Privacy Policy

This Policy details the objective to protect the privacy of individuals using the products and services of Foxpay Ltd (Company Code: 302455836). This policy covers not only the circumstances of users visiting the Company’s website, but also the cases when individuals use the Company’s terminals (Foxbox), money transfer services (Foxpay Bank Link), payment transactions, and related (Foxpay) e-wallet services, as well as query submissions.
If you have any questions regarding this Policy or have any requests regarding the processing of your personal data, please email us at foxpay@foxpay.lt.

Policy Contents:

  1. I. Processing of personal data when using Foxbox terminals, Foxpay Bank Link services, and Foxpay services;
  2. II. Processing of personal data for the prevention of money laundering and terrorist financing;
  3. III. Processing of personal data in terms of query submissions;
  4. IV. Processing of personal data on the website www.foxpay.lt.

I. Processing of personal data when using Foxbox terminals, Foxpay Bank Link services, and Foxpay services


Foxpay Ltd processes your personal data in the following cases: when you use Foxbox terminals to pay bills or purchase certain services; when you are redirected to the Foxpay Bank Link window when shopping online; or when you use Foxpay services on your Foxpay account or the Foxpay app. In the cases specified, we are the controllers of your personal data.

We request access to your personal data only to the extent necessary for the conclusion of the contract and the provision of a specific service. Failure to provide some of the requested data may result in the service being refused. We process your personal data only to conclude the order (payment transfer/order) submitted by you or to conclude and implement a contract.

The recipients of the data you provide are the following: the specific service providers whose services you purchase at the Foxbox terminals or the respective e-stores; or the payees to whom the payment transaction is made out; and the payee’s payment service providers. Please note that some data recipients are located outside the European Economic Area (EEA) in countries such as the United States, Ukraine, and Belarus. Data is transferred to these countries only following your instruction, i.e. in order to fulfil your order or contract (make a payment transfer/order).
Foxpay Ltd has the right to contract data processors to process your personal data. Such processors include: data centre companies; advertising and marketing companies; companies building, providing, maintaining, and developing software; companies providing informational technology infrastructure services; communications companies; cloud service companies; consulting companies; and other service providers to whom your personal data is disclosed only to the extent necessary for the provision of services, conclusion of contracts, fulfilment of contractual obligations and legal obligations (duties) that are established by the legislation. The specified service providers may be established outside the European Economic Area (EEA), such as the United States.
The Company stores your personal data for 5 years after providing the payment service or 10 years after the end of the contractual relationship, unless the legislation provides for longer storing periods for such data.
When your personal data is processed for the purpose of providing the above services, you have the following rights with regards to your personal data:

  • the right to request that Foxpay Ltd allow access to the processed personal data;
  • the right to request the rectification of incorrect or inaccurate data;
  • in cases where the data is processed illegally, the right to request data erasure or the restriction of processing;
  • the right to lodge a complaint with the supervisory authority.
  • You can exercise your rights by contacting Foxpay Ltd in one of the following ways: by visiting our office at Konstitucijos Ave 26, Vilnius or by sending an e-mail to: foxpay@foxpay.lt.

II. Processing of personal data for the prevention of money laundering and terrorist financing


Foxpay Ltd is the controller of your personal data in cases where the provisions of the legislation of the Republic of Lithuania on the Prevention of Money Laundering and Terrorist Financing (hereinafter – the Legislation) apply before starting a business relationship and/or providing services to you. The legislation mandates of us to take action in certain cases and to identify and verify the identity of the customer and the beneficiary (as an example, such case could include an amount exceeding EUR 600 being transferred in cash daily). Therefore, the processing of your personal data for this purpose is necessary in order to fulfil our legal obligation.
Generally, you provide personal data to us directly. However, Mokėjimo Terminalų Sistemos Ltd has the right to identify the customer without their direct participation, using the information about the customer stored in financial institutions and other legally bound entities under the Legislation.
Your personal data may be transferred to the Financial Crime Investigation Service under the Ministry of Internal Affairs of the Republic of Lithuania and to other financial institutions operating in the European Economic Area and outside it in accordance with the procedure and in cases established by law. Mokėjimo Terminalų Sistemos Ltd makes reasonable efforts to ensure that your data is not lost, misused, or disclosed, including in countries where legal standards for personal data protection are different from those in the Republic of Lithuania.
Foxpay Ltd has the right to contract data processors to process your personal data. Such data processors include the following: data centre companies; companies and persons providing programming services; companies building, providing, maintaining, and developing software; companies providing informational technology infrastructure services; communications companies; and other service providers to whom your personal data is disclosed only to the extent necessary to provide the services or to fulfil the legal obligations.
Your personal data is stored in accordance with the requirements of the Legislation, i.e. 8 years from the end date of transactions or business relationships with the client. In some cases, your data is stored for a shorter period of time, e.g. business correspondence with a customer is stored for 5 years.
When your personal data is processed for the purposes of preventing money laundering and terrorist financing, you have the following rights with regards to your personal data:
the right to request that Foxpay Ltd allow access to the processed personal data;
the right to request the rectification of incorrect or inaccurate data;
in cases where the data is processed illegally, the right to request data erasure or the restriction of processing;
the right to lodge a complaint with the supervisory authority.
You can exercise your rights by contacting Foxpay Ltd in one of the following ways: by visiting our office at Konstitucijos Ave 26, Vilnius or by sending an e-mail to: foxpay@foxpay.lt.

III. Processing of personal data in terms of query submissions;


Foxpay Ltd also processes your data in cases when you contact us by phone, e-mail, or submit queries on the website or on social networks. Additionally, when you visit our office to apply for a refund on an incorrect payment, for change, or any other matter. In the specified cases, Foxpay Ltd is the controller of your personal data.
Foxpay Ltd processes your data in these cases in order to administer queries and complaints, to ensure the service quality, to protect and defend their rights and legitimate interests. You consent to provide us with your data by actively engaging with us, i.e. by contacting us.
Foxpay Ltd has the right to contract data processors to process your personal data. Such data processors include the following: call centre service providers; real-time website communications service provider; data centre companies; internet browsing or internet activity analysis and service companies; advertising and marketing companies; companies building, providing, maintaining, and developing software; companies providing informational technology infrastructure services; communications companies; and other service providers to whom your personal data is disclosed only to the extent necessary for the provision of their services.
Please note that the real-time communications service provider on our website is JivoSite Inc., a company established in the United States. We remind you that in non-European Economic Area (EEA) countries, personal data may benefit from less protection than in EEA countries. The current EU-wide decision to ensure an adequate level of protection when transferring data to the US does not cover all US-based companies without exception (nor does it cover this particular service provider). There are also no adequate safeguards in place for this particular service provider within the sense of the Data Protection Regulation. People visiting our website who do not wish their personal data to be processed through this provider should not use the real-time communications platform (Jivochat), but contact us in any other manner (e-mail, telephone).
Your personal data is stored to realise our legitimate interest in gathering evidence of the services provided and the contact had for the following time periods, depending on the type of data:
telephone conversation recordings made when you contact us via the single telephone number are stored for 3 months;

  • communication and data received via email are stored for 12 months;
  • queries submitted via options on our website are stored for 12 months;
  • paper data you received when visiting our office are stored for 5 years.

When your personal data is processed in order to administer queries and complaints and to ensure the service quality, you have the following rights with regards to your personal data:
the right to request that Foxpay Ltd allow access to the processed personal data;
the right to request the rectification of incorrect, inaccurate, or incomplete data;
in cases where the data is processed illegally, the right to request data erasure or the restriction of processing;
the right not to consent to the processing of your personal data, except to the extent necessary in accordance with legal requirements;
the right to request the transfer of your personal data to another data controller or to have the data provided to you directly in a convenient form (applies to personal data provided by the data subject and processed with consent by automated means);
the right to lodge a complaint with the supervisory authority.
You can exercise your rights by contacting Foxpay Ltd in one of the following ways: by visiting our office at Konstitucijos Ave 26, Vilnius or by sending an e-mail to: foxpay@foxpay.lt.

IV. Processing of personal data on the website www.foxpay.lt


When you visit the Company’s website, Foxpay Ltd may process your IP address, network and location data, when they are provided. Data is collected with the use of cookies and other similar technologies with the user’s consent (for more information on the objectives, methods, and data storing period for such data processing, please see our Cookie Policy). In the cases specified, we are the controller of your personal data.
In addition, certain technical data of your visit to the website (e.g. IP address, cookies, technical information of your browser, and other information related to browser activities and website navigation) may be sent to or made available for entities both in the European Economic Area and outside it for statistical, analytical, and related purposes (e.g. when we use the Google Analytics service, this entity would be a U.S.-based company). Please note that in non-EEA countries, personal data may benefit from less protection than in EEA countries. However, we carefully assess the conditions under which your data is further processed and stored if they are transferred to the above entities.
Please note the fact that during each visit to the Company’s website, third parties may collect various technical information generated during your visit (e.g. IP address, cookies, technical information of your browser, and other information related to browser activities and website navigation).
Foxpay Ltd also uses services provided by third parties (e.g. servers provided by third parties, website design, administration services, analysis of web traffic and website browsing, statistics), the proper provision of which may require access to website visitor data. In this case, we ensure that data processors respect their obligations of confidentiality and proper protection of personal data.
Website visitors are granted certain rights related to the protection of their personal data:

  • the right to request that Foxpay Ltd allow access to the processed personal data;
  • in cases where the data is processed illegally, the right to request data erasure or the restriction of processing;
  • the right not to consent to the processing of your personal data;
  • the right to request the transfer of your personal data to another data controller or to have the data provided to you directly in a convenient form (applies to personal data provided by the data subject and processed with consent by automated means);
  • the right to lodge a complaint with the supervisory authority.

You can exercise your rights by contacting Foxpay Ltd in one of the following ways: by visiting our office at Konstitucijos Ave 26, Vilnius or by sending an e-mail to: foxpay@foxpay.lt.