Privacy Policy

In this privacy policy, we, Finbee, provide information about how we process your personal data when you use our services. This privacy policy is an integral part of General Service Agreement of UAB Elektroninių pinigų bitė.

This post answers the following questions:

(a)     how we use your data;
(b)     to whom and when we provide your data;
(c)     how long we store your data;
(d)     what rights you have with respect to your data;
(e)     what else you should pay attention to.

If you have any questions or wish to exercise any of your rights specified in this policy, you may apply in the ways indicated on the website www.finbee.lt.

You can contact our Data Protection Officer by email. email: [email protected].

1. How do we use your data?

1.1.     In this section you will find the information below:
(a)     the categories of data we process;
(b)     in the case of data not received from you, information about the sources of such data;
(c)     the purposes for which we process your data;
(d)     the legal bases for the processing.
1.2.      We process information relating to the services provided to you under the Agreement (” Service Details “). Service delivery data may include your name, unique ID in the system, personal identification number, date of birth, contact information, address, spouse details, workplace details and income, identity document details (and a copy of it), a photo, a live video transmission (direct video streaming), payment account details, nationality, public office, other data required by money laundering and terrorist financing prevention legislation.
1.3.      We receive most of this data directly from you, but we can also obtain it from credit and other financial institutions or their divisions, personal document verification databases (such as Invalid Personal Data Databases and other international databases), credential verification registers (such as Notarial register of authorized credentials and other databases), persons managing joint debtors’ files (for example, UAB “Creditinfo Lietuva” or UAB „Scorify“), SE Center of Registers (Department of the Population Register, the Real Property Register), international registers of sanctions, databases of persons participating in politics.
1.4.      We process your service data so that we can provide you with services, to keep proper records of the provision of our services, and to properly comply with our obligations under our laws, including customer identification and verification responsibilities, and the prevention of money laundering and terrorist financing. and fulfilling the “know the customer” obligation. We process this data for the purpose of performing the agreement between you and us (or, at your request, taking action to enter into such an agreement), as well as for the purpose of fulfilling the obligations arising from the legal acts regulating our activities.
1.5.      We process information related to your activity (“activity data “). Incapacity data include information on the person’s (incapacity for work) and the date of registration of the incapacity for work received from the Register of Invalid and Limited Factors maintained by the State Enterprise Center of Registers. We process performance data to prevent illegal transactions and to protect your personal interests. We process this data for important public interest reasons.
1.6.      We process information related to any communication you send to us (“Communication Data “). Communication data can include both the content of the correspondence, the call, and the metadata associated with such communication. In the case of correspondence, the website automatically creates metadata related to your communication, which is provided using the forms on the website . We process communication data to contact you, as well as for accounting purposes. We process this data on the basis of a legitimate interest, namely, in order to properly administer our activities, ensure uniform and good quality consulting practices, and the resolution of conflict situations between you and our employees.
1.7.      We process your personal data contained in this policy when it is necessary to make, enforce or defend legal claims, whether arising from judicial, administrative or other, non-judicial proceedings. For this purpose, we process your personal data on the basis of a legitimate interest, namely to protect and ensure the rights of us, you and others.
1.8.      We process your personal data for the purpose of identifying and verifying you, concluding and executing contracts with you or taking action at your request, implementing the “know your customer” principle, continuous and periodic monitoring, risk assessment, updating your data to ensure fairness, possible money laundering and the prevention of terrorist financing, the prevention of fraud, the detection, investigation and reporting of potential such activities, the imposition of financial sanctions or political participation on you, the proper management of risk and organization, and other purposes set forth in this Privacy policy.
1.9.      We may process your personal data covered by this policy when necessary to obtain or have insurance coverage, to manage risks or for professional advice. For this purpose, we process your personal data on the basis of a legitimate interest, namely to properly protect our activities from risks.
1.10.      In addition to the specific purposes set out in this section of the policy, we may also process your personal data when it is necessary to fulfill our legal obligations and to protect the vital interests of you or other individuals.

2. To whom and when do we provide your data?

2.1.      We may disclose your personal data to UAB “Finansų bitė“, UAB “Finansų bitė verslui”, to UAB „Elektroninių pinigų bitė“ and to any other company in our group (including both our subsidiaries and our controlling company and all its subsidiaries) to the extent necessary. to achieve the objectives set out in this policy and in the agreement concluded with you.
2.2.      We may disclose your personal data to our insurers and professional advisers to the extent necessary to obtain or have insurance coverage, manage risks, obtain professional advice, or make, enforce or defend legal claims, whether arising from judicial, administrative or other out-of-court procedures.
2.3.      We may disclose your personal data to service providers seeking to perform audits and related consultations, monitoring of provided recommendations in regards internal audit plan, as well as in cases of unscheduled audits in order to ensure compliance of services and activities with legal requirements.
2.4.      We may disclose your personal data to other service providers, including payment service intermediaries, for the purpose of providing specific services, to the extent necessary to provide such services (for example, website hosting providers, platform and server providers and maintainers, call centers , e-mail service providers as well as debt collection companies). Through subcontractors, we take all necessary measures to ensure that our data controllers have implemented appropriate organizational and technical security measures and maintain the confidentiality of personal data.
2.5.      In case of breach of the agreement with us, your personal data will also be transferred to persons handling joint debtors’ data files (for example, UAB “Creditinfo Lietuva” or UAB „Scorify“) in order to protect and defend our violated rights and legitimate interests. In this case, information related to the breach of a specific contract will be provided.
2.6.      In addition to the specific cases of possible disclosure of your personal data specified in this section of the policy, we may also disclose your personal data when such disclosure is necessary to fulfill our legal obligations and when it is necessary to protect the vital interests of you or other individuals.
2.7.      The persons specified in this Part may also be established outside the Republic of Lithuania, the European Union or the European Economic Area. In the event that we transfer your personal data to such persons, we will take all necessary legal measures to ensure that your right to privacy continues to be properly protected.
2.8.      After receiving your consent, your personal data will be transferred to the data processor – the company Manu (UAB Sutelktinis finansavimas , to k. 304071752) for the purposes of developing the experimental model . Manu, acting as a processor of personal data managed by UAB “Finansų Bitė”, has implemented appropriate and sufficient organizational and technical measures for the protection of personal data and ensures a high level of information security. The data transmitted to Manu may include the following personal data provided in your application: name, surname, telephone number, e-mail. postal code, personal identification number, address; marital status, number of family members, number of family members under 18; party to the loan agreement; income; existing financial liabilities; education; area of work; duties; work status; work experience; type of income from work; additional sources of income; income sustainability; monthly income; additional monthly income; liabilities (total amount and breakdown by type of liability); probability of insolvency or risk category; information on how many times you have applied to credit institutions for a loan in the last month; the status of consent to verify the data submitted by the person; the method of signing the consent; the status of concluding the loan agreement (submitted / not submitted offer, reason for non-submission of the offer, concluded, not concluded); meta data: the time at which the information input field in the segment was started to be edited; the time at which the editing in the information input segment was completed; Peculiarities of information input field filling, pace, corrections during filling, corrections during refilling; the time after which the segment returns repeatedly; time spent returning to the peculiarities segment repeatedly; the segment from which to return to the current segment; number of screen swipes; screen swipe length; screen swipe speed; the number of screen touches in a segment; motion detection; the time period from when the segment window was opened until the “next”/”back” button was used to move to the next segment; the time interval between the opening of the segment and the start of the first edit. Detailed information on the processing of your personal data is also available on the Manu website at http://www.manuanalytics.com. If you have any questions regarding the transfer and processing of your personal data, you can contact My Data Protection Officer by e-mail. email [email protected].
2.9.      Also, while having your consent, we can disclose your personal data to our partners, who will contact you and provide with an alternative loan offer.

3. How long do we store your data?

3.1.     We process your personal data for any purpose or purposes for no longer than is necessary for that particular purpose or purposes. In any way:
(a)      the data on the provision of services and uptime is stored for a maximum of 10 (ten) years from the end of the business relationship with you. Communication data related to the business relationship shall be stored for a maximum of 5 (five) years from the end of the business relationship with you, unless the specified term is extended for a maximum of 2 (two) years by order of the competent authority.
(b)      the communication data shall be stored for a maximum of 2 (two) months from the end of the communication.
3.2.     Notwithstanding the terms set forth above in this section of the policy, we have the right to protect your personal data when such storage is necessary to fulfill our legal obligations and when it is necessary to protect the vital interests of you or other individuals.

4. Your rights

4.1.     In this section of the policy, we provide you with an overview of your rights under data protection law. As the implementation of some rights is complicated, we present only the main aspects of them in this report. We invite you to familiarize yourself with the relevant legislation and the guidelines of the supervisory authorities so that you have full information about these rights.
4.2.     Your main rights under data protection law are:
(a)      the right of access;
(b)      the right to request rectification of data (you can perform most of the actions related to this right by logging in to your account);
(c)      the right to request the erasure of data;
(d)      the right to restrict the processing;
(e)      the right to object to the processing;
(f)       the right to data portability;
(g)      the right to lodge a complaint with the supervisory authority;
(h)      the right to withdraw consent.
4.3.     Right of access to data . You have the right to obtain confirmation from us or we process personal data relating to you, and, in the case of processing, you have the right to access the personal data processed and certain additional information. This additional information includes the purposes of the data processing, the categories of personal data, the recipients of the data. Unless this would violate the rights and freedoms of others, we will provide you with a copy of your personal data at your request. We will provide the first copy free of charge, but we may charge a reasonable fee for additional copies to cover administrative costs.
4.4.     Right to request rectification of data . You have the right to request that your inaccurate personal data be corrected and, depending on the purposes of the processing, incomplete data be supplemented.
4.5.     In certain cases, you have the right to request the deletion of your personal data . These situations include cases where: (i) personal data are no longer necessary for the purposes for which they were processed; (ii) you withdraw your consent and there is no other legal basis for processing the data; (iii) you do not consent to the processing of data in accordance with the provisions of applicable law ; (iv) the data are processed for the purpose of direct marketing; (v) the data is processed unlawfully. True, please note that in some cases you will not be able to exercise this right due to applicable exceptions. Such exceptions include cases where the data are necessary to: (i) exercise freedom of expression and information; (ii) comply with our legal obligations; (iii) make, enforce or defend legal claims.
4.6.     In certain cases, you have the right to restrict the processing of data . These situations include cases where: (i) you dispute the accuracy of the data; (ii) the data is processed unlawfully, but you do not want it deleted; (iii) we no longer need personal data, but you need such data to make, enforce or defend legal claims; (iv) You objected to the processing of the data, on grounds of public interest or legitimate interests, pending an assessment of the merits of your objection. In the event of a restriction on the processing of your data, we will continue to protect your data, but will not further process it, except: (i) with your consent; (ii) make, enforce or defend legal claims; (iii) the protection of the rights of others; (iv) for overriding reasons relating to the public interest.
4.7.     You have the right to object to the processing of personal data on the basis of your specific situation, in cases where we process your personal data for public interest purposes or on the basis of a legitimate interest of us or third parties. If you object to such processing of your personal data, we will no longer process your relevant personal data unless we can prove that such processing of your data is for compelling legitimate reasons which take precedence over your interests, rights and freedoms. Also, we will be able to further process such data to make, enforce or defend legal claims.
4.8.     Right to data portability . To the extent that the legal basis for our processing is:
(a)      consent;
(b)      the performance of the contract or the performance of the action at your request prior to the conclusion of the contract, you have the right to receive your personal data in a structured, commonly used and computer-readable format. True, you will not be able to exercise this right if it will adversely affect the rights and freedoms of others.
4.9.     In case you think that we violate data protection legislation by processing your personal data, you have the right to submit a complaint to the State Data Protection Inspectorate, whose registered office address is L. Sapiegos g. 17, LT-10312 Vilnius, https://vdai.lrv.lt/lt/.
4.10.     This is the case where the legal basis for the processing is your consent, you have the right to withdraw your consent at any time . Withdrawal of consent will not affect the lawfulness of the processing of your data until the withdrawal.
4.11.     In addition to the specific measures specified in this part of the policy or on the website, you may also exercise any of the rights mentioned in this part of the policy by contacting us in the manner indicated in the section on the website www.finbee.lt or by contacting our data protection officer by e-mail. email: [email protected] .

5. Personal data of children

5.1.     Our services are intended for persons over 18 years of age.
5.2.     Personal data of persons below the age specified in this paragraph shall be processed only with the consent of the holder of the child’s parental responsibility.
5.3.     If we have reasonable doubts that we process the data of a person who is younger than the age specified in this section without the consent of the holder of parental responsibility of the child, we will delete the data of such person from the databases.

6. Data update

Please let us know if your personal information we process needs to be corrected or updated.

7. Cookie policy

7.1.     Cookies we use:
(a)      Required cookies – used to ensure the proper functioning of the website, the security of users and their data, quality customer service, easy account creation;
(b)      Functional Cookies – allows you to browse our website and use its features;
(c)      Analytical Cookies – Used to identify and count visitors to the Website and to track how visitors navigate the Website. This helps us to improve the user experience of the website, analyze the use of the system and improve our services accordingly;
(d)      Marketing cookies – used to monitor user behavior and optimize advertising companies accordingly;
7.2.     Our service providers also use cookies, which may also be stored on your computer when you visit our website.
7.3.     We use:
(a)      Google Analytics cookies in order to track traffic to our website. The cookies used for this purpose help us to detect website malfunctions as well as to measure the bandwidth of the website. With Google Analytics privacy policy available here;
(b)      Doubleclick cookies in order to manage advertising impressions for our users. The use of cookies for this purpose helps us to separate users who use our services and to reduce or stop the display of advertisements to them.
With Doubleclick Privacy policy can be found here;
(c)      the Facebook cookies , to our management of impressions of our customers. The use of cookies for this purpose helps us to separate users who use our services and to reduce or stop the display of advertisements to them. The Facebook Privacy policy can be found here;
(d)      Google Tag Manager cookies in order to manage advertising cookies. The cookies used for this purpose help us to distribute advertisements to users properly. With Google Tag Manager Privacy policy can be found here;
(e)      FinBee.lt cookies, in order to ensure the smooth and safe operation of your site and give you the ability to connect to your account, select the desired language of the site and so on. This cookie does not receive personal data from applications or otherwise;
7.4.     Most web browsers allow users to refuse or delete cookies. The means to do this may vary depending on your browser and version. You can access up-to-date information on how to block or delete cookies on the websites of browser providers themselves, such as Chrome ; Firefox ; Internet Explorer ; Safari .
7.5.     Cookie management:
(a)      Blocking cookies may adversely affect the use of many websites;
(b)      By blocking cookies, you will not be able to use all the features of our website.

8. Amendments to the notification

Any changes to this policy will be published on the website www.finbee.lt and, in case of significant changes, we will inform you about them by e-mail.