the United Kingdom and EU/EEA, however, there might occur circumstances where your personal data could be transmitted and processed outside these territories. Where we transfer your personal data outside the UK, we ensure that the transfer is permitted under applicable data protection law. Depending on the circumstances, we may rely on UK adequacy regulations, appropriate safeguards under the UK GDPR (including the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses). Where required, we carry out a transfer risk assessment (data protection test) and implement any additional technical, organisational or contractual measures necessary to ensure an appropriate level of protection.
Profiling is a form of automated processing of personal data aimed to evaluate personal aspects of a natural person, and may be applied for example to propose relevant marketing offers to an individual or in the context of risk assessment and analysis to detect and prevent fraudulent activity (e.g. as part of transaction monitoring process). Subsequently, Bilder conducts profiling where necessary to comply with the applicable legislation in the scope of risk management and to ensure the continuous and periodic monitoring of transactions. We may use automated processes as part of our customer onboarding. Where predefined identity verification, eligibility, compliance and risk-related requirements are satisfied, your application may be approved and your account opened automatically without human involvement. If your application cannot be approved automatically, it will not be automatically rejected. We take measures to safeguard your interests and ensure fair treatment, providing you with the right to request human intervention, express your perspective, and challenge the decision.
Our website, portal and app may use cookies and similar technologies in accordance with the UK Privacy and Electronic Communications Regulations (PECR). Where consent is required by law, we will obtain your consent before using such technologies. Further information about the technologies we use, their purposes and your choices is available in our Cookie Policy.
Your personal data will be retained only as long as necessary for the purposes for which it was collected for or which are prescribed by the applicable legislation. When our business relationship with you is fully terminated, we will continue processing only where necessary to comply with the applicable legislation, or for pursuing our legitimate interest, for instance, defending or exercising legal claims. Normally, Bilder retains personal data for 7 years after the business relationships are fully terminated, as stated in the Record Keeping Policy.
Bilder is fully committed to ensure that your personal data is processed in a fair and transparent manner along with protection of your personal data protection rights. In accordance with the applicable legislation, we will respond to your request to exercise your rights without undue delay and, in any event, within one month of receipt of the request. This period may be extended by two further months where necessary, taking into account the complexity and number of requests.
We may first need to verify your identity prior we proceed with your request. Where we have reasonable doubts concerning your identity, we may request additional information necessary to verify your identity before responding to your request. In circumstances where we cannot verify your identity, we may not be able to fulfill your request, unless the right you wish to exercise does not require verification. In certain circumstances, where a request is manifestly unfounded or excessive, in particular because of its repetitive character, we may either charge a reasonable fee or refuse to act on the request, in accordance with Article 12(5) of the UK GDPR.
Your rights under the applicable legislation include the following:
Bilder maintains technical and organisational measures aimed to provide a protection for your personal data against loss, interference, unauthorized access, unlawful disclosure or alteration. The security measures include but are not limited to firewalls, physical access controls, personal data digital access controls and data encryption. We are fully committed to creating a secure environment for our systems and services, however, you are responsible for securing and maintaining the privacy of your passwords and account of profile registration information and verifying that the personal data you have provided us is accurate and up-to-date.
In case you have any questions or complaints regarding this document, the processing of your personal data or your rights, we encourage you to contact us through your personal account, by contacting your manager or via e-mail at [email protected]
Bilderlings Pay Limited
Registered address: 13 Regent Street, London, United Kingdom, SW1Y 4LR
Registration No. 09908958
Phone: +442039368203
E-mail: [email protected]
The Information Commission (ICO):
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Available in United Kingdom and 150+ countries.
11 years of experience
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