Privacy Policy

PRIVACY POLICY

 

Last updated: January 1, 2025 (ver. 1.2)

THIS PRIVACY POLICY covers and describes the manner in which Envision Bullet LLC dba Bullet ATM (hereinafter, “Bullet” or “we” or “us”) handles collect, store, use and protect personally identifiable information, personal data and other information (collectively, “PII”) whether you interact with us (i) on our websites, pages, features, or content we own or operate, (ii) when you use a mobile app or third-party applications relying on such an API, (iii) or in person (including by phone or when visiting the “kiosks” or automated teller machines (referred to as “ATMs”) which we operate, and (iv) merchant processing services, products, or any other features, technologies or functionalities (collectively, hereinafter referred to as “Services”). The purpose of this policy is to ensure that Bullet complies with applicable United States (US) Federal and State regulations, and European Union (the “EU”) data protection laws such as the General Data Protection Regulation (the “GDPR”). Capitalized terms not defined herein shall have the meanings set forth in Bullet’s website Terms of Use (“Terms of Use”) here.

Please take a moment to carefully read this Privacy Policy carefully. If you have any questions about this Policy, please submit your request via legal@BulletATM.com.

Acceptance of this Privacy Policy

By accessing and using our Services, you signify acceptance of the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.IF YOU DO NOT FULLY AGREE TO THE TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, you should immediately discontinue access or use of our Services AND YOU MAY NOT ACCESS OR OTHERWISE USE BULLET’S SERVICES.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will update and publish this Privacy Policy here on this page and we may notify you by email (sent to the email address specified in your registered profile, if any), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law. Please bookmark and check this page frequently for any changes or updates to this Privacy Policy.

Personal Information that we Collect

For purposes of this Privacy Policy, “personal information” is the identifiable information or data from an individual that identifies or relates to an identifiable individual or characteristics. We collect certain personal information when you access our Services and complete the required information request forms This includes information you provide to us, information that is collected about you automatically, and information we obtain from third-parties.

Personal Information Provided

To utilize our Services, you will be asked to provide us with some important information about you. This information is either required by law (e.g. to verify your identity), necessary to provide you with the Services, or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.
Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us. Any information you provide to us that is not required is voluntary which includes, but not limited to:

• Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
• Formal Identification Information: Government-issued identity document such as Passport, Driver’s License, National Identity Card, State ID Card, Tax ID number, passport number, driver’s license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
• Information from Your Biometric Passport: If you use the Identity Verification Services to confirm your identity, process a transaction, or registration on the kiosk or your personal mobile device, as part of the Services may retain encrypted biometric data from your eligible biometric passport or device. We do not have the ability to access, decipher, or read this encrypted biometric data.
• Institutional Information: Employer Identification Number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), and personal identification information for all material beneficial owners.
• Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
• Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, timestamp, including other personal information and details associated with your transactions with our Services, for example, your wallet address and history.
• Employment Information: Employer name, phone number, work address or location, job title, compensation, email, and/or description of the role.
• Questionnaires or Surveys: Survey responses, and information provided to our support team or user research team.
• Correspondence with You: We may collect any correspondence that you send to us and any personal information contained therein, such as email address, phone number, social media handles, or mailing address when you email, message, call, or write to us.

Personal Information Collected Automatically

We receive and store certain types of information automatically, such as whenever you interact with our websites or utilize our Services. This information helps us address customer support issues, improve the performance of websites and applications, provide you with a personalized experience, and protect our Services from fraud which includes:

• Personal Identifiers: Name, Email address, and phone number.
• Online Identifiers: IP address(es), Geo location/tracking details, pixel tags or other similar technologies, browser fingerprint, operating system, browser name and version.
• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
• Blockchain Identifiers: Blockchain information, and related information.

Personal Information Collected from Third-Parties

For purposes herein, We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third-party site.

From time to time, we may obtain information about you from third-party sources as required or permitted by applicable law. These sources may include:

• Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for the purpose of verifying your identity in accordance with applicable law. ID verification partners like Telesign, Veriff or World-Check use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities such as OFAC, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to ensure our Services are not used fraudulently or for other illicit activities. In such instances, we may utilize third-party’s services such as Veriff for  processing as necessary for us to continue to perform our contractual obligations with you and others. Veriff’s Privacy Policy, available at https://www.veriff.com/privacy-notice/, describes its collection and use of personal data.
• Blockchain Data: We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
• Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.
• Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our website and how you interact with the website to utilize our Services. This information may be collected prior to account creation – for more information on how you can manage the collection of this data, please see our Cookie Policy hereinbelow.
• By utilizing our Services you authorize your wireless operator (AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile number, name, address, email, network status, customer type, customer file, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third-party service provider, solely to verify your identity and prevent fraud for the duration of the business relationship.

Use and Sharing of Personal Information

Please see our Privacy Provisions for California Residents below for details regarding our use and sharing of personal information.

In order to provide the Services, we must share your Personal Information in certain cases. This includes sharing your Personal Information within our subsidiaries and affiliates, with our Service Providers and the other third-party(ies) listed herein. Your Personal Information may be disclosed to external linked third-party(ies) when you have requested to interact with a third-party service or platform that is linked to our Services or utilizes our Services. Please be advised, however, that we may use your personal information to send you promotional messages regarding various Bullet products, joint ventures, affiliated and/or additional services, as well as third-party products and/or services that we think may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or use any of the other options available in the “Opt-Out/Unsubscribe” section below.

Our primary purpose for collecting PII is to provide you with a secure, smooth efficient, and customized experience. We may use your PII to:

• To create or register an identity or account to use our Services.
• Enable you to complete transactions through our Service.
• To manage your identity or information on our system.
• Conduct due diligence on and/or verify your identity.
• Conduct due diligence on your use of our Services.
• Comply with applicable laws and regulations.
• Provide the Bullet Services and customer support you request.
• Process transactions and send notices about your transactions.
• Resolve disputes, collect fees, and troubleshoot problems.
• Prevent potentially prohibited or illegal activities, and enforce our Terms of Use.
• Customize, measure, and improve the Bullet Services, content, and layout of our website and applications.
• To process your financial information.
• To permit you to register for events.
• Subject to de-identification, anonymization, pseudonymization, and aggregation, to conduct analytics related to the use of the Services.
• For other purposes, provided that we have obtained your previous consent.
• To evaluate potential transactions.
• Deliver targeted marketing, service updated notices, and promotional offers based on your communication preferences.

Visitors to Website

We may collect the following PII for visitors of our website(s) (https://www.BulletATM.com):

• IP address
• Email address (e.g. when you submit a support or contact request)
• Phone number (e.g. when you submit a support or contact request)
• Name (e.g. when you submit a support or contact request)
• We may collect information about a visitor’s computer or other access devices for fraud prevention purposes.

Wallet Holders

For wallet holders, Bullet may collect the following PII:

• Email address.
• The email address collection is not currently in effect. It may be available in future updates. When it becomes available, it is an optional opt-in service that allows the user to receive email notifications and (if selected) Bullet news and products updates. Users will be able to opt-out at any point in time.
• Wallet information and transaction destination address.

ATM Users

For customer using out ATMs, Bullet collects the following personal information:

• Your name.
• A copy of or information on your government-issued identification document.
• Your address.
• Your phone number.
• Your e-mail address.
• Your date of birth.
• Your tax identification number.
• Your transactional history.
• Wallet information and transaction destination address.
• And any other personal information which we believe is necessary to maintain or provide Services to you.

How we protect and store personal information

We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our offices and files, and we authorize access to PII only for those employees who require it to fulfill their job responsibilities.

Cookie Policy

This policy describes how Bullet uses cookies to customize Bullet Services, content and advertising, measure promotional effectiveness, and promote trust and safety.

How we use cookies

What are cookies?

A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but you can set your browser to decline them and can delete them whenever you like.

What type of cookies do we use?

When you access our website, we, or companies we hire to track how our website is used, may place small data files called “cookies” on your computer. We and our service providers also use cookies to customize the Bullet Services, content and advertising, measure promotional effectiveness, and promote trust and safety.

We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with you use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.

You may encounter cookies from third-parties when using the Services on websites that we do not control (for example, if you view a web page created by a third-party or use an application developed by a third-party, there may be a cookie placed by that web page or application).

Managing your cookie settings

You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies, or delete all cookies. It is your responsibility to seek more information on cookies and how to opt-out of them.

Marketing

We do not sell your PII to third-parties for their marketing purposes without your explicit consent. We may combine your information we collect from other companies and use it to improve and personalize our Services, content, and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, you can simply opt-out from the communications.

Linked Websites

The Services may contain links to third-party owned or operated websites, including, without limitation, social media websites (each a “Linked Site”), as a convenient method of accessing information that may be useful or of interest to you. This Privacy Policy and the practices that we follow under this Privacy Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third-parties on such Linked Sites. These Linked Sites have separate privacy and data collection practices, and we have no responsibility or liability relating to them.

You expressly understand and agree that by clicking on a link to a Linked Site, you have left our Site and this Privacy Policy, as stated on the Site, is no longer in effect.

Limitation of Liability

IN NO EVENT SHALL WE BE LIABLE FOR ANY DAMAGES OF ANY KIND ARISING OUT OF OR RELATED TO YOUR USE OF ANY LINKED SITES THROUGH THE USE OF OUR SERVICES.

Data Retention

We are a regulated entity in the United States and per the applicable Bank Secrecy Act provisions, we will retain PII that has been obtained as a part of our Customer Identification Program for a period of five (5) years after an account has been closed or became dormant. We may also keep your data for as long as it is needed in relation to a legal claim, complaint, litigation or regulatory proceedings.

Request a Copy of Personal Information

Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. Upon written request, we will also give you a copy of the Personal Information we have retained (Personal Information, however, does not include information derived from Personal Information you provided or other information we may be prohibited by law from giving you). There may be a minimal charge for accessing and copying your Personal Information.

Change of Ownership

In the event of a change in ownership, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to another entity, we reserve the right to transfer all your Personal Information to that entity. We will use reasonable efforts to notify you of a transfer to an unaffiliated third-party (by a posting on our homepage, or by email to your email address that you provided to us, as chosen by us at our discretion).

Special Notice for International Transfers of Personal Information

If you provide us with your Personal Information when using the Services from the European Economic Area (“EEA”), Switzerland, or the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing. When we transfer your Personal Information internationally, we ensure that relevant safeguards are in place to afford adequate protection for your Personal Information and we will comply with applicable data protection laws, by relying on an EU Commission adequacy decision, or the current standard contractual protections for the transfer of your Personal Information or a derogation if one is available.

Special Notice to California Residents

In compliance with California law, we provide California residents with certain information and access upon request (“Consumer Request”). This Privacy Policy outlines how California residents can request certain information and what you can receive.

If you would like to submit a Consumer Request, please feel free to send us an email at legal@BulletATM.com. If you choose to submit a Consumer Request, you must provide us with enough information to identify you and enough specificity on the requested data. Bullet will only use the information it receives to respond to your request. Bullet will not be able to disclose information if it cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf.

• Request to Access. You may submit a Consumer Request to obtain a copy of or access to the personal information that Bullet has collected on you.                                   
• Request to Know. You may submit a Consumer Request to receive information about Bullet’s data collection practices. You may request information on the categories of personal information that Bullet has collected about you; the categories of data collection sources; Bullet’s business or commercial purpose for collecting or selling personal information; the categories of third-parties with whom Bullet shares personal information, if any; and the specific pieces of personal information we have collected about you.

Please note that the categories of personal information and sources will not exceed what is contained in this Policy. Additionally, Bullet is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business.

• Request to Delete. You may request that Bullet delete your personal information. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your personal information from our records and direct any service providers to do the same.

Please note that we may not delete your personal information if it is necessary to:

• complete the transaction for which the personal information was collected;
• provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
• debug and repair internal information technology as necessary;
• undertake internal research for technological development and demonstration;
• exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• comply with the California Electronic Communications Privacy Act;
• engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• comply with an existing legal obligation; or
• otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Bullet may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

Special Notice to Nevada Residents

A special notice to Nevada residents, Bullet does not sell, rent, or lease your PII to third-parties. However, if you are a resident of Nevada and would like to submit a request not to sell your PII, you may do so by emailing us at legal@BulletATM.com.

Contact

To communicate with our Data Protection Office, please email legal@BulletATM.com. Subject to applicable law, you also have the right to lodge a complaint with your local Data Protection Authority.

In the United States, Bullet is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Complaints may be submitted by completing the form that can be found here: www.ftccomplaintassistant.gov.

Changes to this policy

Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at our sole and absolute discretion. If we change this Privacy Policy, we will post the amended Privacy Policy on our website. The revised version will be effective at the time we post it.

Questions about privacy?

If you have questions concerning this Privacy Policy, please feel free to send us an email at legal@BulletATM.com.