Privacy Policy

UAB PayrNet (“Payrnet”, “we”, “our” or “us”) is the issuer of your payments card and is the Data Controller for the personal data which is provided to us in relation to payment transactions made on the card only. Personal data refers to information which can be used to personally identify you (for example, a combination of your name and postal address). Payrnet is committed to safeguarding the privacy of your personal data that we hold.

This policy explains when and what personal information we collect, how we use it, the conditions under which we may disclose it to others, how we keep it secure and your rights if you want to change how we use your personal data.

We may change this Policy from time to time so please check this page regularly to ensure that you’re happy with any changes.

Who are we?

Payrnet is an e-money institution, authorised and regulated by the Bank of Lithuania. Our registered office address is Girulių g. 20, 12123, Vilnius, Lithuania and our registered company number is 305264430.

When do we collect your personal data?

We collect information when you use your card to make transactions and when there is a chargeback claim.

What personal data do we collect?

We will collect the following information:

• Your name, address, and date of birth;
• Your email address, phone number and details of the device you use (for example, your phone, computer or tablet);
• When you use your card to make transactions, we store that transactional and financial information. This includes the date, amount, currency, account balances and name of the merchant, creditor or supplier (for example a supermarket or retailer).

On what legal basis do we process your personal data?

Contract

We need certain personal data to comply with our contractual obligations to Credit Unions, who in turn, are contractually engaged by you to provide you with the MYCU service.

Legal/Regulatory

We may also process your personal data to comply with our legal or regulatory obligations.

How is your personal data used?

We use your personal data to:

• monitoring your payment transactions for fraud and money laundering and processing chargeback claims.
• manage our website (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content from our website is presented in the most effective way for you and your device.
• We may make automated decisions which means that we may use technology that can evaluate your payment transactions and other factors to predict risks or outcomes (for example, in relation to anti-money laundering and sanctions checks or detecting fraud or financial crime). We do this for the efficient running of our services and to ensure decisions are fair, consistent and based on the right information. Where we make an automated decision about you and your payment transactions, you have the right to ask that it is manually reviewed by a person.

Who do we share your information with?

When we use third party service providers, we have a contract in place that requires them to keep your information secure and confidential. We normally share your personal data with the following types of entities to help us provide our services to you.

• Suppliers who provide us with IT, payment and delivery services
• Communications services providers
• Information security services organisations, web application hosting providers, mailsupport providers, network backup service providers and software/platform developers;
• Document destruction providers;
• Any third party as a result of any restructure, sale or acquisition of Payrnet or any associated entity, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us.
• Regulatory and law enforcement authorities, whether they are outside or inside of the EEA, where the law requires us to do so.

Sending personal data overseas

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• with service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and Lithuanian data protection law.

These non-EEA countries do not have the same data protection laws as Lithuania and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. We will send your data to countries where the European Commission has made an adequacy decision, meaning that it has ruled that the legislative framework in the country provides an adequate level of data protection for your personal information.

Where we send your data to a country where the European Commission has not made an adequacy decision, our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses, please go to the European Commission’s website.

If you would like further information, please contact our Data Protection Officer on the details below.

How long do we store your personal data?

We will store your information for a period of 8 years after our business relationship ends in order that we can comply with our obligations under applicable legislation such as anti-money laundering and anti-fraud regulations. If applicable legislation requires us to retain your data for a longer period of time, we shall retain it for that period. We will not retain your data for longer than is necessary.

Your rights regarding your personal data?

You have certain rights regarding the personal data which we process:

• You may request a copy of some or all of it.
• You may ask us to rectify any data which we hold which you believe to be inaccurate.
• You may ask us to erase your personal data.
• You may ask us to restrict the processing of your personal data.
• You may object to the processing of your personal data.
• You may ask for the right to data portability.
• You can ask us to carry out a human review of an automated decision we make about you

If you would like us to carry out any of the above, please email the Data Protection Officer at [email protected]. For security reasons, we can’t deal with your request if we are not sure of your identity, so we may ask you for proof of your ID.

Payrnet will usually not charge you a fee when you exercise your rights. However, we are allowed by law to charge a reasonable fee or refuse to act on your request if it is manifestly unfounded or excessive.

How is your information protected?

We implement security policies and technical measures in order to secure your personal data and take steps to protect it from unauthorised access, use or disclosure. Electronic data and databases are stored on secure computer systems with control over access to information using both physical and electronic means. Our staff receives data protection and information security training. We have detailed security and data protection policies which staff are required to follow when they handle your personal data.

While we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Complaints

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your personal information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Lithuania is the State Data Protection Inspectorate. Their contact details are as follows:

The State Data Protection Inspectorate

L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania

Tel. +370 (85) 271 28 04, +370 (85) 279 1445; Fax. +370 (85) 261 94 94; E- mail [email protected]

Other websites

Our website may contain links to other websites. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

Changes to our Privacy Policy

We keep our Privacy Policy under review and we regularly update it to keep up with business demands and privacy regulation. We will inform you about any such changes. This Privacy Policy was last updated on 27^th July 2021.

Website cookies

We use cookies to analyse how you use our website. Please read the Cookies Policy for more information about cookies.

How to contact us

If you have any questions about our Privacy Policy or the personal information which we hold about you, please send an email to our Data Protection Officer at [email protected].