Your Personal and Business Data are treated with extreme caution, safety and always in agreement to the GDPR rules

Privacy Policy                         Last Updated: 17/03/ 2020

 

How we handle your data

Sections:

  1. INTRODUCTION
  2. WHO WE ARE?
  3. COLLECTION OF INFORMATION
  4. CATEGORIES OF PERSONAL INFORMATION WE COLLECT
  5. PERSONAL INFORMATION WE COLLECTT
  6. PURPOSE OF THE PROSSES AND/OR USE OF YOUR PERSONAL INFORMATION
  7. DATA SHARING
  8. LIST OF RECIPIENTS WE MIGHT DISCLOSE INFORMATION
  9. TRANSFERRING YOUR INFORMATION OUTSIDE EEA
  10. MARKETTING
  11. INDUVIDUAL’S RIGHTS
  12. SECURITY OF PERSONAL DATA
  13. ACCESS AND CORRECTION
  14. LINGS
  15. COOKIES
  16. DATA PROTECTION OFFICER
  17. UPDATES TO PRIVATE POLICY
  18. HOW YOU CAN PETITION FOR COMPLAINTS
  19. CONTACT

 

 

Introduction
UAB ECREDO (hereinafter ‘’ eCREDO’’) welcomes you to our website (hereinafter the “Site”). eCREDO, through the eCREDO Prepaid Mastercard, offers you a prepaid master card, which is issued by Prepaid Financial Service (hereinafter ‘’PFS’’). Therefore, in this privacy policy (“Privacy Policy”), the expressions “we” and “us” means eCREDO. This Privacy Statement describes how we collect, use, process and disclose certain personal information.

Who we are?

UAB ECREDO, is a limited liability company incorporated by the State Enterprise Center of Registers in Lithuania under the given registration number 305118895 and their registered offices are at J. Basanavičiaus g. 26, LT-03244 Vilnius, Lithuania (hereinafter ‘’ eCREDO’’). It was incorporated in 2019, having as main activities in the aspects of the financial industry.

eCREDO is a growing Fintech provider of digital financial services – which offers privacy and a new way to connect with their money. With all eCREDO accounts customers can benefit from a free International Bank Account Number (IBAN) for incoming and outgoing transfers, as well as a physical prepaid Mastercard.

The Company respects your privacy and is committed to protect your personal data through its compliance applicable privacy and data protection regulation (GDPR). Therefore, please read carefully the above privacy policy for your information and please do not hesitate to contact us for any further clarification you might have.

How we collect/ obtain information?

  • Directly from you and/or
  • Through third parties
  • Through this website

 

Categories of Personal Information we collect:

  • information you provide to the company by filling in the forms we initially requested from you
  • information you provide to the company when you submit your consent or when you report a problem through the Website
  • information provided by you (including email addresses) in case you contact us

Personal Information we collect:

  • We will collect personal information about you which you provide to us when using the Site, for example, when you activate your eCREDO Prepaid Mastercard, when you log in to manage your eCREDO Prepaid Mastercard, contact us through the Site, when you request information or otherwise provide personal information to us. Such information may include (but is not limited to) the following information and/or Data:
  • your Prepaid Card number and PIN
  • your full name
  •  contact details such as address, telephone number and email address
  •  date of birth
  •  proof of identity documents
  •  proof of address documents
  • transactional information

Please be noted that you must ensure that the personal information you provide to us is accurate and complete.

 Purpose of the prosses and/or use of your Personal Information:

  • We collect, use, store and process personal information about you for the following purposes:
  • (i) to enable you to access and use the Site;
  • (ii) to run your Account Prepaid Mastercard account;
  • (iii) to process your fund transfers and transactions;
  • (iv) to enable us to provide any services which you have requested through use of the Site;
  • (v) to personalise aspects of our overall service to you;
  • (vi) to provide you with information regarding products and services that you might be interested (see the “Marketing” section below);
  •  to provide you with account services as per our contractual obligations;
  • (viii) to comply with our legal obligations for the prevention of fraud, money laundering, counter terrorist financing or misuse of services,
  • verifying your identity, contacting you regarding our services to you;
  • (ix) where requested by law enforcement for investigation of crime.
  • compliance- in order to comply with our legal obligations

 

Data Sharing:

We will not disclose personal information obtained from you to any third parties. However, we may share Personal Information with our affiliates for the purpose of responding to your requests or otherwise as necessary for the purposes described above:

  • in connection with legal proceedings or potential legal proceedings
  • where is required to do so by law or any other Governmental or law enforcement agency (including but not limited to eCREDO Prepaid Mastercard our issuing banks, our processors and our third-party partners.)
  • in accordance for Anti-Money Laundering and Fraud prevention checks and in order to comply with AML Regulations.
  • if you breach this Privacy Policy and/or our Terms of Use

List of recipients we might disclose information

 

  1. Affiliate companies – service providers
  2. Third parties such as authorities, agents and administrative personnel in various countries (Tax Authorities, Bank Institutions etc.)
  3. Legal Successors– we might disclose personal information to a buyer or a successor in the event of merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets
  4. Transfer of the data in countries out of the European Economic Area

Unless you have specifically consented to the transfer, we will only transfer personal data outside the European Economic Area (EEA) as described to the paragraph below.

Transferring your information outside EEA

We may store, process and/or transfer the personal information you submit to us through use of the Site to countries outside of the European Economic Area including (without limitation) to the USA. Personal data transferred outside of the EEA will be stored and processed by affiliate companies or services provides, or representative offices for business and management purposes, to perform a contractual obligation owed by us to you and/or to provide you with information or services that you have requested. By using this Site, you consent to us transferring your personal information to countries outside the EEA for our legitimate business purposes as outlined in this paragraph. We will take appropriate steps to protect your personal data.

Personal data shall not be transferred to a country or territory outside the European Economic Area where:

  • we transfer the data to a country or international organisation which the EU Commission has decided to ensure an adequate level of protection for your personal data;
  • the transfer of your personal data is subject to adequate safeguards, which may include binding corporate rules or standard data protection clauses adopted by the EU Commission; or
  • one of the derogations in the GDPR to transfer personal data outside the EEA applies.

Marketing

We and/or our partners will only use the personal information obtained from you to enable us to provide you with the customer support including any notice, for example changes about any product and/ or service we offer, advertising – in case you have provided us with your consent, we may communicate with you in order to inform you about services and/or products offered by us or other third parties for which you might be interested .

You will be receiving advertising material from eCREDO, only if you have provided your explicit consent. In case you feel that you need to revoke this consent, you will be provided with an automated way to opt-out (unsubscribe) from all marketing e-mails sent by eCREDO. Please follow the instructions from the e-mail you received to do so. In the unlikely case you receive unwanted e-mail from our Company, please forward a copy of that e-mail to [email protected].

Individual’s Rights

You, as Individual, have the following rights:

  1. Right of access – request access to any personal data we hold about you;
  1. Right of rectification -have any personal data which we hold about you which is inaccurate or incomplete rectified;
  2. Right to be forgotten – have personal data erased;
  3. Right to restriction of processing – have the processing of your personal data restricted;
  4. Right of portability – To be provided with the personal data that you have supplied to us in a portable format that can be transmitted to another organisation without hindrance;
  5. Right to object – object to certain types of processing, including processing based on legitimate interests, automated processing (which includes profiling) and processing for direct marketing purposes; and
  6. Right to object to automated processing, including profiling -not be subject to a decision that is based solely on automated processing which produces a legal effect or which has a similar significant effect for the individual.

 

If you wish to exercise any of the rights set out above, you must make the request in writing to the Data Protection Officer, for whom all details are described above.  Please note some of these rights are restricted in some circumstances.

If you have provided your consent to any of the processing of your personal data, you have the right to withdraw your consent to that processing at any time, where relevant. You must contact the Data Protection Officer if you wish to do so.

If you object to processing based on legitimate interests, we must no longer process that personal data, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or that the processing is required for the establishment, exercise or defence of legal claims.

Security of Personal Information:

eCREDO takes appropriate security measures to ensure the protection of the Personal Information from any unauthorised access or disclosure. In addition, all employees had been trained on how to use, handle and process personal data, according to the provisions of Personal Data Law. Furthermore, eCREDO has upgraded technical measures and has transformed the policies and procedures in order to comply with the General Data Protection Regulation.

 

Access and Correction

If you wish to access or update the Personal Information you submitted at eCREDO website, or to make any inquiries about the processing of your information, please contact us. We provide individuals with access to their Personal Information as required by applicable data protection and privacy laws.

Links

This website contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. This privacy policy applies solely to information collected by this Site.

Cookies

Cookies are small files on your computer, which can store information that you transmit when accessing the internet. They are transmitted via the web browser to the computer’s hard drive. Cookies cannot transmit any information from a computer system. They instead help to make a return visit to the Site as simple and user friendly as possible. Some cookies remain on the computer’s hard drive so your computer gets recognised on your next visit. You can change your browser options at any time to deactivate cookies. (Some functions are only accessible when cookies are enabled and we therefore recommend allowing cookies.)
Click this link to read our cookie policy

Data Protection Officer

eCREDO has assigned ARETI CHARIDEMOU & ASSOCIATES L.L.C as the personal Protection Agent.

Areti Charidemou & Associates LLC – Law Firm

21 Vasili Michailidi Street | 3026 Limassol – Cyprus

Postal Address: PO Box 54708 | CY-3727 | Cyprus

D: +357 25 50 82 19| T: +357 25 50 80 00 | F: +357 25 50 80 90

E: [email protected]|

 

 Updates to Privacy Policy

eCREDO reserves the right to change this Privacy Policy from time to time. Please check the Privacy Policy frequently and particularly before you submit additional personal information via the Website. All revisions of this Privacy Policy will be posted on the web site via a link from the homepage. We also display the effective date of the Privacy Statement on the top of this page.

 

How you can petition for complaints

It is very important the principles of privacy to be followed and we should take all the appropriate measures to avoid any breach or loss of these data.

We ensure that the personal data you disclosed to us, are saved in a platform which is protected with additional security factors.

Any breach of the GDPR and/or other relevant Data Protection Acts will be taken seriously and if you consider that the data protection principles have not been followed in respect of personal data about yourself or others you have the right to lodge a complaint with the relevant data protection supervisory authority.

Our Protection Supervisory Authority is the Personal Data Protection Bureau (Independent Supervisory Authority for the Protection of Individuals). If you have any issues with our processing of your personal data and would like to make a complaint, you may contact the Personal Data Protection Bureau on (+357) 22 818 456 or at 1 Iasonos, 1082 Nicosia, Cyprus.

Contact

If you require this Privacy Policy to be provided to you in paper form and/ or you need any further clarification, please contact our Data Protection Officer, at [email protected] or via phone on (+357) 25 508 219.

INTRODUCTION

Welcome to website (the “Site”). In this privacy policy (“Privacy Policy”), the expressions “we” and “us” means Prepaid Financial Services Ltd. We take your privacy seriously and this Privacy Policy explains the steps we take to ensure information about you is kept secure and confidential.

THE INFORMATION WE COLLECT FROM YOU

We will collect personal information about you which you provide to us when using the Site, for example, when you activate your eCREDO Prepaid Mastercard, log in to manage your eCREDO account and eCREDO Prepaid Card, contact us through the Site, request information or otherwise provide personal information to us. Such information may include (but is not limited to) your Prepaid Card number and PIN, your full name, address, telephone number, email address, date of birth, proof of identity documents, proof of address documents, transactional information and telephone recordings. You must ensure that the personal information you provide to us is accurate and complete.

PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We collect, use, store and otherwise process personal information about you for the following purposes: (i) to enable you to access and use the Site; and (ii) to run your eCREDO Prepaid Card account; and (iii) to process your fund transfers and transactions; and (iv) to enable us to provide any services which you have requested through use of the Site; and (v) to personalise aspects of our overall service to you; and (vi) to provide you with information regarding products and services that we feel may be of interest to you (see the “Marketing” section below); and (vii) to provide you with account services to you as per our contractual obligations; and (viii) to comply with our legal obligations for the prevention of fraud, money laundering, counter terrorist financing or misuse of services, verifying your identity, contacting you regarding our services to you, and (ix) where requested by law enforcement for investigation of crime.

DISCLOSING INFORMATION ABOUT YOU

We will not disclose personal information obtained from you to any third parties other than in connection with legal proceedings or potential legal proceedings or if otherwise required to do so by law or any other Governmental or law enforcement agency (including but not limited to eCREDO, our issuing banks, our processors and our third-party partners.) We may need to disclose your account information and verify personal documents for regulatory obligations we have. This will be in accordance for Anti-Money Laundering and Fraud prevention checks.

MARKETING

We and/or our partners will only use the personal information obtained from you to enable us to provide you with information by email, telephone or post regarding products and services that we feel may be of interest to you if you have provided your consent for us to do so by ticking the relevant box (es) on this website where your personal information is collected.

If you wish to withdraw consent to use this information at any time for either us and/or our partners’, then you should contact the Data Protection Officer at Prepaid Financial Services Ltd by emailing at [email protected]

VIOLATION OF THIS POLICY

We may need to disclose your personal information if you breach this Privacy Policy and/or our Terms of Use or in connection with legal proceedings or potential legal proceedings or if otherwise required to do so by law or any other Governmental or law enforcement agency.

TRANSFERRING YOUR INFORMATION ABROAD

We may store, process and/or transfer the personal information you submit to us through use of the Site to countries outside of the European Economic Area including (without limitation) to the USA. Personal data transferred outside of the EEA will be stored and processed by our group companies or representative offices for business and management purposes, to perform a contractual obligation owed by us to you and/or to provide you with information or services that you have requested. By using this Site, you consent to us transferring your personal information to countries outside the EEA for our legitimate business purposes as outlined in this paragraph. We will take appropriate steps to protect your personal data.

Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

COOKIES

Cookies are small files on your computer, which can store information that you transmit when accessing the internet. They are transmitted via the web browser to the computer’s hard drive. Cookies cannot transmit any information from a computer system. They instead help to make a return visit to the Site as simple and user friendly as possible. Some cookies remain on the computer’s hard drive so your computer gets recognised on your next visit. You can change your browser options at any time to deactivate cookies. (Some functions are only accessible when cookies are enabled and we therefore recommend allowing cookies.)

LINKS

This website contains links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. This privacy policy applies solely to information collected by this Site.

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used.

Consent for Children Under 16

If you are giving consent on behalf of a child under sixteen (16) years of age then please be aware that Children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. By consenting to this privacy notice, on behalf of a minor, you are giving permission for their data to be used for the purposes described above.

Withdrawal of Consent Conditions

You may withdraw consent from direct marketing at any time by contacting us on [email protected] Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist. As a payment service provider, PFS are obliged to retain data concerning financial transactions for 6 years in accordance with national law for the purpose of preventing, detecting and investigating, possible money laundering or terrorist financing.

International Data Transfers & Third-Party Disclosures

In limited situations where PFS stores or transfers personal information outside the EEA or the EU, robust procedures and safeguarding measures apply to secure, encrypt and maintain the integrity of the data. PFS will complete continual reviews of the countries with sufficient adequacy decisions, such as the Privacy Shield in the US, and provisions for binding corporate rules, standard data protection clauses or approved codes of conduct. PFS will further perform due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information. PFS undertakes that it shall not transfer Personal Data outside of the EEA or the EU in full compliance with Article 46 of the GDPR, and shall not transfer data outside of the EEA or EU unless the following conditions are fulfilled:

• The data subject has enforceable rights and effective legal remedies;

• PFS shall comply with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred (or, if it is not so bound, uses its best endeavours to assist the Customer in meeting its obligations);

• PFS complies with any reasonable instructions notified to it in advance with respect to the processing of the Personal Data; and

• Upon written direction shall delete or return Personal Data (and any copies of it) unless PFS is required by Law to retain the Personal Data.

Where PFS is required to transfer Personal Data to the United States of America, PFS shall only send such Personal Data to third-party sub-contractors that meet the minimum requirements contained under the Privacy Shield, or in the standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament.

In the event that the Privacy Shield is repealed at any future date, for whatever reason, PFS shall only contract with third-party sub-contractors that satisfy the requirements contained in the standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Customer.

Retention Period

PFS will process personal data for the duration of the contract for services and will store the personal data for six (6) years after that date of termination of the contract.

Your Rights as a Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you;

• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;

• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime;

• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing;

• Right of portability – you have the right to have the data we hold about you transferred to another organisation;

• Right to object – you have the right to object to certain types of processing such as direct marketing;

• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling; and

• Right to judicial review, in the event that PFS refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You will find a copy of the Subject Access Request Form here:

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by PFS (or third parties as above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and PFS’s Data Protection Officer by email to [email protected]

This Privacy Statement describes how UAB ECREDO (hereinafter ‘’ eCREDO’’) collects, uses, and discloses certain personal information obtained through our public website at  www.ecredo.com. This Privacy Statement does not address information collection through other sources such as in-person seminars or a manager’s personal contacts.

Information Collection and Use

In general, you can visit eCREDO. Web Site maintaining your anonymity. Occasionally, however, eCREDO may need from you to provide personally identifiable information, such as your name, company, e-mail address, phone number, access code and address (“Personal Information”). The purpose for requesting the particular info may involve, corresponding with and/or contacting you, fulfilling your requests, or otherwise to provide you with a subscription to a newsletter or publication, or to notify you about events. Where applicable, we will differentiate between personal data fields that are optional and those that are mandatory in order for you to obtain the requested information.

By consenting to supply eCREDO with personally identifiable data, such as your name, address, email address and telephone number, eCREDO will not, in any way, directly or indirectly, sell or transfer any of this information to any third party. Any information supplied will be confidential and will be handled in accordance with the applicable laws and regulations.

You will only be receiving advertising materials from eCREDO, only if you have provided your explicit consent. In the case you feel that you need to revoke this consent, you will be provided with an automated way to opt out (unsubscribe) from that particular communication or from all marketing e-mails sent by eCREDO. Please follow the instructions on the e-mail you received to do so. In the unlikely case that you have received unwanted e-mail from our Firm, please forward a copy of that e-mail to [email protected]

Please note that if you reply to eCREDO address in one of our advertising e-mails or otherwise correspond with us, your communication will not create a company-client relationship with us. Do not send us any information that you or anyone else considers to be confidential or secret unless we have first agreed to be your service providers in that matter or requested in order to create a relationship with us. Any information you send us before we agree to be your service providers cannot be protected from disclosure as a means of company-client confidentiality.

Data Sharing

We may share Personal Information among our service providers affiliates for purposes of responding to your requests or otherwise as necessary for the purposes described above. We may also in limited circumstances share Personal Information with government authorities or others as required to protect the interests of the Company or others, or if necessary, in connection with the sale or transfer of all or a portion of the business, or as required by the applicable law or court order. Your consent will be requested upon establishing the business relationship.

International Data Transfers

This Web Site is hosted on eCREDO web servers in Cyprus. If you are located outside of Cyprus, your provision of Personal Information or other access to our Website constitutes your transfer of such data to Cyprus, a jurisdiction that may not provide a level of data protection equivalent to the laws in your home country. eCREDO servers and I.T. infrastructures are compliant with the laws and regulations enforced within European Union.

Access and Correction

If you wish to access or update the Personal Information you submit through eCREDO website, or to make any inquiries about the processing of such information, please contact us as described below. We provide individuals with access to their Personal Information as required by applicable data protection and privacy laws.


Revisions to this Privacy Statement

eCREDO reserves the right to change this Privacy Statement from time to time. Please check the Privacy Statement frequently and particularly before you submit additional personal information via the Website. All revisions to this Privacy Statement will be posted on the web site via a link from the homepage. We also display the effective date of the Privacy Statement on the top of this page.

Contact details

) Our Data Protection Officer: at [email protected]  or

  1. ii) Our Company by post at: Vasili Michaelidi 24, 3026 Limassol, Cyprus

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