1. Introduction
Blinka Tech Corp, a Delaware corporation (“Blinka,” “we,” “us,” or “our”), is committed to protecting the privacy of our users. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you access or use the Blinka platform, website, mobile applications, APIs, and related services (collectively, the “Services”). By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the Services. This Privacy Policy applies to all users of the Services, including business entities, their authorized representatives, and any individuals who interact with the Services.The Blinka Card is issued by Third National. The issuer maintains its own privacy policy covering card issuance and related services, which is linked from the Card Program Disclosures.
2. Information We Collect
We collect the following categories of information:a. Personal Information
Information that identifies you or your authorized representatives, including:- Full legal name, date of birth, and Social Security Number or Individual Taxpayer Identification Number
- Email address, phone number, and mailing address
- Government-issued identification documents (e.g., driver’s license, passport)
- Photographs or profile images
b. Business Information
Information about your business entity, including:- Legal business name, trade name, and Employer Identification Number (EIN)
- Business address, formation state, and entity type
- Beneficial ownership information
- Business financial statements and tax returns (when required)
- Industry classification and nature of business activities
c. Financial Information
Information related to your financial activity, including:- Bank account numbers, routing numbers, and account balances
- Transaction history, payment details, and settlement records
- Card transactions, merchant details, and receipts
- Invoicing and billing information
- Counterparty and vendor payment details
d. Technical Information
Information collected automatically when you use the Services, including:- IP address, browser type and version, and operating system
- Device identifiers and device type
- Pages visited, time spent on pages, and navigation patterns
- Referring URLs and search terms
- Log data, error reports, and performance metrics
3. How We Collect Information
We collect information through the following methods:a. Directly from You
When you register for an account, complete the Know Your Business (KYB) verification process, initiate transactions, communicate with our support team, or otherwise interact with the Services.b. Automatically
Through cookies, web beacons, pixels, and similar technologies when you access or use the Services. We also collect information from server logs and analytics tools.c. From Third Parties
From our service providers, financial institution partners, identity verification services, credit reporting agencies, and publicly available databases. We may also receive information from other users who designate you as a counterparty or vendor.4. How We Use Your Information
We use the information we collect for the following purposes:- Providing and maintaining the Services. To open and manage your account, process transactions, facilitate payments, issue and service cards, and deliver the features and functionality of the Platform.
- Identity verification and compliance. To verify your identity and the identity of your business, conduct Know Your Business (KYB) and Know Your Customer (KYC) checks, comply with anti-money laundering (AML) regulations, and fulfill other legal and regulatory obligations.
- Fraud prevention and security. To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity, and to protect the security and integrity of the Services.
- Communication. To send you transactional notifications, security alerts, account updates, and customer support responses. We may also send you promotional communications, which you can opt out of at any time.
- Analytics and improvement. To understand how users interact with the Services, identify trends, diagnose technical issues, and improve the Platform’s performance, features, and user experience.
- Legal compliance. To comply with applicable laws, regulations, legal processes, and government requests, including tax reporting, regulatory examinations, and law enforcement inquiries.
5. How We Share Your Information
We do not sell your personal information. We may share your information with the following categories of recipients:- Financial institution partners. We share information with our banking, card issuing, and payment processing partners as necessary to provide the Services, including account opening, card issuance, transaction processing, and regulatory compliance. This includes sharing information with Erebor Bank, N.A. for the provision of banking services and deposit accounts, with Third National for card issuance, and with Mural Pay, Inc. for payment infrastructure and stablecoin-related services.
- Authentication providers. We use third-party authentication services to manage user sign-in and account security. Your authentication credentials and basic profile information are processed by our authentication provider in accordance with their privacy policy.
- Identity verification services. We share personal information with identity verification and fraud prevention providers to conduct KYB/KYC checks and ongoing monitoring.
- Analytics providers. We use analytics tools to understand usage patterns and improve the Services. These providers may collect technical information about your use of the Platform.
- Legal and regulatory authorities. We may disclose your information when required by law, regulation, legal process, or government request, or when we believe disclosure is necessary to protect our rights, property, or safety, or that of our users or the public.
- Professional advisors. We may share information with our attorneys, accountants, auditors, and other professional advisors as needed for the operation of our business.
- Business transfers. In the event of a merger, acquisition, reorganization, bankruptcy, or other business transfer, your information may be transferred to the acquiring or successor entity.
6. Data Security
We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, use, modification, and disclosure. These measures include:- Encryption of data in transit using TLS/SSL protocols and encryption of sensitive data at rest.
- Access controls that limit access to personal information to authorized personnel on a need-to-know basis.
- Regular security assessments, vulnerability scanning, and penetration testing.
- Employee training on data protection and information security best practices.
- Incident response procedures for detecting, responding to, and recovering from security incidents.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Specific retention periods may vary depending on the type of information and the purpose for which it was collected. In general:- Account and identity information is retained for the duration of your account and for a minimum of five (5) years after account closure, as required by the Bank Secrecy Act and related regulations.
- Transaction records are retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable regulatory requirements.
- Records of your acceptance of our agreements are retained for a minimum of five (5) years, as required by our card issuer.
- Technical and usage data is generally retained for up to two (2) years, unless a longer retention period is required for security, fraud prevention, or legal purposes.
8. Your Rights
Depending on your jurisdiction, you may have certain rights regarding your personal information. These rights may include:- Right to know. You may request information about the categories of personal information we collect, the purposes for which we use it, and the categories of third parties with whom we share it.
- Right to access. You may request a copy of the personal information we hold about you.
- Right to correction. You may request that we correct inaccurate or incomplete personal information.
- Right to deletion. You may request that we delete your personal information, subject to certain exceptions (e.g., where retention is required by law).
- Right to opt out. You may opt out of the sale or sharing of your personal information (note: we do not sell personal information), and you may opt out of promotional communications at any time.
- Right to non-discrimination. We will not discriminate against you for exercising any of your privacy rights.
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect information about your interaction with the Services. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information. We use the following types of cookies:- Essential cookies. Required for the operation of the Services, including authentication, security, and session management. These cannot be disabled.
- Analytics cookies. Help us understand how users interact with the Services, which pages are most visited, and how users navigate the Platform. This data is used to improve the Services.
- Functional cookies. Remember your preferences and settings to provide a more personalized experience.