Privacy Policy

Coxipay Website Privacy Notice
General information
This Privacy Notice governs and explains how UAB Coxi (hereinafter
referred to as “we” or “Data Controller”) collects and further processes your
personal data when you use the website coxipay.com.
The terms contained in this Privacy Notice apply each time you access our content
and/or services, regardless of what device (computer, mobile phone, tablet,
TV, etc.) you use.
Data Controller’s details:
UAB Coxi
Legal entity code: 305181963
Office Addrss :Perkūnkiemio g. 13-91, LT-12114 Vilnius
Tel. +37254582826
E-mail: [email protected]

We confirm that we will collect information about you in line with the
requirements of the applicable laws and regulations of the European Union
and of the Republic of Lithuania and the guidelines of the regulatory
authorities, and that we have adopted all reasonable technical and
administrative measures to ensure that data that we collect about website
visitors are protected from loss, unauthorised access and/or alteration. The
Data Controller’s employees have made written commitments not to disclose
and distribute information accessed in the workplace to any third party,
including information about visitors of the website/social media accounts.
Persons under the age of 16 may not provide any personal data through our
website/social media accounts. If you are a person under 16, make sure that
you obtain a parent or guardian’s permission before you provide personal
information to us.
The definitions used in this Privacy Notice have the meanings assigned to
them in General Data Protection Regulation No 2016/679 (EU).
Be sure to read carefully this Website Privacy Notice, because each time you
access this website you agree to abide by the terms described here. If you
disagree with these terms, please do not visit our website, use our content
and/or services.
How do we collect information about you?
We may collect personal data about you, i.e. any information identifying you,
in various ways:

  • You may provide us with information (personal data) directly (by filling
    in a registration form, subscribing to our newsletter, or making a call to
    us).
  • We may collect information about you automatically (when you visit
    our website, our social media account, or use our applications).
  • In certain cases we may acquire information about you from third
    parties and may collect information about you from publicly available
    sources (e.g. through LinkedIn social networking platform, your
    company’s website or otherwise).
    We may collect information that you provide to us directly. Typically this will
    happen when you:
  • sign up to our website;
  • enter into an arrangement with us for provision of services or another
    agreement;
  • install our applications;
  • subscribe to our newsletter or register to receive other
    communications;
  • participate in our surveys.
    We may collect information about you automatically. Typically this will
    happen when you:
  • submit inquiries through our registration system or social media
    accounts;
  • use our website (we collect information about you through the use of
    cookies and similar technologies; to learn more about the cookies we
    use see the information below);
  • make public posts on social media platforms that we follow.
    Where permitted by applicable law, we may acquire information about you
    from third parties. This may include information shared by our partners,
    marketing agencies, your publicly available profile information (LinkedIn,
    Facebook, Twitter, Instagram). We may link information provided by yourself,
    collected from public and commercial sources to other information we obtain
    from you or about you.
    We may also collect information about you in other contexts than discussed
    in this Privacy Notice. If this is the case, we will give you further notice.
    What information (personal data) about you do we process?
    Although we seek to collect as limited amount of your information as
    possible, we collect the following information:
  • information necessary to provide our services to you (provided in
    contracts, registration form);
  • information you give us in surveys;
  • information you give us in calls to us;
  • information about your preferences and interests;
  • information necessary to verify your age and identity;
  • information about the device you use.
    Information that we collect from you directly will be apparent from the
    circumstances and the context in which you provide it. For example:
  • when we provide our services to you we process your information such
    as your name, surname, payment method, address, passport number
    and other information we may need in providing services to you, such
    as your phone number or e-mail address to which we will send your
    registration confirmation;
  • credit card number, credit card expiration date;
  • information about your interests and preferences.
    Information that we collect automatically will generally concern:
  • information about your usage of our websites (device information: IP
    address, operating system version, and settings of the device you use
    to access our content/products; log information: time and duration of
    your login session, search query terms you enter through the website,
    and any information stored in cookies that we have set on your device
    (cookies policy is provided below); location information: your device’s
    GPS signal or information about nearby WiFi access points and cell
    towers that may be transmitted to us when you use our website
    content.
    Information that we collect from third parties or publicly available sources
    will generally consist of the following:
  • your interests;
  • your e-mail address, name, surname, your country, special preferences
    and interests.
    You may choose not to disclose certain information to us (e.g. information
    requested in the registration form), but in that case you may not be allowed
    to register in our website or receive our services.
    Purposes and legal basis of data processing
    We use the above information we collect for the following purposes:
  • to provide payment services;
  • to provide service-related information you request;
  • for marketing purpose , e.g. providing customised advertisements and ss
    sponsored content and sending promotional communications;
    assessment and analysis of our market, clients, products and services
    (including asking for your opinions on our products and services,
    carrying out client/partner surveys, running competitions or
    promotions, as permitted by law);
  • to understand the way people use our online services so that we can
    improve them and develop new content, products and services;
  • to protect our interests before any court or any other institution;
  • otherwise with your consen .ts
    ⃰sYou may opt out of direct marketing communications from us at any time.
    If you prefer not to receive our direct marketing communications, please let
    us know by sending us an e-mail to [email protected] or clicking on the
    opt-out link appearing in the newsletter.
    We process personal data about you based on one or several legitimate
    grounds for the processing:
  • compliance with legislative requirements;
  • discharge of obligations under a contract between you and us;
  • our legitimate interests, unless they are overridden by your private
    interests;
  • in certain cases, your consent.
    The purposes of the processing of your personal data, with respective legal
    bases and personal data collected for such purposes, are set out in the table
    below:
    Purpose Legal
    basis/bases
    Personal data
    To provide payment
    and related services
    Discharge of
    obligations
    under a contract
    between you
    and us.
    Compliance with
    legislative
    requirements.
    Our legitimate
    interests unless,
    these interests
    are overridden
    by your private
    interests.
    Name, surname, payment
    method, credit card number,
    address, passport number, credit
    card expiration date, other
    information we may need in
    providing our services to you,
    such as your phone number or email address to which we will
    send your registration
    confirmation, information about
    your interests and preferences.
    To provide servicerelated information
    you request
    This information
    is provided to
    you on the basis
    of our legitimate
    interest to
    provide you with
    accurate
    information
    about the
    services we
    provide, extra
    services, etc.
    In order to be able to answer
    your queries by phone, e-mail,
    through social media and
    otherwise, we may ask you to
    give us your phone number, email address or other contact
    details convenient to you.
    For marketing
    purposes, e.g.
    providing
    customised
    advertisements and
    sponsored content
    and sending
    promotional
    communications;
    assessment and
    For this purpose
    we process your
    personal data on
    the basis of our
    legitimate
    interest to
    inform about our
    services, events,
    news and other
    Name, social media account
    details, telephone, e-mail,
    address, your interests.
    Purpose Legal
    basis/bases
    Personal data
    analysis of our
    market, clients,
    products and
    services (including
    asking for your
    opinions on our
    products and
    services and
    carrying out
    client/partner
    surveys)
    relevant
    information.
    To understand the
    way people use our
    online services so
    that we can
    improve them and
    develop new
    content, products
    and services
    For this purpose
    we process your
    personal data on
    the basis of the
    legitimate
    interest to
    monitor the
    quality of our
    services,
    develop and
    improve the
    content we
    provide, and
    ensure security
    of the website.
    IP address, operating system
    version, and settings of the
    device you use to access our
    content/products, time and
    duration of your login session,
    search query terms you enter
    through our website, and any
    information stored in cookies that
    we have set on your device, your
    device’s GPS signal or
    information about nearby WiFi
    access points and cell towers that
    may be transmitted to us when
    you use our website content.
    To protect our
    interests before any
    court or any other
    institution
    Compliance with
    legislative
    requirements.
    Legitimate
    interest to
    defend against
    lawsuits and
    claims.
    Depending on the lawsuit or
    claim filed, we may collect all
    personal data mentioned in this
    Privacy Notice that we have
    about you.
    Where we do not base our use of information about you on one of the above
    legal bases, we will ask for your consent before we process your information
    (these cases will be clear from the circumstances and the context).
    In some instances, we may use information about you for purposes other
    than described above. Where this is the case, we will provide a supplemental
    notice to you.
    To whom we disclose your personal data?
    We may disclose your personal data to the following entities:
  • companies that provide services for us;
  • banks/companies that provide payment services;
  • companies assisting with organising competitions/games/promotions;
  • other carefully selected business partners;
  • other group companies: Triff Holding Ltd, Golan Holdings Ltd;
  • other parties, when so required under law or necessary in order to
    protect our legitimate interests.
    Companies providing services for us are currently the following: Scoders
    Limited, UAB Bonus Socius, UAB TaxLink. These entities are limited in their
    ability to use your information for purposes other than providing services to
    us.
    We may share information about you with other third parties, such as public
    authorities, authorities supervising activities in the payment sector, pre-trial
    investigation officials, courts, and others, when we consider disclosure to be
    necessary to protect our legitimate interests.
    To what countries do we transfer your personal data?
    Sometimes we may have to transfer your personal data to other countries
    that may offer lower levels of data protection. In such cases we do all that is
    within our control to ensure the security of the data we transfer.
    The Data Controller transfers your personal data to the following countries
    outside the European Economic Area: Israel, India.
    Where the Data Controller transfers your personal data to countries outside
    the European Economic Area we ensure that any of the following safeguards
    is implemented:
  • A contract is signed with the data recipient based on the standard
    contractual clauses adopted by the European Commission.
  • In respect of data transmission by a group of undertakings, binding
    corporate rules are applied.
  • The data recipient is established in a country recognised by the
    European Commission as applying adequate data protection
    standards (Israel, for example)
  • Authorisation is obtained from the Data Protection Inspectorate.
    How do we protect information about you?
    We have put in place reasonable and appropriate physical and technical
    measures to safeguard the information we collect in connection with the
    provision of our content/services. Please note, however, that although we
    take reasonable steps to protect your information, no website, Internet
    transmission, computer system or wireless connection is completely secure.
    How long will your personal data be kept?
    We will retain your personal data for the period necessary to fulfil the
    purpose for which they were collected. After that, we will delete them, except
    where we are legally obligated to retain the information for tax purposes, or
    such data may be required in conducting a pre-trial investigation, but in any
    event the retention period will not extend beyond 10 years. On expiration of
    this period, the data will be irretrievably deleted.
    Normally, personal data storage periods are as follows:
    Personal data Retention period
    Payment data At least 10 years after the payment transaction
    Personal data used
    for marketing
    purposes
    3 years from your last visit to our website
    IT system logs Up to several months
    Analytical data
    Such data are normally collected automatically
    while you visit the website and immediately
    depersonalised/aggregated.
    Rights that you have
    The data subject whose data are processed in connection with activities
    carried out by the Data Controller, depending on the situation, has the
    following rights:
  • to know (be informed) about the processing of data concerning
    him/her (right to know);
  • to access his/her data and be informed about the methods of their
    processing (right of access);
  • to obtain rectification of personal data or, taking into account the
    purposes of the processing of personal data, to have incomplete
    personal data completed (right to rectification);
  • to obtain the erasure of data concerning him/her or the suspension
    of data processing activities concerning him/her (except storage)
    (right to erasure and ‘right to be forgotten’);
  • to obtain from the Data Controller restriction of the processing of
    personal data if there is a legitimate ground (right to restriction of
    processing);
  • to object at any time to processing of personal data concerning him
    or her which is based for the performance of a task carried out in
    the public interest or for the purposes of the legitimate interests
    pursued by the controller or by a third party. The controller has to
    demonstrate compelling legitimate grounds for the processing
    which override the interests, rights and freedoms of the data
    subject (right to object);
  • to exercise the right to data portability (right to data portability);
  • to lodge a complaint with the State Data Protection Inspectorate.
    We offer you easy ways to exercise these rights. You can do so by giving us a
    call to +37254582826, writing to us to [email protected], or using
    certain links provided at the end of our promotional communications.
    You may not be able to exercise these rights when in the cases provided by
    law it is necessary to ensure prevention, investigation and detection of
    crimes, violations of official or professional ethical standards, as well as the
    protection of the rights and freedoms of the data subject or other persons.
    We will ask you to prove your identity face-to-face, through electronic
    signature or, where the two options are not available, remotely via Skype
    before we enable you to exercise your rights.
    Rights that you
    have Certain restrictions
    To know (be
    informed) about
    the processing of
    your data (right to
    know)
    You have the right be informed in a concise form
    and using simple and plain language before the
    processing of your personal data.
    Rights that you
    have Certain restrictions
    To access your
    data and be
    informed about the
    methods of their
    processing (right
    of access)
    This right means:
  • confirmation whether or not we process
    personal data concerning you;
  • providing you with the list of your data
    that we process;
  • informing you about the purposes and
    legal bases for the processing of your
    personal data;
  • confirmation as to whether or not we
    transfer data to third parties and, if so,
    the safeguards we have implemented;
  • informing you from which source your
    personal data originate;
  • information as to the existence of
    profiling;
  • information about the storage period.
    After we have established your identity, we will
    provide you with the above information, provided
    this does not affect the rights and freedoms of
    others.
    To obtain
    rectification of
    personal data or,
    taking into account
    the purposes of
    the processing of
    personal data, to
    have incomplete
    personal data
    completed (right to
    rectification)
    This applies if the information we hold is
    incomplete or inaccurate.
    To obtain the
    erasure of your
    data (right ‘to be
    forgotten’)
    This applies if:
  • the information we hold is no longer
    necessary in relation to the purposes for which
    we use it;
  • we process your data on the basis of your
    Rights that you
    have Certain restrictions
    consent and you withdraw your consent;
  • we process your data on the basis of
    legitimate interests and we find that, following
    your objection, they are overridden by your
    private interests;
  • the information was unlawfully used.
    To stop all data
    processing
    activities in
    respect of your
    data (except
    storage)
    This right applies, temporarily while we look into
    your case, if you:
  • contest the accuracy of the information;
  • have objected to our processing of your
    personal data on the basis of legitimate
    interests;
  • our processing of your information is unlawful
    and you oppose the erasure of the
    information;
  • we no longer need the information, but you
    require it to establish a legal case.
    To obtain from the
    Data Controller
    restriction of the
    processing of
    personal data if
    there is a
    legitimate ground
    (right to restriction
    of processing)
    You may opt out of our use of your personal data
    for direct marketing purposes.
    To object to
    processing of
    personal data
    This right means that data subject can object at
    any time to processing of personal data concerning
    him or her which is based for the performance of a
    task carried out in the public interest or for the
    purposes of the legitimate interests pursued by the
    controller or by a third party. The controller has to
    demonstrate compelling legitimate grounds for the
    processing which override the interests, rights and
    freedoms of the data subject
    To exercise the
    right to data
    portability
    This right may be exercised if you have provided
    your data to us and the processing is carried out by
    us by automated means and on the basis either of
    Rights that you
    have Certain restrictions
    your consent, or on the basis of discharging our
    contractual obligations to you.
    To lodge a
    complaint with the
    State Data
    Protection
    Inspectorate
    www.ada.lt
    Contact us
    If you discover any inconsistency in this Privacy Notice, any security issue on
    our website, or have other questions related to the processing of your
    personal data, please contact us in a manner convenient to you using the
    contact details below:
    Mailing address: Perkūnkiemio g. 13-91, LT-12114 Vilnius
    Telephone: +37254582826
    E-mail: [email protected]
    Final provisions
    We will review this Privacy Notice at least once every two years. We will
    notify you about changes to this Privacy Notice that we consider material by
    posting a notice on the specific website. By continuing to access or use our
    content and/or services after we have posted such notice you agree to be
    bound by the new terms set out in the update.
    Approved by Order No [03-23] issued by the Managing Director on [23] [03]
    2018.
    Last reviewed [17] April 2020.