Contis Financial Services Limited or UAB “Finansinės paslaugos „Contis“ (“we”, “us” or “our”) is committed to protecting and respecting your privacy.
This policy together with our Terms and Conditions https://baanx.com/cl-cardtermseur/ and any other documents referred to in them, sets out the basis on which any personal data we collect from you, or that we collect about you, on https://www.currencylifecard.com, (“Website”), on [Baanx] (“App”) or when you communicate with us by email, telephone or post will be processed by us.
We will be the data controller of your personal data which you provide to us or which is collected by us about you. This means that we are responsible for deciding how we hold and use personal data about you and that we are required to notify you of the information contained in this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The terms and conditions of your account will identify which Contis company is the controller of your personal data.
If you have any queries, you can contact us using the details provided at the end of this policy in the “Contacting Us” section.
We will only use your personal data where we have a lawful basis to do so. We will usually only use your data:
Further details of how we will use your personal data are provided below.
When you apply to create an account
When you apply to create an account on the https://www.currencylifecard.com, website we will need to collect the following details about you:
We will use this information for the purposes of processing your application and, if your application is successful, creating and managing your account and providing any products or services you request to you. If you have consented, we will also send our newsletter to you by email.
You will not be able to apply to create an account or order products or services from us without providing this information.
This information may be provided to us by the client, we will become data controller of this information once we receive it from them.
Fraud and money laundering checks
In order to process your application and before we fulfil your order and provide services, goods or financing to you, we will use the information you provided to create your account to undertake checks for the purposes of preventing fraud and money laundering, and we may need to verify your identity. This may involve sharing your personal data with fraud prevention agencies. We will continue to carry out these checks on a regular basis while you are a customer of ours.
When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.
We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:
You have rights in relation to automated decision making: if you want to know more please contact us using the details below.
Consequences of processing
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested or we may stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.
Other than the automated processing set out above, we shall not carry out solely automated decision-making using your personal data.
When you contact us
When you contact us, we will need to collect personal data about you to verify your identity before we disclose any information to you for data security purposes. We will be unable to deal with your query unless you provide the information we request. We may also collect any other personal data you choose to provide to us when communicating with us. We will only use that personal data for the purposes of dealing with your enquiry.
We use your personal data for various purposes connected with your use of the account and services. We will only do so where we have a lawful basis to do so. We will usually only use your data:
We use your personal data for the following purposes :
find out more…
The table below sets out further information about the purposes for which we use data about you, with the corresponding methods of collection and legal basis that we rely upon for its use.
To fulfil our contractual obligations to you in providing the account and services.
Our legitimate interests in operating and improving our services to you.
Our legal obligations to comply with regulations that apply to us.
We are also working closely with third parties (including, for example identity verification agencies, marketing agencies and fraud prevention agencies) and we may receive information about you from them for the purposes of identity verification, marketing and fraud prevention.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will usually notify you and we will explain the legal basis which allows us to do so.
We will disclose your information to:
in order to allow us to manage our business and to provide the products and services to you.
Your data is secured by encryption, firewalls and Secure Socket Layer (SSL) technology. This is industry standard encryption technology which manages the security of messages transmitted across the internet. When we receive your data, we store it on secure servers which can only be accessed by us. We store your passwords using one way encryption which means we do not know what your password is.
Our third party data host provider may use servers located in the US to store personal data. As a result, when you use the https://www.currencylifecard.com Website or App to make transactions or update your account information, your personal data may be transferred to the US which is located outside of the European Economic Area and so is not governed by European data protection laws.
However, we have entered into the standard contractual clauses (Model Clauses) adopted by the European Commission with OrcsWeb Inc, in order to safeguard personal data when it is accessed from outside of the European Economic Area.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy when it is transferred, stored or processed in this way.
We have agreed with our third party data host that we will migrate the servers that store your personal data to the UK and EEA. After this migration is completed your data will be stored in the UK or EEA.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose the standard contractual clauses (Model Clauses) adopted by the European Commission on the recipients of that data in order to safeguard personal data when it is accessed from outside of the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
If there is no adequacy agreement between the UK and EU during the transition period following the UK leaving the EU, UAB “Finansinės paslaugos „Contis“ will ensure that it enters into standard contractual clauses with any third party or group company in order to safeguard personal data which is processed or stored in the UK.
More information about the Model Clauses is available here http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32010D0087.
Any changes we make to our policy will be put on our Website and App and, where appropriate, notified to you by e-mail. Please check for updates from time to time.
We will retain your personal data for as long as you continue to use our services. Thereafter, we may retain your information for an additional period as is permitted or required under applicable laws. For example:
Data protection laws provide you with the following rights to:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
If you are unhappy about how your personal data has been used please refer to our complaints procedures which is available by contacting us. You also have a right to complain to the supervisory authority, which in the United Kingdom is the Information Commissioner's Office https://ico.org.uk/ and in Lithuania is the State Data Protection Inspectorate https://vdai.lrv.lt/en/, who regulate the processing of personal data.
If you have any questions about this policy, you can contact us by using the ‘Contact us’ facility on https://www.currencylifecard.com or in the following ways:
By post at:
Data Protection Officer
By email at: firstname.lastname@example.org
By telephone at: 0330 159 6348