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Policy for Implementation of Data Subject Rights

  1. You can apply to us with a request to implement your rights related with processing of your data:
    1. Right to Information: The right to ask us for information about what personal data of Yours is being processed and the rationale for such processing.
    2. Right of Access: The right to access your personal data.
    3. Right of Rectification: The right of rectification of inaccurate personal data concerning you, and the right to have incomplete personal data completed. Please be advised that We may need to verify the accuracy of the new data you provide to us.
    4. Right of Erasure (the right to be forgotten): The right of erasure of personal data concerning you if there is no convincing reason for us continuing to process it. Please be advised that we may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of Your request. Please note that Under GDPR Article 17(3)(b), legal requirements take precedence over the right to be forgotten. From an AML perspective, the EU’s 4th Anti- Money Laundering Directive (4AMLD) introduced the requirement that both customer due diligence and transaction records be retained for a minimum of a set number of years after the end of the customer relationship and as a financial institution Praemoveo will retain your data, in line with AML regulations, for a minimum of 8 years. In this context, the right to be forgotten would only be enforceable after this period had ended.
    5. Right of Restriction of Processing (Right to Withdraw Consent): The right to obtain from us restriction of processing if there is legitimate reason. Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the EU or of a Member State.
    6. Right to Data Portability: The right to receive the personal data concerning you, which you provided to us and have the right to transmit data to another controller. Please be advised that this right only applies to information which You provided for us.
    7. Right to object: The right to object at any time to processing of personal data concerning you which is processed for the purposes of our legitimate interests. we shall no longer process the personal data unless the we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of you or for the establishment, exercise or defense of legal claims. Where personal data is processed for marketing purposes, you shall have the right to object at any time to processing of personal data concerning You for such marketing.
    8. Right to Object to Automated Processing: This right to object to a decision based on automated processing. Using this right, a customer may ask for his or her request (for instance, a loan request) to be reviewed manually, because he or she believes that automated processing of his or her loan may not consider the unique situation of the customer.
    9. Right to withdraw consent: The right to withdraw your consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before You withdraw your consent. In some cases, if you withdraw your consent, We may not be able to provide the Services to you.
    10. Right to complain. You have right to make a complaint at any time to the State Data Protection Inspectorate, Lithuania supervisory authority for data protection issues. We would, however, appreciate the chance to deal with Your concerns before you approach the supervisory authority so please contact us in the first instance.
  2. You shall provide Your request:
    1. by [email protected].
    2. by registered mail at the address 1095 Budapest, Gát utca 21. fszt. 1 Budapest, Hungary.
  3. You shall enclose a copy of your personal identification document so that we can verify Your identity and approve your request using your online account with us.
  4. We shall respond to You in 1 month. Please be advised that according to the complexity of the request this time limit may be extended up to 2 months. In any case you will get a response from us about the actions We took in 1 month. We will contact You via Your added contacts on Your account.
  5. We will provide you with our response free of charge once a year. If you wish to receive a response more often, additional  Fees  might be applied or we may refuse to act on Your request.
  6. If We have reasonable doubt about Your identity, We have the right to ask you to provide additional information to verify your identity.
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Praemoveo brand provides services under SatchelPay UAB  which is licensed by the Supervision Service Department of the Central Bank of Lithuania and granted electronic money institution licence Nr.28, with a payment system participant code Nr. 30600, that conduct business under the laws of the Republic of Lithuania.

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