2. The principles we strictly follow to comply with the needs to protect your Personal data are as follows:

a. Principle of legality, fairness and transparency which means that Personal data with respect to you is processed in a lawful, honest and transparent way;

b. Purpose limitation principle which means that Personal data is collected for specified, clearly defined and legitimate purposes and shall not be further processed in a way incompatible with those purposes;

c. Data reduction principle which means that Personal data must be adequate, appropriate and only which is necessary for the purposes for which it is processed;

d. Accuracy principle which means that Personal data must be accurate and, if necessary, updated; all reasonable steps must be taken to ensure that Personal data which is not accurate in relation to the purposes for which it is processed shall be immediately erased or corrected;

e. The principle of limitation of the length of the storage which means that Personal data shall be kept in such a way that your identity can be determined for no longer than is necessary for the purposes for which Personal data is processed;

f. Integrity and confidentiality principle which means that Personal data shall be managed by applying appropriate technical or organizational measures in such a way as to ensure the proper security of Personal data, including protection from unauthorized processing or processing of unauthorized data, and against accidental loss, destruction or damage.

1. According to the other purposes of processing of the Personal data above, the following Personal data is processed by us (it includes, but is not limited):

a. name, surname, personal code, date of birth, age (year of birth), address, residence place, identification card (passport) number, issuance place and date, mobile phone number, email address, employment data;

b. Clients (natural persons) - photo, signature, financial institution account number, IBAN number, debit card number, video and audio record for identification, telephone conversations, Client IP addresses, date of Client transactions, amount of transactions, currency, location, data about the beneficiary of the funds, the history of the actions performed, the source of funds, sex, nationality, employment status;

c. Representatives of the Clients (legal entities) (members of the Client's management bodies and other representatives (for example, employees) who are authorized according to the corporate documents to represent the Client in relations with the data controller or acting in accordance with the power of attorney, procuration when representing the Client): personal code, personal identity document data, e-mail address, sex, position, surname, address, nationality, phone number, name, photo, signature, bank account information (bank name and bank account number), monetary transaction or transaction date, amount, currency , data about the beneficiary of the funds (natural person's name, surname, date of birth, personal identification number or other unique character assigned to this person to identify the person, legal entity name, legal form, registered office address, code, if any);

d. Ultimate beneficiary owners of the Clients (legal entities) (natural persons who directly or indirectly own or control a legal unit with a sufficient number of shares or voting rights, including through bearer share management): personal identification code, identity card, sex, surname, address , nationality, name, photo, signature, number of shares held, voting rights or share capital part, monetary transaction or transaction date, amount, currency in which the monetary transaction or transaction is executed, data about the beneficiary of funds (natural person's name, surname, date of birth, personal identification number, or other unique character assigned to this person to identify the person, legal entity name, legal form, registered office address, code, if any);

e. Partners (natural persons) – name, surname, personal code, address, mobile telephone number, e-mail, signature, the account of the financial institution, the data of payments made by partners, amount of payments, other related data;

f. Partners (legal entity) – name, surname, position, signature, mobile telephone number, e-mail, the basic of representation, other related data;

g. The person who is contacting us – name, surname, personal code, phone number, address and other data which is provided by the person who is contacting us.

3. The terms of data retention of the Personal date for the purposes of the processing of the Personal data as specified in this Privacy Policy are as follows:

a. Direct marketing: until your consent is valid regarding the use of your Personal data for the purpose of direct marketing;

b. Provision of services of issuance, distribution and redemption of electronic money and provision of payment services: Personal Data collected for this shall be stored in accordance with the Index of the Retention Periods of General Documents approved by the order of the Chief Archivist of Lithuania and the legal acts applicable to our activities;

c. Conclusion and execution of the agreements: Personal Data collected for this shall be stored in accordance with the Index of the Retention Periods of General Documents approved by the order of the Chief Archivist of Lithuania and the legal acts applicable to our activities;

d. Implementation of the obligations under the Law on Money Laundering and Terrorist Financing Prevention of the Republic of Lithuania and Client’s identification: 8 (eight) years after the termination of the business relationship with you. The retention period may be extended for a period not exceeding 2 (two) years, provided there is a reasoned request from a competent authority. Such data retention period is required by the Law on Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania.

5. Your Personal data specified in this Privacy Policy may be transferred to:

a. supervisory authorities, credit, financial, payment and/or electronic money institutions;

b. pre-trial investigation institutions, the State Tax Inspectorate;

c. To any of our partners, payment service agents (if the operation is carried out using their services), who are necessary part of the provision of our products and services;

d. to our contractors or service providers for the purpose of conducting business and providing services or products to You, including web hosting providers, IT system administrators and payment processors;

e. to service providers, who makes Your identity verification using their IT solution;

f. beneficiaries of transaction funds receiving the information in payment statements together with the funds of the transaction;

g. debt collection and recovery agencies, companies processing consolidated debtor files;

h. lawyers, bailiffs, auditors;

i. other entities, including any government regulatory having a legitimate interest;

j. other entities under an agreement with us.

7. Please note that we respect your as data subjects’ rights and due to that we are very carefully by choosing our partners, including Personal data processors and / or sub-processors. In case if Personal data processors and /or sub-processors are based in third countries, we transmit your Personal data to such processors and / or sub-processors only with the application of the standard contractual clauses (the European Commission’s decision of 5 February 2010 on standard contractual clauses for the transfer of Personal Data to processors established in third countries which do not ensure an adequate level of data protection). The standard contractual clauses may be not applied in cases if Personal data processors and /or sub-processors in third countries are:

a. recognized by the European Commission as providing an adequate level of protection for Personal Data;

b. covered by a suitable framework recognized by the relevant authorities or courts as providing an adequate level of protection for Personal Data, including but not limited to binding corporate rules.

3. We use the following cookies:

a. Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website and enter into transactions;

b. Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We use Google Analytics cookies. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit this site.

c. Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

1. Following the requirements of the legal acts regulating protection of Personal data, we shall guarantee the following rights for you:

a. to know about processing of Personal data;

b. to have access to your Personal data and processing thereof;

c. to have your Personal data rectified;

d. to object to processing of your Personal data;

e. to transfer your Personal data to another data controller or provide directly to you in a convenient format (NOTE: applicable to the Personal data which is provided by you and which is processed by automated means on the basis of consent or on the basis of conclusion and performance of the contract);

f. to request to erase Personal data if superfluous Personal data is processed or another ground provided for in the General Data Protection Regulation exists;

g. to request to restrict data processing if a ground provided for in the General Data Protection Regulation exists;

h. to withdraw the consent given to us;

i. to lodge an appeal to the State Data Protection Inspectorate;

j. other rights established in the General Data Protection Regulation and other applicable legal acts.