Utrg, UAB and its affiliates (hereinafter, "Utrg", "utPay.io", "we", "us" or "our") are committed to protecting and respecting your privacy.
This Privacy Policy governs our collection, processing and use of Personal Information of our Users and Website visitors.
We define "Personal Information" or “Personal Data” as information which identifies you personally, e.g. your name, address, e-mail address, trades etc.
The General Data Protection Regulation 2016/679 as of April 27, 2016 (further, the GDPR) applies to processing of personal data by Utrg.

Our Contact Details
Utrg, UAB is a company incorporated and acting under the laws of Lithuania with a registry code 306062887.
Our registered Address is at: Prūsų g. 14-62, LT-02154 Vilnius, Lithuania.
Our contact Email address is: [email protected].

Categories of Personal Information We Collect Include

• full name
• contact details (phone number, email, residence address)
• date of birth
• electronic identifiers (IP address, browser and operating system information, device fingerprint)
• identity documents details (such as driver license, passport)
• photographical images
• banking details
• employment details
• information on transactions you make on our platform
• information on sources of funds
• other information you could provide us upon a request

How We Get the Personal Information and Why We Have it
Most of the personal information we process is provided to us directly by you for one of the following purposes:

• to provide you our services under our Terms of Use
• to enable you open account and operate on
• if you contact us, to reply and process your requests
• to analyze the use of our Website utPay.io
• to comply with regulatory requirements such as (tax, prevention of money laundering and fraud, accounting)
• to prevent fraud within providing our services
• to provide you with information about products and promotions that may be of interest to you, from ourselves
• for market research e.g. surveying our Users' needs and opinions on issues, such as our performance, etc.

We may also receive some information from publicly available sources or from our contractors (for instance, information on sanctions lists).

Cookies
We use a browser feature known as a "cookie", which assigns a unique identification to your computer. Cookies are typically stored on your computer's hard drive.
Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends, and administer the Platform.

How You can Manage Cookies
You can change your cookie preferences at any time by:
Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Who We Share Personal Information
We may share your Personal Information with:

• affiliates, agents and representatives;
• financial institutions and payment service providers;
• customer communications platforms;
• contractors providing software for identification purposes or services on checking against sanctions list;
• law enforcement or regulatory agencies, as may be required by law.

We will enter into contracts with such third parties by which they are bound by terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

International Data Transfer
Our contractors and affiliates may be situated at different locations (including countries located outside the EU. In these cases we may transfer your Personal Information only in the following cases:

• if the country where we transfer your Personal Information to provides the adequate level of personal data protection (based on the relevant decision of European Commission);
• if we take appropriate safeguards to ensure that your rights as data subject are protected;
• if any derogations for specific situations apply (for instance, if is such transfer is necessary for the establishment, exercise or defence of legal claims or for important reason of public interest).

Lawful Bases of Processing
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

• Your consent. You are able to remove your consent at any time. You can do this by contacting us at [email protected].
• We have a contractual obligation
• We have a legal obligation
• We have a vital interest
• We need it to perform a public task
• We have a legitimate interest (for instance, for fraud prevention purposes)

Your Data Protection Rights
Under data protection law, you have rights including:

• Your right of access - You have the right to ask us for copies of your personal information.
• Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

There may be a minimal charge for providing you additional copies of your Personal Information to cover administrative costs.
Please contact us at [email protected] if you wish to make a request. Where possible, you will be able to exercise your rights in your account profile page yourself.
If you make a request, we have one month to respond to you.
We may request you to confirm your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of your rights. If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.
In cases when we will not be able to fulfill your requests due to legal obligations or overriding legitimate interests, we will inform you accordingly.

Automated Decision Making
We may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of your identification, transactional and behavioural patterns.
Please note that such processing is necessary to provide you with our services.
If you feel that this processing might be detrimental to you, we can provide you with further information about this automated processing by contacting us on [email protected].

Security
We have implemented technical and organisational measures (TOMs) to ensure security of our platform.
Where you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organisational security measures from our contractors.
TOMs which we have implemented will be continuously reviewed to be in line with legal and technical developments.

How we store your personal information
Your information is securely stored within our data centers located within the European Union.
We keep your personal data no longer as needed for the purposes indicated in this Policy. As a rule, we will have to store your data for 5 years upon closure of your account within our platform.
We will dispose your information once we do not have any obligation to provide you with a service you requested, nor an obligation to hold personal data for regulatory or legal purpose.

Our Data Protection Officer
Data Protection Officer (DPO) is a person compliance with data protection laws.
Our DPO can be reached at [email protected].

How to complain
If you have questions or concerns about our data protection practices, or wish to exercise your rights under the GDPR please contact us at: [email protected].
You can also raise a complaint with a data protection authority in Lithuania:
State Data Protection Inspectorate
L. Sapiegos str. 17 (Left-hand entrance)
LT-10312 Vilnius
Phones: +370 5 271 2804 / 279 1445
Fax +370 261 9494
E-mail [email protected]
Consultations by phone
+370 5 212 7532

Changes
Our Site policies, content may be revised, modified, updated, and/or supplemented at any time. If we change this Privacy Policy, we will take steps to notify all users with a notice on our Site and a post of the amended Privacy Policy on the Site.
If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continue our relationship with you.
This current version of the Privacy Policy has last been amended on the 24th of December 2022.