Privacy Policy

Last updated 16/10/2024

This Privacy Policy (hereinafter referred to as “Policy”) delineates the practices of Sentvia (“Sentvia”, “we”, “us”, or “our”) concerning the collection, storage, use, dissemination/sharing of, and safeguarding of Personal Information acquired from users of our services (“Services”), such as when You:

• Visit our website at [www.sentvia.com], or any website of ours that links to this privacy notice.
• Download and use our application(s), such as our mobile application app.pay.sentvia.com or any other application of ours that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.

This Policy establishes the framework for processing personal data pertaining to our clients, their partners' representatives, as well as all other visitors of the Website. Sentvia is dedicated to safeguarding Your privacy and has implemented comprehensive legal, technical, and organizational measures to ensure the confidentiality, integrity, and availability of Your Personal Information. For the purposes of this Policy, “Personal Information” or “Personal Data” encompasses any data that identifies or could potentially identify You.

Reading this Policy will help You understand Your privacy rights and choices. The processing of personal data is principally governed by the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'), which is directly applicable and supplemented by the Law No. XIII-1426 of June 30, 2018, amending Law No. I-1374, within the jurisdiction of Lithuania.

If You do not agree with our policies and practices, please do not use our Services. If You still have any questions or concerns, please contact us at:

Contact Details

Sentvia, a corporation duly incorporated under the laws of the Republic of Lithuania with company registration number 306776355.
Registered Office: Vilnius, A. Gostauto STREET 8-224, VILNIUS.
Email: data@sentvia.com

Summary of Key Points

This summary provides key points from our privacy policy, but You can find more details about any of these topics by going to the relevant section on this page:

What personal information do we process?

When You visit, use, or navigate our Services, we may process personal information depending on how You interact with Sentvia and the Services, the choices You make, and the products and features You use.

Do we process any sensitive personal information?

We only process personal information when necessary, with Your consent or as otherwise permitted by applicable law.

Do we receive any information from third parties?

We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process Your information?

We process Your information to provide, improve, and administer our Services, communicate with You, for security and fraud prevention, and to comply with the law. We may also process Your information for other purposes with Your consent. We process Your information only when we have a valid legal reason to do so.

In what situations and with which types of parties do we share personal information?

We may share information in specific situations and with specific categories of third parties.

How do we keep Your information safe?

We have organizational and technical processes and procedures in place to protect Your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not improperly collect, access, steal, or modify Your information.

What are Your rights?

Depending on where You are located geographically, the applicable privacy law may provide You with certain rights regarding Your personal information.

How do I exercise my rights?

The easiest way to exercise Your rights is by filling out our data subject request form available here: [DSAR form URL], or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Sentvia does with the information we collect? Review the policy in full below.

3. Types of Personal Information Collected Or What Information do we collect?

We collect Personal Information that You voluntarily provide to us when You register on or visit the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or contact us.

The Personal Information we collect depends on the context of Your interactions with us and the Services, the choices You make, and the products and features You use.

The categories of Personal Information we may collect include, but are not limited to:

• Contact Details: Email, telephone number, or messenger ID.
• Identity Document Details
• Photographs
• Residential Address
• Educational Information
• Financial Information
• Employment Details
• Geolocation Data/Location Data
• Website Log and Activity History/Log and Usage Data
• IP Address, Browser, and Operating System Information, Device Fingerprint
• Payment Data
• Social Media Login Data
• Device/Mobile Device Access
• Push Notifications
• Sensitive Information: Legal and crime records, insurance data, health data, tax records, drivers’ licenses, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, personal details of nominees, heirs, or assigns (when necessary, with Your consent or as otherwise permitted by applicable law).

We may also collect additional data from public databases, marketing partners, social media platforms, and other outside sources. Refusal to provide information necessary for KYC/AML compliance may hinder our ability to provide services.

Be advised, refusal to provide information necessary to satisfy KYC/AML requirements may hinder our ability to render services. Additional details and documentation may be sought for KYC and AML/CTF purposes. Processing of Your Personal Data may involve automated decision-making, including profiling, for purposes such as onboarding, account maintenance, and fraud prevention.

4. Purpose and Legal Basis for Processing

We process Your data lawfully, fairly, and in a transparent manner for a variety of reasons, depending on how You interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries and offer support.
• To send administrative information to You.
• To fulfill and manage Your orders.
• To enable user-to-user communications.
• To request feedback.
• To send You marketing and promotional communications.
• To deliver targeted advertising.
• To protect our Services.
• To identify usage trends.
• To determine the effectiveness of our marketing and promotional campaigns.
• To save or protect an individual’s vital interest.
• To provide services to individual or corporate clients.
• To respond to inquiries and communications.
• To comply with legal obligations (e.g., KYC/AML requirements).
• To assist in criminal investigations and regulatory actions.
• To protect assets against unauthorized access.
• To prevent fraudulent or scam activities.
• To disseminate information about our products, news, and updates.
• To resolve disputes and protect our interests.
• To carry out legal or official authority.

Lawful bases for processing under the GDPR include:

• Consent, which may be withdrawn at any time by contacting data@sentvia.com.
• Contractual obligations.
• Legal obligations.
• Legitimate and vital interests, including fraud prevention and communication with clients or business partners.
• Performing a task in the public interest or under official authority.
• Preventing a security risk.

5. Sharing of Personal Information

‍We may share Personal Information in specific situations described below and with the following categories of third parties:

• Vendors, consultants, and other third-party service providers.
• Business transfers in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs.
• Offer Wall providers.
• Our affiliates, agents, representatives, and business partners.
• Contractors for identity verification and anti-fraud purposes.
• Contractors providing publicly accessible source information.
• Financial service providers facilitating fiat currency transactions.
• Law enforcement or regulatory authorities (international, national, and local) as legally required or permitted.

6. International Transfers

‍We may transfer, store, and process Your information in countries other than Your own. We have implemented measures to protect Your personal information, including using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and third-party providers.

Transfers of Personal Information outside the European Economic Area are permissible only under the following conditions:

• With client’s explicit consent, or:
  • When the destination country offers an adequate level of protection, as per the European Commission's decision.
  • When appropriate safeguards are employed, such as standard contractual clauses or Your explicit consent.
  • When specific derogations apply, such as for public interest, humanitarian action, contact tracing for contagious diseases, reducing doping in sport, establishing or defending legal claims, or protecting a client’s vital interests (especially if the client cannot provide consent).

7. Data Retention

‍We retain Your Personal Information only for as long as necessary to fulfill the purposes outlined in this privacy notice, unless a longer retention period is required or permitted by law. Personal Information is retained for a maximum of five (5) years following the termination of our legal relationship.

We ensure that the data we hold is accurate and up-to-date. You may request data removal, subject to legal compliance obligations or overriding legitimate interests.

8. Information from Minors

‍We do not knowingly collect data from or market to children under 18 years of age. By using the Services, You represent that You are at least 18 or the parent/guardian of a minor who consents to the minor’s use of the Services.

If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and promptly delete the data. If You become aware of any such data, please contact us at [Email Address].

9. Your Privacy Rights

‍Under data protection legislation, You have various rights, including:

• Right to Access: Request copies of Your personal data.
• Right to Rectification: Request correction of inaccurate or incomplete information.
• Right to Erasure: Request deletion of Your personal data.
• Right to Restriction of Processing: Request restriction of data processing activities.
• Right to Object to Processing: Object to data processing on specific grounds.
• Right to Data Portability: Request transfer of Your data to another entity or to You.
• Right to Not Be Subject to Automated Decisions.
• Withdrawing Your consent
• Opting out of marketing and promotional communications