Limtz

Privacy Policy

Privacy Policy


This Privacy Policy describes the privacy practices for the Website operated by ‘Limtz’ trading name of QubeCard Issuing Ltd, Company Number: 623329, Unit 1, CHQ Building, Custom House Quay, Dublin 1, D01 Y6H7, Ireland (hereinafter "Website" if singular, or, "Websites") and how the Website operated by Limtz collect and use the personal data you provide on the Website, with the purpose to use Limtz Services. It also describes the choices available to you regarding our use of your personal information and how you can access, update and delete this information.

Caen Suffield (legal@limtz.com) is the designated representative of Limtz in EU in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of personal data (the “GDPR”).

The use of the Website is possible without any indication of personal data; however, if a user wants to use Limtz prepaid card programme management services via our Website, collecting and processing of personal data could become necessary. If the processing of personal data is necessary we generally obtain consent from the user as a data subject.

The processing of personal data, such as the name, address, e-mail address, telephone number or billing information of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Limtz (RoI). By means of this Privacy Policy, we would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects (users) are informed, by means of this Privacy Policy, of the rights to which they are entitled. As the controller, Limtz has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this Website.

In this Privacy Policy “Limtz”, “we”, “us” and “our” means QubeCard Issuing Ltd.

DEFINITIONS

Personal data means any information relating to an identified or identifiable natural person (“data subject/user”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject/user is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing; a user to the Limtz software.

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject/user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Encryption is a security protection measure for personal data; as a form of cryptography, it is a process whereby personal data gets turned into an encoded and unintelligible version, using encryption algorithms and an encryption key, and whereby a decryption key or code enables users to decode it again.

Consent of the data subject/user is any freely given, specific, informed and unambiguous indication of the data subject/user`s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection.

INFORMATION COLLECTION AND USE

Anyone can access our Website without necessity to provide its personal data.

The purpose of processing your personal data by Limtz and collection of information about you are as follows (the “Purpose”):

  • Your intention to use our Service;

  • In order for Limtz to provide the user with the ordered and purchased Service;

  • For verifying your identity and providing customer care service and assistance;

  • Analyse your use of our Website and services to better understand how they are being used so we can improve our service and the user experience and engage and retain users.

As you are willing to use our services you are required to provide your personal data (to register an account and purchase a software), thus becoming a user of Limtz.

With this Purpose we collect and process two types of information: (1) aggregate (meaning collective data that relates to a group or category of customers) tracking and Website usage information that we gather automatically as you access our Website, as (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our Website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Website, (6) the Internet service provider of the accessing system, (7) data provided by Google Analytics, Facebook pixels, Adwords pixels, Google Tech Manger, Zendesk and Zopim systems, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our Website correctly, (2) optimize the content of our Website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and Website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, we analyze anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject (depersonalization), and (2) personal data that you supply voluntarily subject to your consent when you place an order for any subscription plan of Limtz software.

Please be aware that you are not obliged to provide us with your personal data. However, if you do not provide us with your name and email address, you may not be able to create an account to log in to and make a purchase of Limtz software, consequently, to use our services.

PERSONAL DATA COLLECTION AND USE

We strive to be compliant with GDPR and implemented data minimization principle. Personal data, as defined above, which we collect, consist of:
(i) full name (first and last), (ii) e-mail address, providing the data subject with the ability to register an account and become a user of our services with the purpose to use the Limtz software correspondingly, (iii) billing information, which includes full address, zip code, city, country, telephone number (not mandatory), (iv) payment method (not full credit card number and expiration date), (v) IP address – assigned by the Internet service provider (ISP) and used by the data subject/user, and (vi) location data – for statistics of user’s areas involvement.

The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses.

Insofar as, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The personal data entered by the data subject/user are collected and stored exclusively for internal use by the controller and for his own purposes. The personal data stores separately in Limtz data base to avoid data subject identification by using depersonalization features in compliance with GDPR storage limitation principle.

We do not authorize the use of your personal data by any third party (only under exceptional conditions as described under "Legal Matters" below). We operate and maintain a variety of online security measures to safeguard and keep your personal information private and secured.

When you purchase Limtz software you have to fill the User’s Information, which should contain your personal information as ID (first name, last name) and email, which is processed and stored by Limtz. Based upon the personal data you provide us at registration of an account, we may send you a welcoming e-mail to verify your login and password. You may enter to your account on our Website under login and password sent to your email. All your activity in your account is password-protected, and you should keep and take all necessary measures to protect the secrecy of your password.

We will also communicate with you in response to your inquiries, regarding any information or services you request.

Our Website contains information that enables a quick electronic contact to us, as well as direct communication with us, which also includes a general address of e-mail address. If a user contacts us by e-mail or via a contact form, the personal data transmitted by this user is automatically stored. We will communicate with you by e-mail or other method chosen by you (including but not limited by telephone).

We may use your Personal data to: (a) improve your browsing experience by personalizing the Website and to improve the Service; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications relating to your use of the Service, and (d) provide our partners with statistical information about our users by secured channels under data processing agreements (DPA).

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that are related to the Service. With this regard, you are required to consent separately within your account for each communication. You may always opt-out (unsubscribe) from any communication in your account.

As you use our service, you may import into your account information you have collected from target devices. All this information is stored in encrypted way on Limtz servers. Downloaded information by a user to its device or browser is not encrypted and user is solely responsible for securing it. We have no direct relationship with any person other than you, and for that reason, you are responsible for making sure you have the appropriate consent to collect and process information from an owner of a target device.

If you use a computer in a public place or share a computer with others, remember to log out/sign out and close your browser window when you finish accessing our Website and Service in order to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.

AGGREGATE INFORMATION THAT IS AUTOMATICALLY COLLECTED. COOKIES. LOG FILES. PIXEL TAGS

We also collect and store information that is generated automatically as you navigate through our Website to enhance your experience on our Website by using tracking technologies as “Cookies“ (please read Cookie Policy), Log Files and Pixel tags.

As you navigate our Website(s) information that we automatically collect is information in "log files" about your device’s connection to the Internet, length of time spent on the Website, and the pages accessed during each visit to the Website. We use this information to analyze trends, administer the Website, track user movement on the Website, and gather broad statistical information for aggregate use.

Our Website use Cookies. Cookies are text files that are stored in a computer system via an Internet browser. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Website, Cookies help us track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Website where you have entered preference information before. Cookies contain a so-called Cookie ID. A Cookie ID is a unique identifier of the Cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the Cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other Cookies. A specific Internet browser can be recognized and identified using the unique Cookie ID.

Through the use of Cookies, Limtz can provide the users of this website with more user-friendly services that would not be possible without the Cookie setting. By means of a Cookie, the information and offers on our website can be optimized with the user in mind.

The data subject may, at any time, prevent the setting of Cookies through our Website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of Cookies. Furthermore, already set Cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of Cookies in the Internet browser used, not all functions of our Website may be entirely usable.

If you do not wish to receive Cookies you may be able to refuse them by adjusting your browser settings to reject Cookies. If you do so, we may be unable to offer you some of our functionalities, services or support. If you have previously visited our Website, you may also have to delete any existing Cookies from your browser.

Limtz also may use pixel tags (single-pixel image files also known as transparent GIFs, clear GIFs or web beacons) to access Cookies and to count users who visit the Website or open our HTML-formatted e-mail messages.

Encryption data: We get opened data from devices using encrypted https protocol. We immediately start encryption process of the data on the server in the RAM without storing on server`s disks. We encrypted data using RSA using user’s public encryption key.

The encrypted data is saved to Limtz servers.

RIGHTS OF THE DATA SUBJECT

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Limtz, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the erasure request is complied with immediately.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • The purposes of the processing;

  • The categories of personal data concerned;

  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

  • Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

  • The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

  • The existence of the right to lodge a complaint with a supervisory authority;

  • Where the personal data are not collected from the data subject, any available information as to their source;

  • The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

  • The personal data have been unlawfully processed.

  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR,

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Limtz, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the erasure request is complied with immediately.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.

  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.

  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject`s rights and freedoms and legitimate interests, or (3) is not based on the data subject`s explicit consent.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Limtz, he or she may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If one of the aforementioned reasons applies, data subject may at any time contact us, as instructed at the end of this Privacy Policy. We shall promptly ensure that the request is complied with immediately.

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period and when we no longer need personal data, we routinely and securely delete or destroy it, as long as it is no longer necessary for the Purpose.

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of Service provision, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

Limtz does not store and process personal data of a data subject for more than it is necessary to achieve the purpose of service provision. However, in case of conflict situations in progress Limtz may store personal data for 180 days period or more if the processing is necessary for the establishment, exercise or defence of legal claims and for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject in case of an expired account or in case data subject requested to delete his personal data. Upon the expiry of this period or earlier, if a conflict situation is settled, all personal data and information gathered from a target device gets deleted.

HOW DO I OPT OUT OR CHANGE MY PERSONAL INFORMATION?

To opt out of further e-mail communications from us, just click on the opt out button in the e-mail, or contact us as instructed at the end of this Privacy Policy. We may need up to 10 (ten) business days to assure compliance with your request.

To change your personal data that you have provided to us, please contact us as instructed at the end of this Privacy Policy.

CHANGES OR UPDATES TO THIS PRIVACY POLICY

We may modify this Privacy Policy at any time and post any changes to the Privacy Policy on the Website, so please review it frequently. We indicate the date of the current version of this Privacy Policy below, so you know when it was last updated.

Changes to this Privacy Policy may not affect your personal data we have previously collected from you or after such changes.

If you object to the changes, please contact us as provided below.

GOVERNING LAW

This Privacy Policy is governed by and construed with the laws of The Republic of Ireland including the Data Protection Directive (95/46/EC) and Regulation 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), effective as of 25 May 2018.

Those who access the website from locations outside of the European Union are responsible for compliance with local laws if and to the extent that local laws are applicable.

Version: July 2, 2018.