UAB Wallter, Lvovo str. 25-140, Vilnius LT-09320, Lithuania, email firstname.lastname@example.org (“we” “Wallter” or “WLT”) is acting as the data controller with respect to data collected via this website or otherwise obtained and processed by us and is committed to protecting your information and respecting your privacy. Wallter website and client onboarding procedure are both operated together with other Wallter group entities located in UK, Israel and Romania. These entities operate as data processors and act strictly upon WLT instructions.
We agree, if so requested, to notify you of:
We may collect and process the following data about you:
In order to fulfill our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies, including your financial history, county court judgments and bankruptcies, credit reference and fraud prevention agencies when you ask to open a WLT Account and at any time when we feel it is necessary to prevent fraud and minimize our financial risks or if we need to comply with the regulator’s request. Please refer to our Money Laundering Policy for further details.
We use information held about you in the following ways:
The data that we collect from you may be transferred to and stored at destinations outside the European Economic Area ("EEA") for the reasons set out below:
We are by law required to retain certain records for a period of at least five years (8 years in some cases) after closure of your WLT Account which will include your personal data such as your name, contact details, customer number and transaction history etc. Otherwise, we will delete and destroy all personal data that we hold about you when you (or we) terminate your WLT Account. We do not store your online banking login PIN, TAN and password. For more specific retention terms, please contact us directly.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries who are based in different countries. This may be necessary in order to, among other things, fulfill your request, process your payment details, provide support services and monitor fraudulent activities.
Other Wallter group companies acting as our data processors are located in UK, Israel and Romania. These entities operate as our data processors and act strictly upon WLT instructions. For a comprehensive list of our group entities and their requisites, please use “Support” section of our Website.
When sending money to another WLT Account holder or a merchant who you wish to pay we will, at a minimum, pass on your email address to the recipient. Depending on the requirements of the merchant and the type of payment involved, we may also send other personal details such as your name, address and country of residence if the recipients request this information from us in order to improve the payment process, to reconcile payments with the commercial transaction or to conduct their own anti-fraud and anti-money laundering checks.
When you open a WLT Account, at intervals of up to every 3 months and at any other time we feel it is necessary to do so to protect our financial interests and prevent money-laundering or fraud, we share certain information about you and your WLT Account, financial history and transactions as part of our normal business operations with our banks, payment facilitator partners, credit/debit card processing services, identity verification service providers and credit reference agencies to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk. We can provide you with a list of the credit reference agencies we use upon your written request to the email address set out in the Contact Us section below. When conducting identification or fraud prevention checks, the relevant parties may retain a record of our query along with your information and may share this information with other fraud prevention agencies. If you want to know what information these companies hold about you, you can write to them to request access to your information.
Please refer to our Money Laundering Policy for further details.
We may contact you by email to the primary email address registered with your WLT Account or by telephone to the contact telephone numbers you have provided when registering for your WLT Account. You can change your primary email address and/or contact telephone number at any time, subject to the provisions of section 8 below.
You may also receive system-generated transactional emails such as confirmation of uploads, notification of receipt of payments, notification of password changes etc. which are necessary for the proper operation and administration of your account.
As a WLT Account holder, you will occasionally receive information by email from us, unless you have chosen not to receive such communication, and if you have consented to do so from our group companies too, about products, services and special deals which we think will be of interest to you via our newsletter. You can change whether or not you receive newsletters from us and our group companies in the “Profile” section of your WLT Account or in any newsletter email by clicking on the appropriate ‘opt-out’ link. Please note that you will still receive communication regarding your WLT Account such as transactional emails or other notification affecting the operation of your WLT Account or our legal relationship. From time to time we do share aggregated information about our customers’ use of our Website and services with other companies for research and analysis purposes, but you cannot be identified from this aggregated information.
Phishing is the name given to attempts to steal personal details and financial account details from a website user.
“Phishers” use fake or “spoof” emails to lead users to counterfeit websites where the user is tricked into entering their personal details, such as credit card numbers, user names and passwords. WE WILL NEVER SEND EMAILS ASKING YOU FOR SUCH DETAILS AND OUR STAFF WILL NEVER ASK YOU FOR YOUR PASSWORD.
If you do receive such an email or are asked for your password by anyone claiming to work for us please forward the email or report the incident by email to our Data Protection Officer (contact details are at the end of this policy) or by contacting Customer Services via the “Support” section of the Website.
A cookie is a small amount of data which contains information that is downloaded to the device from which you access our site. Cookies are useful because they allow us and other websites to recognize your device. For more comprehensive information about how cookies work, see http://www.allaboutcookies.org.
Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For example, they can allow you to navigate between web pages of our site and remember your preferences such as your language selection.
• Strictly necessary – these are cookies that are essential for our Website to operate such as those which identify you so you can log into your WLT Account. They allow you to move around our Website and use the services you have requested. These cookies will be activated when you enter our Website and as you use our Website.
• Measurement / Statistics - these cookies help our Website to understand how visitors interact with the websites by collecting and reporting information anonymously. These cookies will only be placed on your end-device, if you consent. You can accept or reject cookies using browser settings or our cookie pop-up tool (see Managing cookies for more information).
• Targeting & Advertising / Marketing – these cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. These cookies will only be placed on your end-device, if you consent. You can accept or reject cookies using browser settings or our cookie pop-up tool. (see Managing cookies for more information).
You can manage your cookies in two ways: 1) by adjusting your browser settings (please see section 9.4 below); or 2) by using our cookie pop-up tool. Once you open our Website a cookie pup-up shall appear informing you about the cookies on our Website and from the pop-up you will be able to access a panel that allows you to customize your cookies consent preferences. Please select the most appropriate options for yourself. You will always be able to redact you initial cookie preferences by clicking on the green widget in the bottom right of the Website.
We have a legal obligation to ensure that your personal data is kept accurate and up to date. We kindly ask you to assist us to comply with this obligation by ensuring that you inform us of any changes that have to be made to any of your personal data that we are processing.
Right to access: you have the right to request access to any data that can be considered your personal data. This includes the right to be informed on whether we process your personal data, what personal data categories are being processed by us, and the purpose of our data processing;
Right to rectification: you have the right to request that we correct any of your personal data if you believe that it is inaccurate or incomplete;
Right to object: you are entitled to object to certain processing of personal data, including for example, making automated decisions based on your personal data or when we otherwise base the processing of your personal data on our legitimate interest;
Right to restrict personal data processing: you have the right to request that we restrict the processing of your personal data if you wish to: (i) object the lawfulness of the processing; (ii) fix unlawful processing of personal data; (iii) receive or avoid deletion of personal data for establishing or defending against legal claims; or (iv) demand restriction of the processing until assessing the plausibility of Wallter’s legitimate interest in the specific processing activity;
Right to erasure: you may also request your personal data to be erased if the personal data is no longer necessary for the purposes for which it was collected, or if you consider that the processing is unlawful, or if you consider that the personal data has to be erased to enable us to comply with a legal requirement;
Right to data portability: if your personal data is being automatically processed with your consent or on the basis of a mutual contractual relationship, you may request that we provide you that personal data in a structured, commonly used and machine-readable format. Moreover, you may request that the personal data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible;
Right to withdraw your consent: in cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time without any adverse effect;
Right to submit your claim with the supervisory authority: if you are not satisfied with our response to your request in relation to personal data or you believe we are processing your personal data not in accordance with the law, you can submit your claim with the supervisory authority in your country of residence or to the lead supervisory authority – the Lithuanian State Data Protection Inspectorate at www.ada.lt.
Please note that you will need to provide sufficient information for us to handle your request regarding your rights. Prior to answering your request, we may ask you to provide additional information for the purposes of authenticating you and evaluating your request.