2. SCOPE OF OUR PRIVACY POLICY
2.1 This Privacy Policy describes how “Livil Pay” collects, uses,
stores, shares, and protects your
Personal Data whenever you use Services through the Website or by corresponding with us (for
example
by
email or by filling messaging forms on the Website).
2.2 Personal data collected by “Livil
Pay” are processed in
accordance with the Law on Legal
Protection
of Personal Data of the Republic of Lithuania, the General Data Protection Regulation, and other
legal
acts. All employees, agents, and employees of the agents of “Livil Pay” who know the secret of
Personal
data must keep it safe even after termination of the employment or contractual
relationship.
2.3 For the processing of Personal data, “Livil Pay” may engage data
processors and/or, at
its sole
discretion, hire other persons to perform certain functions on behalf of “Livil Pay”. In such
cases,
“Livil Pay” shall take necessary measures to ensure that such data is processed by the personal
data
processors in accordance with instructions of “Livil Pay” and applicable legislation. “Livil
Pay”
shall
also require the personal data processors to implement appropriate measures for the security of
Personal
data. In such cases, “Livil Pay” shall ensure that such persons will be subject to the
non-disclosure
obligation and will not be able to use this information for any other purpose, except to the
extent
necessary to perform the functions assigned to them.
2.4 We assume that you have carefully
read this document and accepted
it. If you do not agree
with
this
Privacy Policy, then you should refrain from using our Services or opening an Account. This
Privacy
Policy is an integral part of “Livil Pay”'s Terms of Use.
2.5 We may change this Privacy
Policy from time to time. We will post
any Privacy Policy
changes on
the
Website and additionally sending you an email informing about changes made. Continued use of
“Livil
Pay”'s Website and/or Services implies your acceptance of the revised Privacy Policy.
2.6
“Livil Pay” respects the individual's right to privacy and makes
all reasonable efforts
to
ensure
the
security and confidentiality of Personal data and other information processed on this Website
and
Mobile
App.
2.7 You can visit this Website not providing any information about
yourself, however, if you
want
to
open
an account using “Livil Pay” services and/or use other payment services offered by “Livil Pay”,
“Livil
Pay” will ask you to provide Personal data indicated in the system and to carry out established
identification procedures.
2.8 “Livil Pay” reserves the right, at its sole discretion to
alter
the provisions of the
present
Privacy
Policy, therefore, when visiting this website, you have a responsibility to make sure that you
are
familiar with the latest version of the Privacy Policy that applies to you at the time you are
visiting
the website.
3. PERSONAL DATA WE COLLECT
3.1 General
To provide you with “Livil Pay” Account and Services thereof, “Livil Pay” is bound by law to
establish
and verify your identity prior to entering financial services transactions with you, also, at
the
time
of
the provision of the services, to request further information, as well as assess and store this
information for the retention period set out by legislation. Taking this into account, you must
provide
correct and complete information. Personal Data is collected and used during 3 principal steps:
registration, identity verification and the use of
“Livil Pay” Account and Services.
3.2 Processing of registration data
3.2.1 In the registration process we collect your email address and
telephone number.
Submission of
herein mentioned Personal data is mandatory for your registration. Failure to provide your email
address/telephone number or decision to delete or object to processing of email
address/telephone
number
will result in dismissal of your registration.
3.2.2 Finalizing your registration you will have to
confirm your email address
provided
after
the
respective message is sent to it.
3.2.3 After providing Personal data for registration you
can continue with an
application
for
opening
the
Account. For this purpose we need to request more information 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:
(1)Name,
(2)Surname,
(3)Date of birth,
(4)personal code,
(5)Residential Address,
(6)Correspondence address for delivery of Debit Card (if
different from residential
address),
(7)mobile phone number,
(8)ID document number (national identification
card/Passport
Number/Itinerary
document),
(9)ID document number expiry
Date,
(10)Nationality,
(11)Occupation,
(12)Source of Funds,
(13)Account
number,
(14)Copy of identification document (ID/Passport/Itinerary
document),
(15)photo,
(16)signature,
(17) IP address, 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.
3.2.4 To open the Account we need to know what expected
activities on it are. Therefore
during the
process of opening your “Livil Pay” Account you must determine and indicate such activities and
provide
details of it. Such information is collected and processed 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.
3.2.5 If you contact us, we will keep a record of that
correspondence (i.e. date of the
letter,
subject,
the content of the correspondence).
3.2.6 Personal data collected by “Livil Pay” in the
Registration step is used for the
following
purposes:
(1)Account opening;
(2)Client identification;
(3)Client risk assessment
mandatory
under the applicable
laws;
(4)To provide Clients with support, letting them know about
upcoming changes or
improvements
of
Website
and/or Mobile APP;
(5)Provide Clients with information regarding changes of any
terms or conditions
applicable
to them
or
Services they use as well as other important information.
3.2.7 “Livil Pay” processes
Client's registration data on
the legal basis of:
(1)Your consent, expressed when voluntarily submitting
your Personal Data details
which
are
not
mandatory; and
(2)Conclusion and performance of contractual
arrangements and obligations
between “Livil
Pay”
and
the
Client;
(3)for compliance with a legal obligation to which
“Livil Pay” is
subject.
3.2.8 You may at any time edit, update, or delete your
contact details
contacting
our
service
center
via
e-mail support. 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 “Livil Pay” to preserve such
data by
the
applicable laws.
3.3 Processing of Client verification data
3.3.1 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.
3.3.2 While exercising this verification step, you
will be requested to upload
your
ID
document.
You
will
undergo facial verification. For the mentioned purposes we receive and rely on a
certain
confirmation
from our service providers that your identity is verified. Please note, that under the
applicable
laws
“Livil Pay” is obligated to collect and store all data received during Client
identification and
verification process therefore scanned copies of ID documents, data related to facial
recognition
and
other information will be stored by “Livil Pay” in accordance with this Privacy policy
and
applicable
legislation.
3.3.3 “Livil Pay” may request to provide further
information (i. e.
information on
participation in
politics (through enhanced customer identification, a bank statement) that will allow
“Livil
Pay”
to
reasonably identify you and verify your identity. “Livil Pay” reserves the right to
contact you
and
request to provide more information or approve that provided information is up- to-date
and
valid.
3.3.4 “Livil Pay” processes the above-mentioned
Personal data used for
Client's
verification
to
comply
with regulatory and legal obligations as well as to ensure that Clients are not
attempting
to
create
additional Accounts or to commit fraudulent actions. Refusal to undergo ID and facial
verification
will
terminate your Account opening process.
3.3.5 Processing of your ID document, facial
verification data, uploaded to a
third-party
database
as
described above, is covered by third parties' privacy policies. All Personal data you
provide
for
the
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. You should carefully review privacy policies of such Service providers before
starting
the
verification process.
3.4 Processing of data generated while using a Mobile App
3.4.1 To provide quality user experience for you we create a
possibility to use
our
Services
through
the
Mobile App. While you are using our Mobile App we collect and process (but not limited
to):
(1)your login history for the security purposes.
(2)history and other information of your actions while
using Mobile app to:
(i)
ensure the
functionality
of Mobile App and to provide further updates and improvements, (ii) ensure compliance
with
a
legal
obligation.
(3)device geolocation.
(4)IP address.
(5)device info (name, model, operating system, unique
ID).
3.5 Processing of data generated while using “Livil
Pay” Account
3.5.1 While you are using our Services and Account, we
are collecting the
following
information:
(1)History of transactions (date, information of payer
and payee, i. e. name,
surname,
account
number,
purpose of transaction, amount of transaction) is processed to: (i) ensure the
functionality of
Mobile
App and to provide further updates and improvements, (ii) ensure compliance with a
legal
obligation;
(2)Messaging history, including, but not limited to,
claims and complaints
made
by
you is
processed
due
to the performance of obligations regarding provision of Services, our responses to
you,
names
of
messages, the dates of messages. Please note that we identify you by email, which you
have
submitted
during the registration process. When you submit your request, always provide your
email.
In
other
case
we will not be able to identify you properly and submit the information requested by
you
or to
fulfil
your request;
(3)Your behavior while using Account (your clicks,
visited sections) to ensure
the
improvements of
functionality of Website;
(4)Your payment card information: date of issue and
expiry date to provide you
Services;
(5)Message content: if you include a message with your
payments, the content
of
that
massage
is
stored
by
“Livil Pay”;
(6)Cookies: like most Websites and mobile applications
we use cookies. Please
see
information
on
cookies
we use in our cookie policy.
3.5.2 “Livil Pay” processes Personal Data collected
while using Services and
Account
on
the
following
legal basis:
(1)Conclusion and performance of contractual
arrangements and obligations
between
“Livil
Pay”
and
the
Client; and
(2)Pursuance of legitimate interests of “Livil Pay”,
as controller and manager
of
Webpage
platform;
(3)for compliance with a legal obligation to which
“Livil Pay” is
subject.
3.6 Personal data of other individuals
3.6.1 In providing personal data of any individual
other than yourself to
us
during
the
use
of our
Services, you agree 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 individuals 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.
4. DEVELOPING THE WEBSITE AND MOBILE SERVICES
We use Personal data to conduct research and development of our
Website, Mobile App and Services to
provide you and others with a better, more intuitive, and personalized experience, driving
membership
growth.
4.1 Client Support
We use Personal data to keep in touch with you to provide you with customer service, notify you
on
news
and updates, and provide you with security notices or information.
4.2 Security and investigations
We use Personal data for security, fraud prevention and investigations. We use your Personal
data
(including your communications) if we think it is necessary for security purposes or to
investigate
possible fraud or other violations of our Terms of Services, this Privacy Policy, implementing
the
regulatory and legal obligations. We may ask you to provide any additional information which we
think
may
influence the process of investigation or examination of your complaint / request.
4.3 Profiling
Profiling carried out by “Livil Pay” involves processing of personal data by automated means for
the
purposes of legislation relating to risk management and continuous and periodic monitoring of
transactions to prevent fraud. Such ongoing profiling is based on legitimate interests of “Livil
Pay”,
the performance of a legal obligation and the execution of the agreement.
4.4 Providing information on similar products and
services
4.4.1 When you sign up to “Livil Pay”, we give you the
opportunity to opt in to offers
and
promotions.
If
you choose to opt in, we then use your data to tailor offers to you, so they are more likely to
interest
you. You can opt out again at any time by going to the settings in your app or browser. You can
adjust
your preferences or tell us you do not want to hear from us, at any time. We will not pass your
details
on to any outside organizations for their marketing purposes without your permission.
4.4.2 When we use social media for marketing, your information
may be shared with
social
media
platforms,
who may use it to check if you also hold an account with them. If you do, we may ask the
advertising
partner or social-media provider to:
(1)use your information to send our adverts to you when we
think you might like one of
our
new
products;
(2)not send you our adverts, because you already used the
service advertised;
(3)advertise to people with a similar profile to you (e.g. if
one of our services might
appeal to
someone
with interests like yours).
4.4.3 If you want us to stop sharing your personal information
for marketing purposes,
just
let us
know
via the “Livil Pay” website or app, or by emailing our support team. You can also manage your
marketing
preferences directly with the social media platforms you are signed up to.
4.5 Third Party Information
We will combine this information with information we have collected about you and we will use
this
information to help us better understand your financial circumstances and behavior so that we
may
make
decisions about how we manage your Account and to decide about whether to agree to approve
application
on
Account opening.
5. PERSONAL DATA RECEIVED FROM THIRD PARTIES
5.1 We collect and receive your Personal data from yourself, as
well as from the following sources:
(1)We work closely with third parties to help us deliver our
Service to you. These
third
parties
are
business partners, sub-contractors in technical, payment and delivery 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.
(2)Other legal sources, such as public registers, internet
search engines, public
sources
such as
social
media.
5.2 If you are a beneficial owner, shareholder, representative
or employee of our
corporate
client
we
are
collecting your Personal data to fulfill legal and regulatory obligations. Your Personal data is
provided
to us by the representatives of the company where you hold a certain position. Personal data
received
under this clause is processed in accordance with the provisions of this Privacy policy and you
have
all
the rights of the Data subject listed herein in this Privacy policy and in the applicable laws.
6. HOW WE SHARE PERSONAL DATA
6.1 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,
we
may
share the information we collect about you with our service providers (Data processors) such as:
(1)Cloud storage/servers' providers. We use their service to
store your data safely and
securely.
(2)Card issuing institutions. For providing you with a card to
use our Services.
(3)Identification and verification services providers - to
verify your identity.
(4)Auditors, accountants, and lawyers: To complete financial,
technical, and legal
audits
of
“Livil
Pay”
operations, we may need to share information about your Account as part of such an audit.
(5)Other service providers with which we have concluded
service provision agreements or
when
such
sharing
is mandatory according to applicable law.
6.2 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.
6.2.1The data that we collect from you will be transferred to,
and stored at, a
destination
inside
the
European Economic Area (EEA).
6.2.2Personal data may be processed outside of the EEA for us
to fulfill our
contractual
obligations
towards you to provide the Services. We will need to process your personal data for us, for
example,
to
action a request made by you to execute an international payment, process your payment details,
provide
global anti-money laundering, and counter terrorist financing solutions and provide ongoing
support
services. We will take all steps to ensure that your data is treated securely and in accordance
with
this
privacy policy.
6.3 Our Legal Obligation to Use or Disclose Personal Data
As a supervised 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.
6.4 Others
“Livil Pay” may partner with other financial institutions, such as Banking, credit, and
financial
services partners, including banking partners, banking intermediaries, credit companies and
international
payments services providers. With their help we can provide you Services and to meet legal and
regulatory
requirements we might be obligated to share your account details with such partners to the
extent
you
transact or interact with customers of such partners.
8. HOW LONG DO WE KEEP YOUR DATA
8.1 “Livil Pay” as a supervised institution is obligated under
the applicable laws regarding
prevention
of money laundering and terrorist financing to retain your Personal data for several years
(1)Client identification data and verification data - eight
years after termination of
the
contract
relations in accordance with the Law of the Republic of Lithuania on the Prevention of Money
Laundering
and Terrorist Financing;
(2)History of transactions - five years after terminations of
the contract relations in
accordance
with
the Law of the Republic of Lithuania on the Electronic Money and Electronic Money Institutions.
We therefore use this retention requirement as a benchmark for all
personal data that we
receive
from
you. To not hold your information for longer than 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. DATA PROTECTION OFFICER (DPO)
10.1 To get in touch with our DPO, kindly contact our support
center who will delegate you to
responsible
team member. If you have any further questions regarding the Personal data “Livil Pay” collects,
or
how
we use it, then please feel free to contact the Data Protection Officer at the details as
indicated
above
hereof.
