We, in company UAB „Findo finansai“, legal entity code 304452187, having its registered office at J. Savickio str. 4, Vilnius, the Republic of Lithuania, with correspondence address at Vilniaus str. 31, Vilnius, the Republic of Lithuania (“Company”), respect your privacy and are committed to protecting personal information that will be delivered to us during your use of software platform developed by the Company – the Fin.do mobile application (“Fin.do app”). Fin.do app is a mobile application which facilitates a card to card payment service, consisting of debiting the payment card account of the sender upon his/her order and crediting the payment card account of the recipient.
This policy sets out the basis on which all personal data we have collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will use your personal data and our practices regarding your personal data.
Collection and use
We collect your personal data through the Fin.do app after you download it and input your details. We only collect necessary personal data about you which does not include any special types of information. This includes:
- Full name,
- Data of the payment card of the user: number, validity date, CVV number¹,
- Data about ordered transaction,
- Phone number,
- Email address,
- Photo of the face of the user,
- Mobile phone contacts,
- Type of the user’s ID document,
- Photo of the front and the end of the ID document;
- Date of birth,
- Country (including country having issued the ID document of the issuer and country having issued the payment card).
We undertake to:
- process your personal data lawfully, fairly and in a transparent manner,
- not to further process your data in a manner that is incompatible with the specified, explicit and legitimate purposes for which your data was collected,
- ensure to collect only personal data that is adequate, relevant and limited to what is necessary in relation to the collection purposes,
- take steps to ensure that your personal data that is inaccurate, would be erased or rectified without delay,
- process your personal data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
¹The Company will retain and store only partial payment card number (only first 4 or 6 digits and last 4 digits) as well as the expiration date of the payment card, all the remaining information will be transferred to a third party payment service provider for the provision of services on the Fin.do app.
We need your personal information to provide you the possibility to use the Fin.do app – a software platform aimed at facilitating card to card payment services. Accordingly, processing of your data is necessary for the performance of a contract between you and us for the using of the Fin.do app. We will use your name and email address to notify you about discounts and new services offered by the Company under the basis of our legitimate interest – to inform our clients about our services and updates. We will also use your personal data for the following purposes:
- to notify you about changes to our service, provide you with important information and required notices,
- to improve the Fin.do app and to ensure that service is provided in the most effective manner for you and for your device,
- to keep the Fin.do app safe and secure,
- to verify your identity.
We will not collect any personal data from you we do not need in order to provide and oversee this service to you. We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We would like to use your name and email address to inform you of our future offers and similar products. This information is not shared with third parties and you may unsubscribe at any time. In every marketing message we will provide you with a clear, free-of-charge and easily realizable possibility to unsubscribe from such marketing messages.
We may disclose your personal data under a personal data disclosure contract in the case of a multiple disclosure or in response to a request of the data recipient in the case of a single disclosure. Your personal data may be shared with a licensed payment service provider that provides the transaction authorization and transaction settlement services as well as with third party provider that provides identity verification and background checks. We may transfer your data outside of the European Economic Area, including countries which have different data protection standards than those which apply in the European Economic Area. Any such transfer of your personal data will be carried out in compliance with applicable laws. For transfers outside the European Economic Area, we will use Standard Contractual Clauses (and you have a right to ask for a copy of these clauses) and Privacy Shield as safeguards for countries without adequacy decision from the European Commission.
We will retain your personal data for as long as you use the Fin.do app and for a reasonable time thereafter. Your personal data will not be stored longer than it is necessary for the data processing purposes. Your personal data will be deleted when it is no longer needed for the processing purposes. We will store your personal data for 10 years after the end of the provision of Service and your usage of Fin.do app. Your data processed for marketing purposes is stored during the provision of service and usage of Fin.do app and for a maximum of 3 years after the end of the provision of service and usage of Fin.do app, unless you object to the processing for marketing purposes sooner. You may contact us if you would like us to delete personal data that you have provided via the Fin.do app. Please note that some or all of the provided personal data may be required in order for the Fin.do app to function properly.
If at any point you believe the personal data we process is incorrect you may request to see this information and have it corrected or deleted. You also have the right to request access to your personal data or restriction of processing of your data as well as the right to data portability and the right to erasure (“right to be forgotten”). We may not be able to implement certain of your rights, such as the “right to be forgotten”, if it is necessary to apply safeguards, in particular to prevent the destruction of data or evidence based on and in accordance with the requirements of the applicable laws and regulations. If you wish to raise a complaint on how we have handled your personal data, you can contact us and we will investigate the matter.
You have a right to object at any time to processing of your personal data concerning you for direct marketing purposes. If you object to processing of your personal data for direct marketing purposes, we shall no longer process your personal data for such purposes.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you have the right to lodge a complaint with your national data protection authority (the list of all such authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).
You may contact us regarding your privacy and your rights via Help Centre of the Fin.do app or website of the Company www.fin.do.