Privacy Policy
Effective as of 2024 09 02
1. General Terms and Conditions
UAB Pace App ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share your personal information when you visit our website www.pace.app or use our services.
This Privacy policy sets out the basis on which the Company processes Customers’ and Partners’ personal data. This is further enforced by the Company’s internal policies and procedures. Moreover, as the Company collects and uses the personal data (hereinafter – the Personal data) of its customers (hereinafter – the Customers), and third party service providers (hereinafter – Partners) the Company is obligated to use and process the Personal data of the Customers and Partners only in accordance with this privacy policy and the applicable acts which regulate the protection of Personal data.
When the Company’s potential Customer is a legal person, the head or other representative of the Customer, filling out the registration application form for the use of the Company’s products and services, shall properly inform the Data subjects (Beneficial owners, Heads, etc.) about the transfer of their data to the Company, as well as the contents of the Company’s Privacy policy.
Profiling by automated means may be used when processing Personal data for some services and products for the purposes of risk management in accordance with the Company’s legal obligations as well as for internal assessment and analysis of the market products. When a decision is based on automated processing including profiling, you have the right to contact us and provide your objection to such a decision.
2. Principles of processing personal data
The Company commits to comply with the provisions of General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other applicable Personal data protection regulations and legal acts in the Republic of Lithuania and the European Union.
This Privacy Policy is prepared for the purposes of introducing Customers and Partners to how the Company processes the Personal data of its Customers and Partners and what kind of measures are implemented in the Company to achieve the adequate protection of the Personal data that are processed during the provision of Services. The principles that the Company strictly follows to comply with the needs to protect its Customers’ and Partner’s Personal data are, as follows:
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Personal data is collected for specified and legitimate purposes and will not be further processed in a way that is incompatible with those purposes established prior to the collection of Personal data.
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Personal data is processed in a lawful, fair and transparent way.
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Personal data is accurate and, if necessary for the processing of personal data, constantly updated.
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Personal data is collected only to the extent which is necessary to fulfil the specified legitimate purpose.
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Personal data is stored for the period specified by the Company, but not longer than the terms set forth by the applicable legal acts. When the storage term has expired, the Personal data will be destroyed.
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Implementation of adequate organizational measures designed to secure Personal data against accidental or illegal destruction, modification, disclosure, and any other illegal management.
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Implementation of measures designated for the prevention of the use of Personal data by persons seeking to acquire funds by fraudulent means.
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The Personal data of the Customers and Partners is considered as confidential information and may only be disclosed to third parties in accordance with the rules and procedure provided in the Privacy Policy, internal documents of the Company and the legal acts of the Republic of Lithuania.
3. Legal basis for Personal data processing and purposes
Personal data is only processed by the Company when:
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the customer has given consent;
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processing of data is necessary to fulfill the Agreement to which the customer is a party or to act at the request of the customer prior to the conclusion of the agreement;
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to process data necessary for the fulfillment of the legal obligation imposed on the Company;
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to process data based on Company’s legitimate interest.
The purposes of the processing of the Personal data are, as follows:
(a) The provision of any of the following Services (directly or through a Partner’s Platform):
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issuance, distribution and redemption of electronic money;
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execution of payment transactions;
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store money value service;
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payment initiation and account information service;
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corporate card service;
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individual card service;
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card acquiring service.
Legal basis of processing: performance of a contract.
(b) The conclusion and execution of agreements (with Customers or Partners).
Legal basis of processing: performance of a contract.
(c) Customer services, including responses to questions, feedback, complaints, and the provision of the information regarding the Company’s products or services.
Legal basis of processing: performance of a contract, legal obligation.
(d) Implementation of obligations under the Law on Money Laundering and Terrorist Financing Prevention and other applicable regulations or imposed by the Partner (Customer’s identification, verification of identity via live conference call, verification of customer’s/ UBO’s data against public registries, databases, public domain, etc., ongoing monitoring of the Customer’s activity, risk assessment and analysis, risk management activities, inspections of the complex or unusually large transactions and unusual transaction structures).
Legal basis of processing: legal obligation, performance of a contract.
(e) Implementation of obligations under regulations or self-regulation governing financial sector (e.g. due diligence of the 3rd party service providers as per EBA guidelines on outsourcing).
Legal basis of processing: legal obligation.
(f) Risk management processes (e.g. data processing for fraud prevention).
Legal basis of processing: legitimate interest – Company’s interest to systematically monitor and prevent illegal acts and constantly assess related risks.
(g) Video surveillance in the physical office of the Company.
Legal basis of processing: legitimate interest – Company’s interest to protect employees, customers, potential customers, third parties and Company’s property.
(h) Administration of data of potential customers, improvement of quality of the products and services.
Legal basis of processing: legitimate interest – Company’s interest of business development.
(i) Customer service quality assurance purposes and to protect customer’s and the Company’s interests.
Legal basis of processing: legitimate interest – Company’s interest to monitor and ensure high quality standards and protect customers and Company from litigation processes.
(j) Debt management process.
Legal basis of processing: legitimate interest – Company’s interest to file and defend legal claims and take other legal actions to avoid losses or reduce them.
k) Additionally, the Company may collect and process the Personal data of the Customer as part of its direct marketing operations.
Legal basis of processing: consent of a data subject.
(l) On receipt of ad hoc data subject’s request and proactive consent, their personal data may also be processed for the respective purposes specified in said request.
Legal basis of processing: consent of a data subject.
Personal data collected for direct marketing purposes may be processed only in those instances where the Customer has given clear consent for such actions. Consent can only be collected in a manner in which it is clearly indicated that the Customer agrees with the processing of their Personal data for the purposes of direct marketing. Direct marketing is all activities by which the Company offers its goods or services to the Customer by post, telephone or other direct electronic means. In the event that the Customer refuses consent to the processing of their Personal data for direct marketing purposes, their Personal data will not be processed for direct marketing purposes.
The Customer is granted the right to withdraw their consent given for the processing of the Personal data for the purposes of the direct marketing. The Customer may withdraw their given consent freely at any point of time by using the electronic channel which is dedicated to the management of the Customer’s account and for the communication with the Company.
4. Information We Collect
We collect the following types of personal information:
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Contact Information: Name, phone number, and email address provided via our contact form.
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Newsletter Subscription: Email address provided via our subscription form.
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Usage Data: Information about your interaction with our website, such as IP address, browser type, and pages visited, collected through cookies.
5. How We Use Your Information
We use your personal information for the following purposes:
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To Communicate with You: To respond to inquiries or requests made via our contact form.
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To Send Newsletters: If you opt-in to receive our newsletter, we will use your email address to send periodic updates and promotional content.
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For Analytics: To understand how our website is used and to improve user experience through the use of analytics tools provided by Wix and Google.
6. Data Sharing
We only share your data with third parties for the purpose of analytics (e.g., Wix Analytics and Google Analytics). We do not sell or rent your personal information to any third parties.
The Customer Personal data specified in this Privacy Policy may be transferred to:
a) payment service users (payees and payers);
b) financial institutions;
c) agent of a payment institution;
d) credit/debit card processing service provider;
e) partner operating the Platform data subject is using (as well as other Platform participants where applicable);
f) identity verification service providers;
g) vendors of software development and support services;
h) transaction monitoring service providers;
i) risk management tools providers;
j) website domain hosting providers;
k) cloud service providers;
l) external consultants, auditors (subject to confidentiality commitment);
m) other suppliers;
n) law enforcement units, regulatory and administrative bodies, auditors or courts, in situations where the Company is required by law to do so.
7. Your Rights
As an EU-based user, you have the right to:
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Access: Request a copy of the personal information we hold about you.
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Rectify: Request that we correct any inaccurate or incomplete personal information.
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Erase: Request that we delete your personal information, subject to certain conditions.
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Restrict: Request that we restrict the processing of your personal information in certain circumstances.
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Object: Object to the processing of your personal information for certain purposes.
Toexercise any of these rights, please contact us at info@pace.app .
8. Data Security
The Company implements necessary organizational and technical measures to protect the Customers’ personal data in transit and at rest from accidental or unlawful destruction, modification, disclosure, as well as any other unlawful handling.
9. Use of Cookies
a) What Are Cookies?
Cookies are small text files stored on your device (computer, tablet, or mobile) when you visit a website. They help improve your experience by remembering your preferences and enhancing site performance.
b) Types of Cookies We Use
We are using various type of cookies, which could be segregated to different groups, regarding their have expiration date, source and functionality (purpose).
Functionality or Purpose
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Strictly Necessary Cookies: These cookies are essential for the website to function properly. They cannot be switched off in our systems.
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Performance Cookies: These cookies allow us to count visits and traffic sources to measure and improve the performance of our site. They help us understand which pages are the most and least popular.
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Functional Cookies: These cookies enable the website to provide enhanced functionality and personalisation, such as remembering your choices.
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Targeting Cookies: We do not use targeting cookies directly, but third-party services integrated into our site might use them to deliver personalised advertisements.
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Marketing cookies: advertisement cookies are used to provide visitors with relevant adds and marketing campaigns. These cookies track visitors across websites and collect information to provide customized adds.
c) Expiration
Session cookies, also known as 'temporary cookies', help websites recognize users and the information provided when they navigate through a website. Session cookies only retain information about a user's activities for as long as they are on the website. Once the web browser is closed, the cookies are deleted.
Permanent cookies, also known as 'persistent cookies', remain in operation even after the web browser has closed. Upon visiting a website repeatedly, the user’s web browser reads any retained persistent cookies and supplies the information back to the website or the element that originally installed the cookie.
d) Source
First-party cookies are originated from domain opened by users’ with the aim of collecting certain information needed to ensure website funtionality and provide a better user experience to the customer.
Third-party cookies are installed by third-parties with the aim of collecting certain information from web users to carry out research into behavior. They are used to ensure that products and services are marketed towards the right target audience.
List of cookies used by us currently is displayed on the cookie banner on the website.
The Customer has to express their consent or non-consent for the use of cookies. The cookies settings present the Customer with an overview of the cookie categories. The cookies (except for strictly necessary cookies) are used only when the Customer consents to their usage.
Delete stored cookies - if at a certain moment you have allowed the use of cookies when visiting our website and now you wish to opt out and delete the cookies collected, please see instructions on how to proceed according to your browser http://www.aboutcookies.org/.
e) How Long Do Cookies Last?
The cookies used on our site vary in duration:
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Session Cookies: These are temporary cookies that expire once you close your browser.
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Persistent Cookies: These remain on your device for up to one year or until you delete them.
f) Third-Party Cookies
We use third-party services like Wix Analytics and Google Analytics to understand how our website is used and to improve user experience. These third parties may use cookies to collect information about your online activities over time and across different websites.
g) Managing Cookies
You can control and manage cookies using your browser settings. Please note that blocking or deleting cookies may affect your experience on our website.
For more details on how to manage cookies, visit allaboutcookies.org.
10. Data Retention Period
We store the data for no longer than is required for the purposes for which the data is initially collected and processed.
Personal data records are stored for a maximum of 10 years after the termination of the business relationship with the Customer to comply with legal obligations and protect the Company’s legitimate interests. Such records include Copies of the identity documents of a Customer, the identity data of a beneficial owner, the identity data of a beneficiary, direct video streaming/direct video broadcasting recordings, other data received at the time of establishing the identity of the Customer and account and/or agreement documentation.
Business correspondence with the Customer in paper or electronic form for 5 years from the date of termination of their business relationship with the Customer.
Consent for direct marketing is valid until such time as the Customer has withdrawn it or when the business relationship ends, but no longer than 5 years. For more detailed information on the specific retention periods applicable for other categories of personal data, please contact us directly via info@pacea.app.
Partner’s (outsourcing partners, correspondent banking partners and other 3rd party service providers) data is kept for 10 years after the partnership agreement expired.
Recorded phone calls, when data subject makes a call to Company’s customer support, are stored for up to 10 years after the recording date.
The Company’s premises’ entrance video recordings are kept for 60 calendar days.
In the event that the transaction was not concluded (no agreement is signed by both parties, business relationship is not started), Personal data of potential customers shall be kept for no longer than 2 years (due to 2 years limitation period for filing a complaint with the Data Protection Authority) from the date of receipt of the data, unless the Data subject has provided a written request for the destruction of the Personal data processed by the Company.
11. Legal Basis for Processing
We process your personal information based on your consent, which you provide when you submit your information through our forms or accept cookies on our site.
12. Changes to This Privacy Policy
The Company may update this Privacy policy in case of changes in applicable legislation or changes in Company’s operations. Updated Privacy Policy will be posted on this website. If updates reflect a substantial or material change to the Personal data processing, the Company will inform the Customer about this prior to these changes coming into effect.
13. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal information, please contact us at info@pace.app.
The Company will be happy to help if any issues occur. Please contact the Company by sending an e-mail to our Data Protection Officer contact listed below.
Email: info@pace.app.
If you have any doubts or suspicions concerning the authenticity of any correspondence you have received from, or on behalf of, Company or its representatives, please contact Pace App immediately via any of the following contacts: by email: info@pace.app.