Date of last revision: 14-06-2018 (v1)
1. ABOUT VALYUZ
(a) Account or Valyuz Account has the meaning of the account created by Valyuz to the Client;
(b) Client has the meaning of an individual or legal entity holding Valyuz Account;
(c) Mobile APPhas the meaning ofValyuz mobile applicationsused for provision of Services.
(e) Personal data has the meaning ofinformation that can be used to directly or indirectly identify you.
(f) Services has the meaning of the services providedby VALYUZ to its Clients;
(h) Websiteor Valyuz Website has the meaning of the website available at https://www.Valyuz.com/;
(i) We has the meaning of Valyuz;
(j) You has the meaning of the person whose Personal data is processed by Valyuz;
4. PERSONAL DATA WE COLLECT
4.1.1. In order to provide You with Valyuz Account and Servicesthereof, Valyuz collects various types of your Personal Data.
4.1.2. Personal Data is collected and used during 3 principal steps: registration, identity verification and the use of Valyuz Account and Services.
4.2. Processing of registration data
4.2.1. In the registration process we collect some important details about you, such details may include: name, surname, email address, mobile phone number. Submission of herein mentioned Personal data is mandatory for your registration.Failure to provide any of this data or decision to delete or object to processing of any of such data will result in dismissal of your registration.
4.2.2. In case you have not finished your registration and have not deleted all your Personal data submitted in the registration form we will understand it as your request for us to take steps before entering into contract and we will contact you in order to assist you with registration for openingtheAccount process.
4.2.3. Finalizing your registration you will have to confirm your email address and/or phone number provided after the respective message is sent to it.
4.2.4. After providing Personal data for registration you can continue with application for opening the Account. For this purpose we need to request more information in order to meet legal and regulatory obligations. Therefore proceeding with the Account opening you should provide us your additional Personal Data, which may include data as such: Residential address, Correspondence address for delivery of Debit card (if different from residential address), ID document number (national identification card/ Passport number), Passport expiry date, Passport nationality, Occupation,Employment status and details of employment, Reason for opening the account, Source of funds, copy of identification document (ID, Passport, utility bill), personal description and photograph and any other information you provide us in order to prove your eligibility to use our Services. Submission of herein mentioned Personal data is mandatory for Account to be created and opened. Failure to provide mentioned Personal data will lead to dismissal of application for Account opening.
4.2.5. In order to open the Account we need to know what expected activities on it are. Therefore during the process of opening your Valyuz Account you must determine and indicate such activities and provide details of it. Such information is collected and processed in order to comply with legal and regulatory obligations. Sometimes we need to request more information to identify you or to meet legal and regulatory obligations. When that is necessary, you will be prompted to provide such information.
4.2.6. If you contact us, we will keep a record of that correspondence.
4.2.7. Personal data collected by Valyuz in the Registration step is used for the following purposes:
184.108.40.206. Account opening;
220.127.116.11. Client identification;
18.104.22.168. Client risk assessmentmandatory under the applicable laws;
22.214.171.124. provide Clients with support, letting them know about upcoming changes or improvements of Website and/or Mobile APP;
126.96.36.199. Provide Clients with information regarding changes of any terms or conditions applicable to them or Services they use as well as other important information.
4.2.8. Valyuz processes Clients registration data on the legal basis of:
188.8.131.52. Your consent, expressed when voluntarily submitting and filling your Personal Data details in our registration form which are not mandatory to fill in; and
184.108.40.206. Conclusion and performance of contractual arrangements and obligations between Valyuz and the Client; and
220.127.116.11. for compliance with a legal and regulatory obligations to which Valyuz is subject.
4.2.9. You may at any time edit, update or delete your contact details contacting our service center though internal messaging system in your Account. Please note that you will be able to request deletion of your contact details and other registration data only if there is no legal obligation for Valyuzto preserve such data by the applicable laws.
4.3. Processing of Client verification data
4.3.1. In order for the Account to be created you must verify your identity. We verify you by the Personal data you provide during registration. However such Personal data must be confirmed, therefore in addition, for verification purposes we also rely on verification services, managed and provided to us by our service providers.
4.3.3. Valyuz may request to provide further information that will allow Valyuz to reasonably identify you and verify your identity. Valyuz reserves the right to contact you and request to provide more information or confirm that provided information is up-to-date and valid.
4.3.5. Processing of your ID document, address proof, facial verification data, uploaded to third-party database as described above, is covered by third parties’ privacy policies. You shall be notified about exact third party performing your verification process before starting such process. All Personal data you provide for verification process shall be provided directly by you to our service provider performing your verification and therefore processing of such data shall be covered by the policies of such Service provider. Youshould carefully review privacy policies of such Service provider before starting the verification process.
4.4. Processing of data generated while using our Mobile App
4.4.1. To provide quality user experience for you we create a possibility to use our Services through the Mobile App. For installing purposes of such Mobile App we do not process any of your data. While you are using our Mobile App we collect and process:
18.104.22.168. yourlogin history for the security purposes.
22.214.171.124. history and other information of your actions while using Mobile app in order to: (i) ensure the functionality of Mobile App and to provide further updates and improvements, (ii) ensure compliance with a legal and regulatory obligations.
4.5. Processing of data generated while using Valyuz Account
4.5.1. While you are using our Services and Account we are collectingthe following information:
126.96.36.199. History of transactions (date, information of payer and payee, amount of transaction) is processed in order to: (i) ensure the functionality of Mobile App and to provide further updates and improvements, (ii) ensure compliance with a legal and regulatory obligations;
188.8.131.52. Internal messaging history on Account, including, but not limited to, claims and complaints made by youis processed in order to: ensure duly performance of obligations regarding provision of Services. Please note that you should limit personal information and details provided during internal massaging to the extent necessary for Service provision or asked by us;
184.108.40.206. Your behaviorwhile using Account (your clicks, visited sections)is processed in order to ensure the improvements of functionality of Website;
220.127.116.11. Your payment card information (date of issue and expiry date) is processed in order to provide you Services;
18.104.22.168. Massage content: if you include a message with your payments, the content of that massage is stored by Valyuz;
4.5.2. Valyuz processes Personal Data collected while using Services and Account on the following legal basis:
22.214.171.124. Conclusion and performance of contractual arrangements and obligations between Valyuz and you; and
126.96.36.199. Pursuance of legitimate interests of Valyuz, as controller and manager of Webpageand Mobile app;
188.8.131.52. for compliance with a legal obligation to which Valyuz is subject.
4.6. Personal data of other individuals
4.6.1. By providing personal data of any individual other than yourself to us during the use of our Services, you confirm that you have obtained consent from such individual to disclose their personal data for collection and use. By providing such Personal data to us you bear all the responsibility towards such individual if you have not received proper consents for such provision and you undertake to indemnify us for any liability which may appear due to unlawful provision and/or disclosure of personal data made by you.
5. OTHER PURPOSES FOR USE OF PERSONAL DATA
5.1. Developing the Website and Mobile App
5.1.1. We use Personal data to conduct research and development of our Website, Mobile App and Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth.
5.2. Client support
5.2.1. We use Personal data to keep in touch with you in order to provide you with customer service, notify you on news and updates, provide you with the security notices or information.
5.3. Security and investigations
5.4. Providing information on similar products and services
5.4.1. We use Personal data to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
5.5.1. WewillcombinePersonal datawithinformationwehavecollectedaboutyouandwewillusethisinformationto helpusbetterunderstandyourfinancialcircumstancesandbehavioursothatwemaymakedecisionsabouthowwemanageyourAccountandinorder to make a decisionsaboutwhether to agree to approveapplicationonAccountopening.
6. PERSONAL DATA RECEIVED FROM THIRD PARTIES
6.1. We collect and receive your Personal data from yourself, as well as from the following sources:
6.1.1. We work closely with third parties in order to deliver our Service to you. These third parties are business partners, sub-contractors in technical, payment services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions;
6.1.2. Other legal sources, such as public registers, internet search engines, public sources such as social media.
7. HOW WE SHARE PERSONAL DATA
7.1. In order to provide you with the Services and meet our legal and regulatory obligations, we use third parties services and such third parties use personal data in delivering their services to us. Therefore wemay share the information we collect about you with our service providers (Data processors) such as:
7.1.1. Cloud storage/servers providers. We use their service in order to store your data safely and securely.
7.1.2. Card issuing institutions. For the purpose of providing you with a card in order to use our Services.
7.1.3. Auditors, accountants and lawyers: In order to complete financial, technical and legal audits of Valyuz operations or provide us with respective services, we may need to share some information about you as part of such audit or in service.
7.2. We only use the services of those Data processors which ensure safeguards and use technical and organizational security measures equivalent to the ones required by EU General Data Protection Regulation.
7.3. Processing personal data inside and outside the EEA
7.3.1. The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (EEA).
7.4. Our Legal Obligation to Use or Disclose Personal Data
7.4.1. As a regulated financial institution, we may need to share your Personal Data to state and public authorities.We will only do so when we are legally required to provide information or when we need to take legal action to defend our rights, as well as the cases, where we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Services, including investigation of potential violations, detect, prevent or otherwise address fraud, security or technical issues.
7.5.1. Valyuz may partner with other financial institutions, such as credit and financial services partners, including banking partners, banking intermediaries, credit companies and international payments services providers.With their help we are able to provide you Services and in order to meet legal and regulatory requirements we might be obligated to share your Account details with such partners to the extent you actually transact or interact with customers of such partners.
8. YOUR RIGHTS
8.1. You are entitled to the following rights regarding the protection of your Personal Data:
8.1.1. The right to request access information we process about you: this right enables you to receive a copy of the personal data we hold about you;
8.1.2. The right to request to correct incorrect / inaccurate information about you:this right enables you to have any incomplete or inaccurate Personal data we hold about you to be corrected. Please note that we may need to verify the accuracy of the new data you provide to us.
8.1.3. The right to request to transfer all or part of the Personal data:This right enables you to ask us to provide you with your Personal data in a structured, commonly used, machine-readable format, which you can then transfer to other appropriate data controller. Note that this right only applies to automated information which you initially provided for us to use and consented for it use or where we used the information to perform a contract with you.
8.1.4. The right to request erasure of Personal data: This right enables you to ask us to delete or remove personal data where there is no good reason for us to process it, or if you have successfully exercised your right to object to processing (as described in clause 9.1herein below). Please note that Valyuz as a regulated financial institution is obligated under the applicable laws regarding prevention of money laundering and terrorist financing as well as of Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania to retain certain information you have provided for a number of years, as indicated per clause 8.6.4 below, therefore we may not always be able to comply with your request of erasure for the mentioned reasons. We will notify you at the time of your request if it the situation is as described.
8.1.5. The right to request restriction of data processing:This right enables you to ask us to suspend the processing of your personal data. Please note that such requests may lead to a situation that we may not be able to perform our contractual obligations towards you or enter into a contract with you. If this would be the case we will notify you about it.
8.1.6. The right to object to processing of Personal Data when processing is carried out on the basis of legitimate interest: This right can be exercised in a situation where we are relying on our legitimate interest (or those of a third party) but in your particular situation such processing impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. Please note that Valyuz as a regulated financial institution is obligated under the applicable laws regarding prevention of money laundering and terrorist financing as well as of Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania to process your certain Personal data for compliance purposes, therefore in some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal data which override your rights. Requirements of the mentioned laws supersede any right to objection under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide you Services and it is likely we will have to terminate your Account.
8.1.7. To exercise any of the rights mentioned above, please reach out to our client support team via the internal massaging available in your Account or contact our Data Protection Officer as indicated below. We may ask you to verify your identity and provide us with more information regarding your request.
9. HOW LONG DO WE KEEP PERSONAL DATA
9.1. Valyuz as a regulated financial institution is obligated under the applicable laws regarding prevention of money laundering and terrorist financing as well as of Law on Electronic Money and Electronic Money Institutions of the Republic of Lithuania to retain your Personal data for a number of years:
9.1.1. Client identification data and verification data –eight years after termination of the contract relations;
9.1.2. History of transactions – five years after terminations of the contract relations.
9.2. We therefore use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than it is strictly necessary we will not hold any of your personal data for more than 8 years after the termination of our business relationship.
10.1. We would appreciate the chance to deal with any of your concerns regarding Personal data and we will try to find a solution at your satisfaction. So please contact us in the first instance. Also know that you have the right to lodge a complaint to the national Data Protection Agency (DPA) in the country of your residence in the event where your rights may have been infringed.
11. VALYUZ’S DATA PROTECTION OFFICER
11.1. Professional partnership of attorneys “CEE Attorneys”, email: DPO@ceeattorneys.com who are responsible for matters relating to privacy and data protection.
11.2. If you have any further questions regarding the Personal data Valyuz collects, or how we use it, then please feel free to contact Data Protection Officer at the details as indicated above hereof.