Effective Date: January 30, 2025

This Privacy Policy describes the policies and procedures of UAB Globopay, registered at J. Savickio g. 4-7, 01108, Vilnius, Lithuania, hereinafter referred to as "we", "our", or "us", related to the collection, use, and disclosure of your personal information. The Privacy Policy sets forth the basic rules and principles by which we process your personal data and outlines our responsibilities while processing your personal data in accordance with transparency obligations under the General Data Protection Regulation (GDPR).

1. Overview

In order to access Wallet services and identify you when registering or authorizing, we ask for personal information such as a mobile phone number or email address to ensure the security of your account and prevent unauthorized access. We do not share your information with third parties except to provide you with Third Party Services.

2. Acceptance of this Policy

By using the Wallet, you consent to the use, disclosure, and practices set forth in this Privacy Policy. If you do not agree with this policy, please do not use our services.

3. Personal Information We Collect

We collect the following types of personal information:

• Personal Information: Phone number or email address.
• Other Required Information:
  • Public addresses of your accounts that you received in our Wallet.
  • The IP address of the device you are using to access the Wallet.
  • The type of browser and operating system you are using.
  • The date and time you access or use the Wallet.
  • Other traffic data that does not allow direct identification.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: When you provide your data voluntarily.
• Contractual Necessity: To perform our obligations under the agreement with you.
• Legitimate Interests: To improve our services and ensure the security of your assets.
• Legal Obligations: To comply with applicable laws and regulations.

5. Collection of Information by Third-Party Services

Some services in the Wallet are provided by third-party organizations, such as processing bank cards when buying cryptocurrency or conducting KYC (Know Your Customer) procedures. These third-party services collect, transmit, and store your personal information on their resources. By submitting personal information to third-party services, you consent to the processing of your data by these third parties. Please note that your use of these Third Party Services is subject to their respective Terms of Service and Privacy Policy. We use and disclose any information collected in accordance with our own Privacy Policy.

If your data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, such as standard contractual clauses approved by the European Commission.

6. Use of Collected Information

We use the limited information we collect for the following purposes:

• To improve the operation of the Wallet.
• To keep your assets safe.
• To comply with legal and regulatory requirements.

We may share your Personal Information with our employees, contractors, agents, service providers, and designees ("Agents") to enable them to provide certain services exclusively for us, including:

• Improvement of services and functions related to maintenance.
• Business transfers, such as mergers or acquisitions.
• Buying or selling assets.

In these matters, customer information is usually one of the transferred business assets.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, this period is 3 years, unless a longer retention period is required by law.

8. Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data:

• Right to Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request corrections to inaccurate or incomplete data.
• Right to Erasure: You can request the deletion of your data under certain conditions.
• Right to Restrict Processing: You can request the restriction of processing your data.
• Right to Data Portability: You can request a copy of your data in a machine-readable format.
• Right to Object: You can object to the processing of your data for specific purposes.
• Right to Withdraw Consent: If processing is based on consent, you can withdraw it at any time.

To exercise these rights, please contact us at [email protected].

9. Data Security

We are committed to protecting your information and employ several physical and electronic safeguards to keep your information secure, including:

• Encrypted user passwords.
• Two-factor verification and password authentication.
• Industry-standard transport layer security (TLS) for all connections.

Despite these precautions, we cannot fully guarantee against access, disclosure, alteration, or deletion of data due to events such as hardware or software failure or unauthorized use. Any information you provide to us is transmitted at your own risk.

10. Use of Cookies

We use cookies to enhance your experience on our website. Cookies are small text files stored on your device that help us analyze web traffic and improve our services. You can manage your cookie preferences through your browser settings.

11. Changes and Updates to the Privacy Policy

We reserve the right to update and revise this Privacy Policy at any time to comply with applicable laws and changes in our business. If we revise this Privacy Policy, we will update the "Effective Date" and notify you via email or through a notice on our website. Your continued use of the Wallet after such changes constitutes your acceptance of the revised Privacy Policy.

12. International Users and Visitors

The Wallet is hosted in the European Union. If you are accessing the Services from outside the EU, please note that your personal data will be transferred to and processed in the EU. By using our Services, you consent to such transfer and processing.

13. Contact Information

If you have any questions about this Privacy Policy, your personal data, or if you would like to exercise any of your data protection rights, please contact us using the following contact details:

• Email: [email protected]
• Phone: +370 667 521 35

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the Lithuanian Data Protection Authority (State Data Protection Inspectorate).

14. Data Protection Officer

If you have any questions regarding data protection, you can contact our Data Protection Officer (DPO) at [email protected].