PRIVACY POLICY

This Privacy Policy describes what personal data eComCharge UAB (“the Company”, “we”, or “us”) collects and how we use (process) them, with whom we share our clients and visitors („you“) personal data, which we collect when you browse our https://begateway.com/ website (“the Website”), or when you choose to contact us or provide us with your personal data through the Website.

WHO WE ARE

UAB eComCharge is a technology company that builds white label software, cloud payment processing systems, and transaction management tools for Payment Service Providers, Acquiring Banks and other kinds of payment businesses.
We respect the privacy of our clients as well as potential customers and visitors to our Website and we are committed to protecting it through this Privacy Policy. Please, take some time and read through the Privacy Policy and get acquainted with the terms and conditions of processing your personal data and information about your privacy rights. If you provide personal data on behalf of someone else, you are required to inform them about the processing of their data and to refer them to this Privacy Policy. Do not hesitate to contact us if you have any questions regarding the processing of your personal data or the exercise of your rights. This Privacy Policy applies to our website and communication with eComCharge. In case you are a customer of eComCharge and are using specific services and solutions from our company, there may be additional documentation regarding privacy which specifies the processing of personal data for those specific solutions. Additionally, for this website there Cookie policy which specifies detailed information about cookies that can be accessed in the cookie banner.

Data controller

UAB eComCharge, a company incorporated and registered under the laws of Lithuania, with legal entity code 306090057, having its registered office address at Juozo Balčikonio g. 3, LT-08247 Vilnius, Lithuania, is the data controller of your personal data. You can contact our company regarding any questions related to your data protection and privacy using the email address below or write a message on our webpage with the topic “Personal data related request” Our contact e-mail address is support@ecomcharge.com.

HOW WE USE YOUR PERSONAL DATA?

We will only collect and process your personal data when the law allows us to. Most commonly, we will collect and process your personal data in the following circumstances:

• When we need to perform the contract, we have entered with you or we are about to enter into and we need to take certain steps at your request.
• When we need to comply with a legal or regulatory obligation.
• When it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• When you consented to data collection and processing for a particular purpose.

WHAT PERSONAL INFORMATION DO WE PROCESS?

The personal data we process (collect, use, store and share, etc.) about you depends on who you are and how we interact with you: whether you are just a regular visitor to our Website, or whether you apply for a job position at our Company, contacting us about services, solutions or any other questions. When we refer in this Privacy Policy to “personal data” we are referring to data about you (or another natural person) from which you could be identified directly or that makes you identifiable indirectly by one or more factors related and specific to you such as your name, your contact details, online identifier and even your IP address.

If you are a Corporate Client

When you wish to cooperate with us, you must fill in the Registration form on our Website. For such reason, we are collecting and processing the personal data you provided for us on the Registration form:

• Your name (first name, last name)
• Company name
• Company address
• Phone number (WhatsApp)
• E-mail address
• Country of incorporation
• Technical data (IP address, location, device, browser, etc.)

The purpose of processing – provision of services
The legal basis for processing – the performance of the contract between us and you as a Corporate Client or the necessity to take steps at your request before entering into a contract.
The period of data storage is 10 years after ceasing the use of our services in case the contract is signed or one year if there are no further actions and services agreed upon after submission of the contact form.

If you communicate with us

When you contact us by corresponding with us, including via e-mail and Website, to answer your requests and provide you with the technical support we may process:

• Your name (first name, last name)
• Company name
• Address
• E-mail address
• Phone number (WhatsApp)
• Country of incorporation
• Business Type
• Other personal information you provide in your communication with us or is necessary to respond to your request
• Technical data (IP address, location, device, browser, etc.) if you communicate through electronic means

The purpose of processing is to answer Client questions and requests while providing support and improving the quality of our services.
The legal basis for processing is the performance of the contract between us and you as a Corporate Client or the necessity to take steps at your request before entering into a contract or legitimate interest of the Company.
The period of data storage is 180 days after the request is solved.

If you file a complaint with us

When you file any complaint in connection with our services we are obliged to handle the complaint and we must therefore process the:

• Your name (first name, last name)
• Company name
• Date of the complaint
• Phone number
• E-mail address
• Other personal information you provide in your complaint
• Technical data (IP address, location, device, browser, etc.) if your complaint is submitted by electronic means

The purpose of processing is to handle Clients’ complaints.
The legal basis for processing is to comply with legal obligations.
The period of data storage is 1 year from the date of the final reply to the complainant.

If you are applying for an open position in the Company (Recruitment process)

The Company is constantly growing and has open positions in the Company. If you are applying for a job at our Company in response to a job advert, whether advertised on a Company’s profile on LinkedIn or you were recommended by a third person (e.g. by current employees of the Company), we shall process personal data of job applicant and potential candidates for employment to assess the suitability of the candidate for a particular position you are applying for. During the recruitment process, we may process the data that you provide us with your resume or application and/or we receive from other sources (e.g. recommendations from your previous employers):

• Your name (first name, last name)
• Contact details (phone No., email address)
• Education
• Work experience
• Professional experience (certificates)
• Other information that you provide on your resume and cover letter (including but not limited to photograph, date of birth, residential address, etc. which are not mandatory and provided by sole intention of the applicant)
• Recommendations from previous employers
• Results/findings of the interview with the candidate
• Communication with the candidate
• Technical data (IP address, location, device, browser, etc.) if your complaint is submitted by electronic means

The purpose of processing is identifying and evaluating candidates for potential employment (assessing his/her suitability for a particular position) and contacting candidates.
The legal basis for processing is your consent (by applying for a particular position in the Company and sending your resume and other documents to us).
The period of data storage is until the recruitment process is completed, but not longer than 1 year from the date of your consent.

Direct marketing

We may engage in various marketing activities and try to improve our Services and user experience. We need to know what Services are or could be most interesting and useful for our clients, from which countries they come to our Website, how often they return, which browsers they use, on which devices the Website is browsed, and what is their IP address. We may collect that data by using third-party tools such as cookies and other technologies (e.g. Google Analytics or similar ones), which allow us to record and analyze statistical data about the use of the Website and/or our Services. Please see our Cookie Policy for further details.

If you are a visitor to our Website

As you visit or interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, session logs and other similar technologies. For this, we also may use Google Analytics tool, which lets us to collect and analyze the relevant data. You can learn more about how Google Analytics works and the information it allows us to collect and analyze here.

We use cookies to improve our Website and make your browsing experience and our business decisions better. Please see our Cookie Policy for further details. Other data collected for users browsing our website through electronic means (PCs, tablets, smartphones and any other applicable devices):

• IP address
• Your location (region you came from to our Website)
• Your device you are browsing from and the browser you use
• What content you are interested in on our Website (the sites you visit and the content you read)
• Referrer website (the website that linked you to our website, if any)

The purpose of processing is to allow the correct functioning of our webpage and to improve our Website and users’ experience.
Legal basis for processing – our legitimate interest (IT security, marketing) and your consent for processing data for a particular purpose (e.g. the use of cookies).
The period of data storage – depends on the technologies used for data collection.

If you do not provide us with your personal data

In case we need to process personal data by legal obligation or under the terms of a contract we have entered with you (or if we need to take steps at your request before entering into a contract) and you do not provide us with this personal data, we may not be able to comply with legal requirements and provide our services to you or will not be able to conclude and execute a contract with you.

Links to other sites

Our Website may contain links to other sites, e.g. links to social media websites such as our LinkedIn (https://www.linkedin.com/company/ecomcharge/) and Meta (Facebook) (https://www.facebook.com/eComCharge) accounts. This Privacy Policy is applicable only concerning our Website, therefore we strongly recommend reviewing the privacy policies of any websites that you may reach by following hyperlinks presented on our Website. We have no control and no responsibilities regarding any content or data processing by controllers of such other websites. More details on this topic are presented in the Cookie Policy.

WHO CAN WE SHARE YOUR DATA WITH?

We put our best efforts into keeping your data safe and always require a high level of security and confidentiality from our employees and partners. eComCharge UAB can transfer personal data in the cases allowed by legal acts to third parties:

• Courts, police, other legal enforcement institutions and other Government bodies such as the Tax inspectorate have a legal right to request information.

eComCharge will inform Customers (legal entities) about all such requests for information containing personal data except in cases where it is not permitted by law.

In some cases, when we provide your personal data to third parties, those third parties may process your personal data as independent data controllers. In such cases, we are not responsible for the processing of your personal data performed by such third parties.

WHERE DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data only in Lithuania — there is no data sent to other European Union countries.

WHAT ARE YOUR RIGHTS?

As a data subject, you have several rights concerning your personal data. You can exercise the rights that are mentioned further by contacting us at support@ecomcharge.com:

• The right of access. You may, at any time, request access to the personal data that we hold which relates to you and receive a copy of data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully.
• The right to rectification. You may, at any time, request us to correct personal data that we hold about you that you believe is incorrect. We may ask you to verify any new data that you provide to us and may take our steps to check that the new data you have supplied us with is correct.
• The right to erasure (“right to be forgotten”). You may also ask us to erase personal data if you do not believe that we need to continue retaining it. We are not always obliged to erase personal data when asked to do so; if, for any reason, we believe that we have a good legal ground to continue the processing your personal data that you have asked us to erase (e.g. your personal data is still processed for other legitimate purposes or we have to comply with a legal obligation or for the establishment, exercise or defence of legal claims). If personal data is erased under your request, we will only retain such copies of the information as are necessary for us to protect our or third parties’ legitimate interests, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement you have entered into with us.
• The right to restrict processing in those situations when the processing of your personal data is based on our legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts your fundamental rights and freedoms or if you feel that those legitimate interests are not valid. You may also ask us to stop processing your personal data in these situations:
  (i) If you dispute the accuracy of personal data we are processing and want us to verify that data’s accuracy.
  (ii) Where it has been established that our use of the data is unlawful but you do not want us to erase it.
  (iii) Where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it to enable you to establish, exercise or defend legal claims.
• The right to data portability. You can ask us to provide you or transmit those data directly to another controller of your choice, where technically feasible, certain personal data that we hold about you in a structured, commonly used machine-readable format. However, you must keep in mind that you may exercise the right of data portability only on data that is processed based on your consent or the performance of a contract between you and us and that is being processed by automated means. We can guarantee only transferring data to you on such occasions and cannot be responsible for the technical compatibility of other party systems where data transfer is requested.
• The right to withdraw consent regarding the processing of personal data.  You may withdraw your given consent for processing of personal data for particular purposes at any time by informing us at email support@ecomcharge.com or following the procedure that was specified before obtaining your consent.
• The right to object (to automated decision-making and profiling). You have the right to be informed about the existence of any automated decision-making and profiling of your personal data and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
• The right to complain to a supervisory authority. If you think that your rights have been violated, you may file a complaint to a State Data Protection Inspectorate (L. Sapiegos str. 17, LT-10312 Vilnius, phones: +370 5 271 2804 / 279 1445, fax +370 261 9494, email ada@ada.lt) or any other EU country data protection regulator of your choice.

How can you exercise your rights?
You can submit a request by sending it by mail or e-mail. The request must provide sufficient details that allow us to properly understand, evaluate, and respond to it (should be clear, include your name, information about what rights and to what extent you wish to exercise, and how you would like to receive a response and the request must be signed). If you submit your application electronically, the information will also be provided electronically, unless you request in advance to provide it in a different way.

Your request must also provide sufficient information that allows us to reasonably verify you are the person or an authorized representative of a person whose personal data we are processing. If your request is submitted by an authorized representative, a written authorization (power of attorney) and information that verifies the identity of the representative must be enclosed with the request.
We cannot provide you with the information or exercise your other rights if we cannot verify your identity. If we cannot identify you from the information provided or if we have reasonable doubts about your identity, we may request you to provide additional information about yourself.

We will endeavour to process your requests and provide you with the information as soon as possible, but no later than 30 calendar days from the date of receipt of your request. If due to certain circumstances, such as the complexity of the submitted request (e.g. if it is necessary to seek the assistance of data processors) or the large number of other requests processed by the Company, the period may be extended up to two further months. In such case, we will inform you of any extension within one month of the receipt of your request together with the reasons for the delay.

Requests are processed and information and data are provided free of charge, but we reserve the right, in certain cases, to either waive your rights (where the request is unreasonable or disproportionate or repetitive), or the provision of information may be subject to charges – a reasonable fee taking into account the administrative costs of providing information or communication.

UPDATES OF THE PRIVACY POLICY

We may change this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Privacy Policy in the future will be posted on our Website at https://begateway.com/privacy-policy/. We may also notify you directly via our website about the changes and the effective date of the updated Privacy. We encourage you to review the information and any changes to our Privacy Policy regularly. If you continue to use our services after the effective date that will mean that you have accepted the changes.
The term “the Website” used in the provisions of this Privacy policy refers to eComCharge.com and beGateway.com.

This Privacy Policy was last updated in November 2023.