Privacy policy

PRIVACY POLICY

This Privacy policy (Privacy policy) contains information about what personal data we are processing for what purpose, how long we keep it, who we can communicate information about you, and what rights you have as a data subject.

Data controller's data

"NEO Finance", AB, legal entity code 303225546, Ukmerges str. 126, Vilnius (hereinafter referred to as "we" or "data controller" or "Company").

DATA PROTECTION OFFICER

A data protection officer has been appointed in the Company.

If you would like to check or find out how the company processes your personal data, or if you are going to exercise your rights as data subjects, please contact the Company appointed data protection officer, email: [email protected], or by phone +37068700300.

PRIVACY POLICY OBJECTIVE AND ITS APPLICATION

The privacy policy is aimed at persons, who are interested in the company, its services, potential and current investors, consumer credit recipients, representatives of service providers whose personal data are processed for the purpose of cooperation, persons who visit the websiteswww.neofinance.com, www.paskoluklubas.lt and https://neopay.online/ (hereinafter referred to as "website" or “ websites”), use the company's electronic services, communicate with the company on social networks or otherwise, or simply monitors the company's activities on social networks.

Additional information may be provided in consumer credit, paid surety, electronic money account and payment service provision and other contracts, as well as in an agreement for investment in consumer credits.

We respect your privacy and undertake to process and protect your personal data in a fair and lawful manner in accordance with the applicable legal requirements of the European Union and the Republic of Lithuania and the instructions of the controlling authorities. We apply appropriate technical and administrative measures to protect personal data against loss, unauthorized use, and changes.

Your data may be transferred outside the European Union by signing agreements with personal data processors that comply with European Union requirements.

Data may be transferred outside the European Union, when the transfer is necessary for the conclusion and performance of contracts, proper provision of services to the Company's customers. In this case, the Company takes steps to ensure that any transfer of personal data outside the EU/ EEA is properly carried out and that the data subjects' rights to privacy are protected to the maximum. When transferring customers' personal data outside the EU/ EEA, the company follows:

  • On the basis of a decision taken by the European Commission on the suitability of a foreign country;
  • Certification mechanism approved in a foreign country;
  • Decision of the European Commission on standard contract terms.

A third country outside the EU / EEA where the recipient of the personal data is located must, by decision of the European Commission, ensure an adequate level of protection of personal data.

By contacting us, you express your will for the Company to contact you regarding your request. By submitting personal data to us on this website or by browsing through it, as well as using electronic services, you confirm that you have read the Privacy policy and are familiarized with the fact your data is processed.

The Privacy policy is governed by the law of the Republic of Lithuania.

We may change the Privacy policy at any time at our sole discretion or if required by applicable law.

Company employees and members of the management bodies are informed about the processing of their personal data in accordance with the procedure, approved by the Company's local acts.

Personal data sources

Personal data may be obtained directly from you when you use electronic services, you enter into contracts with us in your name or while representing other persons, send your CV, as well as other information related to employment, practice in the Company or otherwise contact us, communicate with us through social networks or simply watch our activities on social networks or by visiting the Company.

We may also receive your personal data indirectly from persons you represent, your spouses, data processors, databases collecting separate specific data, registers and information systems, other external sources, including but not limited to: Bank of Lithuania, financial Institutions, State Social Insurance Fund Board (SODRA), Databases and registers administered by the State Enterprise Center of Registers, data controllers managing joint debtor's data files, databases managed by UAB "CREDITINFO LIETUVA", Public register of invalid personal documents, Public register of wanted (missing) people.

You are not required to provide any personal data, but it may make it impossible to provide services for you.

WHY ARE WE PROCESSING YOUR PERSONAL DATA?

We process your personal data for the following purposes, including, but not limited to:

  • For administration of applications or other inquiries, including but not limited to complaints, or to resolve any issues that require your data when you contact us;
  • Determining your identity to implement the principle of prevention of money laundering and terrorist financing - Know Your Customer;
  • For the purpose of contacting you to find out your needs;
  • Business relations and data updating;
  • Data verification, creditworthiness assessment, rating;
  • Identification (including remote identification);
  • Concluding contracts with investors, consumer credit recipients and agreements related to them, as well as service provision, including the electronic money account and payment service provision, reciprocal leasing platform operator's service provision, payment initiation service provision;
  • Calls are being recorded for the purpose of service quality control;
  • Tax payments to the state budget;
  • Debt prevention and administration, including sending reminders regarding the closest payment date and the amount of debt;
  • Extra-judicial and judicial debt recovery, legal claims provision, execution and defense;
  • Defense against claims and complaints;
  • Organizing and conducting lotteries, games, recommendation programs, events;
  • Promotion of the Company awareness;
  • To improve website performance so you can easily find what you are looking for and efficiently use electronic services;
  • Search for employees, trainees;
  • Supporting customer and partner relationships;
  • Internal administration;
  • Accounting;
  • Information provision and communication;
  • Direct marketing.

We process your personal data for the above-mentioned purposes, because we are bound by existing legislation, an agreement with you or we process your personal data on the legal basis of legitimate interest - ours or third party's (or yours), for example, to optimize costs by improving quality. Your data will not be processed on a legal basis for legitimate interests if your interests, rights and freedoms will be of higher importance. We may also process your personal data for thepurpose of entering into an agreement with you or withyour consent, or in order to protect the vital interests of you or any other natural person.

WHAT KIND OF YOUR PERSONAL DATA DO WE PROCESS?

For above-mentioned purposes for processing of personal data, we may process, but not be limited to, the following basic categories of personal data:

Name, surname, personal identification number, date of birth, place of residence (address), identification document, nationality, telephone number, e-mail address, age, amount invested and amount limits, investment conditions, rating of the borrower, rating, risk group, credit history, nickname, representation data, date of conclusion of the contract, method of signing, electronic money account and its money turnover, customer attribute (consumer credit recipient / investor), payment order details, credit institution, investment report, investor status, legal entity representative data, debt, workplace, due payment deadline, income received, business license and individual economic activity data, data on available assets and restraints, number of underage children and dependents, marital status, consumer credit terms, purpose, preferential financial commitments which received a negative decision - types and sums, existing liabilities and past due debts, ensuring guarantee , if the person is / is not included in the list of persons for whom there are request to not allow them to enter into consumer credit agreements, time of conclusion of consumer credit agreement, customer and beneficiary recognition questionnaire data, user identification number , information about a search for the person, managed shares, other rights in a legal person, personal name, alternative names, e-mail, signature data, personalized banking security data, settlement result, website registration details, security code for person identification, actions you take, and information provided when you sign in to customer self-service area, date of identification, time, IP address, website browsing history and date, prize, reward for recommendation, recommendation code, query data, other information needed for up keeping relationship, billing and contract management and providing legal requirements, data subject profile and other information in social media.

Specific categories of processed personal data may also be listed in separate sections of the Privacy policy.

PROCESSING PERSONAL DATA FOR THE PURPOSES OF EMPLOYMENT OR TRAINEESHIP AT THE COMPANY

Potential Company employees (candidates, persons seeking employment) and potential trainees provide the following personal data to the Company: CV, name, surname, contacts (email, telephone number), motivation letter. You can read about the processing of your personal data as a potential employee in this part of this Privacy policy.

If you contact us through social media, the social network controller may process your interest in our published positions for the purposes set out in social network controller's policies.

Your personal data, submitted whenever you apply for a specific position, published by the Company, shall be processed for the purpose of concluding an employment contract, or a traineeship agreement with you as a potential employee and a trainee.

If you are applying for a particular position, but the job or practice offer is not provided, after the end of selection for a specific position, published by the Company, your personal data will be destroyed unless you consent to the retention of your personal data for future trainee or employee recruitment purposes. Withdrawing your consent to the processing of personal data for the purposes, specified in this Privacy policy section, may be expressed at any time to the Company's employee in a clear and unambiguous manner by contacting us by phone or e-mail.

VIDEO DATA AND PICTURE PROCESSING FOR IDENTIFICATION PURPOSES

While implementing the requirements of the Law on the Prevention of money laundering and terrorist financing of the Republic of Lithuania, we must determine the identities of clients and beneficiaries and their representatives. We can also determine identity remotely (e.g. by using the MARK ID identification program). If we identify you with the MARK ID identification program, we will process your image data: image, face, identity document, video transfer time, date, your name, zodiac sign, etc. and we will capture the face and identity document by taking pictures during video recording.

RECORDING OF CALLS FOR SERVICE QUALITY CONTROL PURPOSES

For this purpose, we will process your name, telephone number, date of call, conversation start and end time, conversation content. We will only record the conversations that are taking place by your call to 8 700 80075, 8 700 500 56 and when we call you by the Company's assigned numbers during the Company's business hours. We inform you that the conversation is being recorded, prior to the start of the actual conversation. By continuing the conversation, you express your consent to the recording of the conversation. If you do not agree with the conversation being recorded, we invite you to the Company for the conversation.

Data processing for direct marketing purposes

By submitting your name, surname and e-mail address, you may agree / disagree with the use of this data for direct marketing purposes.

When processing personal data for direct marketing purposes, we may also receive information about whether the newsletter has been read: when and how many times the letter or its link has been opened.

If you have a contract with us and have not objected to the processing of personal data for direct marketing at the time of data collection, we will process your data for this purpose according to a legitimate interest by sending notifications regarding similar services.

We will process your personal data 5 years the receipt of the consent or until you withdraw the consent.

You can refuse to receive such direct marketing messages at any time by emailing us at [email protected] or by clicking on the opt-out link at the bottom of the newsletter, received from the Company.

The consent you have us to use the data for direct marketing purposes may be revoked at any time by the following e-mail: [email protected] or by clicking on the rejection of subscription link at the bottom of the newsletter, received from the Company.

PERSONAL DATA PROCESSING DURING THE PROVISION OF OPEN BANKING SERVICES

We provide open banking services (payment initiation, recurring payments initiation, account information services) in accordance with the principles of Law on Payment of the Republic of Lithuania, Law on Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania, good practice of Payment initiation prepared by the Bank of Lithuania. We will process the personal data received for this purpose, only in order to provide the payment initiation service.

By providing open banking services (payment initiation, recurring payments initiation, account information services), we process such personal data of yours as name, bank account number or electronic money account number, details of the selected account servicing payment service provider, information on payment account balances and transactions performed, payment purpose, initiated (recurring) payment amount, unique financial operation number, status of the operation performed, periodicity of the initiated recurring payments, term of validity of the recurring credit transfer agreement, date of the first payment under the recurring credit transfer agreement. The specific categories of your personal data processed by the Company depend on the respective open banking service provided to you.

By providing open banking services, we may also process other data that is received and processed in order to ensure the proper provision of payment services, implementation of legal acts regulating the prevention of money laundering and terrorist financing and applicable to the Company.

We will process the acquired personal data only for the purpose of proper provision of open banking services.

You can only use open banking service if you implement active actions in confirming that the information about you, received by the Company, would be used to provide respective service.

When we provide you a payment initiation service, we enable you to take active steps to express your consent to save certain of your data and to make a payment to the relevant payee faster next time. In this case, on the basis of your consent, we store your account numbers and relevant coded technical information which shall help to identify you more quickly next time. We will store such data for 180 days from the date of consent. After this term, you will be able to resubmit your consent to process your data and make payments more quickly.

Personalized security features provided by your credit institution are only available to you and the credit institution that issued them. We will not keep, store, or transfer to you any sensitive open banking service user data, i.e. such as data that is usable for fraudulent purposes and that includes personalized security features.

If, with your consent, we provide a payment initiation or recurring payments initiation services, the Company will provide the information about a successfully executed payment, your name, surname, account number or accordingly a successfully concluded recurring credit transfer agreement and its terms to the payee.

If we provide an account information service on the basis of your consent, we may transfer account statement information to third parties for your creditworthiness assessment or other lawful purposes only with your separate consent and by ensuring additional technical means.

When providing open banking services, we will store your personal data for a maximum period of 3 years, except for the exceptions established by legal acts.

INITIAL SHARE PUBLIC OFFERING (IPO) PARTICIPANT DATA PROCESSING

We conduct the initial public offering (IPO) in accordance with the Law on Securities of the Republic of Lithuania and other legal acts. We will process personal data received for this purpose only for the purpose of participation in the initial public offering (IPO).

To participate in the initial public offering (IPO), you can register at www.neofinance.com by opening an electronic money account and selecting the status of a participant in the public offering (IPO).

We will keep the following data for the initial public offering (IPO): user ID number, offered share price, quantity, total offered amount. We will keep this data for 10 years after the day of the end of the initial public offering (IPO).

PROFILING AND AUTOMATED DECISION MAKING

In order to achieve the objectives set out in the Privacy Policy, such as providing your credit rating, submitting a consumer credit offer, preventing money laundering and terrorist financing in the Republic of Lithuania, we may analyze personal data automatically, make automated decisions, and divide data subjects into groups, personal aspects. We carry out automated decision-making, including profiling, with your consent, in order to conclude or execute a contract with you, to implement the legal requirements (respectively Article 6 (1) (a), (b), (c), Article 22 (2) (d) of the General Data Protection Regulation).

We process the following personal data about you for the purpose of assigning your credit rating and submitting a consumer credit offer for profiling and automated decision making: name, surname, place of residence, citizenship, age, gender, your credit history, number of minor children and dependents, marital status, spouse data, current financial liabilities and delays, information about the workplace, data about the available assets, information on the desired consumer credit (amount, term), your income, etc.

When profiling for the purposes of money laundering and terrorist financing prevention in the Republic of Lithuania, we process the following personal data of you: name, surname, date of birth, place of residence (address), citizenship, income, source of income, position held, type of activity, information on political vulnerability, the number of shares held in the company and other data provided in the customer identification questionnaire or data obtained from external sources, such as lists of international sanctions.

The following personal data will be processed in accordance with the above purposes:

• we will process your data for a maximum of 10 years for the purposes of profiling your credit rating and submitting a consumer credit offer through profiling and automated decision-making;

• carrying out profiling for the purposes of prevention of money laundering and terrorist financing of the Republic of Lithuania for a maximum of 8 years. The storage period may be additionally extended for a maximum of 2 (two) years.

Please be informed that in addition to the rights set out in another section of the Privacy Policy, you have the right to request human intervention, to express your view and to contest an automated decision (Article 22 (3) of the General Data Protection Regulation).

MANAGING YOUR DATA WHEN YOU PROVIDE FEEDBACK AND SUGGESTIONS

We process your data, which you provide by writing reviews and suggestions to the Company.

In this case, we process data such as your name, surname initials/ nickname, e-mail address, as well as data on existing and existed loans and / or investments, type and/ or purpose of loans, as well as your personal history and experience provided by you, related to the services we provide or have provided.

By sharing your feedback and suggestions, you must submit a consent to the Company, on the basis of which the Company may publish them on social networks, newsletters, website news (without providing your contact details). Your feedback, suggestions can be published in the public space without specifying your real name, for example, you can specify a false name (nickname) when submitting feedback or suggestions.

You may provide feedback and suggestions to the Company and indicate that you do not wish this information to be disclosed to the public, to provide it anonymously.

We remind you that you can at any time cancel the consent given to the Company to publish your feedback, offers in a way convenient for you: by e-mail, registered mail, telephone or upon arrival at the Company's registered office address.

Company contact details: e-mail email: tel. no. 870080075, registered office address: Ukmerges str. 126, Vilnius, Lithuania.

PERSONAL DATA STORAGE PERIOD

Personal data shall be processed for no longer than it is necessary for the purposes for which the data is processed, or for no longer than is required by the data subjects and / or provided for by law.

Usually, we keep data during the course of the provision of services, during the validity of the contract and 10 years after the expiration of the contract or legal relationships, while executing the requirements set forth in legal acts related to document archiving and in order to declare, execute or defend the legal claims of the Company.

If the transaction has not been concluded, we will store personal data for 3 years from the date of its receipt. If a transaction is refused due to the implementation of money laundering and terrorist financing prevention measures, personal data shall be stored for 8 years from the moment of refusal.

When the personal data of the payment initiation service participant are provided, it is stored for 3 years after the receipt of the data.

According to the requirements of legal acts regulating the prevention of money laundering and terrorist financing of the Republic of Lithuania, we will process personal data for 8 years from the date of receipt.

Data provided by candidates, trainees after a specific selection has ended, and whenever a candidate did not enter into a contract with the Company, or in case the candidate has submitted his / her data without applying for a specific position in the Company, with the consent of the data subject, is retained for 1 year or until the data subject revokes the consent for data processing.

Data received by recording conversations are stored and processed for a maximum of 10 years from the date of their receipt.

For the purpose of direct marketing and according to your consent, we process your personal data for no longer than 5 years after receiving your consent, or until you revoke your given consent regarding data processing.

For the purposes of direct marketing, while providing messages regarding similar service, according to the basis of legitimate interest, we process personal data during the term of the contract with you and during 3 years after the expiration of the contract or until you will object to the receipt of such messages.

If you revoke your consent for data processing or the data processing term expires (when the data is processed on the basis of your consent), only the data confirming the fact of your consent is retained for 10 years from the end of the consent period or the cancellation of consent in order to declare, execute or defend the legal claims of the Company.

PERSONAL DATA RECIPIENTS AND DATA PROCESSORS

We may provide your personal data to the following persons according to the data provision basis and after ensuring the safety of transferred data:

  • investors, when we mediate regarding the provision of consumer credit (impersonal information mandatory for the investment: consumer credit recipient's rating, loan repayment history, loan purpose, loan date);
  • recipients of funds, whenever the payment service initiation service is provided;
  • consumer credit institutions or financial companies, participating in the Infobank information system, managed by UAB "Creditinfo Lietuva" and the credit bureau system;
  • financial institutions with whom we have concluded agreements regarding provision of personal data for identification purposes;
  • State Social Insurance Fund Board (SODRA);
  • in case of a dispute - to persons providing legal services to us, attorneys;
  • for extrajudicial debt recovery - UAB "Legal Balance";
  • auditors, other consultants, notary offices, bailiff offices;
  • To third parties in the case of payment initiation and transfers or other payment solutions: gambling organization companies, betting organization companies, as well as game organization and implementation companies which use data for identification and verification of a person's identity;
  • used data processors (i.e. UAB "Klavakrapštis", UAB „Duomenų logistikos centras“, to natural persons, providing contractual IT services to the Company, UAB "TCG TELECOM", UAB „Scorify“, UAB „Creditinfo Lietuva“);
  • business partners;
  • to the Bank of Lithuania, the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania, to the Ministry of Foreign Affairs; The State Tax Inspectorate under the Ministry of Finance of the Republic of Lithuania;
  • state institutions, law enforcement agencies and other persons in accordance with the procedure established by legal acts of the Republic of Lithuania or when the provision of data is necessary in order to declare, execute or defend the Company's legal claims.

If you participate in games and/or lotteries, organized by the Company, we may publicly disclose your winnings upon the receipt of your consent.

We may also provide personal data to other persons upon receiving your consent.

We may also provide your data to protect your vital interests (for example, if you feel ill in our premises and we have to seek medical assistance).

If we disclose your personal data to groups of recipients other than those specified in this Privacy policy, we will inform you as soon as when we disclose the data for the first time, unless we have already provided such information to you earlier.

Data processors

We may use the services of data processors who, in accordance with our instructions and to the extent that we determine, will process personal data to the extent necessary to achieve the purposes for which the data was processed. With the help of data processors, we strive to ensure that processors also implement appropriate organizational and technical security measures and maintain the confidentiality of personal data.

RIGHTS OF DATA SUBJECT

As a data subject, you have the rights, provided below in this section.

The right to know (be informed) about the processing of your personal data .

When we receive information about the processing of personal data directly from you, we inform you orally and / or in writing during the receipt of your personal data.

If we do not receive personal data directly from you, we will inform you about the processing of your personal data within one month of receipt of the data and, if we use your personal data to maintain contacts with you, not later when we contact you for the first time.

The right to familiarize with your processed personal data and know how they are processed , i.e. to obtain information on the period of retention of personal data, information regarding from which sources and which personal data is collected, for what purpose it is processed, to whom it is provided.

Within one month of receiving the request, we will verify if your personal data is being processed by the Company. Having determined that we are processing your personal data, we will provide you with information about the personal data processed and a copy of the personal data processed.

We may extend the time period for the response, if necessary. We will inform you about this. You are entitled to apply to the State Data Protection Inspectorate due to such extension.

Usually we will give you information free of charge. However, if your requests are obviously unfounded or disproportionate, in particular because of their repetitive content, or if you wish to receive a copy of the processed personal data in a different form / content than the Company has prepared it, we have the right to charge a fee for the provision of information or reports or actions, requested from the Company, as well as for administrative costs.

If your requests are obviously unfounded or disproportionate, we have the right to refuse to execute your request.

If your request does not specify the form of the information, we will provide the information in the same form as we received your request.

The right to request the correction of personal data and to suspend the processing of such personal data, if after familiarizing with your personal data, you will find that the data is incorrect, incomplete or inaccurate.

We will notify you of any correction, termination or suspension of personal data processing performed at your request. We will inform the data recipients of this, unless it is impossible or too difficult to provide such information. We will provide you with information about such recipients at your request,

The right to request to terminate personal data or to limit their processing activities, if, after becoming familiarized with your personal data, you become aware that personal data is processed unlawfully or unjustly.

We will notify you of any limitation of processing that we executed or did not execute according to your request. We will inform data recipients if this unless it is impossible or would require a disproportionate effort. We will provide you with information about such recipients at your request,

Personal data, the processing of which is restricted, are protected.

The right to disagree with the processing of personal data, except if we process personal data due to the legitimate interest of the Company or other person to whom personal data are provided, and your interests are not more important.

In case you have expressed your disagreement with the processing of personal data, we will further process your personal data if we reasonably decide that the reasons for processing personal data take precedence over your interests, rights and freedoms, or if your personal data is required to state, execute or defend your legal claims.

The right to revoke the given consent for processing

You have the right to revoke your consent to the processing of your personal data at any time, whenever your personal data processing is based on your consent.

Right to "be forgotten"

You have the right to request the deletion of your data in the cases provided by law. We have the right to refuse to comply with this request in the cases provided for by law, including but not limited to the cases referred to in Article 17, part 3 of the Regulation.

If your request is met and personal data (deleted on your request) have been previously transferred to data recipients, we will inform the recipients of the data, unless it is impossible or would require a disproportionate effort. We will provide information on such recipients at your request.

Right to data portability

You have the right to request that the personal data you provided (in case they are processed on the basis of consent or contract, and if they are processed by automated means), to be forwarded to another data controller or transferred to you in a structured, commonly used and computer-readable format, if it is technically possible. When applying for the implementation of this right, you must indicate whether you want the personal data to be transferred to you or to another data controller.

If your request is granted and you wish to have the data transferred on a digital medium, we will provide the personal data processed by the Company on the single-use Compact disc (CD), provided by you or the Company's single-use Compact disc (CD), whenever you provide compensation for the purchase price of this media.

The right to data portability cannot be implemented in regard to personal data, processed in files, structured in a non-automatic way, such as paper files.

The transferred personal data is not automatically deleted. If you wish, you must apply to the Company for the implementation of the right to be forgotten.

The right to disagree with the data subject being subjected only to automated processing, including profiling

You have the right to know and be informed about the logic of the automated processing of personal data and what could the consequences of such processing of personal data, when the data is processed only in an automated way.

After you have addressed us regarding the automated data-processing-based decision (if such decisions are made by the Company regarding yourself), we will conduct a thorough evaluation of all relevant data, including the information you provide.

The right to file a personal data complaint with the State Data Protection Inspectorate or the competent court

The actions or inactions of the Company, related to the implementation of the data subject's rights, can be appealed by yourself or through a properly authorized representative or a non-profit institution, organization or association, compliant with requirements of Article 80 of the Regulation, to the State Data Protection Inspectorate, located at A. Juozapavičius str. 6, Vilnius, e-mail address [email protected] , website www.ada.lt also to the competent court of the Republic of Lithuania.

Right to compensation for damage, caused by violation of data subject's rights

If you have suffered damage as a result of a violation of the data subject's rights, you are entitled to compensation, which you must apply for to the competent court of the Republic of Lithuania.

ORDER OF ADDRESSING THE COMPANY TO IMPLEMENT DATA SUBJECT'S RIGHTS

You can apply regarding the implementation of rights of the data subject either verbally or in writing by providing a personal application, by post or by electronic means according to the contacts, specified in this Privacy policy.

You must confirm your identity by submitting an identification document. Failure to do so will prevent us from accepting your requests and the data subject's rights will not be enforced. This provision shall not apply if you apply for information on the processing of personal data pursuant to Articles 13 and 14 of the Regulation.

In case you decide to claim your rights as the data subject by post, then a copy of the identity document certified either by a notary or according to another order, provided for in the legal acts, must be submitted together with the application. If your personal data (name, surname) have changed, copies of the documents confirming the change of such data should be provided together with the application; if they are sent by post, then a copy of the identity document certified either by a notary or according to another order, provided for in the legal acts, must be submitted together with the application.

If you decide to submit an application by electronic means, the application must be signed by a qualified electronic signature or by electronic means which allow to ensure the integrity and indispensability of the text. This provision shall not apply if you apply for information on the processing of personal data pursuant to Articles 13 and 14 of the Regulation.

The request for the implementation of the data subject's rights must be readable, signed and must contain your name, address and / or other contact details for the purpose of maintaining the contact or providing a response.

In case you have decided to implement your rights through a representative, your representative must indicate his / her name, address and / or other contact details to be used by your representative, as well as your name and any other data necessary for the proper identification of the data subject and to provide a document or a copy thereof, confirming the representation.

If we have any doubts about your identity, we have the right to request additional information to inspect it and be sure of the identification.

You may contact the Data protection officer of the Company on all matters relating to the processing of personal data and the exercise of your rights. We recommend that the correspondence be addressed to the Data protection officer of the Company.

If you do not follow the procedure in this section when applying to us, we will inform you about it within 7 calendar days from the receipt of the request and will indicate any shortcomings. If the deficiencies noted are not corrected or you fail to inform the Company of reasonable grounds for not rectifying the shortcomings, we will not examine the request.

In the event of objective circumstances that prevent the identified shortcomings from being removed, we may decide to consider and process your application after evaluating such circumstances.

COMPANY'S ACCOUNTS IN SOCIAL MEDIA

The company owns an account on social media Facebook, Instagram, LinkedIn and YouTube. The information you provide on Facebook, Instagram, LinkedIn, or YouTube (including notifications, use of the Like and Follow boxes, and other communications) or which comes from visiting our Company account on Facebook, Instagram, LinkedIn, or YouTube (including information from cookies used by social network controllers) is controlled by the social network controller. Therefore, we recommend that you read the social network controller's privacy notices (policies).

As the Company's Facebook, Instagram, LinkedIn, or YouTube account Administrator, we select the appropriate settings based on our target audience and performance management and promotion goals. By enabling the company to create and manage an account on the social network, the Social network controller may impose restrictions on the ability to change certain essential settings, and so, we cannot influence what information the Social network controller will collect about you due to the Company crating an account on the social network.

All such settings may affect the processing of personal data while using social media, visiting the Company's account or reading Company's announcements on the social media network. Even if you just review our messages on Facebook, Instagram, LinkedIn or YouTube, the social network controller can get some personal information, such as what end device you use, your IP address, and more.

Usually, the social network controller processes your personal data (even those that are collected when we choose additional account settings) for the purposes set by the social network controller, based on the social network controller's privacy policy. However, whenever you are using the social network, communicating with the Company through the social network, visiting the Company's account on the social network or reviewing the Company's records therein, the Company receives information about you. The amount of data we receive depends on our chosen account settings, agreements with the social network controller on ordering additional services and cookies set by the social network manager.

LinkedIn Privacy policy: https://www.LinkedIn.com/legal/privacy-policy .

Facebook Privacy policy: https://www.facebook.com/policy.php .

Instagram Privacy policy: https://help.instagram.com/519522125107875 .

YouTube Privacy policy: https://www.youtube.com/static?template=privacy_guidelines and here https://policies.google.com/privacy .

COOKIES

Cookies are used on the website are small pieces of text information that are automatically generated while browsing the website and are stored on a computer or other end device that you use. The information gathered by Cookies allows us to make the website more user-friendly, offer suggestions and learn more about the behavior of our users, analyze trends, and improve the website. If the Company's websites contains links to other sites that also use cookies, they are not described here.

When we save functional, tracking, and / or third-party cookies, we request your consent. When we save the necessary cookies, we use them on according to legitimate interest and we do not ask for your consent to such cookies. If we have already received your consent, we will not ask for your consent again for future use of the same cookie for the same purpose. This also applies to cookies used by third parties.

We use the following types of cookies on our websites:www.neofinance.com; www.paskoluklubas.lt and https://neopay.online/

Required cookies. Required to use the features of the site to log in to the user account. Without these cookies, you would not be able to use our electronic services.

Action-enhancing (sessions) cookies . They are designed to improve website performance and collect general anonymous information about the use of the website.

Tracking cookies (tracking cookies from "Google Analytics"). Allows the Company to identify and count visitors to the website and to track how visitors travel throughout the pages the website when using it. This helps to improve the performance of the site, for example, by ensuring that users can easily find what they are looking for.

Functional cookies. Used to identify website visitors when they return to the website. This allows the company to provide content tailored to the needs of visitors on social networks, memorizing information relevant to visitors.

Advertisement cookies . Used to display promotional ads that should be of interest to you and to meet your interests. They can also be used to help measure the effectiveness of your advertising campaign.

Websites www.neofinance.com; www.paskoluklubas.lt and https://neopay.online/ uses the following cookies (their descriptions):

Name

Expiry date

Purpose

Group

PHPSESSID

Session

Cookie is designed to realize the functionality of a website.

Necessary

_hssc

Session

Used to track a session

Advertising

hubspotutk

10 years

The cookie is designed to track the visitor's identity

Advertising

_hssrc

Session

Used to determine changes to the browsing session cookie for a new session

Advertising

_hstc

2 years

Used to distinguish users by groups

Advertising

mp_6d7c50ad560e01715a871a117a2fbd90_mixpanel

2 years

Used for statistical and analytical purposes

Monitoring

hl

1 year

Used to save website language

Functional

JSESSIONID

Session

Used to realize website functionality.

Necessary

_dc_gtm_UA-XXXXXXXX-X

Session

Used to connect the website with "Google tag manager"

Monitoring

picreel_tracker__visited

Unlimited

Used for statistical purposes when counting the number of pages, the user visited

Monitoring

picreel_tracker__first_visit

Unlimited

Used for statistical purposes, keeping the date of the first visit

Monitoring

_gid

1 day

One of the Google Analytics cookies used to store a unique ID that is used to generate statistical information

Monitoring

_ga

2 years

One of the Google Analytics cookies used to analyze information about how a user is using a website

Monitoring

cid

2 months

Displaying ads according to user actions

Advertising

uid

2 months

A unique number is stored that identifies the user on the same ad network allowing to show relevant ads

Advertising

fr

3 months

Used to share content on "Facebook"

Advertising

_vwo_uuid_v2

366 days

This cookie is used to determine the loading (opening) speed of different page versions

Monitoring

IDE

390 days

Used to track ad clicks / views to measure ad performance.

Advertising

DSID

2 weeks

Used to track ad clicks / views to measure ad performance.

Advertising

Cookies used by LinkedIn are described here https://www.LinkedIn.com/legal/cookie-policy .

Cookies used by Facebook are described here https://www.facebook.com/policies/cookies/ .

Cookies used by Instagram are described here https://help.instagram.com/519522125107875.

Cookies used by YouTube are described here https://www.LinkedIn.com/legal/cookie-policy .

If you do not agree that cookies are stored on your computer or other end device (when we ask for your consent to record (store) cookies), you can change your web browser settings and turn off all cookies or turn them on / off one by one. However, we note that in some cases this may slow down the speed of surfing the web, limit the functionality of certain websites, or block access to the site. For more information, see AllAboutCookies.org or www.google.com/privacy_ads.html .

STATISTICS

Site visitors’ statistics are analyzed using Google Analytics. Information collected from Google Analytics cookies about your website browsing history can be transferred and stored on servers, located in the USA.

POLICY REVIEW

We may review and modify our Privacy policy at any time. The changes will come into effect starting from their publication on the websiteswww.neofinance.com;www.paskoluklubas.lt and https://neopay.online/. It is recommended to always check the latest version of the Privacy policy.

Last updated on 10 February 2021.

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