This notice was updated on 23.09.2025.
The platformwww.digitap.app is operated and managed by RMATM EUROPE LIMITED (“DIGITAP”). Whilewww.digitap.app functions as a technology integrator specializing in financial technology solutions, the financial services available through the platform are provided by Joint Development Bank (JDB), a licensed financial institution based in Lao PDR.
What is this document about?
We’re committed to protecting and respecting your privacy. We will:
- always keep your personal data safe and private
- never sell your personal data
- allow you to manage and review your marketing choices at any time
1. About us
The DIGITAP company providing you with a product or service will be responsible for processing your personal data for that product or service. This DIGITAP company is known as the ‘controller’ of your personal data.
2. Why do I need to read this notice?
We collect your personal data when you use:
- our website atwww.digitap.app
- the DIGITAP app
- any of the services available to you through the DIGITAP app or website When we say ‘personal data’, we mean information which:
- we know about you (for example, we know when you use your DIGITAP card to pay for things)
- can be used to personally identify you (for example, a combination of your name and postal address)
This notice explains what information we collect, how we use it, and your rights over your personal data.
Sometimes, we may also provide you with ‘just in time’ privacy explanations in the DIGITAP app. When you use a new DIGITAP product or service for the first time:
- these explanations will help you to understand what specific personal data DIGITAP collects, uses or shares about you for that product or service
- where relevant, you will be prompted to review your in-app privacy preferences
We may provide privacy notices and explanations in languages other than English. If there are any discrepancies between other language versions and the English language version, the English language version is authoritative.
If you have concerns about how we use your personal data, you can contact us at using the designated channels mentioned on www.digitap.app.
3. What personal data do you collect about me?
The table below explains what personal data we collect and use.
| Type of personal data | Details |
|---|---|
| Information you give us | We collect information you provide when you:
We will collect the following information:
If you give us personal data about other people (such as a joint account holder, your spouse or family), or you ask us to share their personal data with third parties, you confirm that you have brought this notice to their attention beforehand. |
| Information collected from your use of our products and services | Whenever you use our website or the DIGITAP app, we collect the following information:
|
| Information about your location | If you turn location services on in the DIGITAP app, we may track your location using GPS technology. |
| Information from social media | Occasionally, we’ll use publicly available information about you from selected social media websites or apps to carry out enhanced due diligence checks. |
4. What is your legal basis for using my personal data?
We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis will be one of the following:
- Keeping to our contracts and agreements with you We need certain personal data to provide our services and cannot provide them without this personal data.
- Legitimate interests We sometimes collect and use your personal data because we have a legitimate reason to use it and this is reasonable when balanced against your human rights and freedoms.
- Substantial public interest Where we process your personal data, or your sensitive personal data (sometimes known as special category personal data), to adhere to government regulations or guidance, such as our obligation to prevent fraud or support you if you are or become a vulnerable customer.
- Consent Where you've agreed to us collecting your personal data, or sensitive personal data, for example when you tick a box to indicate you’re happy for us to use your personal data in a certain way.
5. How do you use my personal data?
Explore the ways in which we may use your personal data using this table:
| What we use your personal data for | Our legal basis for using your personal data |
|---|---|
Providing our services Whenever you apply for or use a DIGITAP product or service, we’ll use your personal data to:
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Protecting against fraud We use your personal data to check your address and identity, protect against fraud, keep to financial crime laws and to confirm that you’re eligible to use our services. We also use it to help us better understand your financial circumstances and manage fraud risks related to your DIGITAP account. |
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Marketing and providing products and services that might interest you We use your personal data to do the following:
Remember, you can ask us to stop sending you marketing information by adjusting your marketing choices section below explains how to do this). |
|
To keep our services up and running We use your personal data to manage our website and the DIGITAP app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content is presented in the most effective way for you and your device. We also use your personal data to:
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Helping with social interactions We use your personal data to help with social interactions through our services, or to add extra functions in order to provide a better experience. For example, if you give us permission, we'll use the contacts list on your phone so you can easily make payments to, or message, your contacts using the DIGITAP app. |
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Providing location-based services If you turn location services on in the DIGITAP app, we use your personal data to:
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Preparing anonymous statistical datasets We prepare anonymous statistical datasets about our customers’ spending patterns:
These datasets may be shared internally or externally with others, including non-DIGITAP companies. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual. For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country. We’ll provide anonymised statistical information that explains the broad categories of merchants that DIGITAP customers in that country spend their money with. We’ll also provide information about how DIGITAP customers top up their accounts and transfer money. However, we won’t provide any customer-level information. It will not be possible to identify any individual DIGITAP customer. |
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Improving our products and services We use your personal data to help us develop and improve our current products and services. For example, we may include you in a focus group to test and develop new products because we think you will be interested based on how you spend or use other DIGITAP products. This allows us to continue to provide products and services that our customers want to use. | Legitimate interests (to understand how customers use our products so we can develop new products and improve the products we currently provide) |
6. How do you use my personal data for marketing?
If you sign up to our services, and where national laws allow, we’ll assume you want to be contacted by post, push notification, email and text message with information about DIGITAP products, services, offers and promotions. Where national laws require us to get your consent to send marketing messages, we’ll do so in advance.
We use your personal data to personalise marketing messages about our products and services so they are more relevant and interesting to you (where allowed by law). This may include analysing how you use our services and your transactions.
You can object to profiling for direct marketing purposes. You can also adjust your preferences or tell us you don't want to receive direct marketing at any time. Just use the privacy settings in the DIGITAP app or tap the unsubscribe links in any marketing message we send you.
If you do not want to receive personalised marketing messages, and opt out from receiving them, you will not receive any marketing communications. However, you may still receive generic information about our products and services in the DIGITAP app.
We won't pass your details on to any organisations outside the DIGITAP group of companies for their marketing purposes without your permission.
Our legal basis is:
- consent (where we are required by law to collect your consent)
- legitimate interests (to send you marketing and to provide information relevant to your interests)
7. What are my rights?
| Your right | What it means |
|---|---|
You have the right to be told how we use your personal data | We provide this privacy notice to explain how we use your personal data. |
You have the right to ask us for a copy of your personal data | If you ask, we’ll provide a copy of the personal data we hold about you. We can’t give you any personal data about other people, personal data which is linked to an ongoing criminal or fraud investigation, or personal data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers. |
You can ask us to correct your personal data if you think it's wrong | You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided. |
You can ask us to delete your personal data | You can ask us to delete your personal data if:
Just to let you know, we may not be able to agree to your request. As a regulated financial services provider, we must keep certain customer personal data even when you ask us to delete it (we've explained this in more detail below). If you've closed your DIGITAP account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We’ll always let you know if we can't delete your personal data. |
You can object to us processing your personal data for marketing purposes | You can tell us to stop using your personal data, including profiling you, for marketing. |
You can object to us processing other personal data (if we’re using it for legitimate interests) | If our legal basis for using your personal data is 'legitimate interests' and you disagree with us using it, you can object. |
You can ask us to restrict how we use your personal data | You can ask us to suspend using your personal data if:
|
You can ask us to transfer personal data to you or another company | If we can, and are allowed to do so under regulatory requirements, we’ll provide your personal data in a structured, commonly used, machine-readable format. |
You can withdraw your permission | If you’ve given us the consent we need to use your personal data, you can withdraw it at any time by changing your privacy settings in the DIGITAP app or sending an email at the contact information found onwww.digitap.app (Please note, it will have been lawful for us to use the personal data up to the point you withdraw your permission.) |
You can ask us to carry out a human review of an automated decision we make about you | If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision. |
Your ability to exercise these rights will depend on a number of factors. Sometimes, we won’t be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).
8. How do I exercise my rights?
For security reasons, we can't deal with your request if we’re not sure of your identity, so we may ask you for proof of ID.
When you exercise one of your rights, or update your privacy settings in the DIGITAP app, it may take us up to one month to respond or implement your changes.
DIGITAP will usually not charge you a fee when you exercise your rights. However, we’re allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.
9. Do you share my personal data with anyone else?
DIGITAP group companies
We share your personal data within the DIGITAP group of companies to:
- provide you with the best service
- protect you, other customers and our systems from fraud or harmful behaviour
- facilitate you quickly signing up to use other DIGITAP products or services
- improve existing, or develop new, products or services
- send you information about DIGITAP products and services we think you’ll be interested in hearing about
DIGITAP group companies
We’ll ask you to let us sync your mobile phone contacts. This will help you to identify which of your trusted mobile phone contacts are DIGITAP customers. Your ‘trusted contacts’ will also be able to see if you’re a DIGITAP customer through our in-app discoverability settings.
We use technological safeguards to ensure a ‘trusted contact’ is somebody you already know and who knows you (for example, you have each other saved in each other’s mobile phone contacts lists or have already received or given money through a peer-to-peer payment with them).
Both you and your trusted contact must have synced your mobile phone contacts lists with DIGITAP to be viewable to each other in the DIGITAP app.
If you have synced your mobile phone contacts, we show basic details about you in the DIGITAP app to your trusted contacts who are also DIGITAP customers (for example, your name (as saved in your friend’s contacts list), mobile phone number, UserID, DIGITAP membership plan, and DIGITAP profile photo (if you have one)).
You can, of course, choose not to sync your contacts list with DIGITAP. This means that you won’t be able to identify which of your mobile phone contacts are DIGITAP customers.
You can also change your discoverability preferences through the privacy settings in the DIGITAP app.
Other DIGITAP customers will be able to search for you through the DIGITAP app using your UserID.
When they input your UserID, they will be able to see your name and profile photo (if you have one). You can turn off being discoverable by your UserID through the privacy settings in the DIGITAP app.
People or companies that you transfer money to
Where you make a payment from your DIGITAP account, we’ll provide the recipient with your details alongside your payment (for example, your name and IBAN). This is because, like all payment institutions, we’re required by law to include certain information with payments.
People or companies that transfer money to you
When you receive a payment to your DIGITAP account, we’ll provide the payer with your details (for example, your name and IBAN). This is necessary to confirm that the payment has been made to the correct account.
Suppliers
The table below explains which suppliers we normally share your personal data with:
| Type of supplier | Why we share your personal data |
|---|---|
Suppliers who provide us with IT, payment and delivery services | To help us provide our services to you |
Our banking and financial services partners and payments networks, including Visa and Mastercard | To help us provide our services to you. This includes banking and lending partners, banking intermediaries and international payment service providers |
Identity verification and KYC service providers | To help us verify your identity so we can provide our services to you |
Card manufacturing, personalisation and delivery companies | To create and deliver your personalised DIGITAP card |
Analytics providers and search information providers | To help us improve our website or app |
Customer-service providers, survey providers and developers | To help us provide our services to you |
Communications services providers | To help us send you emails, push notifications and text messages |
Debt collection agencies | To manage and recover debts that you owe or may end up owing (including if you have a DIGITAP credit product) |
Partners who help to provide our services
We may share your personal data with our partners to:
- provide certain services you’ve asked us for (for example, when we offer insurance as part of our membership plans)
From time to time, we may work with other partners to offer you co-branded services or promotional offers, and we’ll share some of your personal data with those partners. We will always make sure you understand how we and our partners process your personal data for these purposes.
Joint account holders
If you have a joint account with us, we will share account and transaction information between joint account holders. For example, your co-account holder will see any transactions you make from your joint account.
Other third parties
We may share your personal data with other third parties where necessary to facilitate you receiving payments to your DIGITAP account.
If fraud is detected, you could be refused certain services by DIGITAP or other companies.
Social media and advertising companies
When we use social media for marketing purposes, your personal data (limited to only your name, email address and app events) may be shared with the social media platforms so that they can check if you also hold an account with them. If you do, we may ask the advertising partner or social media provider to:
- use your personal data to send our adverts to you, because we think that you might be interested in a new DIGITAP product or service
- not send you our adverts, because the marketing relates to a service that you already use
- send our adverts to people who have a similar profile to you (for example, if one of our services is particularly useful to people with similar interests to the ones on your social media profile, we may ask our advertising partner or social media partner to send our adverts for that service to those people)
We may share your personal data with our advertising partners in the ways described above, but the personal data is hashed before we send it, and the advertising partner we share it with is only allowed to use that hashed personal data in the ways described above.
Our legal basis is:
- legitimate interests (to ensure DIGITAP’s advertising is as effective as possible)
You can contact us at any time, either through the DIGITAP app or by emailing at the contact information found on www.digitap.app if you don’t want us to share your personal data for advertising purposes. You can also use the privacy settings in the DIGITAP app to opt out from having your personal data shared in this way.
Remember you can also manage your marketing preferences directly with any social media provider that you have an account with.
Where you ask us to share your personal data
Where you direct us to share your personal data with a third party, we may do so. For example, you may authorise third parties to act on your behalf (such as a lawyer, accountant or family member or guardian under a power of attorney). We may need to ask for proof that a third party has been validly authorised to act on your behalf.
10. How do you protect my personal data?
We recognise the importance of protecting and managing your personal data. Any personal data we process will be treated with the utmost care and security. This section sets out some of the security measures we have in place.
We use a variety of organisational and technical measures to:
- maintain the confidentiality, availability and integrity of your personal data
- make sure your personal data is not improperly used or disclosed
We have detailed information security and data protection policies which our employees are required to follow when they handle your personal data. Our employees receive data protection and information security training. Personal data is stored on secure computer systems with access management controls in place to limit physical, system and information access to only authorised employees.
DIGITAP has strict policies in place that control how we share your personal data with other companies. Before sharing personal data with any company, we thoroughly:
- vet the company in advance
- assess the security controls the company has in place to protect your personal data
While we take all reasonable steps to ensure that your personal data will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to our app, our website or other services we may provide. We use HTTPS (HTTP Secure), where the communication protocol is encrypted through Transport Layer Security for secure communication over networks, for all our app, web and payment-processing services.
If you use a password, PIN or generated authorisation code or prompt to use the DIGITAP app, our website or other services, you will need to keep it confidential. Please do not share it with anyone. DIGITAP will never ask you for this credential.
When you use our public services, which includes our social network accounts and the DIGITAP Community forum, do not share any personal data that you don't want to be seen, collected or used by other customers, as this personal data will become publicly available.
11. How long will you keep my personal data for?
We will keep your personal data:
- for as long as necessary to achieve the original purpose we collected it for
- in line with relevant laws
We may keep your personal data for a longer time period because of a potential or ongoing court claim, or for another legal reason.
12. How will you keep me updated about how you use my personal data?
If we change the way we use your personal data, we’ll update this notice and, if appropriate, let you know by email, through the DIGITAP app or through our website.
13. How do I contact the DigiTap privacy team?
If you have questions, feedback, or concerns about how we handle your data, contact our Privacy Team: privacy@digitap.app
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