What personal data is collected
Data collected directly from you –
This may be done through the Sites,
use of our
services, over the phone, email, or in person when you meet our staff or representative, when
you report any problem(s) to us or request any support from us, or when you complete any survey
or questionnaire that we send to you. Information that you provide us may include but is not
limited to: a. your name, employment information, contact information including your (first and
last) name, (billing and/or delivery) address, birthdate, email address and telephone number. We
need your email address and telephone number so that we may contact you if we havequestions or
information for you regarding your order or the service that we are providing or will provide to
you; b. other financial information required to be able to provide you with the products and
services, such as credit card information, bank account information, and other personal
description necessary to facilitate the same;
c. if you have an account with us, the preferences and interests stored in such profile or
account; and d. if you have contacted us, the details of the contact and the contact history.
Data collected by automated means – Various technologies may be used on our Sites
products and services. Such technologies may lead to data being collected automatically by us.
Such data may include but is not limited to: a. technical information, including the Internet
protocol (IP) address used to connect your computer to the Internet and your login information,
browser type and version, time zone setting, browser plug-in types and versions, operating
system and platform; b. information about your visit, including the full Uniform Resource
Locators (URLs), clickstream to, through and from the Sites (including date and time), products
and services you viewed or searched for, page response times, download errors, length of visits
to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and
c. methods used to browse away from the page, and any phone number used to call our customer
(III) DData collected from third parties – We work with third parties and we may receive
information about you from them, for example: a. business partners,
sub-contractors in technical, payment and delivery services, advertising networks, analytics
providers and search information providers; b. blockchain data; and c. public databases and
credit reference agencies.
Uses made of the information
We may use your personal data for the following purposes: a. providing, improving and
developing the Sites and our products and services; b. researching, designing and launching new
features or products and services; c. presenting content and information in our Sites in the
most effective manner for you and for the device you use; d. providing you with alerts, updates,
materials or information about our services or other types of information that you requested or
signed up to; e. enforcing obligations owed to us such as collecting owed payments in any part
of the world; f. responding or taking part in any claims, actions or legal proceedings
(including but not limited to drafting and reviewing documents, transaction documentation,
seeking legal advice, and facilitating dispute resolution) and/or protecting and enforcing our
contractual and legal rights and obligations; g. complying with legal and regulatory obligations
and requirements such as
anti-money laundering laws across jurisdictions; h. accounting, risk management,compliance and
record keeping purposes; i. staff training; j. communicating with you and responding to your
issues, questions, requests or feedback, purposes directly related or incidental to the above;
k. if you have consented, for the purposes of marketing products and services offered on our
Sites; and l. matching any personal data held which relates to you for any of the purposes
When using your personal data to contact you for the above purposes, we may contact you via
regular mail, fax, email, SMS, telephone or any other electronic means.
- If we need to use your personal data for any other purposes, we will notify you and obtain your
consent beforehand. You will be given the opportunity to withhold or withdraw your consent for
the use of your personal data for these other purposes.
Disclosure of your information
We will not sell your personal data to third parties.
We will keep your personal data we hold confidential, but you agree we may provide your personal
data to: a. any member of our group, which means our affiliates and subsidiaries to allow us to
provide the products and services which you have requested; b. personnel, agents, advisers,
auditors, contractors, financial institutions, and service providers in connection with our
operations or provision of the products and services (for example, staff engaged in the
fulfilment of your order, the processing of your payment and the provision of support services);
c. our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis
only); d. persons or entities under a duty of confidentiality to us; e. persons or entities to
whom we are required to make disclosure under applicable laws and regulations in any part of the
world; f. actual or proposed transferees of our operations (or a substantial part thereof) in
any part of the world; g. third parties where you have provided us consent and in the situations
expressly set out in this Policy; and h. our strategic partners and business associates if you
have consented to receiving marketing information from us.
- You fully understand and consent that we may transfer your personal data to any location
outside of Lithuania or the jurisdiction that we operate in for the purposes set out in this
paragraph 3. When transferring your personal data outside of Lithuania or the jurisdiction that
we operate in, we will protect your personal data to a standard comparable to the protection
accorded to your personal data under the GDPR by ensuring that the recipient is either in a
jurisdiction which has
comparable data protection laws, or is contractually bound to protect your personal data.
Storage and retention of your information
We only retain personal data for so long as it is necessary, which may be archived as long as
the purpose for which the said data was used still exists. We will cease to retain your personal
data, or remove the means by which the data can be associated with you, as soon as it is
reasonable to assume that such retention no longer serves the purpose for which the personal
data was collected, and is no longer necessary for legal or business purposes.
We may store and process all or part of your personal and transactional information, including
certain payment information, such as your encrypted bank account and/or routing numbers, in
Lithuania and elsewhere in the world where our facilities or our service providers are located.
We protect your personal information by maintaining physical, electronic, and procedural
safeguards in compliance with the applicable laws and regulations.
provide you with a good experience when you browse our websites and also allows us to improve
A cookie is a small file of letters and numbers that we store on your browser or the hard drive
transferred to your computer’s hard drive.
- We use persistent cookies and session cookies. A persistent cookie stays in your browser and
will be read by us when you return to our websites or a partner site that uses our services.
Session cookies only last for as long as the session (usually the current visit to a website or
a browser session). All web-browsers offer the option to refuse any cookie, and if you refuse
our cookie then we do not gather any information on that visitor.
- We use the following cookies: a. Strictly necessary cookies – These are cookies that are
required for the operation of our websites. They include, for example, cookies that enable you
to log into secure areas of our websites, use a shopping cart or make use of e-billing services.
b. Analytical/performance cookies – They allow us to recognise and count the number of visitors
and to see how visitors move around our websites when they are using it. This helps us to
improve the way our websites work, for example, by ensuring that users are finding what they are
looking for easily.
- Functionality cookies – These are used to recognise you when you return to our websites. This
enables us to personalise our content for you, greet you by name and remember your preferences
(for example, your choice of language or region). d. Targeting cookies – These cookies record
your visit to our websites, the pages you have visited and the links you have followed. We will
use this information to make our websites and the information displayed on it more relevant to
your interests. e. You can block cookies by activating the setting on your browser that allows
you to refuse the setting of all or some cookies. However, if you do so, you may not be able to
access all or parts of our websites. f. We may use third-party web services on our websites. The
service providers that administer these services use technologies such as cookies (which are
likely to be analytical/performance cookies or targeting cookies), web server logs and web
beacons to help us analyse how visitors use our websites and make the information displayed on
it more relevant to your interests. The information collected through these means (including IP
addresses) is disclosed to these service providers. These analytics services may use the data
collected to contextualise and personalise the marketing materials of their own advertising
Our Sites or our communications with you may from time to time contain links to third-party
websites over which we have no control. If you follow a link to any of these websites, please
note that they have their own practices and policies. We encourage you to read the privacy
policies or statements of these websites to understand your rights. We accept no responsibility
or liability for any practices of third-party websites.
All information you provide to us is stored on our secure servers.
- Any payment transactions will be encrypted using TLS/SSL technology.
- Where we have given you (or where you have chosen) a password that enables you to access certain
parts of the Sites, you are responsible for keeping this password confidential. We ask you not
to share a password with anyone.
- We restrict access to personal information to our employees, service providers, agents,
representatives and contractors on a strictly need-to-know basis and ensure that those persons
are subject to contractual confidentiality obligations.
- We review our information collection, storage and processing practices from time to time to
guard against unauthorised access, processing or use.
- Please note, however, that the transmission of information via the Internet is not completely
secure. Although we will do our best to protect your personal data, we cannot guarantee the
security of your data transmitted to the Sites. Any transmission is at your own risk. We
recommend that you change your passwords often, use a combination of letters and numbers, and
ensure that you use a secure browser.
- If applicable, you undertake to keep your username and password secure and confidential and
shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as
soon as reasonably practicable if you know or suspect that someone else knows your username and
password or believe the confidentiality of your username and password has been lost, stolen or
compromised in any way or that actual or possible unauthorised transactions have taken place. We
are not liable for any damages resulting from any security breaches, on unauthorised and/or
fraudulent use of your username and password.
For individuals who are located in the European Economic Area, United Kingdom or Switzerland at
the time their personal data is collected, we rely on legal bases for processing your
information under the GDPR. We generally only process your data where we are legally required
to, where processing is necessary to perform any contracts we entered with you (or to take steps
at your request prior to entering into a contract with you), for our legitimate interests to
operate our business or to protect our or your, property, rights, or safety, or where we have
obtained your consent to do so.
- When processing your personal data as set out in this Policy, as we are located in various
countries throughout the world, it will have been transferred outside the EU. However, if your
personal data is originally collected from within the EU, it will only be transferred on one of
the following bases: a. the country that we send the personal data to is approved by the
European Commission as providing an adequate level of protection for personal data; or b. you
have explicitly consented to the same. To find out more about international transfers by us of
your personal data and the countries concerned, please contact our Data Protection Officer.
If you have any questions, comments or requests regarding the processing of your personal data
or about this Policy, if you do not accept the Policy, if you wish to withdraw any consent you
have given us at any time, or if you wish to update or have access to your personal data, please
contact us at:
Attention it to the “Data Privacy Officer” Office address:
Registered Office: UAB “Pinigai”, Partizanų g. 61-806, Kaunas, Lithuania.
- Your rights under the GDPR are the following: a. To obtain access to, and copies of, the
personal data that we hold about you; b. To require that we cease processing your personal data
if the processing is causing you damage or distress; c. To require us not to send you marketing
communications; d. To require us to erase your personal data; e. To require us to restrict our
data processing activities; f. To receive from us the personal data we hold about you which you
have provided to us, in a reasonable format specified by you, including for the purpose of you
transmitting that personal data to another data controller; and g. To require us to correct the
personal data we hold about you if it is incorrect. Please note that the above rights are not
absolute, and we may be entitled to refuse requests where exceptions apply. If you are located
in Europe, to find out more about your rights please refer to the EU regulator in the place
where you are located (in the EU). If you have any questions about how we use your personal
data, or you wish to exercise any of the rights set out above, please contact our Data
- Any request under Clause 9.2 and 9.3 may be subject to a small administrative fee to meet our
cost in processing your request.
- All requests for correction or for access to your personal data must be in writing. We will
endeavour to respond to you request within 30 days, and if that is not possible, we will inform
you of the time by which we will do so.
- We may be prevented by law from complying with any request that you may make. We may also
decline any request that you may make if the law permits us to do so.
In many circumstances, we need to use your personal data in order for us to provide you with
products and services which you require or have requested. If you do not provide us with the
required personal data, or if you do not accept the Policy or withdraw your consent to our use
and/or disclosure of your personal data for these purposes, it may not be possible for us to
continue to serve you or provide you with the products and services that you require or have
Changes to our Policy
We may amend this Policy from time to time by posting the updated policy on our Sites. By
continuing to use our Sites and products and services after the changes come into effect means
that you agree to be bound by the revised policy.
In case of discrepancies between the English and other language versions of this policy, the
English version shall prevail.
General Disclaimer and Limitation of Liability
To the maximum extent permitted by law, we shall not be liable in any event for any special,
exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss
of reputation or goodwill, whether based in contract, tort (including negligence), equity,
strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use,
access or disclosure of your personal data.
- Our total aggregate liability to you (if any) for any individual claim or series of
connected claims for losses, costs, liabilities or expenses which you may suffer arising out of,
or in connection with, any breach of this Policy by IZOBI shall be limited to a maximum
aggregate value of the combined value of the Digital Currency and E-Money on deposit in your
E-Money Wallet and your Digital Currency Wallet at the time of the relevant claim (kindly refer
to the User Agreement for definitions of these terms). Where we are considering a specific claim
relating to a specific transaction this sum shall be further limited to the purchase / sale
relevant) of the transaction in dispute. We shall not be liable where the said liability has
arisen from your negligence, gross negligence or fraud.