loading

Updated: 06 Oct 2025

This Privacy Policy explains how Silvo ("Silvo", "we", "us", "our") collects, uses, discloses, and protects personal data when you use our mobile application and related services (together, the "App" and the "Services"). It complements the Silvo Terms and Conditions.

 

  1. Who we are & how to contact us

Data Controller: Silvo, Waliców 11, 00‑851 Warszawa, Poland
Email: info@silvo.com

 

  1. Scope

This Policy applies when you:

  • use the App and create/manage your Account;
  • submit a Proposal and enter into contracts with Silvo (including the Framework Agreement);
  • use the Customer Panel and other features of the App; and
  • access Silvo Services via a Partner application.

If you access Silvo Services via a Partner's mobile application, that Partner administers its own app and processes personal data under its privacy policy. Silvo remains an independent controller for data it processes to provide its own Services.

 

  1. Personal data we process

We process the following categories of personal data (as applicable):

  • Identification data: name, surname, date of birth, nationality, and basic identity details you provide during onboarding.
  • Contact data: email address, phone number, correspondence/physical address.
  • Account & security data: login (email), password, PIN, authentication settings, account states (e.g., blocked/unblocked), login attempts, session tokens.
  • Payment & transaction data: account identifiers maintained by Silvo, card tokens (masked or tokenised), transaction amounts, currency, merchant descriptors, statuses, top‑up and payout details where available in the Customer Panel.
  • Technical data (telemetry): device model and OS, device and session identifiers, IP address, logs, crash reports and diagnostic information.
  • Communications & documents: support requests, complaints, attachments, and documents shared with us.
  • Preferences & marketing: in‑App preferences, consents/withdrawals, message delivery and open metrics.

Sources: data you provide directly in the App; data generated by your use of the Services; and, where relevant, information from payment networks/processors and Partners that integrate with Silvo to deliver features you choose to use.


  1. 4. Sharing your data

We share personal data only as needed and with appropriate safeguards:

  • Service providers (processors): hosting, IT support, customer support tooling, payment processing, anti‑abuse/security, communications, and analytics — under data processing agreements.
  • Payment networks and financial institutions: to execute and settle transactions.
  • Partners: when you choose to use their services through the App; your relationship with a Partner is governed by that Partner’s terms/policies.
  • Public authorities/regulators: where we are legally required to do so.
  • Successors: in the context of a merger, acquisition, or reorganisation, in accordance with data protection law.

 

  1. 5. Retention

We keep personal data only for as long as necessary for the purposes described above or as required by law. Typical retention periods include:

  • contract and account records — for the duration of your relationship with us plus the applicable limitation period;
  • payment and transaction records — for the period required by financial and tax laws;
  • security and diagnostic logs — typically up to 24 months unless a longer period is necessary for security or compliance;
  • marketing preferences and logs — until consent is withdrawn or you object, or as required by e‑communications laws.

 

  1. 6. Your rights

Subject to applicable law, you have the right to:

  • access your personal data and obtain a copy;
  • rectify inaccurate or incomplete data;
  • erase data in the circumstances provided by law;
  • restrict processing;
  • data portability for data processed by automated means on the basis of consent or contract;
  • object to processing based on our legitimate interests, including direct marketing;
  • withdraw consent at any time.

 

  1. 7. Automated decision‑making

We do not take decisions producing legal effects concerning you solely by automated means. Limited profiling may be used for security and service personalisation that does not produce such effects and is subject to appropriate safeguards.


  1. 8. Security

We apply appropriate technical and organisational measures, including encryption in transit and at rest where applicable, strict access controls, multi‑factor authentication, network segmentation, logging/monitoring, and regular testing/audits. If we become aware of a personal data breach, we will notify the competent authority and affected users where required by law.

  1. 9. Cookies, SDKs and mobile telemetry

The App may use SDKs and similar technologies necessary for core functionality (authentication, stability, performance). Marketing/analytics SDKs are used only where permitted by law and, where required, with your consent. You can manage permissions in your device and App settings.

 

  1. 10. Children’s privacy

The Services are intended for individuals with full legal capacity. We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us so we can take appropriate action.

 

  1. 11. Changes to this Policy

We may update this Policy to reflect legal, technical, or business developments. Where required, we will provide advance notice (e.g., 30 days) on a durable medium and make the updated Policy available in the App. If you do not accept the changes, you may stop using the Services and/or terminate agreements as set out in the Terms and Conditions.