Herein the following definitions will apply:
“You”, “Your”, “Yours” refers to any user of the DSBC Financial Europe Site, DSBC Financial Europe Account or DSBC Financial Europe Services.
“We”, “Our” and “Us” refers to UAB “DSBC Financial Europe”.
“DSBC or DSBCF” means a business name of a UAB “DSBC Financial Europe”, a legal entity registered in Lithuania with its registration number 304785124 and having a Payment Institution license #33 issued by the Bank Of Lithuania November 06, 2017. DSBCF’s place of business is at Lvovo str. 25, Mažoji bure, 15th floor, LT-09320, Vilnius, the Republic of Lithuania. Any references to DSBCF shall refer to UAB “DSBC Financial Europe”.
“DSBCF Account” means personal or business e-money account disc eco-system DSBCF.
“DSBCF Services” means access to DSBCF Account allowing you to open an individual or business account and make payments inside eco-system DSBCF or payouts from it, pay bills, exchange currency, and obtain any other services provided by DSBCF.
“DSBCF Account” means internet-based software, API and other software and technologies allowing obtaining DSBCF Services.
“Data Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
You should be aware that by providing you with DSBCF Services we act as a data controller and you may act as a data subject or as a joint data controller as a case may be. The terms personal data, data subject, data controller and data processor are used in the meaning given by the general data protection regulation (GDPR).
By opening DSBCF account for you, we collect your personal data, so in this case we act as data controller, and you act as a data subject, therefore we are subject to respective rights and obligations under applicable data protection laws.
In some cases, when you are a business, you transfer to us personal data of your clients or the personal data your officers. Insofar you and we jointly determine to process personal data for the purposes of our cooperation we and you are joint data controllers and bear several liabilities for data protection infringements. You shall warrant that you have appropriate legal grounds to collect, process and transfer to the third parties the personal data of your clients or officers. In more details your and our obligations and responsibilities will be allocated in the data protection agreement with you.
We processed your personal data in accordance with valid legal acts and following principles:
In case you access your DSBCF Account, use DSBCF Site or use any of the DSBCF Services, the following type of personal data might be gathered:
When you are an entity, we collect personal code, identity card, surname, address, nationality, name, photograph, signature, number of shares held, voting rights or share capital part, data about the beneficiary of funds of the ultimate beneficiary owners (natural persons who directly or indirectly own or control an entity).
Also, pay attention to the fact we may acquire information related to you provided by third parties like services for person verification, marketing agencies, your publicly available profile information (LinkedIn, Facebook, Twitter, Google Accounts), information related to payments to or from your accounts with us, provided by payment processing services, banks, card schemes and other financial services firms, information from fraud prevention agencies.
We do not collect any extra data but only that information that is necessary for the purpose of providing DSBCF Services to you.
Please be aware that the list of information types mentioned above is not exhaustive. Additional information about you might be gathered in some other way, for instance by your contacting our Customer Support hotline or taking part in surveys, etc.
When required by AML legislation we may collect biometric information (such as facial photographs or fingerprints) of their clients for the identification purpose. Such information is defined by GDPR as sensitive information and can be processed only if the law requires this or the data subject has given express consent. Client who refuses to provide such information cannot obtain DSBCF Services in full. Client may contact DSBCF support to obtain information on what services may be used without providing biometrics.
We do not intentionally collect any other sensitive personal data, such as religious beliefs, health information, racial or ethnic origin etc. Nevertheless, there might be cases when information or documents data subject submits to us contain sensitive information or we can obtain it in the course of providing our services (e.g. during KYC procedure or information that follows from payment transactions of certain types). To allow us to process your sensitive personal data you will be requested to provide explicit consent by means of DSBCF Account functionality or by e-mail. In some cases, we may be required to process such data for the reasons of substantial public interest, on the basis of EU or local law.
The main goal of gathering and processing your personal data is to deliver effective, scalable, smooth, and personalized DSBCF experience. Hence, personal data we collect might be used to:
In some cases, we may make automated decisions regarding you using your information. When you instruct us to make a payment from your account, or to request a payment into your account from a bank or other payment services provider, our systems (or systems provided to us by our suppliers) make an automated check for authorization and automated checks to detect an unusual transaction pattern or location of your transaction and help us to fight fraud. You are entitled to contest automated decision making by contacting us.
We warrant and represent that DSBCF has implemented the technical and organizational security measures and technological development to ensure an appropriate level of security of personal data. Your data is protected by the means of physical, technical, and administrative resources to lower the risks of loss, misusage, unauthorized entry, disclosure, or alteration by a third party. To keep your data be safe we apply:
And much more things.
As DSBCF is PCI DSS V3.2.1 certified, we maintain all required technology, methods and business processes to protect cardholder data, and also use such technology and methods as regards the security of your personal data.
We monitor our systems 24x7 and our staff is always ready to respond to your notifications and queries within a short time.
DSBCF respects your privacy and your personal data and warrants that:
We will notify you of any personal data breaches (including any unauthorized or accidental access) without undue delay after becoming aware of a personal data breach.
We will notify you of personal data breaches where the breach is likely to create significant risks to your rights and freedoms (including any unauthorized or accidental access) without undue delay after becoming aware of a personal data breach.
We are not obliged to give the notification to you if at least of the following conditions is fulfilled:
DSBCF warrants that it will not disclose your personal data to any unauthorized third party.
DSBCF may share your data with DSBCF’s contractors who may use such information only for the limited purpose of providing services to you and who are obligated to keep the information confidential, including without limitation:
To ensure the payment process runs smoothly, some of your personal information may be shared with a company or entity you cooperate with inside eco-system DSBCF. Your registration date, number of payments you have issued/received via DSBCF, info whether you have an authorized control over a bank account – all that information might be showed to DSBCF users you work with at the moment.
We may also transfer your personal data to our professional advisers (such as lawyers, accountants, auditors, it consultants, management consultants), who is under a professional obligation to maintain confidentiality and security of personal data.
Your personal information may be shared with third parties if so required by applicable laws, regulations, instructions we must obey or in the response of valid court order or requirement of other government bodies.
In addition, we may convert your personal information into anonymous or aggregated form, in which case it will cease to be personal data.
For the purpose to provide you with DSBCF Services we can engage the third-party service providers outside the EU. In such case personal data may be transferred outside the EU, including to the United States. Data protection law of third countries may be different from EU data protection laws and not guaranty adequate level of security. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that personal data remains protected.
We use European commission-approved standard contractual clauses as a legal mechanism for data transfers from the EU. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. DSBCF does not participate in privacy shield at this time. Nevertheless, we rely on the EU-US privacy shield to transfer personal information to some of our third party service providers in the united states, where they are certified to receive such information under the privacy shield program.
When you act as a joint data controller, you shall inform your clients about risks of cross-border transfers and obtain their consent for that.
A cookie is a small text file stored in a computer’s web browser memory.
There are three main types of cookies:
Session cookies – they help you do not re-enter information and stay logged in each time you change web–pages. Session cookies are deleted automatically after you leave the site or when you close your browser.
Persistent cookies – they help us to recognize you each time you return to the DSBCF Site and remember your preferences for viewing the site. Such cookies are stored on your computer until deleted by you or automatically after its expiration.
Third-party cookies - are the persistent cookies placed not by DSBCF which help to gather browsing activity across numerous websites and during several sessions. Such cookies are stored on your computer until deleted by you or automatically after its expiration.
You can find out more from https://www.aboutcookies.org/
Fraud prevention. With help of cookies we can obtain information about security of your computer and web browser used to access to DSBCF Site or DSBCF Account and to detect harmful or illegal use of DSBCF Services.
There are other technologies used by us to track your activity on the site or DSBCF Account portal.
Web beacons (web pixels) are small graphics helping to understand browsing activity, track conversion and optimize ads. These graphics file is downloading when you visit the site or DSBCF Account portal.
Local storage objects (flash cookies) are files that can be stored on your browser and can be used to detect preferences, to record the history of usage, or remember settings of the site or DSBCF Account. You can block or control flash cookies at any time by modify the settings of your browser.
You can to delete and disable cookies using setting of your browser. You can find out more about how to manage cookies from the following links:
For Chrome browser: https://support.google.com/chrome/answer/95647?hl=en
For Explorer browser:
For safari browser: https://support.apple.com/kb/ph21411
For Firefox browser: https://support.mozilla.org/products/firefox/cookies
For Opera browser: http://www.opera.com/help/tutorials/security/cookies/
We may use your data for as long as reasonably necessary for the limited purpose of providing DSBCF Services to you.
DSBCF as a regulated electronic money institution is obliged under PSD2 and AML laws to keep your data so long as mentioned below:
|Type of data||Retention period|
|The data of our registers||At least 8 (eight) years from the day of termination of transactions or other business relationship with you|
|Documents confirming monetary operation or transaction or other documents having legal force related to the performance of the monetary operations or conclusion of the transactions||For a period of 8 (eight) years from the day of the performance of the monetary operation or conclusion of the transaction|
|Copies of the documents proving your identity, invoices and/or contractual documentation (original documents)||For a period of 8 (eight) years from the day of termination of the transactions or business relationship with you|
|Written or electronic correspondence relating to the business relationship with you||For a period of 5 (five) years from the day of the termination of the transactions or business relationship with you|
|Results of investigations of complex or unusually large transactions and unusual transaction structures||For a period of 5 (five) years in paper format or on an electronic medium|
The storage period may be extended additionally upon a reasoned instruction of a competent institution, nevertheless the extension cannot last longer than 2 (two) years. Moreover, we follow the requirements of legal acts of Lithuania while keeping other your personal data.
After the termination of the agreement between DSBCF and you, you may request deletion of your data. We are able to consider your request and delete your data within ninety days. Nevertheless, we may retain some of your personal information for the purpose to comply of with technical and legal requirements related to the security, integrity and operation of DSBCF Services. For instance, if DSBCF Account has been terminated by the reasons of fraud or security reasons, we may retain certain information from that account to prevent opening a new DSBCF Account by the same user.
Please be aware that applicable law may prevent us from returning or destroying all or part of the personal data or require storage of the personal data for some period to comply with AML requirements, tax reporting or auditing. In which case we will protect the confidentiality of the personal data and will not actively process the personal data anymore after the termination of the legal relations with you.
Your personal data processed for the purposes of the sending personalized offers of services and products or to or find out your opinion on different issues in relation to us and our services (direct marketing) are used so long as we have contract with you or until you unsubscribe from receiving such messages using the link in the bottom of the e-mail or by using functionality of DSBCF Account.
When we act as data controller, you have the following rights for personal data that we have about you.
You may contact us using the contact information below to make the request or ask us about your rights.
If you reasonably believe that processing of personal data related to you is performed in violation of the applicable legal requirements you have the right to submit a complaint to us. You can submit a complaint by post or e-mail, specifying your name, surname, contact details, relevant information, which would indicate why you reasonably believe that the processing of the data related to you is performed in violation of the applicable legal requirements. Upon receipt of a complaint from you, we confirm receipt of the complaint and indicate the time limit within which the reply will be submitted. In each case, the deadline for submitting a reply may vary as it directly depends on the extent and complexity of the complaint filed, but we will make the maximum effort to provide the response to you within the shortest possible time. We, after examining the complaint, report the results and actions taken to satisfy your complaint, or provide relevant information on what further actions you may take if your complaint was not satisfied.
Our legal basis for collecting and using personal data depends on the type of personal information collected and the specific context in which we collect it.
We can process your personal data to fulfill our contractual obligations. We rely on contract as a legal basis to process personal data submitted by you in case you are an individual or your transfers personal data of your officers. Processing of your personal data is necessary to provide you with DSBCF Services. We cannot provide you with payment services without carrying out of KYC procedure or business risk assessment.
You acknowledge and agree that your personal data may be transferred to the countries situated outside EU when it is necessary for the conclusion or performance of a contract concluded in your interest between us and another legal person.
We may process your personal data on the basis of our legitimate interests provided that such processing shall not outweigh your rights and freedoms. We rely on this legal basis when we carry out procedures which are the part of our services or which are transparent, expectable and are the stable business practice. For example, to:
Please note that in most cases, if you do not provide the requested information, DSBCF will not be able to provide the requested service to you, e.g. our support cannot reach you in case of emergency without collecting your e-mail address or phone number.
If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.
We can request from you a consent for processing when we required to do so by law or when we do not have another legal basis for processing of your data. Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time.
We do not rely on consent in common cases, because the right to withdraw a consent can be used for fraudulent activity. This would jeopardize the financial stability of DSBCF, reliability and integrity of DSBCF Services, thereby harming all legitimate parties in the payment process.
In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
You shall maintain the confidentiality of your password and login from DSBCF account. You are recommended to sign out of the DSBCF account when you have finished work with it. In any case responsibility for any loss of passwords and misuse of DSBCF account by third parties lay with you.
DSBCF does not voluntarily collect, use or disclose personal data of minors, according to the minimum age equivalent in the relevant jurisdiction. The DSBCF Services are not designed to attract minors. If you are minor, you may not submit any personal information to us or subscribe for the DSBCF Services. If we become aware that we collected the personal information of a minor, we will take steps to delete the information as soon as possible.
We ensure you that we have all the necessary technologies and methods to prevent, detect and investigate a personal data breach. In case of any data breach, we will endeavor our best efforts to notify you and any applicable regulator of becoming aware of the breach as soon as possible.
Please feel free to contact our data protection officer to:
Tel: + 370 5240 5555
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