In order to provide our payment processing services we need to process your personal data as described below. In the course of our business we collect personal data in a variety of ways. We collect personal data directly from data subjects, via data subject’s usage of our service and through our customers (i.e.,Merchants). You may directly or indirectly give us information about yourself in a variety of ways, such as when you place an order on a merchant’s site, choose to pay with one of UAB Alternative Payments payment methods, contact us, use our Merchant Portal or any other UAB Alternative Payment service where you submit personal data.
- Personal and contact information: name, date of birth, national identification number, government identification numbers such as: driver’s license, state identification, passport, social security or tax identification number, address, e-mail address, mobile and land line telephone number, title, billing and shipping address. We are under legal obligation to collect documentation of such information, for example in the form of copies of your passport or driver’s license.
- Payment information: bank account number, invoice information, credit and debit card data
- Historical information: your purchase and payment acceptance history
- Financial information: your income, turnover, negative payment remarks, type of agreement, transactional data
- Information on goods/services: details about the items you purchase
- Information related to legal requirements: country of taxation or foreign tax payer reference, customer due diligence and anti - money laundering requirements
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number
- Geo-Location Information, some devices allow applications to access real-time location based information (for example GPS). Our applications may collect such information from your device at any time while you download or use our services. We may use this information to optimize your experience
Special categories of data
UAB Alternative Payments does not collect or process any special categories of personal data.
Personal data we may collect from third parties
We may collect your personal data from third party services either publicly available or engaged by us to verify you against sanction lists (EU, UN sanction lists or OFAC lists) and registers held by tax authorities, company registration agencies and other commercial or non commercial information providers on beneficial owners and politically exposed persons. We also collect information from remitters, shops, banks, payment service providers and others. Our legal basis for collecting, processing and sharing such information about you with third party services as explained in this paragraph is fulfilling our legal obligations, such as preventing, detecting and investigating money laundering, terrorist financing and fraud prevention.
We use your personal data for a variety of reasons and based on different legal basis.
Collecting personal data based on consent
We may use your personal data to send you marketing communication which you requested. These may include information about our products and services, events, activities and promotions of our associated partners’ products or services. This communication is subscription based and requires your consent.
The collection of personal data is based on a consent from, the data subject will be done by using “Consent Forms” that will store documentation related to the consent given by the individual. Individual consent will always be stored and documented in our system. If you have given consent to processing of your personal data you can always withdraw the consent.
Collecting personal data based on contractual necessity
We use your personal data for fulfilling our contractual obligations towards you. It is impossible for us to perform our service to you without collecting and processing your personal data (contractual necessity as legal basis). Examples of contractual necessity as legal basis for your personal data collection and processing are: opening an account with us, processing and/or initiating payment transactions using our services, receiving settlements from us, invoicing, etc.
Collecting personal data based on legal obligations
As registered financial institution we are under legal obligation to process your personal data as part of our KYC requirements, preventing, detecting and investigating money laundering, terrorist financing and fraud prevention, sanction screening, reporting to tax authority, police authorities, supervisory authorities, payment service requirements.
We may also send you information about the products and services that you have purchased from us.
Replies to a “Contact me” or other web forms you have completed on our website.
Follow up on incoming requests (customer support, emails, chats or phone calls).
Notify you of every disruption to our services (system messages).
We also have a legitimate interest to use profiling when monitoring transactions in order to detect fraudulent transactions.
We do not share, sell, rent or trade your personal data with any third parties without your consent, except from what is described below:
We may share with the merchant at which you made your purchase the personal data necessary for the merchant’s performance, support and administration of your order, including disputes. The personal data shared with the merchant will be subject to the merchant's privacy policies and practices.
Third party service providers
We may pass your personal data on to our suppliers, acquirers, payment service providers, banks, clearing and settlement mechanisms and other business partners if necessary for providing our service to you. Before sharing your personal data, we will always ensure that we respect relevant financial industry secret obligation.
For example, if you have asked us to transfer funds, we need to disclose certain information to fulfill such transfer.
We disclose personal data to authorities to the extent we are under statutory obligation to do so. Such authorities may include tax authorities, police authorities, AML authorities, law enforcement authorities and supervisory authorities in relevant countries.
Sub-contractors (processors and sub- processors)
Third country transfer
We may transfer personal data to organizations outside the EU/EEA area. If the sub-contractor (data processor) processes personal data outside the EU/EEA area, such processing is done in accordance with the EU Standard Contractual Clauses for transfer to third countries.
UAB Alternative Payments has taken a number of steps in order to provide an extremely secure service. We use appropriate technical, organizational and administrative security measures to protect any information we hold from loss, misuse, unauthorized access, disclosure, alteration and destruction.
The information is encrypted using secure socket layer technology (SSL) and is stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
Where we have provided you (or where you have chosen) a password or access code which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share any passwords with anyone, you authorize UAB Alternative Payments to act upon instructions and information from any person that enters your user id or password.
You have the following rights in regards to your personal data:
Right of Access
You have the right to request a copy of your personal data we hold about you. In the most of the cases this information is already presented to you in your online services from us. Your right to access may, however, be restricted by legislation and protection of other person’s privacy rights.
Right to Rectification
You have the right to request from us to correct your personal data if inaccurate, incomplete or out of date.
Right to be Forgotten
You have the right to request that your personal data is deleted when it is no longer necessary for us to retain such data. Please note that due to the financial sector legislation we are in many cases under statutory obligation to retain personal data on you not only during the customer relationship but also for many more years after. For more details please see Section 7. How long we keep your personal data.
Right to Restriction of Processing
If you contest the correctness of the data which we have registered about you or lawfulness of processing, or if you have objected to the processing of the data in accordance with your right to object, you may request us to restrict the processing of this data to storing purposes only. The processing will only be restricted to storing until the correctness of the data can be established, or it can be checked whether our legitimate interests overwrite your interests. If you are not entitled to deletion of the data which we have registered about you, you may instead request that we restrict the processing of this data to storing purposes only. If the processing of the data which we have registered about you is solely necessary to assert a legal claim, you may also demand that other processing of this data be restricted to storing purposes only. We may process your data for other purposes if this is necessary to assert a legal claim or if you have granted your consent to this.
Right to Object
You can always object to the processing of your personal data for direct marketing band profiling in concern to such marketing.
Right to Data Portability
You have the right to receive the personal data that you provided to us in a machine-readable format. This right applies to personal data processed only by automated means and on the consent or fulfilling a contract basis. Where secure and technically feasible the data can also be transmitted to another data controller by us.
Right to Complain to Supervising Authority
If you are not satisfied with the way in which we process your personal data you may in the first instance contact firstname.lastname@example.org. UAB Alternative Payments has appointed a Data Protection Officer that you can contact by sending a message to email@example.com. If you remain dissatisfied then you have the right to apply directly to your national supervisory authority for a decision. To find your national supervisory body please go to http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
Right to Withdraw your Consent to e-marketing
In the case you want to withdraw your consent from e-marketing, please make use of the link to manage your subscription included in our communication. Please note that you may still receive system messages and notifications about your account activities.
Your request to exercise your rights as listed above will be assessed given the circumstances in an individual case. Please bare in mind that we may also retain and use your personal data as necessary to comply with legal requirements, resolve disputes and or enforce our agreements.
Any query about your Privacy Rights should be sent to firstname.lastname@example.org.
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Your data will be kept as long as it is necessary for the purposes for which the data was collected and processed or as long as it is required by law.
Please note that we are under legal obligation to retain your data for the following statutory retention period
- Preventing, detecting and investigating money laundering, terrorist financing and fraud - minimum of five years after termination of contractual relationship
- Bookkeeping regulation - up to ten years
- Payment services requirement - five years
- Agreement performance details - up to ten years after termination of customer relationship to defend against possible claims
This statutory retention period list is not complete and is given as an example only.
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