Privacy Policy
E-Money & IBAN Services
PRIVACY POLICY OF UAB PILSENGA
This privacy policy establishes basic principles for personal data processing by UAB PILSENGA registration code 305930213.
Respective Policy applies if a customer uses, has used or intends to use financial services provided by UAB PILSENGA, including the relationship with the customer is established before this policy comes into force.
This privacy policy will be updated at least once a year to make sure it reflects our current data processing activities.
- FOR THE APPLICATION OF THIS POLICY, THE FOLLOWING DEFINITIONS ARE USED:
1.1. Customer – A private person who uses, has used or intends to use financial services provided by UAB PILSENGA.
1.2. Personal data – means all information relating to an identified or identifiable Customer.
1.3. Processing – All activities performed with Personal Data (including collection, recording, storage, modification, granting of access to, requests, transmission, etc.).
1.4. UAB PILSENGA – a Lithuanian limited liability Company registered office at Vilnius, Mėsinių g. 5, Lithuania LT-01133.
- GENERAL PROVISIONS
2.1 This policy describes general principles for how UAB PILSENGA processes personal data. Specific details about the processing of personal data may also be included in agreements concluded or entered into between the customer and UAB PILSENGA and reflected on the website www.pilsenga.com;
2.2. UAB PILSENGA guarantees, within the framework of applicable law, the confidentiality of personal data and has implemented appropriate technical and organizational measures to protect personal data from unauthorized access, illegal processing or disclosure, accidental loss, alteration or destruction.
2.3. UAB PILSENGA can use authorized processors for personal data. In such cases, UAB PILSENGA takes the necessary measures to ensure that such data processors process personal data according to the instructions from UAB PILSENGA and in accordance with current legislation and requires appropriate security measures.
- CATEGORIES OF PERSONAL DATA
3.1. Personal data may be obtained from the customer, from the customer’s use of financial services and from external sources, such as public and private records or other third parties.
3.2. The data categories of personal data that UAB PILSENGA primarily, but not exclusively, collects and processes are the following:
3.2.1. Identification data, e.g. name and personal identification code;
3.2.2. Contact information such as telephone number, e-mail address or application form for special products residential address;
3.2.3. Financial data such as income and liabilities;
3.2.4. Data that enables UAB PILSENGA to carry out its known – measures regarding money laundering and the prevention of terrorist financing and to ensure that international sanctions are followed, including business-related purposes and if the Customer is a political person;
3.2.6. Information about the customer’s tax residence permit, e.g. information about country of residence, tax identification number, citizenship;
3.2.7. Marketing and Communication data – collected when the customer communicates with UAB PILSENGA via telephone, e-mail or application form.
- PURPOSE AND BASIS FOR PROCESSING PERSONAL DATA
UAB PILSENGA processes personal data mainly to:
4.1. Manage customer relations in general and give administration access to the financial services offered by UAB PILSENGA.
4.2. To protect the interests of the customer and/or UAB PILSENGA and to investigate the quality of the services provided by UAB PILSENGA and to provide evidence of a commercial transaction or to take action on Customer’s request before agreement or compliance with legal obligation or consent from Customer or UAB PILSENGA legitimate interests to prevent, limit and investigate incorrect use or improper use or disruption of UAB PILSENGA financial services or quality assurance of services.
4.3. Conduct customer surveys, market analyzes and statistics; organize lotteries and campaigns for customers based on UAB PILSENGA legitimate interest to improve UAB PILSENGA services, improve the customer’s user experience of services and to recommend products and services.
4.4. Complying with legal obligations and verifying identity. To comply with applicable law, prevent, detect, investigate and report potential money laundering, terrorist financing, if the customer is subject to financial sanctions or is a political person.
4.5. Prevent abuse of financial services and ensure appropriate services. To allow and control access to and function of digital channels, prevent unauthorized access and misuse of these and to ensure the security of information based on: execution of an agreement or taking measures at the Customer’s request before entering into an agreement. Improve technical systems, IT infrastructure, adapt the display of the service to the unit and develop UAB PILSENGA services, e.g. by testing and improving technical systems and IT infrastructure.
4.6. To process incoming and outgoing payments.
4.7. To process, deliver and load your card.
- PROFILING, PERSONAL OFFERS
Profiling refers to the automatic processing of personal data that is used to assess the personal characteristics of certain customers. Profiling is used for direct marketing.
5.1. UAB PILSENGA may process personal data to improve the user experience of digital services. Unless direct marketing has been restricted by the customer, UAB PILSENGA can process personal data for the purpose of providing general and personal offers about UAB PILSENGA services.
5.2. UAB PILSENGA always ensures that customers can make their choices and use a convenient tool to manage their privacy settings.
5.3. UAB PILSENGA can also collect statistical data about the customer, such as typical behavior and lifestyle patterns based on demographic household data. Statistical data to create segment profiles can be collected from external sources and can be combined with UAB PILSENGA internal data.
- HOLDER OF PERSONAL DATA
Personal data is shared with other recipients, for example:
6.1. Authorities (eg law enforcement, tax authorities, regulators);
6.2. Fraud prevention agencies (eg. financial risk verification agencies and identity verification agencies).
6.3. Credit and financial institutions to handle incoming and outgoing payments;
6.4. Companies that provide and support our IT infrastructure (eg. Software and technical assistance providers)
6.5 Advertising partners (eg. Search Engines and Social Media)
6.6 Third parties helping us provide products and services (FCA-regulated companies, our issuer and payments processor provider).
6.7. Accountants, legal and financial consultants, or any other processor authorized by UAB PILSENGA.
6.8. The maintenance of registers by third parties (such as credit bureaus, population registers, the trade register or other registers that hold personal data);
6.9. Debt collector when assigning claims;
6.10. courts, out-of-court dispute resolution bodies and bankruptcy administrators.
6.11. Other persons related to the provision of services by UAB PILSENGA, such as providers of postal services or analytical services.
- GEOGRAPHICAL AREA FOR PROCESSING
7.1. As a general rule for the processing of personal data within the EU/EES area (EU/EES).
7.2. Given the global nature of financial services and technological solutions and to process Personal data for the purposes specified in the Policy, for the provision of individual services Personal data may be transferred for Processing to the Personal data receivers located outside the European Union and the European Economic Area, for instance, if their services are provided by a counterparty (processor, separate controller, joint controller). Any such international transfer of Personal data is done in compliance with the requirements of the applicable laws. The transfer and processing of Customer data outside of the EU/EEA can take place provided there is a legal basis and appropriate safeguards are in place. Appropriate safeguards include for example:
– The EU Standard Contractual Clauses or other approved clauses, code of conducts, certifications approved in accordance with the GDPR.
– The country outside of the EU/EEA where the recipient is located has an adequate level of data protection as decided by the EU Commission.
- ACTION TIME
8.1. The period for which UAB PILSENGA stores Personal data depends on the purposes for which UAB PILSENGA processes it and under which criteria it assesses Personal data storage periods.
8.2. When determining Personal data storage periods, UAB PILSENGA assesses:
8.2.1. the need to store Personal data to ensure performance of a valid service agreement;
8.2.2. the need to store Personal data for UAB PILSENGA to fulfill its legal obligations, for instance, within the 8-year period stipulated in the AML/CTF Law and within the different storage periods specified in other legal acts;
9. DIRECT MARKETING: EMAIL, SMS AND PUSH NOTIFICATIONS.
9.1. When you sign up for your account we’ll ask if you’d like to be contacted about new features, offers and tips about your money. If you tell us you’re happy to be contacted, we’ll send you information about things you might be interested in via email, SMS or push notifications.
9.2. You’ll only get push notifications if you have the Pilsenga app and have enabled notifications in your phone settings. If you wish to stop receiving push notifications just turn this off in your phone settings.
- RIGHTS OF THE CUSTOMER AS DATA SUBJECT
10.1. A customer (data subject) has rights regarding his/her data Processing that is classified as personal data according to applicable law. Such rights are generally the following:
10.1.1. Demand that his/her personal data be corrected if it is insufficient, incomplete or incorrect.
10.1.2. Objects for processing his/her personal data, if the use of personal data is based on legitimate interests, including profiling for direct marketing purposes (for example, receiving marketing offers or participating in surveys).
10.1.3. Demand the deletion of his/her personal data, for example processed based on consent, if he/she has withdrawn consent. Such right does not apply if personal data requested to be deleted is also processed on other legal grounds, such as contracts or obligations under applicable law.
10.1.4. Limit the processing of his/her personal data according to applicable law, e.g. during the time when UAB PILSENGA assesses whether the Customer has the right to have his data deleted.
10.1.5. Receive information about his/her personal data being processed by UAB PILSENGA and, if so, to access it.
10.1.6. Receive his/her personal data provided by him/herself and be feasible to transfer such data to another service provider (data portability).
10.1.7. Revoke his/her consent to process his/her personal data.
10.1.8. Not to be subject to fully automated decision-making, including profiling, if such decision-making has legal effects or similarly affects the customer. This right does not apply if the decision-making is necessary to enter into or enter into an agreement with the customer if the decision-making is permitted according to applicable law or if the customer has given his express consent.
10.1.9. Complaints about the use of personal data to the data protection authority can be submitted to:
Pilsenga Data Protection Officer
Name: Fausto Blanca
Email: fausto@pilsenga.com
Phone: +370860156009
MLRO
Name: Sigita Rubazeviciuté-Sajoniene,
Email: compliance@pilsenga.com
Phone: +37061250290
Lithuania State Data Protection Inspectorate
Name: Raimondas Andrijauskas
Email: ada@ada.lt
Address: L. Sapiegos str. 17 (Left-hand entrance)
LT-10312 Vilnius
Phone: +370 5 271 2804 / 279 1445
Website: https://vdai.lrv.lt/en/
Consultations by phone
+370 5 212 7532
Monday–Thursday 9–11 AM and 1–3 PM
Moorwand Limited
Fora, 3 Lloyds Avenue, London, EC3N 3DS, United Kingdom
E-mail: legal@moorwand.com
In the UK a client can complain to the Information Commissioner’s Office https://ico.org.uk/
Registered address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Telephone: 0303 123 1113; Fax: 01625 524510
Moorwand DPO Name: David Campbell
Email: legal@moorwand.com ; subject line “Data Protection Officer”
- CONTACT INFORMATION
11.1. Customers can contact UAB PILSENGA for any inquiries, withdrawal of consent, inquiries about the exercise of personal data and complaints regarding the use of personal data.
11.2. UAB PILSENGA contact details can be found on UAB PILSENGA website www.pilsenga.com.
11.3. UAB PILSENGA has the right to unilaterally change the policy in accordance with current law by notifying the customer of any changes via UAB PILSENGA website no later than one month before the changes take effect.
- VALIDITY AND AMENDMENTS OF THE PRIVACY POLICY
12.1. UAB PILSENGA is entitled to amend the Policy at any time unilaterally, in compliance with the applicable law, by notifying the Customer of any amendments via the website of UAB PILSENGA.
