BT EXCHANGE (LT) UAB
Privacy Policy

Name

BT Exchange (LT) UAB

Legal entity code

306321553

Address

Gedimino pr. 20, Vilnius, Lithuania

E-mail

[email protected]

Phone No

+35924372241

Purpose

Provision of the Services – providing access and utility through our virtual asset trading platform via software, API (application program interface), technologies, products and/or functionalities, i.e.:

• enabling data subjects to create the account to access the Services,
• enabling data subjects to manage the account details and information,
• enabling data subjects to purchase / sell virtual assets,
• enabling data subjects to transfer virtual assets,
• enabling data subjects to perform other transactions with virtual assets.

Data subjects

Users of the Services (if users are natural persons) / representatives of the users (if users are legal persons).

Personal data

• identification data (e.g., full name, position at the represented entity, name of the represented entity),
• contact data (e.g., e-mail address, phone number),
• usage data (information about your use of our Services, e.g., sign-up activity, virtual assets, bank details, payments),
• other data related to the provision of our Services (e.g., communication with us regarding the use of our Services).

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

Source

The user or the entity it represents, the use of the Services and / or third parties (e.g., payment service providers).

Legal ground(s) for processing

Such processing is necessary for the provision of our Services to our users (Article 6(1)(b) of the GDPR) and our legitimate interest to provide safe and reliable services, as well as to enter into contractual relations with the legal entity you represent (Article 6(1)(f) of the GDPR).

If you do not provide this information, we may be unable to provide you with requested Services.

Data retention

Data will be stored for up to 10 years following the end of relations with the user.

Purpose

Compliance with legal requirements applicable to the Company, including anti-money laundering (AML) and Know Your Customer (KYC) regulations.

Data subjects

Users of the Services (if users are natural persons) / representatives, shareholders, managers, ultimate beneficial owners (UBOs) of the users (if users are legal persons).

Personal data

• identification data (e.g., full name (including former name), position at the represented entity, name of the represented entity, nationality, passport number or any government issued ID number, date of birth, proof of identity (e.g., passport)),
• contact data (e.g., address, e-mail address, phone number),
• AML / KYC data (e.g., date of birth, citizenship, address, country of residence, country of tax residence, activities, sources of income, copy of identification document (and personal data included therein), bank details, information about applied international sanctions, politically exposed person (PEP) status),
• payment data (e.g., information about payments via the Services, including recipients),
• other personal data as may be required for the Company to comply with applicable legal acts).

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

The Company may also use profiling in order to enable the fulfilment of the requirements of the abovementioned legal obligations on anti-money laundering and countering the financing of terrorism (AML/CFT). Please see Section 7 of this Privacy Policy for more information.

Source

The user or the entity it represents, the use of the Services and / or third parties (e.g., identification service providers, public registers, state and / or municipality institutions).

Legal ground(s) for processing

Such processing is necessary for the Company to comply with legal requirements (e.g., AML / KYC obligations) (Article 6(1)(c) of the GDPR).

Personal data of special categories, if any, will be processed in order for us to comply with AML / KYC legal requirements (Articles 6(1)(c) and 9(2)(g) of the GDPR), and, if required in particular cases, upon your consent (Articles 6(1)(a) and 9(2)(a) of the GDPR).

Data on convictions and criminal offenses will only be processed when and to the extent required by applicable law.

If you do not provide this information, we may be unable to provide you with requested Services.

Data retention

Data will be stored for up to 8 years following the end of relations with the user. If the supervisory authority adopts a respective decision, such personal data may be stored for 2 additional years.

Purpose

Processing personal data in relation with recruitment procedures.

Data subjects

Candidates to work at the Company.

Personal data

• identification data (e.g., full name),
• contact data (e.g., e-mail address, phone number),
• information about your experience, education and other information provided by you in your CV and (or) other documents or communication with the Company,
• information required to verify whether candidate is in line with the legal requirements applicable to the Company (e.g., impeccable reputation), where applicable,
• information obtained from current (only upon receiving your explicit consent) or previous (only upon informing you thereof) employers,
• information about the results of the recruitment procedures (e.g., results of tests, interviews).

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

Source

The candidate himself / herself, or his / her current or previous employers.

Legal ground(s) for processing

Such processing is necessary for the Company in order to take steps at the request of the data subject prior to entering into an employment contract (Article 6(1)(b) of the GDPR), for the legitimate interest of the Company to carry out the recruitment procedures (Article 6(1)(f) of the GDPR), in order to comply with the applicable legal obligations (e.g., requirements on impeccable reputation) (Article 6(1)(c) of the GDPR) or your consent (Article 6(1)(a) of the GDPR).

Data on convictions and criminal offenses will only be processed when and to the extent required by applicable law.

If you do not provide the information required by the Company to enter into contractual relations with you or to comply with our legal obligations, we may refuse to enter into employment relations.

Data retention

The Company will store the personal data about the candidate for as long as the selection to the specific position is taking place. Based on your consent such personal data may be stored longer.

Purpose

Commercial relations with our suppliers & partners, e.g., day-to-day business communication related to the services and (or) goods provided.

Data subjects

Our suppliers & partners or their representatives.

Personal data

• identification data (e.g., full name, position at the represented entity, name of the represented entity),
• contact data (e.g., address, e-mail address, phone number),
• payment data (e.g., bank account number, information about payments to or from our suppliers & partners),
• subject matter and text of the communication with us.

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

Source

Our suppliers & partners or their representatives and / or third parties (e.g., banks).

Legal ground(s) for processing

Such processing is necessary for the performance of the agreement between the Company and the respective supplier or partner (Article 6(1)(b) of the GDPR), for the legitimate interest of the Company to maintain the respective contractual relations with the legal entity the data subject represents (Article 6(1)(f) of the GDPR) or to comply with legal requirements (e.g., accounting) (Article 6(1)(c) of the GDPR).

If you do not provide the information required by the Company to comply with legal requirements (e.g., accounting) or maintain contractual relations, we may be unable to carry out our contractual obligations.

Data retention

Data will be stored for up to 10 years following the receipt of such data or termination of the respective agreement.

Purpose

Managing and answering the inquiries sent / provided to the Company via e-mail, phone or other means.

Data subjects

Persons submitting / providing the abovementioned inquiries to the Company.

Personal data

• identification data (e.g., full name, position at the represented entity, name of the represented entity),
• contact data (e.g., e-mail address, phone number),
• subject matter and text of the communication with us.

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

Source

Persons submitting / providing the abovementioned inquiries to the Company themselves.

Legal ground(s) for processing

Such processing is necessary for the legitimate interest of the Company to answer such inquiries (Article 6(1)(f) of the GDPR) or in order to comply with the respective legal obligation where the Company has a legal obligation to submit a reply (Article 6(1)(c) of the GDPR).

Data retention

Data will be stored for 2 years following the receipt of your query.

Purpose

Informing you about special offers, news or providing other information about the services of the Company.

Data subjects

Persons receiving the abovementioned communications from the Company.

Personal data

• identification data (e.g., full name, position at the represented entity, name of the represented entity),
• contact data (e.g., e-mail address, phone number),
• information about purchased or otherwise used Services.

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

Source

Persons receiving the abovementioned communications from the Company themselves and the use of the Services.

Legal ground(s) for processing

• your consent to the processing of personal data for direct marketing purposes (Article 6(1)(a) of the GDPR), or
• our legitimate interest to inform our users about similar services of the Company (Article 6(1)(f) of the GDPR).

Based on our legitimate interest to inform our customers about our similar services, the Company will process your e-mail address for direct marketing purposes only if all the following conditions are met:

• by using service from the Company, you do not initially object to the direct marketing communications,
• each time we send a direct marketing message, you will be given the option to opt out from such direct marketing messages, and
• on this basis, your personal data will only be processed for the marketing of similar services of the Company itself.

You can unsubscribe from marketing messages at any time.

Data retention

Your personal data will be processed for this purpose for 2 years from the date of its collection, or until you object to such processing of your personal data, or until your consent to process personal data for this purpose is revoked, whichever occurs first.

Purpose

Improving the Services and ensuring their proper operation and security, ensuring fraud prevention.

Data subjects

Users of the Services.

Personal data

• device data (e.g., internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services),
• information about your use of the Services.

Please note that the Company may not process all the above data, and the scope of the processed data is determined on a case-by-case basis in accordance with the principle of data minimization.

Source

Your use of the Services.

Legal ground(s) for processing

Our legitimate interest to improve our Services, ensure their proper operation and security, also our legitimate interest to prevent fraud (Article 6(1)(f) of the GDPR).

Data retention

Your personal data will be processed for this purpose for 5 years.

Right of access

You have the right to obtain from the Company the confirmation as to whether your personal data is being processed and to access the information about how the Company processes your personal data, as well as to receive the copy of your personal data.

Right to rectification

You have the right to obtain from the Company the rectification of your inaccurate personal data. You also have the right to have incomplete personal data completed by providing a supplementary statement.

Right to erasure (‘right to erasure’)

You have the right to obtain from the Company the erasure of your personal data, if conditions established in Article 17 of the GDPR are met.

Please note that Article 17(3) of the GDPR establishes some exceptions for such cases where processing is necessary. If they are applied in your case, we will inform you about them accordingly.

Right to restriction of processing

You have the right to obtain from the Company restriction of processing if conditions established in Article 18 of the GDPR are met.

Where processing has been restricted, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.

Right to data portability

You have the right to receive your personal data, which you have provided to the Company, in a structured, commonly used, and machine-readable format and have the right to transfer this data to another controller, if:

• the processing is based on a consent or on a contract, and
• the processing is carried out by automated means.

You also have the right to have the personal data transferred directly from the Company to such another controller, where technically feasible.

Right to object

You have the right to object at any time to processing of your personal data for the purposes of the legitimate interests of the Company, including profiling based on those provisions.

The Company will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.

Where you object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Right to withdraw the consent

If the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time. Your withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority in the EU member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.

Lithuanian supervisory authority is Lithuanian State Data Protection Inspectorate, address L. Sapiegos str. 17, 10312 Vilnius, Lithuania, e-mail [email protected], website https://vdai.lrv.lt/.

The Company would recommend and be grateful if you contact us before lodging a complaint to the relevant supervisory authority and express your concerns or questions to us. We will do our best to assist you with all your queries.