Privacy Policy

Our Privacy-First Architecture

Saldo.tech is a card-linked offers marketplace that connects merchants with financial institutions. Our platform is architected around a core principle: Saldo.tech operates on tokenized identifiers only. We do not store, process, or have access to cardholder personally identifiable information (PII).

What We Store

For each cardholder interaction, Saldo.tech stores only the following data:

• cardholder_token — An opaque identifier generated by the financial institution (e.g., HMAC of institution_id + internal customer ID). This token cannot be reversed to identify a real person without the institution's secret key.
• card_token — A tokenized representation of the payment card, generated by the financial institution. This is never a real card number or PAN.
• institution_id — Identifies which financial institution the cardholder belongs to.
• Offer interaction data — Timestamps for when offers were added, redeemed, or expired.
• Transaction match records — Purchase amount, timestamp, and merchant identifier for matched transactions.

What We Never Store

Saldo.tech does not collect, store, or process any of the following:

• Legal names or display names
• Email addresses
• Physical or mailing addresses
• Full card numbers (PANs) or real card data
• Government identifiers (SSN, CURP, RFC, or equivalent)
• Dates of birth
• Phone numbers
• IP addresses tied to cardholder identity

How Tokenization Works

Each financial institution generates its own tokens for cardholder identity and card data. The token generation process uses cryptographic methods (such as HMAC) with keys that only the financial institution controls. Saldo.tech receives these tokens but has no ability to reverse them back to real identities or card numbers.

The mapping between tokens and real customer identity lives exclusively within the financial institution's own systems. Each institution signs a data processing addendum confirming that token generation and PII retention stays within their infrastructure.

Multi-Tenancy and Data Isolation

Every financial institution's data is isolated at the database level using Row-Level Security (RLS) policies. One institution's cardholder data is never accessible to another institution. Merchant data is shared across institutions (as merchants create offers visible to all), but all performance and redemption data is scoped to the specific institution.

Regulatory Compliance

Because Saldo.tech does not store or process cardholder PII, our compliance posture is fundamentally different from platforms that handle personal data:

• GDPR (EU/EEA) — Saldo.tech is not a data processor for cardholder personal data under GDPR, as we do not receive identifiable personal data.
• CCPA (California) — Saldo.tech does not collect personal information as defined under CCPA from cardholders.
• LFPDPPP (Mexico) — Saldo.tech does not process datos personales of cardholders under Mexican data protection law.
• PCI DSS — Because Saldo.tech never touches real card numbers or PANs, our PCI DSS scope is minimized. All card data is tokenized before it reaches our platform.

Merchant Data

Merchants who use Saldo.tech provide business information (company name, business address, contact email) through the merchant portal. This data is used to manage merchant accounts, process offer campaigns, and handle billing via Stripe Connect. Merchant data is handled in accordance with our Terms of Service.

Institution Data

Financial institutions provide business and technical information (institution name, API configuration, contact details) through the institution portal. This data is used to manage the institution's CLO program, process settlements, and facilitate communication.

Website Visitors

This marketing website may use standard analytics tools to understand traffic patterns. No analytics data is linked to cardholder tokens or financial institution transaction data.

Contact

For privacy-related inquiries, contact us at privacy@saldo.tech.