UAB “ZEN.COM”, company code 304749651 (hereinafter – the Company or we), registered address at Lvivo g. 25-104, LT-09320, Vilnius, the Republic of Lithuania, is an electronic money institution, holding a license No. 35 issued by the Bank of Lithuania on 24 of May 2018.
As we collect and use personal data (hereinafter – the Personal Data), we are obligated to use and process your Personal Data only in accordance with this Privacy Policy (hereinafter – the Privacy Policy), as well as, applicable legislation, including the General Data Protection Regulation (2016/679) (hereinafter – GDPR), the Law on Money Laundering and Terrorist Financing Prevention of the Republic of Lithuania, Law on Legal protection of personal data of the Republic of Lithuania and other applicable legal acts.
Please note that in case you provide us with the information about any person other than yourself, your employees, counterparties, advisers or suppliers, you must ensure that they understand how their information will be used.
This Privacy Policy provides basic rules for collecting, storing, processing and retention of your Personal Data and other information relating to you, as well as, the scope of processed Personal Data, the purposes, sources, recipients and other important aspects of data processing in using our services as an electronic money institution.
These definitions should help you understand this Privacy Policy and add clarity to any terms we use:
We regularly review this Privacy Policy and reserve the right to modify it at any time in accordance with applicable laws and regulations. Any changes and clarifications will take effect immediately on the date on which we post the modified terms on our website: www.zen.com.
Please check this Privacy Policy occasionally to ensure that you are happy with any changes.
You can contact us by writing to us at [email protected] or post us at UAB “ZEN.COM” – Lvivo g. 25-104, LT-09320 Vilnius, Lithuania.
You can also contact our Data Protection Officer by sending an e-mail to the address: [email protected].
The principles we follow in order to comply with the need to protect your Personal Data are the following:
Your Personal Data is considered as confidential information and may only be disclosed to third parties in accordance with the rules and procedure provided in this Privacy Policy and the applicable legal acts.
Please note that in case you provide us with the information about any person other than yourself, your employees, counterparties, advisers or suppliers, you must ensure that they understand how their information will be used.
The categories of Personal Data that we may collect about you are as follows:
Please be informed that other data not listed above that relate to the provision of our services or which you have provided to us may also be collected.
We use information held about you in the following ways:
1. Conclusion of the contract or for performance of measures at your request prior to the conclusion of the contract (to get to know, identify and verify our clients):
For this purpose we may process your Basic Personal Data, Identification and other background verification Data, Contact Information and other Personal Data (in order to identify the possibility of providing services).
The legal basis for the processing of the above-mentioned data is: concluding a contract with you, fulfilling our legitimate interests and/or fulfilling the legal obligations applicable to us.
2. For the fulfilment of a contract concluded with you, including but not limited to provision of services of issuance, distribution and redemption of electronic money and provision of payment services:
For this purpose we may process your Basic Personal Data, Identification and other background verification Data, Transaction Data, Information which is related to legal requirements, Contact
Information and other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services.
The legal basis for the processing of the above-mentioned data is: performance of a contract signed with you, fulfilling our or third parties’ legitimate interests and/or compliance with legal obligations applicable to us.
3. To comply with legal obligations (e.g. implementation of the obligations under the Law on Money Laundering and Terrorist Financing Prevention of the Republic of Lithuania and other fraud and crime prevention purposes) and risk management obligations):
For this purpose we may process your Basic Personal Data, Identification and other background verification Data, Transaction Data, Information which is related to legal requirements, Contact
Information and other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. The legal basis for the processing of the above-mentioned data is: fulfilling our or third parties’ legitimate interests and/or compliance with legal obligations applicable to us.
4. To provide an answer when you contact us through our website or other communication measures:
For this purpose we may process your Basic Personal Data, Contact Information and other Personal Data provided to us by or on behalf of you.
The legal basis for the processing of the above-mentioned data is: your consent, fulfilling our or third parties’ legitimate interests.
In order to make your identity verification, we are using the facial recognition solutions provided by iDenfy and Veriff (Identification solution). Please read more about solutions here: https://www.idenfy.com/, https://www.veriff.com/
You will not be asked to complete the Identification solution procedure unless we are required to confirm your identity pursuant to the applicable laws and regulations – for example before a new ZEN account is created for you.
Identification solution is used for comparing live photographic data or video record of yourself and your ID card/passport, to comply with legal obligations (e.g. implementation of the obligations under the Law on Money Laundering and Terrorist Financing Prevention of the Republic of Lithuania and other fraud and crime prevention purposes) and risk management obligations.
The result of the face recognition (match or mismatch) will be retained for as long as it is necessary to carry out identity verification and for the period required by anti-money laundering laws.
We conduct your face recognition using Identification solution on a consent basis. If you do not feel comfortable with this method, you may contact us by email for alternative way to identify yourself.
We want to make it clear how we use your Personal Data for marketing purposes.
We may use our existing clients’ e–mail for the marketing of our similar goods or services, unless you object to the use of your e-mail for the marketing of our similar goods and services. You are granted with a clear, free of charge and easily realisable possibility to object or withdraw from such use of your contact details on the occasion of each message.
We may also provide the information to you as our client about our products or services by sending messages through the application. Such messages may be viewed in the notification center, in case you do not choose the “opt-out” function in our application.
In other cases, we may use your Personal Data for the purpose of direct marketing, if you give us your prior consent regarding such use of data.
We are entitled to offer the services provided by our business partners or other third parties to you or make assessments about your opinion on different issues in relation to our business partners or other third parties on the legal basis for this, i.e. on the basis of a prior consent.
In case you do not agree to receive these marketing messages and/or calls offered by us, our business partners or third parties, this will not have any impact on the provision of services to you as the client.
We provide a clear, free-of-charge and easily realisable possibility for you at any time not to give your consent or to withdraw your given consent for sending proposals put forward by us. We shall state in each notification sent by e-mail that you are entitled to object to the processing of the Personal Data or refuse to receive notifications from us. You shall be entitled to refuse to receive notifications from us by clicking on the respective link in each e-mail notification.
We obtain personal information from you when you provide it directly to us. For example, when becoming a new client or when you provide us information through direct communication (e.g. completing a form on our website or mobile application, registration for our services), by access and use of our website or mobile application, by setting up an account with us, when you subscribe to our electronic publications (e.g. newsletters).
We also collect personal information about you from third parties, mainly:
We may disclose and/or transfer your Personal Data only in accordance with legal regulations and the principles of confidentiality to the following categories of recipients:
We may also disclose your Personal Data, if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
As we provide international services, your Personal Data may be transferred and processed outside the European Union (hereinafter – the EU) and the European Economic Area (hereinafter – the EEA).
The transfer of Personal Data may be considered as needed in such situations as, e.g.:
When we transfer your Personal Data internationally, we put in place safeguards in accordance with applicable laws and in accordance with this Privacy Policy and we will ensure that it is protected and transferred in a consistent way with the legal requirements applicable to the Personal Data.
There are different ways to ensure that your Personal Data is treated securely, mainly:
We may transfer Personal Data to a third country by taking other measures if it ensures appropriate safeguards as indicated in the GDPR.
In some cases, we may use automated decision-making which refers to a decision which is taken solely on the basis of automated processing of your Personal Data.
Automated decision-making refers to the processing using, for example, a software code or an algorithm, which does not require human intervention.
We may use forms of automated decision-making on processing your Personal Data for some services and products. When using automated decision-making we will provide you with further information about the logic involved, as well as the significance and the envisaged consequences to you.
Please be informed that you can request a manual review of the accuracy of an automated decision in case you are not satisfied with it and you have the right not to be subject to a decision based solely on such automated processing.
We have taken a number of security measures to guarantee the safety of your Personal Data. We adopt appropriate data collection, storage and processing practices, and security measures for protection against unauthorized access, loss, misuse, accidental or unlawful destruction, modification, disclosure, unauthorized access or any other unlawful handling. We take all appropriate measures to ensure you’re your Personal Data is handled securely.
The Company and any third-party service providers that may engage in the processing of Personal Data on our behalf (for the purposes indicated above) are also contractually obligated to respect the confidentiality of the Personal Data.
The length of time we retain your Personal Data is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. It means that we will keep your Personal Data for as long as it is needed for the purposes for which your data was collected and processed but no longer than it is required by the applicable laws and regulations.
The Company will store your Personal Data for as long as it is necessary for providing services and as required by retention requirements in laws and regulations. If the legislation of the Republic of Lithuania does not provide any period of retention of Personal Data, this period shall be determined by us, taking into account the legitimate purpose of the data retention, the legal basis and the principles of lawful processing of Personal Data.
The terms of data retention of the Personal Data for the purposes of the processing of the Personal Data as defined in this Privacy Policy are following:
In the situations when the terms of data keeping are stated in the legislative regulations, the legislative regulations shall be applied.
Please also be informed that under some circumstances, your Personal Data might be stored longer, mainly:
You as a data subject have a number of rights in relation to your Personal Data. Under certain circumstances and in accordance with EU or other applicable data protection laws, you may have the right to:
1. Right to be informed about the processing of your Personal Data
You have the right to get information about which Personal Data concerning we process. However, this right may be restricted by legislation, protection of other persons’ privacy and consideration for the Company’s business concept and business practices. The Company’s know-how, business secrets as well as internal assessments and material may restrict your right of access.
2. Right to rectification of incorrect or incomplete data
If it turns out that we process Personal Data about you that is inaccurate, you have the right to request a rectification of the Personal Data. You can also request to have incomplete Personal Data about you completed.
3. Right to erasure
You have the right to have any or all of your Personal Data erased. Provided we do not have any continuing lawful reason to continue processing or holding your Personal Data, we will make reasonable efforts to comply with your request. In certain cases, we cannot erase all of your Personal Data. In such case this would be due to the fact that we need to store your Personal Data due to a contractual relationship or law.
4. Right to restriction of processing of your Personal Data
You may also ask us to restrict processing your Personal Data for a period of time. This can pertain, for example, to a situation where you believe it is unlawful for us to do so and/or data about you is inaccurate and we need to verify it. It can also pertain to a situation where you object to processing that we base on a legitimate interest. In such case we must verify if our grounds override yours;
5. Right to object to any use of your Personal Data which is based on the legitimate interests
Where we rely on our legitimate interests as the legal basis for processing your Personal Data, you have the right to object to us using your Personal Data, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.
6. Right to Personal Data portability
In certain situations you can ask us to transfer your Personal Data to another data controller or provide directly to you in a convenient format (NOTE: applicable to 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).
7. Right to withdraw your consent
In certain situations, where we rely on your consent as the legal basis for processing your Personal Data, you may withdraw your consent at any time. In case you withdraw your consent, we will stop that particular processing, when the processing is based on such consent. However, if you withdraw your consent, our use of your Personal Data before you withdraw remains lawful;
8. Right to lodge a complaint with a supervisory authority
You have the right to file a complaint concerning our processing of your Personal Data in the same manner as stated below in Section “Implementation of Your right” of this Privacy Policy. All queries and complaints shall be handled in a timely manner by us in accordance with internal procedures.
In case you consider that our processing of your Personal Data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation, you may also lodge a complaint with a supervisory authority – the State Data Protection Inspectorate. You may apply in accordance with the procedures for handling complaints that are established by the State Data Protection Inspectorate and which may be found by this link: https://www.ada.lt/go.php/Skundu-nagrinejimas378.
We will exercise the above-mentioned rights only after we receive your written request to exercise a particular right indicated above and only after confirming the validity of your identity. Such written request shall be submitted to us by personally appearing at our registered office address, by ordinary mail or by e-mail: [email protected].
Your requests shall be fulfilled or fulfilment of your requests shall be refused by specifying the reasons for such refusal within 30 (thirty) calendar days from the date of submission of the request meeting our internal rules and GDPR. The afore-mentioned time frame may be extended for 30 (thirty) calendar days by giving a prior notice to you if the request is related to a great scope of Personal Data or other simultaneously examined requests. A response to you will be provided in a form of your choosing as the requester.
To ensure our website works correctly, we may at times place a small piece of data known as a cookie on your computer or mobile device.
For more information on how to control your Cookie settings and browser settings or how to delete Cookies on your hard drive, please read the Cookies Policy which is available on our website: <Cookies Policy>.
If you have any questions or concerns regarding how we processes Personal Data about you, or if you wish to exercise any of your rights, the Company encourages you to contact us via e-mail [email protected].