Cookies Policy

BEEPAY X PRIVACY POLICY

Protecting your private information is our priority. This Privacy Policy applies to the website and services of BEEPAY X and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to BEEPAY X means BEEPAY X UAB,
a company incorporated and registered in Lithuania with company number 306127961 whose registered office is at Mėsinių g. 5, LT-01133 Vilnius
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By using the BEEPAY X website or services, you consent to the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then we cannot make our website or services available to you and you should stop accessing and using them.

BEEPAY X encourages you to review the privacy statements of websites you choose to navigate to from BEEPAY X so that you can understand how those websites collect, use and share your information. BEEPAY X is not responsible for the privacy statements or other content on websites outside of the BEEPAY X website or software.

This Privacy Policy is provided in accordance with BEEPAY X’ obligations under applicable privacy and data protection law, including Regulation (EU) 2016/679 (GDPR) (Applicable Data Protection Law). Definitions in this Privacy Policy shall be as set out in the Applicable Data Protection Law. For the purposes of this Privacy Policy, the term “personal data” means any information which identifies you or which allows you to be identified when combined with other information. It does not include data where the identity has been removed (anonymous data).

For the purposes of Applicable Data Protection Law, BEEPAY X is a data controller (for example, when collecting personal data from our customers to provide them with an account and/or our financial services, send them marketing information and collecting personal data from our staff and consultants). BEEPAY X may also be a data processor where it processes personal data belonging to another party under their instruction and control. This Privacy Policy primarily applies in the context where BEEPAY X is a data controller.

Collection of your Personal Information

BEEPAY X may collect and process personal data, such as your name and email address if you enter these on the contact form on our website or to fulfil our contractual obligations - to provide our services, invoice and receive payment for services, send legal updates, news and information about our services and related services. We may gather additional personal or non-personal information in the future. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and to others and other details of services you have purchased from us.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device model and other technology on the devices you use to access this website or our software.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Compliance Data includes information required by regulators or law enforcement under compliance procedures (e.g. AML/KYC) or applicable law in connection with efforts to prevent money laundering, criminal activity and terrorist financing, such as relationship to the beneficiary of the transaction, the purpose of the transaction and proof of funds.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. This information is used for the operation of the website and the services provided by BEEPAY X, and to provide general statistics regarding use of the BEEPAY X website and services. In the course of providing our services we may collect Special Categories of Personal Data (such as details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your name, email address and contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

request an account or our services;
download or access our web wallet;
meet with one of our employees or consultants;
participate in an event which we have organised;
complete a form on our website requesting us to contact you;
subscribe to our publications or newsletter;
request marketing to be sent to you;
enter a competition, promotion or survey;
submit an application for a role within BEEPAY X; or
make a complaint or give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies Please see our cookie policy details.

Automated technologies through the use of our website or services. In your use of our website or services (including receiving our newsletter), certain Usage Data is transmitted to us such as the device you are using, your IP address and other such data.

Third parties or publicly available sources.We may receive personal data about you from various third parties as set out below:

Technical Data or Usage Data from analytics providers or search information providers.
Employment, Identity and Contact Data from third party recruitment agencies.

If you fail to provide personal dataWhere we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with ours services). In this case, we may have to cancel the services you have with us but we will notify you if this is the case at the time.

Purposes for which we will process your personal data

BEEPAY X collects and uses your personal information to operate its website(s) and deliver the services you have requested including processing your account application. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message (although we may also rely on legitimate interests). You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processiong including basis of legitimate interest
To register you as a new customer or user	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver services including: (a) Manage payments, fees and charges (b) Make a decision regarding your identity and whether to provide an account or wallet (c) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (f) Compliance	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage (c) Financial (d) Compliance	Necessary for our legitimate interests (to define types of customers suitable for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical	Necessary for our legitimate interests (to develop our products/services and grow our business).
To comply with any laws or regulations that apply to us, for example investigating fraudulent claims, carrying out fraud, credit and anti-money laundering checks and preventing other crimes.	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Compliance	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to prevent fraud and criminal activity). (c) Necessary to comply with a legal obligation.

BEEPAY X may also use your personally identifiable information to inform you of other products or services available from BEEPAY X and our partners. BEEPAY X may also contact you via surveys to conduct research about your opinion of our website and services. BEEPAY X does not sell, rent or lease or provide in any other way its customer lists to third parties.

BEEPAY X may keep track of the websites and pages our users visit within BEEPAY X and which services our users access. This data is used to deliver customised content within BEEPAY X to customers whose behaviour indicates that they are interested in a particular subject area.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Transfer of Personal Data

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 and applicable law. You agree that BEEPAY X may share data with trusted partners to help provide our services including to perform electronic ID verification checks, KYC/AML compliance checks, credit-checks, fraud prevention, facilitate our foreign exchange transactions, statistical analysis, send you email or postal mail, provide customer support and IT support, or securely store your data. All such third parties are required to maintain the confidentiality of your information.

We may also transfer your personal data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy. Whenever we transfer your personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

BEEPAY X will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

(a) conform to the edicts of the law or regulation comply with legal process served on BEEPAY X or the site;
(b) protect and defend the rights or property of BEEPAY X ; and,
(c) act under exigent circumstances to protect the personal safety of users of BEEPAY X, or the public.

Additional Information regarding Third Party Tracking Services

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable BEEPAY X to monitor and analyze web traffic and can be used to keep track of User behavior.

Place of processing: Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of www.bpayx.com to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.