Herein the following definitions will apply:
“You”, “Your”, “Yours” refers to any user of the Genome Site, Genome wallet or Genome Services.
“We”, “Our” and “Us” as well as “data controller” refers to Genome.
“Genome” means a business name of a UAB “Maneuver LT”, a legal entity registered in Lithuania with its registration number 304785124 and having an Electronic money institution licence #32 issued by the Bank Of Lithuania 29.03.2018. Genome’s place of business is at Zalgirio str. g. 92-502, LT-09303 Vilnius, the Republic of Lithuania. Any references to Genome shall refer to UAB “Maneuver LT”.
“Site” means Genome Site (www.genome.eu), including all its content and subdomains.
“Genome Services” means supply of Genome Wallet, issuance and redemption of E-Money, execution of Transactions, currency conversion, providing access to Genome User Portal, where You can top-up Your Genome Wallet, make and receive Transactions, proceed with currency exchange, withdraw funds from Our System etc., as well as any other related services or products that We provide or make available to You.
“Genome Wallet” means a web-based multicurrency personal or business E-Money account inside Eco-System Genome opened and maintained by us in your name or in the name of any other natural or legal person.
“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, organisation, 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 Genome Wallet and Genome 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 Genome Wallet 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 personal data of your officers, shareholders (ultimate beneficiary owners) or other representatives. 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 liability for data protection infringements. You shall warrant that you have appropriate legal grounds to collect, process and transfer to third parties personal data of your clients, officers, shareholders (ultimate beneficiary owners) or other representatives. In more details your and our obligations and responsibilities in such a case may be allocated in the data protection agreement with you and/or other agreements, terms and conditions of our service.
We processed your personal data in accordance with valid legal acts and following principles:
The categories of personal data that we may collect about you are as follows:
Please be informed that other data not listed above that relate to the provision of our services or which you have provided to us may also be collected.
For this purpose, we may process your Basic Personal Data, Identification and other background verification Data, Information which is related to legal requirements, Contact Information and other personal data (in order to identify the possibility of providing services).
The legal basis for the processing of the above-mentioned data is: concluding a contract with you, fulfilling our legitimate interests and/or fulfilling the legal obligations applicable to us, your consent.
For this purpose we may process your Basic Personal Data, Identification and other background verification Data, Transaction Data, Information which is related to legal requirements, Contact Information and other personal data provided to us by or on behalf of you or generated by us in the course of providing services.
The legal basis for the processing of the above-mentioned data is: performance of a contract signed with you, fulfilling our or third parties’ legitimate interests and/or compliance with legal obligations applicable to us, your consent.
For this purpose, we may process your Basic Personal Data, Identification and other background verification Data, Transaction Data, Information which is related to legal requirements, Contact Information and other personal data provided to us by or on behalf of you or generated by us in the course of providing services.
The legal basis for the processing of the above-mentioned data is: fulfilling our or third parties’ legitimate interests and/or compliance with legal obligations applicable to us.
For this purpose, we may process your Basic Personal Data, Contact Information and other personal data provided to us by or on behalf of You.
The legal basis for the processing of the above-mentioned data is: your consent, fulfilling our or third parties’ legitimate interests.
What do we mean when we say:
Contract performance : processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
We rely on contract as a legal basis to process personal data submitted by you in case you are an individual or you transfer personal data of your officers or other representatives. Processing of your personal data is necessary to provide you with Genome Services. We cannot provide you with payment services without carrying out of “know your client” procedure or business risk assessment.
Legal Obligation : processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legitimate Interest : the interest of ours as a business in conducting and managing our services to enable us to provide to you and offer the most secure experience.
For example, to:
Consent : 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.
In order to make your identity verification, we are using as well the solution of partner Onfido that match photo image or video records of your face point that you provide through a mobile app or camera with your ID document. Please read more about Onfido solution here: https://onfido.com/.
Onfido solution is used for comparing live photographic data or video record of yourself and your ID card/passport, to comply with legal obligations (e.g. implementation of the obligations under the Law on Money Laundering and Terrorist Financing Prevention of the Republic of Lithuania and other fraud and crime prevention purposes) and risk management obligations.
The result of the face similarity (match or mismatch) will be retained for as long as it is necessary to carry out verification and for the period required by anti-money laundering laws.
We ensure that your face similarity check is a process of comparing data acquired at the time of the verification, i.e. this is a one-time user authorization by comparing two person's photos to each other. Your facial template is not created, recorded and stored. It is not possible to regenerate the raw data from retained information.
Using Onfido services, personal data is not used for your identification since Onfido verifies the identity of the person in the identity document and the person captured in the photo.
This process shall allow us to verify you more precisely and will make the process quicker and easier to carry out. Using Onfido services is a part of our KYC procedure which is necessary for the provision of Genome Wallet and Genome Services to you. If you do not feel comfortable with this method, you may contact us by email email@example.com for further clarification.
We want to make it clear how we use your personal data for marketing purposes.
We may use our existing clients’ e–mail for the marketing of our similar goods or services, unless you object to the use of your e-mail for the marketing of our similar goods and services. You are granted with a clear, free of charge and easily realisable possibility to object or withdraw from such use of your contact details on the occasion of each message.
We may also provide the information to you as our client about our products or services by sending messages through the application. Such messages may be viewed in the notification center, in case you do not choose the “opt-out” function in our application.
In other cases, we may use your personal data for the purpose of direct marketing, if you give us your prior consent regarding such use of data.
We are entitled to offer the services provided by our business partners or other third parties to you or make assessments about your opinion on different issues in relation to our business partners or other third parties on the legal basis for this, i.e. on the basis of a prior consent.
In case you do not agree to receive these marketing messages and/or calls offered by us, our business partners or third parties, this will not have any impact on the provision of services to you as the client.
We provide a clear, free-of-charge and easily realisable possibility for you at any time not to give your consent or to withdraw your given consent for sending proposals put forward by us. We shall state in each notification sent by e-mail that you are entitled to object to the processing of the personal data or refuse to receive notifications from us. You shall be entitled to refuse to receive notifications from us by clicking on the respective link in each e-mail notification.
The main goal of gathering and processing your personal data is to deliver effective, scalable, smooth, and personalized Genome 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.
Please be informed that you can request a manual review of the accuracy of an automated decision in case you are not satisfied with it and you have the right not to be subject to a decision based solely on such automated processing.
We warrant and represent that Genome 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 third parties. To keep your data safe we apply:
As Genome is PCI DSS V 3.2.1 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.
Genome respects your privacy and your personal data and warrants that:
We will notify you of personal data breaches where such violation may result in a serious risk to the data subject's rights and freedoms.
We obtain personal information from you when you provide it directly to us. For example, when becoming a new client or when you provide us information through direct communication (e.g. completing a form on our Site, registration for our services), by setting up, access and use of Genome Wallet, when you subscribe to our electronic publications (e.g. newsletters).
We also collect personal information about you from third parties, mainly:
Genome warrants that it will not disclose your personal data to unauthorized third party.
Genome may share your data with Genome’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.
We may disclose and/or transfer your personal data only in accordance with legal regulations and the principles of confidentiality to the following categories of recipients:
We may also disclose your personal data, if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request.
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 Genome.
For the purpose to provide you with Genome Services we can engage the third-party service providers outside the EU. In such case personal data may be transferred outside the European Economic Area (EEA), 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.
As we provide international services, your personal data may be transferred and processed outside EEA.
The transfer of personal data may be considered as needed in such situations as, e.g.:
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.
There are different ways to ensure that your personal data is treated securely, mainly:
We may transfer personal data to a third country by taking other measures if it ensures appropriate safeguards as indicated in applicable law.
We may use your data for as long as reasonably necessary for the limited purpose of providing Genome Services to you.
In the cases when the terms of data keeping are indicated in the legislative regulations, the legislative regulations are applied.
Your personal data might be stored longer if:
When we act as data controller, you have the following rights for personal data that we have about you:
We will exercise your rights only after we receive your written request to exercise a particular right indicated above and only after confirming the validity of your identity. The written request shall be submitted to us by personally appearing at the registered office address of Genome, by ordinary mail or by e-mail: firstname.lastname@example.org, email@example.com.
Your requests shall be fulfilled or fulfilment of your requests shall be refused by specifying the reasons for such refusal within 30 (thirty) calendar days from the date of submission of the request meeting our internal rules and GDPR. The afore-mentioned time frame may be extended for 30 (thirty) calendar days by giving a prior notice to you if the request is related to a great scope of personal data or other simultaneously examined requests. A response to you will be provided in a form of your choosing as the requester.
Moreover, you have the right to submit a complaint to us if you reasonably believe that processing of personal data related to you is performed in violation of the applicable legal requirements. 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.
You can also address the State Data Protection Inspectorate with a claim regarding the processing of your personal data if you believe that the personal data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation. You may apply in accordance with the procedures for handling complaints that are established by the State Data Protection Inspectorate and which may be found by this link: https://www.ada.lt/go.php/Skundu-nagrinejimas378.
You shall maintain the confidentiality of your password and login from Genome Wallet. You are recommended to sign out of the Genome Wallet when you have finished work with it. In any case responsibility for any loss of passwords and misuse of Genome Wallet by third parties lay with you. Read more about it in Genome T&Cs.
Genome does not voluntarily collect, use or disclose personal data of minors, according to the minimum age equivalent in the relevant jurisdiction. Genome Services are not designed to attract minors. If you are minor, you may not submit any personal information to us or subscribe for the Genome 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.
You can contact us by writing to us at firstname.lastname@example.org or post us at UAB “Maneuver LT”, address Žalgirio g. 92-502, LT-09303 Vilnius, Lithuania. Other contact details provided: https://genome.eu/contact/.
You can also contact our Data Protection Officer by sending an e-mail to the address: email@example.com.