BEBAWA cares about the privacy of its customers and personal data protection and therefore seeks to ensure a fair and transparent processing of personal data and comprehensively inform customers about the processing of their personal data.
These Personal Data Processing Rules (hereinafter the Rules) determine the key aspects relating to the processing of customer personal data by BEBAWA. Please read these Rules carefully. Should you have any questions regarding the processing of your personal data, please contact us using the contact information provided in these Rules.
BEBAWA or we shall mean the controller of your personal data BEBAWA, a public limited liability company incorporated and operating according to laws of the Republic of Lithuania, Company Reg. No. 305483424, registration address Mėsinių str. 5, Vilnius, Lithuania.
These Rules shall apply to customers who use, have used or expressed the intention to use the services provided by BEBAWA either electronically (for instance, by using our internet websites www.bebawa.com, logging into the e-services system of BEBAWA, etc.) or personally. The Rules shall also apply to customers with which BEBAWA forged relations before the entry into effect of these Rules, where such persons have provided their personal data and/or where BEBAWA has received their personal data.
BEBAWA shall act as a data controller in respect of the customer personal data that it processes.
In the process of processing of your personal data, BEBAWA shall adhere to the following:
Should you have any questions regarding the protection of your personal data, please e-mail us at dataprotection@BEBAWA.com, call us, or send us a letter to Mėsinių str. 5 Vilnius, Lithuania.
BEBAWA shall be responsible and shall ensure that the following principles be adhered to in the process of processing of your personal data:
BEBAWA shall process your personal data for the following main purposes:
BEBAWA shall process your personal data in the presence of at least one of the following legal grounds:
You should be aware that in case you do not provide your personal data, which is required for concluding or implementing an agreement or the provision of which is envisaged in legal acts or the respective agreement, we will be unable to provide our services to you.
BEBAWA uses personal data obtained directly from you when you fill out applications or other forms in order to order our services, correspond with us by e-mail, present specific documents to us, submit requests or claims, call us or contact us in another manner, use our internet websites or electronic services system, participate in our customer surveys or promotional campaigns.
BEBAWA may also obtain your personal data from other legitimate sources:
In the process of engaging in our operations, we may combine the available information about you that is obtained from different sources.
Profiling is a method of automated processing of your personal data that BEBAWA employs. Profiling is used in order to automate the processing of customer personal data and be able to evaluate certain personal traits of customers and in this manner analyse and forecast a variety of aspects such as a person’s financial situation, remote customer identification, personal preferences and interests.
Profiling may be used to process the available customer data and take decisions (with human intervention) regarding your creditworthiness and financial risks) as well as to provide you with appropriate advice or offer you specific services customised to your needs and ensure a more effective monitoring of transactions and operations for the purposes of identifying and preventing money laundering and/or terrorist financing and/or fraud. This enables us to ensure the smoothness, promptness and objectivity of the aforementioned processes. Normally, such profiling is based on the fulfilment of the legitimate interests of BEBAWA, but it may also be exercised on the basis of an applicable legal obligation, implementation of the respective agreement or customer consent.
BEBAWA may also process personal data in order to improve the quality of its services and develop new proposals with consideration of customer needs. Where a customer does not express its disagreement to the processing of its data for direct marketing purposes, we may process the customer’s personal data in order to select and present general and customised offers of BEBAWA services (depending on the manner and the types of our services the customer uses). This profiling for marketing purposes shall be based on our legitimate interest. If you disagree that your personal data be processed for direct marketing purposes, please notify us of this immediately.
In its operations, BEBAWA may involve different processors of your personal data (i.e. certain service providers). Such data processors chosen by us shall only process your personal data according to our instructions. For instance, data processors may include companies providing data storage services, companies developing and supporting software, companies providing communications services, companies performing analysis of online activity, companies providing marketing services and other service providers. Your personal data may only be disclosed by BEBAWA to these data processors to the extent necessary for providing the respective services.
We shall ensure that the chosen data processors adhere to the requirements of the General Data Protection Regulation (EU) 2016/679, laws and other applicable legal acts and recommendations issued by competent authorities. The relationship of BEBAWA and a specific data processor (except in cases where such relationship is regulated by laws or other legal acts) shall be regulated by the respective written agreement or written conditions.
BEBAWA may also provide your personal data to other recipients of data:
In its operations, BEBAWA normally does not transfer the personal data of its customers outside of the European Union/European Economic Area (EEA). In individual cases where we must transfer certain personal data of a customer to a data recipient outside of the EU/EEA, we seek to ensure that at least one of the following measures be implemented:
It should be noted that the providers of payment and other services that are involved in the implementation of your agreements concluded with us may be also established or operate in a State outside of the EU/EEA. Such a State may lack an adequate level of data protection (for instance, it may be a State that the European Commission has not included on the list of States with an adequate level of data protection). We shall take all steps to ensure that your personal data be used securely, but there may be instances where we will be unable to ensure that the data recipient adhere to the same requirements as applicable to EU/EEA States.
BEBAWA shall store customer personal data for a term not longer than necessary. The term of processing of personal data shall be set with consideration of the agreement concluded with the respective customer, the legitimate interests of BEBAWA or legal requirements, e.g.:
Your personal data may also be stored for a longer term, where it is necessary to defend the rights and legitimate interests of BEBAWA, provide a response to an inquiry, settle a complaint or dispute and in other cases envisaged by legal acts.
On expiry of the term of processing of personal data, your personal data shall be destroyed or irreversibly anonymised.
BEBAWA shall implement a variety of organisational and technical security measures that help to protect your personal data against accidental or unauthorised destruction, alteration, disclosure and/or any other unauthorised processing. BEBAWA requires that the data processors, which are involved by BEBAWA to process your personal data or which have access to your personal data in the process of providing services to BEBAWA, implement the appropriate organisational and technical measures to ensure the security and integrity of your personal data.
Nevertheless, it should be borne in mind that in certain cases the transmission of information by electronic means of communication (e-mail, mobile phone, etc.) may be less secure for reasons not depending on the technical or organisational measures implemented by BEBAWA. To ensure the security of your confidential data, we recommend that you do not provide us with any information via less secure electronic systems or via any electronic systems not used by BEBAWA.
You have the following rights in respect of your personal data as envisaged in legal acts:
Please remember that these rights of data subjects are implemented subject to satisfaction of all the requirements and conditions envisaged in legal acts.
In order to exercise your above rights, you must present a written application to us by e-mail to firstname.lastname@example.org by sending your application to Mėsinių str. 5Vilnius, Lithuania. The information contained in your written application must be sufficient to identify you (for instance, you must specify your full name, date of birth, residence address and other contact information); you must also provide information on which of the above rights and to what extent you wish implemented. Upon receipt of your written application, we may request that you additionally confirm your identity and/or refine the scope of implementation of the specific data subject right that you wish implemented.
A received written application shall be examined and a response shall be provided to you within 30 calendar days from the date the appropriate written application is received. In exceptional cases, which require additional time, we, subject to prior notice given to you, may extend the term for considering the claims contained in your application to up to 60 calendar days from the date of your appropriate application.
You may familiarise yourself with these rules at any time by visiting the websites of BEBAWA (www.bebawa.com).
We shall be entitled to amend these rules unilaterally at any time. In this case, we will notify you about the respective amendments to the rules and publish the new wording of the rules.