Updated – February, 2020
For the purpose of compliance with the relevant data protection legislation, the party controlling your personal data is RRR FI LP (hereinafter – “RRR”, “us” or “we“). This policy (together with our Customer Agreement and any other documents referred to in it) 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 the types of information we collect from you, how we use that information and the circumstances under which we will share it with third parties. By visiting our website (“Website”) at polydirection.com or using the RRR mobile application (“App“) you are accepting and consenting to the practices described in this policy. Unless the context otherwise requires, a reference to the Website shall be deemed to also refer to the App.
2. In order to show respect to your individual rights to privacy, RRR processes the collected personal data in accordance with the Law on Legal Protection of Personal Data of Lithuania, the General Data Protection Regulation and other legal acts such as the Directive No. 95/46/EC of the European Parliament. The employees, agents, and other parties who have access to your personal data are committed to ensuring its safety even upon termination of the contractual relationship.
3. It is possible that RRR may engage data processors and third-parties, who will perform certain functions on behalf of RRR. RRR bears the responsibility to ensure that the latter treat sensitive data in compliance with the active legislation and given instructions. RRR can also request certain security measures and monitor their implementation. Under those circumstances, RRR guarantees the imposition of the non-disclosure obligation, which will prevent parties from using information beyond the scale necessary to perform the given functions.
5. Providing personal data is necessary in order to continue using the services provided by RRR. For instance, it is a required step in the RRR account opening procedure. Personal data you provide is processed within the system in order to complete the established identification procedures.
7. The core reason for data collection is the provision of RRR services to individuals who transact within the system. As a payment service provider, RRR is required by law to establish and verify your identity before it begins to cooperate with you and provide any sort of financial services. RRR has the right to store any initially and further requested information throughout the retention period estimated by the relevant legislation. Therefore, the Client is obliged to provide valid and complete information.
8. PURPOSE: identification of Client’s identity, provision of payment services (account opening, transfers of funds, payment collection and other), implementation of other legal obligations of the payment service provider.
8.1. Personal data collected for the purposes listed above is processed within the following legal framework:
8.1.1. establishing and verifying the identity of the Client;
8.1.2. concluding agreements with the Client in order to proceed with fulfilling his requests;
8.1.3. executing financial transfers in compliance with legislation;
8.1.4. following the “Know Your Client” provisions;
8.1.5. conducting systematic monitoring;
8.1.6. carrying out risk assessment;
8.1.7. ensuring the accuracy of data provided by the Client;
8.1.8. preventing possible money laundering, terrorist financing, and fraud; timely detecting, profoundly investigating and informing of such activity, acting in accordance with financial sanctions imposed on the Client;
8.1.9. effective performing of risk and organization management.
8.2. The processing of the following data is a priority in accordance with above listed provisions: name, surname, personal identification number, address, date of birth, identity document information, photo, direct video transmission recording, citizenship, email address, phone number, payment account number, IP address, current activity, current public function, and any other data required by the Law on Prevention of Money Laundering and Terrorist Financing.
8.3. The relevant information is collected and processed on the grounds of a legal obligation imposed on RRR as the payment service provider by the Law on Payments of the Lithuania, the Law on Electronic Money and Electronic Money Institutions of Lithuania and the Law on Prevention of Money Laundering and Terrorist Financing of Lithuania Therefore, in order to open an account and/or use the payment services of RRR , the Client is obliged to provide a full set of requested documents.
8.4. Parties that might be among the recipients of Client-related data: supervisory authorities, credit, financial, payment and/or electronic money institutions, pre-trial investigation institutions, the State Tax Inspectorate, payment service agents of SatchelPay (if their services are essential for carrying-out an operation), beneficiaries of transaction funds receiving the information in payment statements together with the funds of the transaction, debt collection and recovery agencies, companies processing consolidated debtor files, lawyers, auditors, other third-parties having a legitimate interest, other entities under an agreement with RRR, strictly upon reception of a separate consent from you.
8.5. Third countries may also obtain access to the data, yet only in the case it/its national is directly involved in your payment transfer execution.
9. PURPOSE: Debt management.
9.1. Under this provision, Client-related information is processed in order to manage issues related to debt collection, submission of claims, demands, lawsuits and other documents.
9.2. Processing of the following data can be involved: name, surname, personal identification number, address, date of birth, data from an identity document, email address, phone number, payment account number, IP address, payment account statements.
9.3. Groups of data recipients: companies processing consolidated debtor files, credit, financial, payment and/or electronic money institutions, lawyers, courts, pre-trial investigation institutions, the State Tax Inspectorate, debt collection and recovery agencies, other entities having a legitimate interest.
9.4. Third countries may also obtain access to the data, yet only in the case it/its national is directly involved in your payment transfer execution.
10. PURPOSE: Supporting and managing relations with Clients, preventing disputes and collecting evidence (recording phone conversations), correspondence of business relations with the client.
10.1. Processing of Client’s data can be involved for reasons of: 10.1.1. protecting the interests of the Client and/or RRR;
10.1.2. preventing disputes, providing evidence of business communication with the client (recordings of conversations, correspondence);
10.1.3. ensuring the top-level quality of services provided by RRR;
10.1.4. executing Client’s requests, following the obligations levied by law or other legal documents.
10.2. The following Client-related information may be processed: name, surname, address, date of birth, email address, phone number, IP address, payment account statements, phone conversation recordings, correspondence with the client.
10.3. Data recipients: supervisory authorities, companies processing consolidated debtor files, lawyers, bailiffs, courts, pre-trial investigation institutions, debt collection and recovery agencies, other entities having a legitimate interest, other entities under an agreement with RRR, strictly upon reception of a separate consent from you.
10.4. No third country may be granted access to such data.
11. PURPOSE: Informing the client about services. In this case, Client’s data is processed in order to inform the Client about the services provided by RRR, their prices, specifics, for sending system and other messages related to the services provision by RRR.
11.1. This provision implies processing of the following Client’s data: email address, phone number.
11.2. The Client hereby acknowledges and agrees that he/she is aware that such messages shall be perceived as necessary under the General Payment Service Agreement and/or its supplements concluded with the Client, which differentiates them from direct marketing messages.
11.3. Data recipients: no third-party shall receive access to data described in this provision.
12. PURPOSE: Direct marketing. In this case, Client’s data is processed in order to inform the Client concerning the offers related to services provided by RRR.
12.1. This provision implies processing of the following Client’s data: email address, phone number.
12.2. With this provision the Client acknowledges and confirms that he/she is aware of the fact that the data listed above may be processed for the purpose of direct marketing. The Client maintains the right to disagree and to object this clause at any time by informing RRR via email to email@example.com. The email must provide valid information necessary to identify the data subject.
12.3. Data recipients: The procedure of data processing may involve search or social networking systems (objections to data processing may be filed within the framework that the websites of these systems provide). No other persons shall receive access to data described in this provision.
14. No third-party shall be granted access to the Client-related data marked as “personal” without prior Client’s consent. Situations when it is required to do so by applicable law or for the purpose of services provision shall be viewed as exception. Profiling
15. RRR may use automated means of personal data processing, following the provisions of risk management-related legislation, and systematic monitoring of transactions with the goal of fraud prevention; such profiling is justified by legitimate interests and legal duties of RRR.
17. Cookies are used in order to distinguish you from other users of RRR Website. This helps to ensure your pleasant experience when navigating RRR Website and also allows improving its organisation. In technical terms, cookies are small files containing a string of characters that are sent to a person’s computer upon visiting the website. Cookies allow the Website to recognize a person’s browser upon the next visit to the Website and may detect user preferences and other information.
18. Like most website managers, RRR monitors traffic of the website and automatically collects information on the number of visitors browsing the website, the domain name of Internet service providers of visitors, etc. Such cookies are required for technical reasons in order to ensure the sound and efficient Website operation (administer the Website, maintain security, measure or understand the effectiveness of advertising etc.), as well as track and target the interests of users and Clients in order to improve their experience.
20. In case of altering the settings, the functionality of the Website may change. Restriction of data processing
21. You have the following rights:
21.1. THE RIGHT OF ACCESS TO DATA: to be informed as to whether or not RRR processing your personal data, and access to the related information.
21.2. THE RIGHT TO RESTRICTION OF PROCESSING: you have the right to ask us not to process your personal data for marketing purposes by contacting us at firstname.lastname@example.org
21.3. If, for whatever reasons, you believe that the processing of your personal data is taking place under conditions of violation of your rights and legitimate interests protected by applicable legislation, you may address the supervisory authority.
22. You are free to contact RRR in case you are willing to learn details or voice an objection to data processing via email at email@example.com. The individual communicating must provide information that will enable the identification of his/her identity, along with a copy of a personal identification document or an electronic signature. Unrelated websites
24. It is a priority of RRR to provide highest-level security to our Clients concerning all the information and sensitive data we receive access to. Relevant legal, administrative, technical and physical security measures are undertaken in order to protect this information from unauthorized access, use, copying, accidental or unlawful erasure, alternation, or disclosure, as well as from any other unauthorized form of processing. Law and jurisdiction
26. For the purpose of the relevant data protection legislation, the data controller is RRR FI LP of Office 7 196 Rose Street, Edinburgh, United Kingdom, EH2 4AT.