Privacy policy

The current privacy policy depicts your privacy rights in terms of gathering, use, storing, sharing, and protecting your personal data. You agree to this privacy policy by registering, accessing, or using Genome’s products, services, solutions, features, and technologies. If you do not agree, you should stop accessing this site or Genome Services immediately and refrain from further access and use of them.

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” 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. 88, LT-09303 Vilnius, the Republic of Lithuania. Any references to Genome shall refer to UAB “Maneuver LT”.
“The Site” refers to the Genome Site (www.genome.eu), including all its content.
“Genome Account” means personal or business e-money account disc eco-system Genome.
“Genome Services” means access to Genome Wallet allowing you to open an individual or business account and make payments inside eco-system Genome or payouts from it, pay bills, exchange currency, and obtain any other services provided by Genome.
“Genome Wallet” means internet-based software, API and other software and technologies allowing obtaining Genome 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Roles and responsibilities

You should be aware that by providing you with 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 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 liability 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.

Principles of personal data processing

We processed your personal data in accordance with valid legal acts and following principles:

  1. personal data with respect to you is processed in a lawful, honest and transparent way;
  2. personal data is collected for specified, clearly defined and legitimate purposes and shall not be further processed in a way incompatible with those purposes;
  3. personal data must be adequate, appropriate and only which is necessary for the purposes for which it is processed;
  4. personal data must be accurate and, if necessary, updated; all reasonable steps must be taken to ensure that personal data which is not accurate in relation to the purposes for which it is processed shall be immediately erased or corrected;
  5. personal data shall be kept in such a way that your identity can be determined for no longer than is necessary for the purposes for which personal data is processed;
  6. personal data shall be managed by applying appropriate technical or organizational measures in such a way as to ensure the proper security of personal data, including protection from unauthorized processing or processing of unauthorized data, and against accidental loss, destruction or damage.

What data we collect

In case you access your Genome Account, use Genome Site or use any of the Genome Services, the following type of personal data might be gathered:

  1. Personal information, used for opening Genome account, manage and administer Genome Services:
    • First and last name
    • Date, country and place of birth
    • Nationality
    • Gender
    • Names, roles, and contact details of your officers, power of attorney, in case if you are opening the business account.
  2. Contact details, used to maintain permanent communication with you, to send you legal and information notices:
    • First and last name
    • Residential address
    • Telephone number
    • Email address
  3. Information used for carrying out the Know Your Client (KYC) procedure and anti-money laundering (AML) check:
    • Personal code
    • Date of birth
    • Age (year of birth)
    • Passport or other government-issued identity document
    • Your photograph
    • Documents establishing your source of funds
    • Results of KYC checks, including information collected by our service providers
    • Video identification data
  4. 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).

  5. Information generated or collected in the course of providing Genome Services, which Genome use to develop and improve its services.
    • Signature
    • Correspondence with Genome and support data (telephone, chat conversations and email)
    • Your transaction data
    • Genome site activities
  6. Financial information including your full bank account number and/or credit card number, IBAN number (used for payments to you and full use of Genome Service);
  7. Device data (such as a type of device, operating system, IP-addresses and advertising ID’s, your location, web and mobile network data), сookies and usage data on how you use our products and services. It is used for accepting you as a customer of Genome Wallet, to safeguard you from scam, fraud, and misuse of any private data you might share, to improve our services. For more details about cookies please see our Cookie Policy below.
    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 Genome 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.

Sensitive personal data

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 Genome Services in full. Client may contact Genome 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 Genome Wallet 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.

How we use your data

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:

  • Ensure maximum Genome Wallet user experience;
  • Process transactions and issue relevant notifications in the most comprehensive manner;
  • Settle disputes, levy charges, and resolve occurring problems;
  • Prevent clients from becoming a subject to illegal activities and potential fraud;
  • Improve quality of services, solutions, and incentives Genome offers on a daily basis;
  • Being able to contact you in case of emergency via one of the means available;
  • Make sure information you provide is accurate, in case discrepancies occur;
  • send personalised offers of services and products, in accordance with the rules as they are described in part “Legitimate interest” of the section “Legal basis for processing” of this Privacy Policy;
  • carry out regulatory checks and meet our obligations to our regulators;
  • prevent and detect fraud, money laundering and other crime (such as terrorist financing and offences involving identity theft);
  • develop new services based on the collected information.

Your personal data is not used for any additional purposes not mentioned in this Privacy Policy or the contract with Genome.

Automated decision-making

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.

How we protect your data

We warrant and represent that Genome has implemented the technical and organisational 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 safe we apply:

  • Firewall and data encryption protection
  • Physical authorization control system
  • Surveillance facilities, video/cctv monitor, alarm system
  • Securing decentralized data processing equipment and personal computers
  • User identification and authentication procedures
  • Tunneling, logging, transport security
  • Audit trails and documentation
  • Backup procedures,

  • And much more things.

As Genome is PCI DSS 1 V3.2 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:

  • Your data will not be disclosed to advertisers or any unauthorized third parties except as provided by this Privacy Policy;
  • We keep your data and any information provided by you in confidence in accordance with the terms and conditions set in a separate agreement with Genome;
  • We will use your data only as described in this Privacy Policy;
  • We will maintain appropriate administrative, technical and organizational measures to protect your personal data;
  • We will notify you promptly of any suspected or actual breach of the security of your data;
  • We will assist you in ensuring compliance with your duties under GDPR;
  • We impose on our sub-contractors the same data protection obligations as set out in the contract with you.

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 be obliged to give the notification to you if at least of the following conditions is fulfilled:

  • We have ensured and implemented the appropriate technical and organisational security measures, for example, encryption of personal data or other measures rendering the personal data unintelligible to any person who is not authorised to access it and such measures were applied to the personal data affected by the personal data breach;
  • We keep your data and any information provided by you in confidence in accordance with the terms and conditions set in a separate agreement with Genome;
  • We have taken subsequent measures which ensure that the high risk to the rights and freedoms of the data subject(s) is no longer likely to materialise;
  • If giving of the notification to you would involve disproportionate effort. In such a case, a public communication or another chosen measures whereby you were informed in an equally effective manner may be applied by us instead of giving a notification to you.

We immediately inform you if, in our opinion, you infringe GDPR protection provisions. You shall ensure the security of data you transfer to Genome. You assume full liability for failures to meet the GDPR in cases when it envisaged by this Privacy Policy or GDPR.

How we share your data

Genome warrants that it will not disclose your personal data to any 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, including without limitation:

  1. Card schemes, banks and payment service providers - to make you able to obtain acquiring services, bank transfers and other payment services;
  2. Suppliers related to financial services or operations (e.g. Kyc and sanctions screening, credit checking, card supply) – to provide you high-quality service, fight fraud and comply with requirements of law.
  3. Suppliers of analytic services – to monitor, evaluate and improve Genome wallet.
  4. Information generated or collected in the course of providing Genome Services, which Genome use to develop and improve its services.
  5. It services suppliers (e.g. disaster recovery services, website hosting, data and applications hosting, software application provision and maintenance) - to ensure uninterrupted operation of Genome wallet.
  6. Communications services suppliers - to communicate with you and provide you with up-to-date information on the usage of Genome wallet, e.g. by sms or e-mails.
  7. Customer support services - to operate our payment services platform and provide administration and customer support.

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. Your registration date, number of payments you have issued/received via Genome, info whether you have an authorized control over a bank account – all that information might be showed to Genome 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.

Cross-border transfers

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 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. Genome 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.

How long we retain your data

We may use your data for as long as reasonably necessary for the limited purpose of providing Genome Services to you.
Genome as a regulated electronic money institution is obliged under PSDII 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 Genome 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 Genome Services. For instance, if Genome 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 Genome 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 personalised 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 Genome Wallet.

Your rights as a data subject

When we act as data controller, you have the following rights for personal data that we have about you.

  • You have the right to know about processing of your personal data as well as to have the access to your personal data and processing;
  • You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you). We have to properly authenticate you before we fulfill your request. Some of your information may be used further in order to track any unpaid fees, unresolved disputes, prevent from scam. We keep your data during the term of the contract with Genome and delete it if it is no longer needed or if the law does not require otherwise. Notwithstanding the above, we may be obliged to store your data longer for purpose of compliance with card shames rules, taxation and accounting purposes as envisaged by applicable law.
  • You can also ask us to change, update or fix your data in certain cases, particularly if it is inaccurate. You may do it by yourself, simply log in to your Genome account and change profile settings at once. You can also close your account using the Genome wallet functionality. If your personal data was transferred to third-parties data processors, they will be notified of any editing or deletion of your personal data.
  • You can ask us to stop using all or some of your personal data (e.g., if you believe that we have no legal right to keep using it) or to limit our use of it (e.g., if you believe that your personal data is inaccurate or unlawfully held). You have the right to temporary mark your profile as restricted by using the relevant option in your Genome account. That means it should no longer be visible to the back office staff and its processing will be suspended.
  • You can obtain a copy of your personal data we retain about you unless this adversely affects the rights and freedoms of others. You have the right to ask us to provide your information in an easily readable format to another company.
  • Where we are processing your personal information based on a legitimate interest you may object to this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object the usage of personal information for direct marketing purposes or automated decision-making.
  • You have the right to appeal to the Data Protection Authority of Lithuania or the court, in case if you do not agree with our answer to your request or claim.
  • other rights established in GDPR and legal acts.

You may contact us using the contact information below to make the request or ask us about your rights.

How we deal with your requests

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.

Password policy

You shall maintain the confidentiality of your password and login from Genome account. You are recommended to sign out of the Genome account when you have finished work with it. In any case responsibility for any loss of passwords and misuse of Genome account by third parties lay with you.

Minors

Genome does not voluntarily collect, use or disclose personal data of minors, according to the minimum age equivalent in the relevant jurisdiction. The 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.

How may this privacy policy be changed

We can make amendments to this privacy policy at any time by the means of publishing a revised edition on the site. You will be notified of any substantial changes. The revised version will be in effect immediately and be noted by updated date to the end of this privacy policy. You are entitled to terminate the agreement with Genome if you do not agree on any changes. By continuing using Genome Services, you accept the changes.

Data breaches

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:

  • Request access to information that Genome has about you
  • Correct any information that Genome has about you
  • Delete information that Genome has about you
  • Ask any other questions or concerns.

Our contacts:

dpo@genome.eu
support@genome.eu

https://genome.eu/contact

Privacy policy last modified on 29 august 2018