Privacy Policy

Privacy Policy

Edition: 10 January 2025

The structure of this document Some terms

· Definitions

· About us and our contacts

· Age restriction

· Personal data

· Purposes and legal basis

· Your rights and how to exercise them

· How we receive your personal data

· Who we can share your data with

· How long do we store your personal data?

· How does the service ensure the security of your data?

· Personal data breach

· Tracking data

· Changes to the Privacy notice

· Cookies

· Lithuanian Supervisory authority

· List of processing

· Category of data

· Service providers

This document is divided into 2 parts: a detailed text version (on the right) and a summary of the sections (on the left), which briefly and more clearly explain the content of the section.

Summary

This document explains what data is processed in   connection with your use of the Skanmetas service. It also explains how we   receive and use your data, where we store it and how we protect it.

We want the use of our service to be as secure as   possible for your personal data, so your privacy is a priority for us. By Skanmetas   service (hereinafter referred to as the “Service”) are understood any of its   components:

· Technological payment solutions

· Website 

It explains how and why we process your personal   data, as well as how you can control it and stop it from being processed.

This Privacy notice applies to all personal data   that we receive when you are using the Service.

Please carefully read this document. This is because   using the Service implies that you fully understand and accept the terms of   use of your personal data without any conditions, exceptions, or   reservations. If you do not accept the terms of this document (in general and   / or in part) or do not agree with the terms of use of personal data, we ask   you not to use the Service. If you disagree with the terms of the Privacy   notice, further use of the Service and its components is not allowed.

Some terms

Some terms that can be seen in this document:

Skanmetas

Automated decision-making is a decision 

Processor (vendor) 

Group Companies

Some terms that can be seen in this document:

Skanmetas shall refer to both MB Skanmetas and the   Group Companies in the context of the Personal data and the Services.

Automated decision-making is a decision that our   system makes automatically due to its specific algorithm and without human   participation.

We don’t use any algorithms to make any decision   that would significantly affect you.

Processor (vendor) – a third party company that we   attract to perform on our behalf certain actions necessary for the operation   of the Service and related to the processing of your personal data (for   example, a payment system, a message sending service, etc.)

Definitions

The terms listed below have the meanings assigned to   them in the Data privacy regulation and the accompanying Policy:

• Personal   data means any information relating to an identified or identifiable natural   person ("data subject"); an identifiable natural person is one who   can be identified, directly or indirectly, in particular by reference to an   identifier such as a name, an identification number, location data, an online   identifier or to one or more factors specific to the physical, physiological,   genetic, mental, economic, cultural or social identity of that natural   person; 

• Activity   and usage data means any personal data which is generated, collected and   processed during the usage of New Sphere's services; 

• 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, organization, structuring, storage, adaptation or   alteration, retrieval, consultation, use, disclosure by transmission,   dissemination or otherwise making available, alignment or combination,   restriction, erasure or destruction;

• Controller   means any natural or legal person, public authority, agency or other body   which, alone or jointly with others, determines the purposes and means of the   processing of personal data;.

• Processor   means a natural or legal person, public authority, agency or other body which   processes personal data on behalf of the Controller;

• Data   subject is an identified or identifiable natural person who can be   identified, directly or indirectly, based on particular information   representing personal data;

About us and our contacts

Our company, which is responsible for processing   your personal data using the Service, is called MB Skanmetas

Contacts of our Data protection officer:

1) e-mail: info@scanmetas.com

2) Postal address: Laisvės pr. 78B-214,   LT-05263 Vilnius

MB Skanmetas is the administrator of the Service and   the controller of personal data processed in accordance with this notice.

Our address: Laisvės pr. 78B-214,   LT-05263 Vilnius

If you have any questions about this Notice or   questions about our processing of your personal data, we hope that you   contact us and we will be able to resolve your issue. You can contact our   Data protection officer using:

1) email: dpo@skanmetas.com or

2) by writing us to: Laisvės pr. 78B-214,   LT-05263 Vilnius

We will send responses to your requests to the   e-mail address specified by you during registration in the Service or in any   other form, at your wish. You can also contact the Lithuanian Supervisory   Authority.

Group Companies   may as well participate in the Service.

The following Group   Companies may take some part in processing of personal data under substantial   agreements with MB Skanmetas:

AiDLT Global LTD: has its   business address at Sovereign place 117 Main Street, GX11 1AA, Gibraltar,   registered in the Registrar of Companies of Gibraltar under No 121171 and is   involved in building technology solution for the Service. 

Genblock Financial INC: has   its nosiness address at 26 Bastion Square, 3RD floor – Burnes   House, Victoria, British Columbia Canada, registered in the Registrar of   Companies of Province of British Columbia Canada under No BC1328020 and is   involved in building technology solutions for the Service.

Age restriction

You can use the   Service only when you reach a certain age. The minimum age for using the   Service is 18 years.

We will delete the   data of a user whose age does not meet our age requirements as soon as we   become aware of this.

The Service can only be used   by users who are minimum 18 years old If you are under the minimum age,   please do not use the Service and do not provide us with your personal data.

If we become aware that   personal data of users who have not reached the minimum age has been obtained   through the service, we will immediately take all possible measures to delete   such personal data and account.

If you are aware that the   App is being used by a person under the age of consent, please contact us   using any of the methods described in Section About us and our contacts, and   we will take the necessary steps to delete the corresponding information and /   or account.

Personal   Data

While using the   Services various types of your Personal Data may be processed by Skanmetas:

- Contact and general account creation data;

- Verification data;

- Financial data for facilitation of transactions;

- Log data on the website;

- Mobile app data;

- Company details in case of business accounts;

- Business onboarding data;

- Details to and proof of funds, if necessary;

- Personal data provided by you in requests to our Support or other   employee;

- Marketing data;

- Research data;

- Photo, video and audio data from events or fairs or interviews;

- Recordings of telephone conversations and electronic communication;

- Blockchain data.

• Contact and general        account creation data: when creating a new User account or communicating        with Skanmetas, we might process for example: name, address, telephone        number, email, date of birth, photo for the account, etc.; 
• Verification data: when        an account is verified, we might process for example: screenshots/photos        of national identity documents (e.g.:passport, driving licence, ID card)        and identification data from these documents, utility bill details for        residence verification, data about status of politically exposed        persons, video data from the video authentication process, biometric        data for verification (see point 7), etc.; 
• Financial data for        facilitation of transactions: e.g.: bank details (IBAN, BIC), payment        service provider information, payment details, transaction-ID, and other        sensitive payment data. In addition, data relating to the placing of        orders for financial instruments (number of units purchased, amount,        time of acquisition/termination and similar) will be processed. 
• Log data on the        website: e.g.: IP-address, transaction data, deposit and withdrawal        address, computer or mobile device information, frequency, time,        operating system, browser type, device type, unique device        identification number, identification cookies, optionally form data,        crash reports, performance data, interactive chat (for Skanmetas        Custody), third-party cookies, etc.; 
• Mobile app data:        e.g.:IP-address, transaction data, deposit and withdrawal address,        mobile device information, frequency, time, operating system, browser        type, device type, unique device identification number, optionally form        data, crash reports, performance data and only with your explicit        consent, data from: camera, microphone, storage, telephone (read SMS        confirmation); 
• Company details in case        of business accounts: commercial register reports, data of/or concerning        beneficial owners, records or additional information on recent, past or        planned business activities, other data necessary to determine/validate        the structure, the beneficial ownership or any power of attorney of the        company. 
• Business onboarding        data: e.g.:  KYC company data, ultimate beneficial ownership (UBO),        legal entity type, PEP status of UBOs, Country of Incorporation, VAT and        registration Number, Financial Statement Data, Shareholder data,        Authorised individual data (which might include personal data of an        individual such as name, ID number, ID type, issuing authority, email        address, phone number). 
• Details to and proof of        funds, if necessary: e.g.: banking statements or any other details        provided by banks or financial institutions, contracts of sales or        contracts in general, or any other suitable data to prove or determine        the origin of funds; 
• Personal data provided        by you in requests to our Support or other employee; if you contact our        support, we might process for example: data provided in your request to        the support team. 
• Marketing data: if you        visit our website or social media sites or during the usage of the        Mobile App, we might process statistical and marketing data for example:        number of visitors, frequency, clicks, time, places, target groups, data        from cookies and similar technologies, consumer’s behaviour, interests        and preferences, data about market research and target groups surveys,        etc.; 
• Research data: if you,        inter alia, participate in any discussion boards, panels, etc. provided        by Skanmetas or take part in one of our research initiatives and provide        data via forms (which you might receive separate information about if        you voluntarily agree to participate); 
• Photo, video and audio        data from events or fairs or interviews: e.g.: photo, video and audio        data. 
• Recordings of telephone        conversations and electronic communication: when applicable by the laws.        We will inform you of this in advance. 
• Further User        identification information in the sense of applicable Anti-Money        Laundering laws obtained during the initial registration process.
• Blockchain data: your        private blockchain key that will be managed and used to verify and carry        out transactions you make online through the App/site;

All processing   is performed in accordance with applicable data protection legislation. This   includes, inter alia, the EU General Data Protection Regulation (GDPR), the   E-Privacy Directive and the national implementing acts (e.g. the Lithuanian   Data Protection Act). Generally, we process your personal data based on one   of the legal bases listed below:

- For the performance of contractual obligations (Art 6   para 1 lit b GDPR);

- For compliance with legal obligations (Art 6 para 1 lit c GDPR);

- To protect legitimate interests (Art 6 para 1 lit f GDPR);

- Based on your consent (Art 6 para 1 lit a GDPR);

For the performance of   contractual obligations (Art 6 para 1 lit b GDPR): 

Processing of personal data might be necessary for the   performance of the contract with you or in order to take steps at your   request prior to entering into a contract. The following data processing   operations, for example, are covered by such contractual obligations: 

• general performance of our        services, all tasks necessary for the operation, performance and        administration of Skanmetas and its platform; 
• video authentication process if you        register for an account (validation of identity); 
• account management (e.g. continuous        updating of User data);  
• execution of your orders (e.g.        payment processing, chargebacks, proof of purchase and selling); 
• data processing and data        transmission to precious metals vendors for the transferal of ownership        of precious metals to you in accordance with your order;  
• Users service and support request; 
• application processing and data        transmission for the Skanmetas prepaid Debit Card. 

· analysis and improvement of the   platform's quality and the general User experience (e.g. performance tracking   on the platform); 

For compliance with legal   obligations (Art 6 para 1 lit c GDPR): 

Processing of personal data might also be necessary for   complying with various legal obligations. The following data processing   operations, for example, are covered by such legal obligations: 

• contract management, accounting and        invoicing; 
• compliance and risk management; 
• Know-Your-Customer measures like        video authentication process (validation of identity) and proof of        funds; 
• monitoring for prevention of fraud,        misuse (e.g. for illegal purposes), money laundering and terrorist        financing; 
• providing information to fiscal        criminal authorities in the context of fiscal criminal proceedings or to        prosecution in accordance with official orders; 
• consultation of credit agencies to        determine creditworthiness and default risks. 
• appropriateness test.  
• transaction information; such as        sender’s name, account number, location information, recipient's name        and account number in order to prevent money laundering and terrorist        financing within the means of complying with FATF Travel Rule ;
• recordings of telephone        conversations and electronic communication. 
• appropriateness test. 

To protect legitimate interests   (Art 6 para 1 lit f GDPR): 

Where necessary, data processing might take place beyond the   performance of the contract in order to maintain the legitimate interests of Skanmetas   or a third party. The following data processing operations are covered by   such a legitimate interest: 

· prevention of fraud, misuse   (e.g. for illegal purposes), money laundering and terrorist financing; 

· processing inquiries from   authorities, lawyers, collection agencies in the course of legal prosecution   and enforcement of legal claims in the context of legal proceedings; 

· risk management and risk   minimisation e.g. through enquiries to credit agencies, debtor directories or   providers of business analysis; 

· data transmission within the Skanmetas   Group for internal administrative purposes; 

· account management and handling   general User requests and inquiries; 

· testing and optimisation of   procedures and models for analysing requirements, business management,   product development and direct User engagement; 

· process and quality management   measures; 

· analysis and improvement of the   platform's quality and the general User experience (e.g. performance tracking   on the platform); 

· market research, business   management and continuing development of services and products; 

· processing statistical data,   performance data and market research data via the website, the Mobile App or   social media platforms; 

· direct marketing and advertising   (e.g. performance of marketing strategies, targeting of Users, dispatch of   vouchers, advertisement from Skanmetas and its partner companies); 

· use of audio, video and photo   data from public spaces (e.g. public events, fairs, etc.) for marketing and   other representation purposes on our social media channels or our website; 

· processing User preferences   (e.g. language, region) via cookies on our website ; 

· identification and examination   of potentially defective or suspicious business cases and accesses to our   websites (e.g. website analysis); 

· Payment services (e.g. transfers   from your Account to Account or a third party, initiating payment initiation   services at a third party, etc.) 

· measures for protecting our   Users and Partners, as well as safeguarding network and information security;   also measures to protect our employees, Users and property of Skanmetas; 

· data security and IT-security on   our website and safeguarding our network (e.g. prevention of identity theft   and defective or suspicious accesses to our websites). 

Based on your consent (Art 6   para 1 lit a GDPR): 

If you have given us your consent to process your personal data,   processing will only take place in accordance with the defined purposes and   to the extent agreed in the declaration of consent. Given consent may be   withdrawn at any time without giving reasons and with future effect, if you   no longer agree to the processing. For example, with your consent we are   processing data for the following purposes: 

• for the use of all functions of the        Mobile App (e.g. telephone permission to read SMS confirmation, camera        to scan barcodes, microphone for commands, etc.); 
• direct marketing and advertising        (e.g. User satisfaction surveys, newsletters, sweepstakes and other        advertising communications); 
• website analysis and tracking for        advertising purposes; 
• certain uses of audio, video and        photo data (e.g. commercials, interviews, etc.) for marketing and other        representational purposes via various channels; 
• auto-ident procedures for verifying        your account (validation of identity).

Please note that the withdrawal of the consent does not affect   the lawfulness of processing based on consent before its withdrawal. 

Processing for other   purposes:  

As a general principle of Skanmetas, we only process personal   data for the purposes for which they were collected. In exceptional cases,   however, we might process your personal data which we have collected for one   specific purpose for another purpose. In this case, we will inform you before   the intended processing about this purpose, the period for which your   personal data will be stored, the exercise of data subject rights, the option   to withdraw consent, the existence of the right to file a complaint with the   data protection authority, whether provision of the data was necessary on   legal or contractual grounds and what the consequences would be if it were   not provided, and whether automated decision-making or profiling is carried   out.

Your rights and how to exercise them

You have a   number of rights in relation to your personal data:

a) to access   them (Right of access, Art 15 GDPR)

b) make   amendments and additions to them (Right to rectification, Art 16 GDPR)

c) require us to   erase them (Right to erasure, Art 17 GDPR)

d) request a   restriction on their processing (Right to restriction of processing, Art 18   GDPR)

e) object to a   particular data processing (Right to object, Art 21 GDPR)

f) receive your   data from us in electronic format, so that you can then transfer it to   another person or ask us to do so (Right to data portability, Art 20 GDPR).

g) not to be   subjected to automated decision-making (i.e., a decision that our system   makes

automatically   due to its specific algorithm and without human participation) (Right to not   be subject to automated decision-making, Art 22 GDPR)

h) to withdraw   consent to their processing (Right to withdraw consent, Art 7(3) GDPR). 

In any case, you   can always ask us via email dpo@Skanmetas.group or by writing us to:   Naugarduko 68B, Vilnius, 03203, Lithuania, how we process your data and how   you can exercise your rights.If we suspect that someone is impersonating you,   we will check whether it is really you who made the request to us.

Your rights in relation to   your personal data:

a) The right to access   personal data We provide you with the opportunity to access your personal   data that is processed by the service. You can request information about what   your personal data is processed by us and to what extent by sending us a   request *.

b) Right to rectification   You can independently change (clarify / supplement) certain personal data in   your profile, and you can also contact us with a request to clarify your   personal data*. We may ask you for documents confirming

the need for changes, if   such changes are related to the receipt of paid services of the service.

c) The right to erasure (the   “right to be forgotten”) In certain cases, you can request * the deletion of   your personal data and the termination of their processing, for example, when   the personal data is no longer needed for the purposes of specific   processing, or when you withdraw your consent or object to the processing of   your personal data, or when in your opinion the processing of personal data   does not comply with the law.

d) The right to restrict   processing You may request* that we temporarily or permanently stop   processing all or some of your personal dataif:

dispute the accuracy of your   personal data,

if you believe that the   processing is illegal and, instead of deleting personal data, you want to   restrict their use by us,

you believe that they are   necessary for you to declare, implement or challenge legal claims and claims.

e) The right to object to   processing Taking into account your specific situation, you can at any time   object to the processing of your personal data if the basis for their   processing was our legitimate interest or the processing is necessary to   perform a task in the public interest or within the framework of the exercise   of state power entrusted to us (the grounds for processing are described in   the Appendix List of treatments. You can also object to profiling based on   these grounds. Also, in cases where we process data for the purposes of   direct marketing, you have the right at any time to object to the processing   of your personal data for the purposes of such marketing, including   profiling, to the extent that the processing of your personal data relates to   this direct marketing.

f) The right to data   portability You have the right to receive your personal data available to us,   which we received with your consent or they were provided to us for the   performance of the contract, from us in electronic format and then you can   transfer such data to another person. We may, at your direction, transfer   such data directly to another person, if this is technically feasible.

g) The right not to be   subjected to automated decision-making You have the right not to be subjected   to a decision that is based solely on the automated processing of your   personal data, including profiling, if such actions entail legal consequences   (for example, some of your legal rights will be infringed, limited) or in a   similar way significantly affect you.

In certain cases, automated   decision-making may take place, but we will take measures to protect your   rights, freedoms and interests of the data subject. In this situation, you   can request* the intervention of our specialist to make a decision, and also have   the right to express your position, challenge such a decision.

h) The right to withdraw   consent to the processing of personal data If we process your personal   information based on your consent, you can revoke your consent to the   processing of personal data at any time by changing the settings in your   profile or by sending us a request* indicating the revoked consent. Please   note that the fact of revocation of consent does not affect the legality of   data processing actions performed before the revocation. If you have any   questions about your privacy rights or how you can exercise them, or if you   want to exercise any of these rights, you can send us a request*. We will try   to respond to your request as soon as possible, but in any case we will do it   within a month from the date of receipt of the request. In some cases, it may   take up to 3 months to fulfill your request, which we will definitely notify   you about and explain

the reasons for the delay.

Please keep in mind that if   the request is unclear, we can contact you to better understand the content   of the request. We may also refuse to satisfy a request if it is clearly   unfounded or excessive (repetitive).

If we have doubts whether   you have really contacted us (and not someone impersonating you), we have the   right to ask you to confirm your identity (for example, to confirm some data   known to you and us or to provide a copy of your identity card). This will   allow us to make sure that the satisfaction of your request does not violate   the rights of third parties.

If you are not completely   satisfied with our response, you can also complain about our processing of   your personal data to the appropriate data protection authority.

How we receive your personal data

Where do we get   your data from:

1) we receive   from you (for example, when you enter data during registration or write a   request to our

mail);

2) we   automatically collect data from your device (phone, computer) from which you   use the Service;

3) we receive it   from other services and persons (for example, from Facebook, Google, Apple);

4) we create it   ourselves (for example, by collecting the history of your use of the   service).

We may receive your personal   data:

· directly from you when you enter this data when registering or using   the service or in connection with its use (for example, when you enter data   during registration or write a request to our email);

· automatically received by us when you use the service (for example,   technical data of the device);

· received by us from third-party resources and services (for example,   from Sum and Substance Ltd (UK) that provides KYC for us);

· generated by our service when you use it (payment history). When you   register or log in to our service via Facebook, Google, Apple, you give us   permission to receive certain information from these services. The specific   types of information that we may receive depend on your settings for this   service and will be governed by their privacy policy.

When we ask you to provide   your personal data for the provision of the services, we strive to collect   only those whose collection is the minimum necessary for the provision of   services of the service. If you do not provide us with complete and accurate   data, we will not be able to provide you with the services.

If for some functionality   (for example, sending news to the mail) or for some of our needs (for   example, sending advertising to you), your consent to the processing of   personal data is required, such processing will be carried out at your   discretion and only after receiving your consent.

How long do we store your personal data?

As a rule, we store   your personal data as long as it is necessary to provide you with the Service   and to provide access to the Service and for no less than 5 years  period after termination of business   relationship or for other term established by applicable laws for the storage   of certain data.

As a rule, we store your   personal data as long as it is necessary to provide you with the Service and   to provide access to the Service and for no less than 5 years or for the period after termination of   business relationship or for other term established by applicable laws for   the storage of certain data.

We will store the necessary   personal data after deleting your account, only if it is necessary for:

· fulfillment of our tax and legal obligations,

· compliance with the requirements of the legislation,

· to resolve claims or disputes,

· ensuring security,

· prevention of fraud and money laundering,

· ensuring the safety of our users.

Please note that if you   delete some personal data of users from the Service, this deletion may affect   the ability to use the Service and its functionality for the user.

Who we can share your data with

Your data may be   processed by other companies engaged by us. Your data may sometimes be   transferred for processing outside the EU, including to countries where the   level of personal data protection is not adequate to the European level.   However, in such cases, we undertake to monitor such processing.

- Data transfer within the Skanmetas Group;

- Data transfer to Processors;

- Data transfer to public bodies and institutions;

- Data transfer to other third parties;

For the operation,   development, promotion of the service, we cooperate with other service   providers who may have access to or receive from us or directly some of your   personal data to provide relevant services. Such suppliers may be located   outside the European Union and in countries that do not provide an adequate   level of personal data protection (for example, the United Kingdom, etc.).

We allow these companies to   process your data in accordance with our instructions and exactly to the   extent that they need it to provide their services and products. As a tool   for transferring data to countries that do not provide a level of protection   adequate to the European one, we use such as Standard Contractual Clauses   (approved by the EU Commission), which describe the conditions for processing   data by recipients and mechanisms for their protection (including various technical,

organizational and legal protection   measures). 

Data transfer within the Skanmetas   Group: 

Within the Skanmetas Group, your personal data will be shared   between companies: if there is a legal basis as described above. This happens   for internal administrative purposes to conduct internal administrative   activities efficiently. Our employees treat your data with the highest   security standards and also only have access on a need-to-know basis. In all   these cases only those offices or employees will receive your personal data   who need it to fulfil the contractual and legal obligations and legitimate   interests.

Data transfer to   Processors  

To a limited extent, we also transmit personal information to   Processors. Such include, inter alia, service providers for video   authentication services, IT services, User support, improvement of our   website, monitoring of defective business cases, application management.   Processors may only use or disclose this data to the extent necessary to   perform services for us or to comply with legal requirements. We   contractually oblige these Processors to ensure the confidentiality and   security of your personal data that they process on our behalf. 

Data transfer to public bodies   and institutions: 

We might also transfer your personal data might be disclosed to   public bodies and institutions (i) if we are required to do so by law or in   the context of legal proceedings, (ii) if we believe that disclosure is   necessary to prevent damages or financial loss, or (iii) in connection with   an investigation into suspected or actual fraudulent or illegal activities. 

Data transfer to other third   parties: 

Skanmetas will only share your personal data with other third   parties if a legal basis applies. This may be due to our contract with you,   our legitimate interests, a legal obligation or your prior consent   (withdrawable at any time). 

We want to especially highlight five types of third parties that   we might have to share data with:  

· Card Provider: if you use the Skanmetas   prepaid debit card, we will send your personal data as required to our   partner providing the card, technology and gateway; 

• Content managing system, e.g. the Skanmetas        Custody provider. 
• Data storage provider (servers        located in the EU). Amazon Web Services (AWS)
   https://aws.amazon.com/compliance/data-privacy-faq/
• KYC provider: Sum and        Substance Ltd (UK) https://sumsub.com/privacy-notice/ 
• Other third parties: Skanmetas Group might transfer        your personal data to any other person with your consent to the        disclosure or the purpose of performing a contract or in order to take        steps at the request of the data subject prior to entering into a        contract, especially for the performance of payment services to credit        institutions and other payment service providers as far as the        disclosure is necessary for the performance of transactions of        cryptocurrencies, digital assets. 

How does the service ensure the security of your data?

The security of   your data is important to us. To do this, we use certain common measures to   protect them, and also make sure that our partners provide an appropriate   level of protection of your data.

We strive to protect the   personal data of our users and take all reasonable and appropriate measures   to protect the personal data of users from loss, theft, misuse and   unauthorized access, disclosure, alteration and destruction.

To protect your personal   data, we:

· have designed and have developed the Service in such a way as to   minimize the risks of data breach;

· have chosen reliable partners who comply with the requirements of the   laws on personal data protection. Our partners with whom we share your   personal data are required to comply with all applicable data privacy   requirements and ensure an appropriate level of data protection;

· have restricted access and differentiated the levels of access to your   personal data for our employees and third parties, and we also monitor who   accesses, uses and transmits your personal data;

· conduct vulnerability scanning of the Service to prevent data breach;

· store personal data on servers located in the European Union;

· encrypt personal data for safe transmission and storage.

If you have any questions   about the security of our Service, please contact our Data protection officer   at dpo@skanmetas.com

No service is 100%   secure. If your data is suddenly leaked in our Service, we will do everything   to eliminate such a leak and its consequences for you. It is important for   you to restrict the access of others to your device and its contents, since   we cannot ensure the security of your data in the event of such access.

Please note that no security   system is perfect, and therefore we cannot fully guarantee the absolute   security of the service or unauthorized access to personal data by third   parties. In case of occurrence of such circumstances (events) we will take   all reasonable measures to eliminate these circumstances (events) and their   consequences.

We recommend that you   restrict access to the device from which you use the service and log out   after using the Service.

If necessary, we will notify   you of any violations related to your personal data breach and report such   breach to the relevant authority for the supervision of compliance with the   legislation on the protection of personal data.

We use   "Cookies", which are text files placed on your computer, to help us   analyze how users use our services, and similar technologies (e.g. web   beacons, pixels, ad tags and device identifiers) to recognize you and/or your   device(s) on, off and across different devices and our services, as well as   to improve the services we are offering, to improve marketing, analytics or   website functionality. The use of Cookies is standard on the internet.   Although most web browsers automatically accept cookies, the decision of   whether to accept or not is yours. You may adjust your browser settings to   prevent the reception of cookies, or to provide notification whenever a   cookie is sent to you. You may refuse the use of cookies by selecting the   appropriate settings on your browser. However, please note that if you do   this, you may not be able to access the full functionality of our websites.

Google Analytics:

• The MB Skanmetas website uses Google Analytics, a   web analytics service from Google, Inc. ("Google"). Google   Analytics uses cookies-text files hosted on visitor computers that help   website operators analyze how visitors use the site. Information about the   use of the website by visitors, created using cookies, is usually transmitted   and stored on Google's servers in the United States.

• On behalf of the website operator, Google will use   this information for the purpose of evaluating the website for its users, in   order to compile reports on website activity, and to provide other services   relating to website activity and internet usage for website operators.

• Google will not associate the IP address   transferred in the context of Google Analytics with any other data held by   Google. You may refuse the use of cookies by selecting the appropriate   settings on your browser. However, please note that in this case you may not   be able to use the full functionality of this website.

• Furthermore, users can prevent the collection of   data about their use of the website (including their IP address) generated by   the cookie, and the processing of data by Google, by downloading and   installing the browser plug-in through the following link:   http://tools.google.com/dlpage/gaoptout?hl=en .

Facebook Tracking Pixel   service:

• Facebook Tracking Pixel with Remarketing is used by   MB Skanmetas to display targeted ads to visitors to this website, depending   on how they are used when visiting the Facebook social network (hereinafter   referred to as Facebook Advertising). With Facebook Tracking Pixel, a direct   link to Facebook servers is used when visitors use this website. He sends   information to the Facebook server about the user visiting this website, and   Facebook processes this information and can link it to a Facebook user   account. For more information about how Facebook collects, processes data,   and protects their privacy, see Facebook Privacy Policy at   https://www.facebook.com/about/privacy.

• You may at any time object to using your   information for such remarketing. You can disable Facebook Tracking Pixel in   your Facebook account settings or in the following cookie tracking settings   at any time.

Content recommendation

• In accordance with your individual consent or in   cases where this is expressly permitted by applicable e-mailing laws, MB   Skanmetas may send you marketing messages on your email address about   products and services offered by MB Skametas In this case, we can also use   your collected information to set up such marketing messages, and collect   information about whether you opened the message and what link in the text   you clicked on).

• You can opt out or withdraw your consent to receive   marketing emails at any time by either withdrawing the consent clicking the   "unsubscribe" link provided in every marketing email.

We may periodically make   changes to this Privacy policy and, if necessary, we will notify you about it   (for example, by posting a notification in the Service or sending you an   email and / or notification to your device). Your continued access to or use   of the Service after the effective date of such changes will be governed by   the revised Privacy notice. If you do not agree with the changes made to   Privacy notice (in general and / or in part), please do not use the Service   and delete your profile (if you want us to stop processing your personal   data).

In any case, you can get   acquainted with the current version of Privacy policy and all its previous   versions on our website. We recommend that you periodically review our   website or Service applications to get the latest information about our   privacy policies regarding your personal data.

You bear the risks   associated with untimely familiarization with the Privacy Policy, changes and   (or) additions made to the Privacy Policy before using the Skanmetas service.

The invalidation of certain   provisions of the Privacy notice for any reason does not entail the   invalidity of the Privacy notice as a whole and its other provisions.

Cookies are   small text files sent by us to your computer or mobile device. They are   unique to your account or your browser. Session-based cookies last only while   your browser is open and are automatically deleted when you close your   browser. Persistent cookies last until you or your browser delete them or   until they expire. To find out more about cookies, visit   http://www.allaboutcookies.org/

Some cookies are   associated with your account and personal information in order to remember   that you are logged in and which workspaces you are logged into. Other   cookies are not tied to your account but are unique and allow us to carry out   analytics and customization, among other similar things.

Cookies can be   used to recognize you when you visit a Site or use our Services, remember   your preferences, and give you a personalized experience that's consistent   with your settings. Cookies also make your interactions faster and more   secure.

Cookies also   help provide us with aggregated auditing, research, and reporting, and know   when content has been shown to you.

Some people   prefer not to allow cookies, which is why most browsers give you the ability   to manage cookies to suit you. In some browsers you can set up rules to   manage cookies on a site-by-site basis, giving you more fine-grained control   over your privacy. What this means is that you can disallow cookies from all   sites except those that you trust.

Contacts of the   authority that controls the use of your personal data by us:

State Data   Protection Inspectorate

L. Sapiegos str.   17, LT-10312 Vilnius

Phones: +370 5 271   2804 / 279 1445

Consultations by   phone +370 5 212 7532

E-mail ada@ada.lt

Website:   https://vdai.lrv.lt/en/

The entire list of   supervisory authorities can be found at the link

https://edpb.europa.eu/about-edpb/about-edpb/members_en