Privacy Policy

Effective as of 14^t^h of June 2022

Nandi Pay respects your privacy and is committed to protect your personal data. This Privacy Policy (“Policy”) describes how we may collect and use personal information, and the rights and choices available to our visitors and users.

In this Policy, you will find the answers to the following questions:

who we are;
how we use your data;
when we disclose your data to others;
how long we store your data;
when we send our communications;
what rights related to personal data you possess;
other issues that you should take into account.

In case of any inquiries or if you would like to exercise any of your rights provided in this Policy, you may submit such inquiries and requests by contacting our Data Protection Officer regarding all privacy related issues by email: privacy@nandipay.com.

Important information and who we are
In this Policy we, Nandi Finance, UAB, legal entity’s code 305138937 (“Nandi Pay”), inform you how we look after your personal data collected when you visit our website and use our services. Nandi Finance, UAB is the controller of such data and is responsible for this website.
Our website incorporates privacy controls that enable you to decide how we will process your personal data. By using privacy controls, you can specify whether you would like to receive our email messages (newsletters).
How we use your personal data?
1. This Section provides the following information:
  1. categories of personal data that we process;
  2. in case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  3. purposes for which we may process your personal data; and
  4. legal basis of the processing.
2. We process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We obtain such data through use of cookies and similar technologies. We process such data to have a better understanding of how you use our website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services, and accommodating the services for individual interests of every user.
3. We process information relating to provision of services by us to you (“service provision data”). The service provision data may include your contact details, bank account details, including the account number, sort code and IBAN and information, related to services (details of your debit cards and credit cards, including the card number, expiry date and CVC (the last three digits of the number on the back of the card). The service provision data is processed to provide services and keep proper records of transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
4. We process information relating to the proper establishment of your identity (“identification data”). The identification data may include your identification data, copies of any documents you have provided for identification purposes (for example your passport or ID card), a personal description and photograph of you and any other information you provide to prove you are eligible to use our services. The identification data is processed to ensure the prevention of money laundering and terrorism financing. The legal basis for this processing is legal requirements of anti-money laundering and counter-terrorism financing.
5. We process biometric data from facial image/s, processed only during the remote identification process (“biometric data”). Such processing is necessary for compliance with a legal obligation to which Nandi Pay is subject, i.e. legal requirements of anti-money laundering and counter-terrorism financing (Article 6(1)(c) of the General Data Protection Regulation) also based on data subject’s consent as confirmed below (Article 9(2)(a) of the General Data Protection Regulation).
6. We process information on transactions (“transaction data”). The transaction data may include payments into and out of your account), including the date, time, amount, currencies, exchange rate, beneficiary details, details of the merchant or ATMs associated with the transaction, your personalised payment card details, IP address of sender and receiver, sender’s and receiver’s name and registration information, details of your payment account, also deposit transfers to your payment account and deposit withdrawals back to your account opened with us, messages sent or received with the payment, details of device used to arrange the payment and the payment method used. The service provision data is processed to provide services and keep proper records of transactions. The legal basis for this processing is the performance of a contract between you and us.
7. We process data from your and (or) your company profile (“profile data”). The profile data may include your first and last name, email address, phone number and other contact details, position in the company (if our client is legal entity), your username, password and other registration information. We obtain such data directly from you or, upon your choice, from your profile. We process profile data for the purposes of operating our website, providing our services, ensuring the security of our website and services and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, as well as our legitimate interests, namely monitoring and improving our website and services.
8. We may process information that you provide when applying for a job or other position (“career data”). The career data may include your first and last name, email address, phone number, information about your education and professional experience and other data that you provide in your CV and application form. We process career data to enable recruitment process. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, as well as our legitimate interests, namely making decision about your recruitment and ensuring business continuity.
9. We may process information that you provide to us for subscribing to our email messages (newsletters) (“messaging data”). The messaging data may include your name and email address. We process messaging data for the purposes of sending to you relevant email messages and newsletters. The legal basis for this processing is your consent.
10. We may process information relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. In case of communication through our website, the website will generate metadata associated with communications made using the website contact forms. We process correspondence data for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, ensuring uniform and high quality consultation practice and for investigating disputes between you and our employees.
11. We may process any of your personal data identified in this Policy where necessary for the establishment, exercise or defence of legal claims. The legal basis for this processing is legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
12. We may process any of your personal data identified in this Policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
13. In addition to the specific purposes set out in this Section, we may also process any of your personal data where such processing is necessary to comply with our legal obligations or to protect the vital interests of any individual.
When we disclose your data to others?
1. We may disclose your personal data to our banking and financial services partners and payments networks, including Visa and Mastercard, also payment systems administrators including the Bank of Lithuania insofar as reasonably necessary for the purposes of providing the services to you.
2. We may disclose your personal data to our professional advisers (including lawyers, bankers, auditors and insurers) insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice or the establishment, exercise or defence of legal claims.
3. We may disclose your personal data to our anti-fraud, risk and compliance solution providers insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.
4. We may disclose your personal data to other service providers (including server maintenance, email service and other IT services providers, advertisement service providers and others) insofar as reasonably necessary for the provision of specific services.
5. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary to comply with our legal obligations or to protect the vital interests of any individual.
7. Third parties, indicated in this Section, may be established outside the European Economic Area (“EEA”). In case we transfer your personal data out of the EEA, we will take all the necessary measures to ensure that your privacy remain properly secured, including, where appropriate, signing standard contractual clauses for the transfer of data. To find out more information regarding appropriate safeguards, you may contact our Data Protection Officer via email: privacy@nandipay.com.
How long we store your data?
1. Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case, we ensure that your:
  1. service provision data will be retained for no longer than 10 (ten) years following the end of provision of services;
  2. identification data will be retained for no longer than 8 (eight) years following the end of provision of services;
  3. transaction data will be retained for no longer than 10 (ten) years following the end of provision of services;
  4. profile data will be retained for no longer than 10 (ten) years following the end of provision of services;
  5. career datawill be retained for no longer than 1 (one) year following the provision of such data;
  6. messaging datawill be retained for no longer than 3 (three) years following the provision of consent, unless you withdraw your consent earlier;
  7. correspondence data will be retained for no longer than 1 (one) year following the end of such communication.
2. In some cases, it is not possible for us to specify the retention period in advance. Therefore, your usage data will be retained for as much as will be necessary for the relevant processing purposes.
3. Notwithstanding the other provisions of this Section, we may retain your personal data longer than indicated in this Section, where such retention is necessary to comply with our legal obligations or to protect the vital interests of any individual.
When we send our communications?
1. In case you consent, we will send you email messages (newsletters) to inform you on what we are up to.
2. You may opt-out of receiving our email messages (newsletters) at any time.
3. You may do so by:
  1. clicking on the relevant link in any of our email messages (newsletters);
  2. contacting our Data Protection Officer via email: privacy@nandipay.com.
4. Upon completing any of the provided actions, you will not receive our email messages (newsletters) in the future.
5. Please be informed that as our business activities consists of a network of closely related services, it may take a few days until all the systems are updated, thus you may continue to receive our email messages (newsletters) while we are still processing your request.
6. The opt-out of email messages (newsletters) will not stop you from receiving messages directly related to and necessary for the provision of our services.
What rights related to personal data you possess?
1. In this Section, we have summarised the rights you have under the data protection laws. Some of those rights are complex thus we only provide the main aspects of such rights. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full understanding of these rights.
2. Your principal rights under the data protection laws are the following:
  1. the right to access your personal data;
  2. the right to rectification of your personal data;
  3. the right to erasure of your personal data;
  4. the right to restrict processing of your personal data;
  5. the right to object to processing of your personal data;
  6. the right to data portability;
  7. the right to lodge a complaint with a data protection authority; and
  8. the right to withdraw consent.
3. The right to access your personal data. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
4. The right to rectification of your personal data. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to the erasure of your personal data. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defence of legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful, but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted, we may continue to store your personal data, however we further process such data in any other way only: (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: (i) the performance of a task carried out in the public interest; or (ii) the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds, which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out in the public interest.
10. The right to data portability. To the extent that the legal basis for our processing of your personal data is:
  1. consent; or
  2. performance of a contract or steps to be taken at your request prior to entering into a contract,
    you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11. If you consider that our processing of your personal information infringes data protection laws, you have the right to lodge a complaint with a data protection authority. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of Lithuania, registered office at L. Sapiegos St. 17, LT-10312 Vilnius, website https://vdai.lrv.lt/.
12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
13. We try to respond to all legitimate requests within 1 (one) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
14. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Third party websites
On the website you may find links to and from partner sites, information sources and related party websites. Please take note that such third party website that you will visit by clicking on links have their own privacy policies and we take no responsibility regarding such privacy policies. We recommend familiarising with privacy policies of such websites before providing any personal data to such.
Cookies
1. We use cookies to analyse how you use Nandi Pay website. Please read the Cookies Policy for more information about cookies.
Children personal data
1. Our website and services are targeted at persons over the age of 18 or another age under respective country’s law which allow you to assume responsibility for obligations emerging from contractual relations and have a full capacity to take legal actions.
2. If we have reason to believe that we hold personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.
Updating your data
Please let us know if the personal information about you that we hold needs to be corrected or updated.
Changes to the privacy Policy
We keep our Privacy Policy under regular review. Any changes to this Policy will be published on our website.