Privacy and Personal Data Management Policy
General Provisions.
This personal data processing agreement is a public contract (hereinafter referred to as the "agreement"), concluded between the owner of the digital (electronic) currency exchange service — Lightpay, (hereinafter referred to as the "Operator") and the user, in accordance with the data protection article in the British Virgin Islands, based on the Law of the British Virgin Islands on "Personal Data and Their Protection", as well as provisions of the Federal Law "On Personal Data", and applies to all information containing users' personal data that the Operator can obtain about users while they visit the service: Lightpay.
1. Basic Concepts-Terms Used in the Agreement.
1.1. Personal Data — any information related directly or indirectly to a specific or identifiable user of Lightpay service, recorded on electronic, paper, and/or any other material carrier;
1.2. Website — a collection of graphic and information materials, as well as computer programs and databases available on the Internet at the network address: lightpay.info, providing services for the exchange of title signs;
1.3. User — any visitor to the website lightpay.info;
1.4. Operator — a natural person, the owner of the digital (electronic) currency exchange service — lightpay.info/, who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
1.5. Automated processing of personal data — processing of personal data using computing technology;
1.6. Collection of personal data — actions aimed at obtaining personal data;
1.7. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons;
1.8. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting personal data with an unlimited circle of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way;
1.9. Anonymization of personal data — actions as a result of which it is impossible to identify the ownership of personal data to a specific User or another subject of personal data without the use of additional information;
1.10. Blocking of personal data — temporary suspension of the processing of personal data (except if the processing is necessary to clarify personal data);
1.11. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or as a result of which material carriers of personal data are destroyed;
1.12. Processing of personal data — any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data;
1.13. Website Services — all services available for use on the site lightpay.info;
1.14. Cookies — are small text files that the browser writes data from the sites visited by the User. Cookies perform a whole range of functions, for example, they allow the User to efficiently navigate between pages, remembering his preferences, and thus improve the user’s interaction experience with the Website. They can also help ensure that the advertising that the User sees online matches his interests;
1.15. IP address — a unique network address of a node in a computer network built according to the IP protocol, which allows determining the User’s location. The website does not track the location more precisely than the city and region;
1.16. Non-personal data — information that is automatically transmitted during viewing of advertising blocks by the User and when visiting pages on which a statistical script of the system is installed: the address of the requested page, cookie information, IP address, browser information, referrer (address of the previous page), access time;
1.17. Protection of personal data — a set of measures, including legal, organizational, and technical, carried out for the purposes established by the BVI Law "On Personal Data and Their Protection";
1.18. Transborder transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
1.2. Website — a collection of graphic and information materials, as well as computer programs and databases available on the Internet at the network address: lightpay.info, providing services for the exchange of title signs;
1.3. User — any visitor to the website lightpay.info;
1.4. Operator — a natural person, the owner of the digital (electronic) currency exchange service — lightpay.info/, who independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
1.5. Automated processing of personal data — processing of personal data using computing technology;
1.6. Collection of personal data — actions aimed at obtaining personal data;
1.7. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons;
1.8. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting personal data with an unlimited circle of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way;
1.9. Anonymization of personal data — actions as a result of which it is impossible to identify the ownership of personal data to a specific User or another subject of personal data without the use of additional information;
1.10. Blocking of personal data — temporary suspension of the processing of personal data (except if the processing is necessary to clarify personal data);
1.11. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or as a result of which material carriers of personal data are destroyed;
1.12. Processing of personal data — any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data;
1.13. Website Services — all services available for use on the site lightpay.info;
1.14. Cookies — are small text files that the browser writes data from the sites visited by the User. Cookies perform a whole range of functions, for example, they allow the User to efficiently navigate between pages, remembering his preferences, and thus improve the user’s interaction experience with the Website. They can also help ensure that the advertising that the User sees online matches his interests;
1.15. IP address — a unique network address of a node in a computer network built according to the IP protocol, which allows determining the User’s location. The website does not track the location more precisely than the city and region;
1.16. Non-personal data — information that is automatically transmitted during viewing of advertising blocks by the User and when visiting pages on which a statistical script of the system is installed: the address of the requested page, cookie information, IP address, browser information, referrer (address of the previous page), access time;
1.17. Protection of personal data — a set of measures, including legal, organizational, and technical, carried out for the purposes established by the BVI Law "On Personal Data and Their Protection";
1.18. Transborder transfer of personal data — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2. Privacy Policy.
2.1. The website respects the User’s right and observes the Privacy Policy, thereby establishing the Operator’s obligations for non-disclosure and ensuring the protection regime of the confidentiality of personal data, which the User provides at the request of the Operator when registering on the website and/or when using the Website Services.
2.2. Personal data allowed for processing under the Privacy Policy are provided by the User by filling out the registration and other forms on the Website and include the following information:
2.2.1. The User’s surname, name, patronymic;
2.2.2. Contact phone numbers of the User;
2.2.3. Email address (e-mail);
2.2.4. Details of the document proving identity, including ID number (tax identification number), year, month, date, and place of birth;
2.2.5. Photographs;
2.2.6. Photo of the front of the bank card and the name of the owner;
2.2.7. User’s phone number linked to the bank card;
2.2.8. Numbers and addresses of the User’s wallets in payment systems.
2.3. The website collects and processes anonymized data about users (including "cookie" files) using Internet statistics services (Yandex.Metrica, Google Analytics, and others). Anonymized data of Users collected with the help of Internet statistics services serve to collect information about Users' actions on the site, to improve the quality of the site and its content. The Operator processes anonymized data about the User if this is allowed in the browser settings of the User (saving of "cookies" and use of JavaScript technology is enabled). The above data are united by the general concept of Personal Data.
2.4. Any other personal information not specified above (used services, browsers, operating systems, etc.) is securely stored and not distributed, except in cases specified in clauses 4.3. and 4.4. of this Agreement.
2.2. Personal data allowed for processing under the Privacy Policy are provided by the User by filling out the registration and other forms on the Website and include the following information:
2.2.1. The User’s surname, name, patronymic;
2.2.2. Contact phone numbers of the User;
2.2.3. Email address (e-mail);
2.2.4. Details of the document proving identity, including ID number (tax identification number), year, month, date, and place of birth;
2.2.5. Photographs;
2.2.6. Photo of the front of the bank card and the name of the owner;
2.2.7. User’s phone number linked to the bank card;
2.2.8. Numbers and addresses of the User’s wallets in payment systems.
2.3. The website collects and processes anonymized data about users (including "cookie" files) using Internet statistics services (Yandex.Metrica, Google Analytics, and others). Anonymized data of Users collected with the help of Internet statistics services serve to collect information about Users' actions on the site, to improve the quality of the site and its content. The Operator processes anonymized data about the User if this is allowed in the browser settings of the User (saving of "cookies" and use of JavaScript technology is enabled). The above data are united by the general concept of Personal Data.
2.4. Any other personal information not specified above (used services, browsers, operating systems, etc.) is securely stored and not distributed, except in cases specified in clauses 4.3. and 4.4. of this Agreement.
3. Purposes of Collecting and Processing Users' Personal Data.
3.1. The Operator collects and processes the User’s personal data only in case they are filled in and/or sent by the User through special forms located on the site: lightpay.info/. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Agreement.
3.2. The Operator uses the User’s personal data for the purposes of:
3.2.1. Identifying the User when registering on the website for the execution of services on the website;
3.2.2. Processing and receiving payments from the User;
3.2.3. Fulfilling the Operator’s obligations to the User;
3.2.4. Providing the User with effective customer support;
3.2.5. Providing the User with personalized Services;
3.2.6. Communicating with the User, including sending notifications, requests, and information regarding the use of Services, provision of services, as well as processing requests and applications from the User;
3.2.7. Improving the quality of Services, the convenience of their use, developing new Services and services;
3.2.8. Informing the User about the events and promotions being conducted;
3.2.9. Conducting statistical and other studies based on anonymized data, as well as optimizing advertising messages;
3.2.10. For the purposes of identification (verification) of Users within the framework of combating the legalization (laundering) of proceeds from crime and financing terrorism.
3.2. The Operator uses the User’s personal data for the purposes of:
3.2.1. Identifying the User when registering on the website for the execution of services on the website;
3.2.2. Processing and receiving payments from the User;
3.2.3. Fulfilling the Operator’s obligations to the User;
3.2.4. Providing the User with effective customer support;
3.2.5. Providing the User with personalized Services;
3.2.6. Communicating with the User, including sending notifications, requests, and information regarding the use of Services, provision of services, as well as processing requests and applications from the User;
3.2.7. Improving the quality of Services, the convenience of their use, developing new Services and services;
3.2.8. Informing the User about the events and promotions being conducted;
3.2.9. Conducting statistical and other studies based on anonymized data, as well as optimizing advertising messages;
3.2.10. For the purposes of identification (verification) of Users within the framework of combating the legalization (laundering) of proceeds from crime and financing terrorism.
4. Rights and Obligations of the Parties
4.1. The User is obliged to:
4.1.1. Provide information about personal data necessary to use the website;
4.1.2. Update, supplement the provided information about personal data in case of changes in this information;
4.1.3. Stop using the website if they disagree with the terms of this Agreement.
4.2. The User has the right to:
4.2.1. Access and edit their personal data information at any time through the web interface provided as part of the services;
4.2.2. Refuse to receive informational messages by sending the Operator a letter to the email address lightpay.info with a note "Refusal from notifications of new products and services and special offers";
4.2.3. Withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator’s email address officelightpay@gmail.com with a note "Withdrawal of consent to the processing of personal data".
4.3. The Operator is obliged to:
4.3.1. Use the information received exclusively for the purposes specified in section 3 of this agreement;
4.3.2. Ensure the storage of confidential information in secret, not to disclose without the prior written permission of the User the transmitted personal data, except for the transfer of data to authorized state authorities of the British Virgin Islands in the manner prescribed by the law of the BVI;
4.3.3. Take precautions to protect the confidentiality of the User’s personal data according to the order usually used for protecting such information.
4.4. The Operator has the right to:
4.4.1. Provide access for collecting and analyzing non-personal data of Users to third parties for the purposes of statistics and optimization of advertising messages. The use of non-personal data by third parties is regulated by their own privacy policies, and the website is not responsible for their use.
4.1.1. Provide information about personal data necessary to use the website;
4.1.2. Update, supplement the provided information about personal data in case of changes in this information;
4.1.3. Stop using the website if they disagree with the terms of this Agreement.
4.2. The User has the right to:
4.2.1. Access and edit their personal data information at any time through the web interface provided as part of the services;
4.2.2. Refuse to receive informational messages by sending the Operator a letter to the email address lightpay.info with a note "Refusal from notifications of new products and services and special offers";
4.2.3. Withdraw their consent to the processing of personal data by sending the Operator a notification by email to the Operator’s email address officelightpay@gmail.com with a note "Withdrawal of consent to the processing of personal data".
4.3. The Operator is obliged to:
4.3.1. Use the information received exclusively for the purposes specified in section 3 of this agreement;
4.3.2. Ensure the storage of confidential information in secret, not to disclose without the prior written permission of the User the transmitted personal data, except for the transfer of data to authorized state authorities of the British Virgin Islands in the manner prescribed by the law of the BVI;
4.3.3. Take precautions to protect the confidentiality of the User’s personal data according to the order usually used for protecting such information.
4.4. The Operator has the right to:
4.4.1. Provide access for collecting and analyzing non-personal data of Users to third parties for the purposes of statistics and optimization of advertising messages. The use of non-personal data by third parties is regulated by their own privacy policies, and the website is not responsible for their use.
5. Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing.
5.1. The Operator stores only those personal data that are necessary for the provision of the Website’s Service.
5.2. The personal data of Users are processed exclusively by the Operator, are stored exclusively on electronic media located on a server in Estonia, where appropriate protection of personal data is ensured, hence there is a transborder transfer of Users' personal data.
5.3. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
5.4. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
5.5. The term for processing personal data is unlimited.
5.2. The personal data of Users are processed exclusively by the Operator, are stored exclusively on electronic media located on a server in Estonia, where appropriate protection of personal data is ensured, hence there is a transborder transfer of Users' personal data.
5.3. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
5.4. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
5.5. The term for processing personal data is unlimited.
6. Other Conditions.
6.1. The use of the website by the User implies their agreement with the content of this agreement, the privacy policy specified in this Agreement, the conditions for processing and storing Users' personal data, and the transborder transfer of the User’s personal data.
6.2. This Agreement applies only to the site lightpay.info/. The website is not responsible for third-party sites to which the User can click on links available on the website.
6.3. Disabling Cookies may lead to the impossibility of accessing parts of the website requiring authorization.
6.4. The website collects statistics about the IP addresses of its Users. This information is used to identify and solve technical problems, to control the legality of conducted financial payments.
6.5. The current legislation of the BVI applies to this Agreement and the relationship between the User and the Operator.
6.6. The Operator reserves the right to unilaterally amend this Agreement for further improvement of the system of security in accordance with the current legislation of the BVI.
6.7. All suggestions or questions regarding this Agreement should be reported to the Operator’s email address: officelightpay@gmail.com.
The current version of the Agreement is freely accessible on the Internet at the address: lightpay.info/
6.2. This Agreement applies only to the site lightpay.info/. The website is not responsible for third-party sites to which the User can click on links available on the website.
6.3. Disabling Cookies may lead to the impossibility of accessing parts of the website requiring authorization.
6.4. The website collects statistics about the IP addresses of its Users. This information is used to identify and solve technical problems, to control the legality of conducted financial payments.
6.5. The current legislation of the BVI applies to this Agreement and the relationship between the User and the Operator.
6.6. The Operator reserves the right to unilaterally amend this Agreement for further improvement of the system of security in accordance with the current legislation of the BVI.
6.7. All suggestions or questions regarding this Agreement should be reported to the Operator’s email address: officelightpay@gmail.com.
The current version of the Agreement is freely accessible on the Internet at the address: lightpay.info/