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Privacy Policy

1. Who we are

This Privacy Policy explains how Borderli PTE. LTD. (UEN 202629455K), together with Borderli SRL (CUIT 30-71956943-5) (collectively, “Borderli”, “we”, “us”), collects, uses, discloses and protects personal data in connection with our website https://borderli.io and our business-to-business payment-orchestration services (the “Services”).

Borderli provides neutral payment-orchestration technology. We route payment data and instructions between our business clients and licensed payment partners. We do not hold client or end-user funds, do not operate payment accounts, and do not settle or execute payments ourselves; those functions are performed by licensed, regulated partners. As a result, for most end-user payment data we act as a data processor on behalf of our business clients and partners, and as a data controller only for the limited data we collect directly.

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2. Scope

This Policy covers:

  • Visitors to https://borderli.io.

  • Representatives of our business clients, partners and prospects (“business contacts”).

  • Personal data contained in payment instructions that we process on behalf of clients and partners (“payment data”), to the limited extent described below.

It does not cover the independent privacy practices of the wallets, merchants, PSPs, banks or licensed partners you interact with; please consult their policies.

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3. Personal data we collect

From website visitors: IP address, device and browser type, pages viewed, referring URLs, and cookie or analytics identifiers.

From business contacts: name, business email, phone, company, role, and the content of your communications with us.

Payment data processed on behalf of clients and partners: transaction technical data needed to decode and route a payment, such as scheme, country, amount, currency, a merchant or creditor identifier, FX quote reference, and transaction timestamps and status. Borderli is designed to minimize personal data in this flow and does not require end-user government IDs, card PANs, or account credentials to perform its orchestration function.

We do not knowingly collect special categories of data, and our Services are not directed to children.

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4. Our role: controller vs processor

  • Controller: for website-visitor data and business-contact data, Borderli determines the purposes and means and is the controller.

  • Processor: for payment data processed to deliver the Services, Borderli acts as a processor (or sub-processor) on documented instructions from the relevant business client or licensed partner, who is the controller.

5. How we use personal data and legal bases

Under Singapore's PDPA, we rely on consent (express or deemed) and the exceptions permitted by the Act, including the legitimate-interests and business-contact-information provisions. Under Argentine data protection law and the EU/UK GDPR (where it applies), we rely on the bases above.

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6. Disclosure of personal data

We disclose personal data to: licensed payment partners, acquirers, rails and PSPs necessary to route and settle a transaction; our business clients whose end-users or transactions the data relates to; service providers and sub-processors (cloud hosting, analytics, KYC/AML tooling, security, support), bound by confidentiality and data-protection terms; authorities, regulators or legal advisers where required by law; and a successor in a merger or reorganization, subject to this Policy. We do not sell personal data.

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7. International transfers

Borderli operates across Singapore, Argentina and works with partners globally, so personal data may be transferred across borders. Where we transfer personal data internationally, we use appropriate safeguards, such as the EU Standard Contractual Clauses, comparable-protection or consent mechanisms under the PDPA, and the transfer mechanisms recognized under Argentine law.

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8. Retention

We keep personal data only as long as necessary for the purposes above, for the duration of the client or partner relationship, and as required to meet legal, regulatory, tax and audit obligations, after which it is deleted or anonymized. Payment data processed as a processor is retained per the controller's instructions.

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9. Security

We maintain administrative, technical and organizational measures appropriate to the risk, including encryption in transit, least-privilege access controls, network and application security, logging, and vendor due diligence. No method of transmission or storage is completely secure, but we work to protect your data and respond promptly to any incident.

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10. Your rights

Depending on where you are and the applicable law, you may have the right to access, correct, update, delete, port, restrict or object to the processing of your personal data, and to withdraw consent. Under the PDPA you may request access to and correction of your personal data and withdraw consent. Under the GDPR and Argentine law you have the corresponding data-subject rights and the right to lodge a complaint with your supervisory authority (in Argentina, the Agencia de Acceso a la Información Pública).

For data we process as a processor on behalf of a client or partner, please direct your request to that controller; we will support them in responding. To exercise rights for data we control, contact us at borderli@borderli.io.

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11. Cookies

Our website uses cookies and similar technologies as described in our Cookie Policy.

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12. Third-party links

Our website may link to third-party sites and services that we do not control. This Policy does not apply to them.

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13. Changes

We may update this Policy from time to time. We will post the updated version here and revise the “Last updated” date; material changes will be highlighted where appropriate.

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14. Contact

Questions or requests: borderli@borderli.io.

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