Privacy policy for processing of personal data in relation to the use of the form “Let‘s talk Fintech” published at

This privacy notice is intended to provide you with information, in relation to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), about what personal data is processed by phyre during your use of the form Let’s talk Fintech, published at

“phyre/We/Us” means “phyre JSC” - company registered in Republic of Bulgaria with UIN No. 203617076, with seat and management address: 76A James Baucher Blvd., ground floor, Lozenetz area, Sofia, registered as an agent of Paynetics in the register under Art. 19 of the Bulgarian “Law on Payment Services and Payment Systems”, kept by the Bulgarian National Bank. phyre is a provider of technical services supporting the provision of payment services by Paynetics, in relation to the Services, without assuming possession of the funds which should be transferred, including through processing and storage of data, the authenticity of the data and the object, the information technologies and the communication network, procurement, provision and maintenance of terminals and devices used for payment services. Regarding the use of the form Let’s talk Fintech, phyre processes personal data as an administrator of personal data;

“Paynetics” means "Paynetics AD" – company registered in Republic of Bulgaria with UIN No. 131574695 with seat and management address: 76A James Baucher Blvd., ground floor, Lozenetz area, Sofia. Paynetics AD is a company for e-money, holder of a license for performing activity as e-money company, issued by the Governing board of Bulgarian National bank with Decision № 44 from  11.04.2016 г. and is entered into the register kept by Bulgarian National bank which may be found here. Bulgarian National bank performs supervision on the activity of Paynetics. Paynetics provides the payments services in relation to the Services;

“Merchant/You” means sole proprietor and/or legal entity, which uses the form Let's talk Fintech;

“Services” means white-label solution for embed financial services and/or digital banking app, technically developed by phyre, which provides access to the payment services of Paynetics;

“” means online website at on which the form Let’s talk Fintech is published, and through which phyre advertises the Services;

“Let‘s talk Fintech” means a contact form published at, which gives you the ability to make a contact with phyre by sending a message. To send a message, you must (obligatory) enter the following data: Name, Email, Company name, and optionally enter a data, which is part of the content of the message.

“Privacy Policy” means this document, governing the conditions and the way in which your personal data is processed when you use the form Let's talk Fintech. You accept this Privacy Policy before you send a message through the form Let's talk Fintech.

“Commercial communications” means commercial communications by the meaning of Art. 5, Par. 1 from the Bulgarian “Electronic Commerce Act”.

This policy is an important document. We recommend you to read it carefully, print it, and keep a copy for a reference.

“Cookie” is a file containing identifier (a sequence of letters and digits) which is sent by a web server to a web browser and is stored by the browser. The identifier is sent back to the server any time when the browser loads a page from the server. "Cookies" may be "permanent" cookies or "session": the permanent cookies will be stored by a web browser and will remain valid until the defined expiration date, unless they are not deleted by the user before the expiration date; on the other hand, a session-cookie, will expire at the end of user's session, when the web browser is closed.

How can you contact us?

If you have questions about how we collect, store and use your personal information or want a copy of the information which we hold about you, please contact us by:

Write to us at the following address: 76A James Baucher Blvd., ground floor, Lozenetz area, Sofia, Bulgaria; or send us an email at:

Through the form Let’s talk Fintech, you can contact phyre with the purpose to exchange information in connection with the Services.

In order to ensure the fulfillment of the above purpose, phyre processes personal data of natural persons - sole proprietors, and / or representatives of legal entities - Merchants, only for communication with the following purposes:

- commercial communications for direct marketing, in relation to the Services;

- entering into pre-contractual and/or contractual relations.

What personal data we process?

-Name and Email which you enter into the form Let’s talk Fintech;

-Other voluntarily provided personal data, part of the content of the message that you send us through the form Let’s talk Fintech.

phyre processes this personal data in order to enter into a pre-contractual relationship with you, enter into a contractual relationship with you and / or send commercial communications for direct marketing in relation to the Services, as well as to comply with legal requirements established by the applicable EU and Bulgarian law.

The Period for which the personal data are processed for these purposes is up to 5 / five / years, starting from the year following the year in which the legal relationship between you and phyre is terminated.

Your rights in relation to the personal data processed in accordance with this Privacy Policy:

Any subjects whose personal data are processed in accordance with this Policy are entitled to:

- object to the processing of their personal data;

- to be informed what types of personal data is being processed by phyre;

- right of access and a copy of their personal data that is being processed by phyre;

- right to correct and delete their personal data;

- the right to restrict the processing; and

- the right to data portability.

You can exercise any of your rights, described above, by submitting a written application in any of the following ways:

- by email to:

- by letter addressed to: 76A James Baucher Blvd., ground floor, Lozenetz area, Sofia, Bulgaria.

You also have the right to file a complaint in relation to the processing of your personal data before the supervisory body, which for the Republic of Bulgaria is the Commission for Personal Data Protection.

Please note that your application for the exercise of any of your rights must include at least your name and other identifying information, a description of your request, the preferred means of communication with you, an address for correspondence, a signature and the date of the application.

If the application is signed by a proxy, you must attach the relevant power of attorney.

phyre may contact you for further information if your identity needs to be verified or your application further clarified.

If we receive personal data that is excessive for our needs to achieve the above purposes, we will delete this information immediately, but no later than 1 month after receiving it.


To protect your personal information, we have implemented measures for physical, personal, technical and administrative protection. We regularly update and test our security technologies. We restrict the access to your personal data only to those employees and processors who must have this information in order to provide you with benefits, goods and services. In addition, we educate our employees about the importance of maintaining the confidentiality and security of your information. We are committed to take the necessary disciplinary measures to enforce the confidentiality obligations of our employees.


We use Google Analytics, in order to analyze the use of Google Analytics collects information about the use of websites through "cookies". The Privacy declaration of Google may be accessed at this address.


This Privacy Policy is subject to change and modification. We will promptly notify you about any changes, where the latest version can be found published here.

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