Privacy Policy
1. Who we are
1.1 The ALT.VU mobile application and the alt.vu website are published and operated by ATLAS PAY LIMITED, a company incorporated in Hong Kong with Business Registration Number 79950367, whose registered office is at Unit 1603, 16/F, The L. Plaza, 367–375 Queen's Road Central, Sheung Wan, Hong Kong ("we", "us", "our").
1.2 We are the data controller for the personal data described in this Policy. We decide what data is collected and why.
1.3 This Policy covers the ALT.VU application and the alt.vu website. It does not cover a third party's own service that you reach from ours, or a merchant at which you use your Card.
1.4 For any question about this Policy or about your data, write to privacy@alt.vu or to the postal address in section 15.
2. Summary
| What we collect | Identity and contact details, identity document images, a live selfie check, country of residence, payment and transaction records, wallet addresses, and basic technical data about your device |
| Why | To open and operate your account, to issue and operate your card, to verify your identity as the law requires, to keep the service secure, and to answer you when you contact us |
| What we do not collect | Location, contacts, calendar, installed applications, advertising identifiers, browsing history. We run no analytics in the application |
| Where it is stored | On servers in Falkenstein, Germany |
| How long | For the life of your account and for at least six years after it closes. Records we must keep are then de-identified, not erased — section 9 explains why |
| Who else sees it | Our card issuing partner, our identity verification provider, and a small number of named technical providers listed in section 7 |
| We never sell your data | We do not sell personal data, and we do not share it for advertising |
3. What we collect
3.1 Information you give us
| Data | When |
|---|---|
| Email address | Registration and sign-in |
| First name and last name | Registration; also printed as the name on the Card |
| Mobile telephone number | Registration and one-time codes |
| Photograph of an identity document | Identity verification |
| Live selfie with a liveness check (biometric data — see section 5) | Identity verification |
| Country of residence | Identity verification and eligibility |
| PIN code | Securing access to the application. Stored only in a form from which the PIN itself cannot be recovered |
| Blockchain wallet addresses you enter for withdrawals | When you make or save a withdrawal address |
| Profile photograph | Optional, only if you choose to add one |
| The content of your messages to support | When you contact us |
3.2 Information collected automatically
| Data | Why |
|---|---|
| Device model and Android version | Compatibility, diagnosing faults |
| Application version | Support and updates |
| Device language | Showing the interface in your language |
| Firebase push notification token | Sending you notifications about your account |
| Google Play Integrity verdict | Confirming the application is genuine and unmodified, to prevent fraud |
| A device record identifier issued by our server | Recognising your device between sessions and detecting unauthorised access |
3.3 Information generated by your use of the service
Your balance, your transaction history, deposits and withdrawals of stablecoins and the blockchain addresses involved, internal transfers, card transactions passed to us by the Card Issuer, and records of security events such as sign-ins and PIN changes.
3.4 What we do not collect
We do not collect your location, your contacts, your calendar, the list of applications installed on your device, any advertising identifier, or your browsing history. There is no analytics software in the application. The application holds no camera permission: a QR code is read by the operating system's own scanner, and a profile photograph is taken from the operating system's single-photo picker.
4. Why we use your data, and on what basis
| Purpose | Data | Basis |
|---|---|---|
| Creating and operating your account | Identity, contact, device data | Performance of our contract with you |
| Verifying your identity before you can use funded services | Document image, selfie, country, name | Legal obligation, and our legitimate interest in preventing financial crime. The biometric element rests on your explicit consent — section 5 |
| Issuing and operating the Card | Name, telephone number, document data, transactions | Performance of our contract with you |
| Executing deposits, withdrawals and transfers | Wallet addresses, amounts, transaction records | Performance of our contract with you |
| Preventing fraud, money laundering, terrorist financing and sanctions breaches | All of the above | Legal obligation, and our legitimate interest in protecting the service and other users |
| Keeping the service secure | Device data, Play Integrity verdict, security events | Our legitimate interest in security |
| Answering your questions and handling complaints | Your messages, account records | Performance of our contract with you, and our legitimate interest in supporting users |
| Notifying you about your account | Push token, email address | Performance of our contract with you |
| Keeping records after your account closes | Identity and transaction records | Legal obligation, and our legitimate interest in defending claims |
We do not use your personal data for advertising, for profiling with legal effects, or for automated decision-making that produces a legal effect on you, other than automated fraud and sanctions screening, whose results are reviewed by a person before an account is closed.
5. Biometric data
5.1 Identity verification includes a live selfie check. The provider analyses the image to confirm that a living person is present and that the face matches the identity document. That analysis produces biometric data, which is treated as a special category of personal data in many jurisdictions.
5.2 We ask for your separate, explicit consent to this processing on its own screen, before the selfie step. It is not bundled with acceptance of our Terms of Service.
5.3 If you do not consent, we cannot verify your identity and cannot provide the funded services. You may still close your account.
5.4 You may withdraw this consent at any time by writing to privacy@alt.vu. Withdrawal does not affect processing already carried out. Because verification is a condition of the funded services, withdrawing consent will usually mean your account is closed.
5.5 The selfie and the biometric analysis are retained under section 9.
6. Your PIN, your card details and your credentials
6.1 Your PIN is stored only in a form from which the PIN itself cannot be recovered. We cannot tell you your PIN, and neither can our support staff.
6.2 Card details are never written to your device's storage. The card number, expiry date and security code are displayed to you within the application and are not cached.
6.3 If you enable biometric sign-in on your device, the key involved never leaves the secure element of your device. We do not receive your fingerprint or face data from your device.
7. Who we share data with
We share personal data only with the recipients below, only to the extent each needs it, and only for the purposes stated.
| Recipient | What they receive | Their role | Where |
|---|---|---|---|
| Our licensed card issuing partner — a payment institution licensed in Singapore, which issues and operates the Card | Name, telephone number, identity document data, card transaction data | Independent controller for card issuance and card operations, and our recipient for the purposes of providing the Card | Singapore |
| Sumsub (Sum and Substance group) — identity verification | Identity document image, live selfie and biometric analysis, country, name | Processor acting on our instructions | European Union / United Kingdom |
| Prelude — delivery of one-time codes | Mobile telephone number | Processor acting on our instructions | European Union / United States |
| Resend — delivery of transactional email | Email address, message content | Processor acting on our instructions | United States |
| Google LLC — Firebase Cloud Messaging and Google Play Integrity | Push notification token, application integrity verdict | Processor for messaging; independent controller for the integrity service | United States / European Union |
| Telegram — only if you choose to link a Telegram account | Your Telegram identifier | Independent controller | Outside Hong Kong |
| SHKeeper — blockchain payment processing | Blockchain addresses and amounts | Processor acting on our instructions | Outside Hong Kong |
| Hetzner Online GmbH — hosting | All data stored by the service, as hosting provider | Processor acting on our instructions | Germany |
We also disclose personal data:
- to a court, regulator, law enforcement agency or tax authority where we are legally required to, or where it is necessary to establish, exercise or defend a legal claim;
- to our professional advisers, under a duty of confidence; and
- to a buyer or successor if the business is sold or reorganised, under equivalent protection.
We do not sell personal data, and we do not share it with anyone for their own marketing.
8. Where your data is stored, and transfers across borders
8.1 Our servers are operated by Hetzner Online GmbH in Falkenstein, Germany. Your data is therefore stored in the European Union, even though we are a Hong Kong company.
8.2 The recipients listed in section 7 are located in several countries, including Singapore, the United States and countries of the European Union. Providing the service necessarily involves transferring your data to them.
8.3 When we transfer personal data to a recipient outside the territory where it was collected, we do so on the basis of a written contract that requires the recipient to protect it to a standard comparable to the one described in this Policy, to use it only on our instructions where it is our processor, and to return or delete it when the contract ends. Where the transfer involves data originating in the European Economic Area, we use the European Commission's Standard Contractual Clauses.
8.4 You may ask us for more information about a particular transfer by writing to privacy@alt.vu.
9. How long we keep your data
| Data | Retention |
|---|---|
| Identity verification records — document image, selfie, biometric analysis result, verification report | At least six years from the day your account closes, then de-identified |
| Transaction records — deposits, withdrawals, transfers, card transactions | Kept as accounting entries and de-identified when your account closes; not erased |
| Account and contact details | At least six years from the day your account closes, then de-identified |
| Support correspondence | De-identified together with the account record; kept in full while a complaint or a disputed transaction is open |
| Security and access logs | Kept while they are useful for security and for investigating incidents; de-identified with the account record |
| Profile photograph | Deleted when you remove it or when your account closes |
We keep identity and transaction records for at least six years because that is the record-keeping period applied to customer due diligence and transaction records under Hong Kong's Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). We apply it as our standard even where we are not ourselves a financial institution under that Ordinance, because it is the longest period we are likely to be held to and it also covers the period for bringing most civil claims.
We would rather be plain with you than tidy. Six years is a minimum, not an expiry date. Our financial ledger is append-only: an entry, once written, is never removed or rewritten, because a record of money that can be edited is not a record. We therefore do not erase these records when the six years are up. What we do is remove or replace the identifiers that connect an entry to you, so that what survives is an accounting entry rather than information about a person. Section 10.5 explains the limits of that.
If a court order, a regulatory request or an ongoing investigation requires the full record, we keep it in full until that requirement ends.
10. Deleting your account and your data
10.1 You can ask us to delete your account from inside the application: Profile → Settings → Delete account. You can also write to privacy@alt.vu. The process is described in full at https://alt.vu/delete-data/.
10.2 Withdraw your balance before you ask us to delete the account. Deletion does not transfer money to you.
10.3 What is deleted. Your name, your email address, your telephone number, your profile photograph, your link to Telegram, your payment code, your PIN record, your push notification token, your device records, your sessions on every device, and your ability to sign in. Your email address is replaced by a marker at a domain that does not exist, because our database will not hold an account with no way in at all.
10.4 What is retained, and why. We are required to keep records of customer due diligence and of transactions for at least six years after the relationship ends. Accordingly, after deletion we retain:
- the identity verification record;
- the transaction ledger — deposits, withdrawals, transfers and card transactions;
- the withdrawal addresses you sent money to, and the labels you gave them, because a withdrawal without its destination is not a record of anything;
- your correspondence with support, which belongs to the account record; and
- the account record to which all of this is attached.
Everything in this list is de-identified as described in 10.5.
10.5 We de-identify these records rather than erase them. Direct identifiers are removed or replaced so that the records can no longer be read as being about you by someone looking at them. We state plainly that this is de-identification and not irreversible anonymisation: where the law requires us to reconstruct a record for a regulator, a court or an auditor, we may be able to do so. Records that remain re-identifiable remain personal data, and everything in this Policy continues to apply to them, including security and the rights in section 11.
10.6 When the six-year period ends, the retained records are not erased. They remain in our append-only ledger in the de-identified form described in 10.5. We remove or further obscure identifiers wherever we can do so without destroying the accounting record itself.
10.7 Deletion from inside the application takes effect immediately: the account is closed and the data in 10.3 is removed in a single operation when you confirm with your PIN. A request sent to us by email is completed within 30 days of us confirming who you are, and we tell you when it is done. The application will not let you delete an account that still has an active card or a balance you can still withdraw; https://alt.vu/delete-data/ explains what to do in each case.
11. Your rights
11.1 Subject to the law that applies to you, you may:
- ask what we hold about you and receive a copy;
- correct data that is wrong or incomplete;
- ask us to delete data, subject to the retention obligations in sections 9 and 10;
- object to processing we carry out on the basis of legitimate interests;
- ask us to restrict processing while a dispute about accuracy or lawfulness is resolved;
- receive certain data in a portable form, where the law gives you that right;
- withdraw a consent you gave, including the biometric consent in section 5; and
- complain to a data protection authority.
11.2 To exercise a right, write to privacy@alt.vu. We may ask you to confirm your identity first — we will not disclose an account's data to someone who cannot prove it is theirs.
11.3 We answer within 30 days. If a request is complex we may take longer, and we will tell you why before the 30 days are up.
11.4 There is no charge, unless a request is manifestly unfounded or repetitive, in which case we may charge a reasonable fee or decline, and we will explain why.
11.5 If you are in Hong Kong, you may complain to the Office of the Privacy Commissioner for Personal Data (PCPD). If a data protection authority in another territory has jurisdiction over your data, you may complain to that authority instead.
12. Security
We protect your data with, among other measures:
- transport encryption only — plain HTTP is disabled at build level, so the application cannot send data unencrypted;
- certificate pinning against two public-key fingerprints, so a substituted certificate is rejected;
- encryption of tokens and cached data on your device with a key held in the Android hardware-backed keystore;
- biometric sign-in keys that never leave the device's secure element;
- application backup disabled, so your application data is not copied into a cloud backup;
- card details never written to device storage;
- access to production systems limited to named staff, with individual credentials; and
- logging of access to personal data.
No system is perfectly secure. If a breach occurs that is likely to cause you serious harm, we will notify you and the relevant authority without undue delay.
13. Children
The service is for adults. You must be 18 or over. We do not knowingly collect personal data from anyone under 18, and the application is not directed at children. If we discover that we hold data about a person under 18, we delete it and close the account. If you believe a child has given us data, write to privacy@alt.vu.
14. Cookies and the website
The alt.vu website is a static site. It sets no analytics cookies, no advertising cookies and no tracking pixels, and it does not profile visitors. A small number of strictly necessary cookies may be used to keep the site working and secure. Because we set no cookies that require consent, the site shows no cookie banner. If that changes, we will update this Policy and ask for consent before setting any non-essential cookie.
15. Changes to this Policy, and how to contact us
15.1 We may update this Policy. The version in force is always at https://alt.vu/legal/privacy/, with its version number and dates at the top.
15.2 Where a change materially affects how we use your data, we will tell you by email and in the application at least 30 days before it takes effect.
15.3 Contact:
ATLAS PAY LIMITED Unit 1603, 16/F, The L. Plaza, 367–375 Queen's Road Central, Sheung Wan, Hong Kong Business Registration Number 79950367 Privacy enquiries and data rights requests: privacy@alt.vu Other legal matters: legal@alt.vu