-
Privacy Policy
Last revised: 2024 October
SUPERB PAYMENTS UAB may be referred to in this Privacy Policy as “we,” “us,” “our” or other similar pronouns. This privacy policy (“Policy” or “Privacy Policy”) outlines, in general, the Personal Information (as defined herein) and other information that is collected by us from clients and how we use and protect it. This Policy governs your use of our client-directed websites (the “sites” or “websites”) and collection of data through both online means and offline means.
Introduction
As used in this Privacy Policy, “Personal Information” means personally identifiable information such as your name, street address, telephone number, credit card and other payment information, screen name, e-mail address, wireless e-mail address, short message service or text message address, demographic information and other information that may identify you or allow online or offline contact with you. We process Personal Information in accordance with the provisions of the General Data Protection Regulation No 2016/679 (EU) the “GDPR”, the requirements of applicable legal acts, as well as the instructions of the authorities or internal regulation.
If you use the Services, website, subscribe to our newsletters, or contact us on any issues, we assume that you have read and agreed to the terms of this Privacy Policy. If you do not agree with the Privacy Policy, you may not use our services or otherwise interact with us. This Privacy Policy is a subject to a change, so please visit the website from time to time and read the latest version available herein.
Collection of Personal Information
We may collect your Personal Information from you directly, or from third parties in order to establish and maintain a service relationship with you that will be appropriate to the situation and your needs. We will only collect the information about you that will allow us to serve your efficiently. In certain cases, we may acquire information about you from third parties (our identification, compliance and fraud prevention service providers) or publicly available sources (credit card blacklists and other online public information). We may link information provided by yourself, collected from public sources to other information we obtain from you or about you.
Purpose and Personal data elements collected
We seek to collect as limited amount of your information as possible. The purposes of the processing of your personal data, with respective legal bases and personal data collected for such purposes, are set out in the table below:
Data processing purpose
Personal data being processed
Legal basis
Retention term
Registration
Company name, legal form, address, registration number, information about representatives of the company (name, surname, personal code, date of birth, contact details).
Compliance with legal obligation;
Performance of the contract;
Company’s legitimate interest (audit and record keeping, resolving or exercising claims regarding disputes).
Up to 8 years as of the termination of the Company’s relationship with the client.
To identify/verify client representatives (we use ___ as a service provider)
ID document details (type, number, issuance place and date, expiry date, signature), selfie, IP address, device geographical location, KYC questionnaire.
Compliance with legal obligation;
Up to 8 years as of the termination of the Company’s relationship with the client.
Service provision
Performance of the contract;
Compliance with legal obligation;
Up to 8 years as of the termination of the Company’s relationship with the client.
Customer support
Communication content, email address and any other information, required for the performance of support service.
Performance of the contract;
Compliance with legal obligation;
During the administration of the question and 5 years after the end of the administration of the question or the last contact.
Settlement of disputes and claims
Contact details, content of the claim or other document/information related to the dispute/claim
Compliance with legal obligation;
Legitimate interest of the Company or a third party.
The entire period of the dispute/claim and 5 years after the end of the out of court dispute/claim resolution and 10 years after the end of judicial proceedings.
How We Use Your Information
When you provide your Personal Information to us, we will use all or part of the Personal Information for the following purposes. We are able to deliver our products or services to you by using your Personal Information and to understand how you use or interact with our products or services to help us evaluate and improve products or services, develop new product or services and conduct audits and troubleshoot activities related to the provision of products or services. We use your information to send you information relating to your account, marketing communications, communicate with you about our products or services and let you know about our policies and terms. We also use your information to respond to you when you contact us.
You May be Contacted
Should you contact us in any form for the purpose of ordering our products, we consider such an inquiry for a return contact. As such, we may contact you via telephone to follow up with you and help you complete you order. Accordingly, even if your contact information appears on any state or federal Do Not Contact lists, you acknowledge in such a case that you may receive a telephone call or other contact from us pursuant to your express business inquiry or transaction. You may stop us from calling you at any time by simply asking us to refrain from further calls to you. We maintain an internal no-call list and abide by all applicable laws relating to such.
How is Personal Information Shared?
The information we collect, and use may be shared with third parties such as our affiliated, our suppliers or agents who assist in providing you with a service or as required or permitted by law. If we are involved in a merger, acquisition or sale of all or a portion of our assets, Personal Information may be disclosed, released, transferred, , or otherwise conveyed to prospective or actual buyers, sellers and/or entities related to us. We may disclose Personal Information as required by law or subpoena or similar legal process. We may also disclose Personal Information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request or to any other third party without your prior consent.
Your Rights
As a data subject, you have following rights regarding your Personal Data:
1. Right of information
2. Right of access;
3. Right to rectification;
4. Right to request the erasure of your Personal Data;
5. Right to restrict the processing of Personal Data;
6. Right to transfer data. This right may be exercised only if there are grounds for its exercise and appropriate technical measures to ensure that the transfer of the requested Personal Data does not pose a risk of security breach to the data of other Data Subjects;
7. The right to object the processing of your Personal Data when we process Personal Data based on a legitimate interest of the Company or a third party, including profiling. If you object, we will only be able to further process your Personal Data for compelling legitimate reasons that take precedence over your interests, rights, and freedoms, or to make, enforce or defend legal claims;
8. Right to revoke your consent to the processing of your Personal Data when this data is processed or intended to be processed for direct marketing purposes.
We may refuse to exercise your rights listed above, except for refusal to process your Personal Data for direct marketing purposes or in other cases when Personal Data is processed with your consent, or when, in cases provided for by law, it is necessary to ensure the prevention, investigation and detection of crimes, violations of official or professional ethics, as well as the protection of the rights and freedoms of the Data Subject, us and other persons, or when the Company has a legitimate interest.
Requests should be sent to support@superbbit.com. When submitting such a request, we may ask you to fill in the necessary forms, as well as provide an identification document or other information that will help us to verify your identity, to better understand the content of your request. Upon receipt of your request or instruction regarding the processing of Personal Data, no later than within 1 month from the date of the request, we will provide a response and perform the actions specified in the request or inform you why we refuse to perform them. If necessary, the specified period may be extended by a further 2 months, considering the complexity and number of requests. In such a case, within 1 month from the date of receipt of the request, we will inform you of such extension.
Indemnify
You agree to indemnify and hold us, and our parent corporation, subsidiaries, affiliates, officers, agents, co-branders or other partners, and employees, harmless from any claim or demand, including reasonable legal fees, made by any third party due to or arising out of content you submit, your use of the Site, your violation of the TOU, or your violation of any rights of another.
Third Party Linked to Sites
When you are on our websites you may be able to visit, or link to, other sites which may be operated by unaffiliated third parties, but which are not covered by this Privacy Policy. These sites may collect Personal Information about you, and you should check the privacy policies of the specific site you are visiting to understand your rights.
Your Personal Information is Protected
SUPERB PAYMENTS UAB make it a priority to protect your information with the appropriate safeguard and security measures. Safeguarding your data and privacy is at the top of our priority list having been established as one of our key pillars to success. You have entrusted us with your personal information, and we intend to use every tool at our disposal to keep it out of the hands of bad actors.
· To start, we limit the use, disclosure, and retention of your information. That means we only collect data that is necessary to comply with Anti-Money Laundering and Know-Your-Customer requirements set out by FCIS.
· We utilize best-in-class encryption protocols for both data-at-rest and data-in-transit.
· We employ routine penetration tests and dynamic threat models to get ahead of and defend against new vulnerabilities and cyber-attacks.
· To protect your privacy and security, we take reasonable steps (such as requesting a unique passcode or PIN) to verify your identity before granting you access to your account.
· All of our service providers, as part of their contract with us, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose.
· All employees of SUPERB PAYMENTS UAB are familiar with the procedures that must be taken to safeguard clients information. It is specified tin our employment agreements and confirmed in writing annually.
Thorough security standards are applied to protect our systems and your information against unauthorized access and use. Our initiatives are underpinned by a firm belief that there are no shortcuts in cyber security. Being a successful business to us means your data is as secure as your funds.
Your Obligation to Protect Data
You may be able to create an account on our website with a username and password. In some cases, your username may be your e-mail address. If so, you are responsible for maintaining the strict confidentiality of your account password. We recommend that you choose a unique password for your website account and that you do not use any password that you also use for any other accounts which may contain your sensitive information, such as financial accounts or e-mail accounts. You agree to immediately notify of any unauthorized use of your password or account or any other breach of security. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.
Privacy of Children Online
We are committed to protecting the online privacy of children and making the Internet safe for our users. We do not offer products or services to children under the age of 18 years old and will never knowingly collect information from minors. Minors should not place orders or provide personal information through this website.
Changes to Our Policy
We reserve the right to change or remove this Privacy Policy at our discretion, so check back to this page from time to time to see such changes. For certain material changes to this Privacy Policy, we may notify you by additional means, such as by posting a notice on the front page of our website or sending you an email.
Our Contacts
If you have concerns about this Privacy Policy or you have a privacy escalation, you may contact us at: support@superbbit.com. We will try to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response or decision, you can reach out to the applicable data protection authority:
The State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija in Lithuanian, website available at https://vdai.lrv.lt/).