PRIVACY NOTICE
FOR CUSTOMERS
IN THE UK AND EEA
About us
Paladis Finance UAB also in this document known as (“Paladis”), a modern Fintech company, serving
both individual and business customers from all
over the World; however, the business focus shall initially be in Lithuania and Lichtenstein. Paladis
strives to offer its customers a constantly growing ecosystem of value-added services for
innovative digital payments: online, at the point of sale, and entirely mobile.
The Paladis company providing the relevant product or service to you will be responsible for
processing your personal data for that product or service. This Paladis company is known as the
‘controller’ of your personal data.
Why do I need to read this notice?
We will collect your personal data when you use:
• our website at www.paladis.com
• the Paladis Business app
• any of the services available to you through the Paladis Business app or website
We may also collect your personal data from other people or companies. We explain how this
can happen in more detail at What personal data do you collect about me? section below.
When we say ‘personal data’, we mean information which:
• we know about you (for example, if you are a director of a company applying for a
Paladis Business account, we may ask you to provide identification documents)
• can be used to personally identify you (for example, a combination of your name and postal address)
Data protection laws do not apply to information about legal entities (for example, limited liability
companies). However, they do apply to people. When we provide Paladis Business products, we
process personal data of the individuals authorised to set the account up and give us instructions about
the account. We also may process personal data about other employees and customers of the
company that receives Paladis Business products.
If more than one person is authorised to give instructions on a Paladis Business account, references in
this notice to ‘you’ and ‘your’ will mean any, or all, of those people. When we refer to a ‘company’, we
mean the company that holds the Paladis Business account.
This notice explains what personal data we collect, how we use it, and your rights if you want to change
how we use your personal data. This notice only applies to personal data. It does not apply to company
information.
If you are a customer of a company that holds a Paladis Business account, or one of its employees who
uses the company’s Paladis Business account, but are not authorised to give us instructions, we do not
process personal data about you as a ‘controller’. The company that holds the Paladis Business account
is the ‘controller’ of your personal data. You should contact the company that holds the Paladis
Business account for information about how it processes your personal data.
We may provide this notice in languages other than English. If there are any discrepancies between
other language versions and the English language version, the English language version is authoritative.
If you have concerns about how we use your personal data, you can contact dpo@paladis.com.
What personal data do you collect about me?
The types of personal data we collect depend on how you use Paladis Business.
When you use Paladis Business, you can be:
• a freelancer, sole proprietor that has applied for a Paladis Business account, which we call
a ‘Freelancer’
• an employer or an employee that is responsible for applying for and / or running a
Paladis Business account on behalf of a company, which we call an ‘Account
Owner’
• an employee of a company that has a Paladis Business account, and your employer has
invited you to use its Paladis Business account, which we call a ‘Team Member’
If you are a:
Customer privacy notice for business customers in the UK and EEA
• Freelancer or Account Owner, we are the ‘controller’ of your personal data when we
provide you with Paladis Business
• Team Member, the company that holds the Paladis Business account you have been
invited to use, is a ‘controller’ of your personal data. Please contact it if you have any
questions about how your personal data is processed by Paladis Business on its behalf
• customer of a company that holds a Paladis Business account, that company is a
‘controller’ of your personal data. Please contact it if you have any questions about how
your personal data is processed by Paladis Business on its behalf
Types of personal data and details
We collect information you provide when you:
• fill in any forms
• correspond with us
• respond to any of our surveys
• register to use the Paladis Business app
• open a Paladis Business account, are assigned to be an Account Owner or Team Member,
or use any of our services
• give us access to your, or your company’s, other financial accounts
(for example, through Open Banking)
• take part in online discussions or promotions
• speak with a member of our social media or customer support
teams (for example, through our social media pages, website, on the
phone or through the Paladis Business app)
• enter a competition or share information with us on social media
• contact us for other reasons
We will collect the following information:
• your name, address, and date of birth
• your email address, phone number and details of the device you
use (for example, your phone, computer or tablet)
• your registration information
• details of the relevant Paladis Business account you are associated
with, including the account number, sort code and IBAN
• details of your Paladis Business cards (or other cards you have
registered with us) including the card number, expiry date and CVC (the
last three digits of the number on the back of the card)
• copies of your identification documents (for example, your passport or
driving licence) and any other information you provide to prove you are eligible
to use our services
• your country of residence, tax residency information and tax identification
number
• records of our discussions, if you contact us or we contact you (including
records of phone calls)
• your image in photo or video form (where required as part of our
Know-Your-Business (KYB) checks, to verify your identity if you contact us when
logged out of your Paladis Business account, or where you upload a photo to
your Paladis Business account)
• information about other people (such as the company’s shareholders,
directors, employees, customers or business partners) where we are legally
required to ask for such information (for example, as part of KYB checks or
under anti-money laundering laws to verify your company’s sources of funds)
Where you, or your company, give us personal data about other people, you are
responsible for ensuring
​
When you use Paladis Business, we get information about:
• how you use your Paladis Business card
• any transactions you make with your Paladis Business card
• your device (as explained below)
​
Whenever you use our website or the Paladis Business app, we collect the following information:
• technical information, including the internet protocol (IP) address used to
connect your computer to the internet, your log-in information, the browser type
and version, the time-zone setting, the operating system and platform, the type
of device you use, a unique device identifier (for example, your device's IMEI
number, the MAC address of the device's wireless network interface, or the
mobile phone number used by the device), mobile network information, your
mobile operating system and the type of mobile browser you use
• information about your visit, including the links you have clicked on, through
and from our website or app (including date and time), services you viewed or
searched for, page response times, download errors, length of visits to certain
pages, page interaction information (such as scrolling and clicks), and methods
used to browse away from the page
• information on transactions (for example, payments into and out of your Paladis Business account), including the date, time, amount, currencies,
exchange rate, beneficiary details, details of the merchant or ATMs associated
with the transaction (including merchants’ and ATMs’ locations), IP address of
sender and receiver, sender's and receiver's name and registration information,
messages sent or received, details of device used to arrange the payment and
the payment method used
• information stored on your device. The Paladis Business app will regularly
collect this information in order to stay up to date (but only if you have given us
permission)
​
Information from your employer:
Where a company that holds a Paladis Business account nominates you as an
Account Owner, your employer will give us information about you. Typically, this
will include your name and business contact details. In some cases, it may also
include your employment status, salary details and tax information (for
example, if your employer uses Paladis Business to administer its payroll).
​
Information from others
We collect personal data from third parties, such as credit reference agencies,
financial or credit institutions, official registers and databases, as well as fraud
prevention agencies and partners who help us to provide our services.
This includes your credit record, information about late payments, information
to help us check your identity, information about you and information relating to
your transactions. We have explained more in the Do you run credit checks on me?
section below.
When you ask us to, we’ll also collect personal data from accounts you, or your
company, have with third party financial institutions (when you create a linked
account by activating Open Banking in the Paladis Business app).
What is your legal basis for using my personal data?
We must have a legal basis (a valid legal reason) for using your personal data. Our legal basis
will be one of the following:
​
• Keeping to our contracts and agreements with you
• We need certain personal data to provide our services and cannot provide them without
• Legal obligations
In some cases, we have a legal responsibility to collect and store your personal data (for example, under anti-money laundering laws we must hold certain information about our customers).
​
• Consent
We sometimes collect and use your personal data because we have a legitimate interest to use it and this is reasonable when balanced against your right to privacy.
• Substantial public interest
Where we process your personal data, or your sensitive personal data (sometimes known as special category personal data), to adhere to government regulations or guidance.
​
We explain more about how we use your personal data in the How do you use my personal data? section below.
How do you use my personal data?
​
If you apply to use a Paladis Business product or service, we will use your personal data to check your identity (as part of our KYB process) and decide whether or not to approve your application.
We use your personal data to:
What we use your personal data for
​
Providing our services
If you apply to use a Paladis Business product or service, we will use your personal data to check your identity (as part of our KYB process) and decide whether or not to approve your application.
We use your personal data to:
• meet our contractual and legal obligations relating to any Paladis Business products or services you use (for example making payments into and out of your Paladis Business account)
• help you understand your, or your company’s, Paladis Business spending behaviour (for example, by providing you with spending insights)
• exercise other rights we have under any agreement we have with you
• provide you with customer support services. We may record and monitor any communications between you and us, including phone calls, to maintain appropriate records, check your instructions, analyse, assess and improve our services, and for training and quality control purposes.
Our legal basis for using your personal data
​
• Keeping to contracts and agreements between you and us
• Legitimate interests (we need to be efficient about how we meet our obligations and we want to provide you with good products and services)
• Legal obligations
Protecting against fraud
​
We use your personal data to check your identity and to protect against fraud, keep to financial crime laws and to confirm that you are eligible to use our services. We also use it to help us better understand your company’s financial circumstances and manage fraud risks related to your Paladis Business account.
​
• Legitimate interests (to develop and improve how we deal with financial crime and meet our legal
responsibilities)
• Legal obligations
Marketing and providing new products and services that might interest you
​
We use your personal data to do the following:
• provide you with information about other products and services we offer that are similar to those you have already used (or asked about, where allowed by law)
• if you agree, provide you with information about our partners’ promotions or offers which we think you might be interested in
• if you agree, allow our partners and other organisations to provide you with information about their products or services
• measure or understand the effectiveness of our marketing and advertising, and provide relevant advertising to you
• ask your opinion about our products or services
Remember, you can ask us to stop sending you marketing information.
• Legitimate interests (to send business-to-business marketing, develop our products and services, ensure our marketing is relevant to your interests, and to be efficient about how we meet our legal and contractual duties)
• Consent (where we are legally required to get your consent for business-to-business marketing)
To keep our services up and running
We use your personal data to manage our website and the Paladis Business app, (including troubleshooting, data analysis, testing, research, statistical and survey purposes), and to make sure that content is presented in the most effective way for you and your device.
We also use your personal data to:
• verify your identity if you contact our customer support or social media teams
• allow you to take part in interactive features of our services
• tell you about changes to our services
• help keep our website and the Paladis Business app safe and secure
Preparing anonymous statistical datasets
We prepare anonymous statistical datasets about our
customers’ spending patterns:
• for forecasting purposes
• to understand how customers use Paladis Business
• to comply with governmental requirements and requests
These datasets may be shared internally or externally with others, including non-Paladis companies. We produce these reports using information about you and other customers. The information used and shared in this way is never personal data and you will never be identifiable from it. Anonymous statistical data cannot be linked back to you as an individual.
For example, some countries have laws that require us to report spending statistics and how money enters or leaves each country. We will provide anonymised statistical information that explains the broad categories of merchants that Paladis Business customers in that country spend their money with. We will also provide information about how Paladis Business customers top up their accounts and transfer money. However, we will not provide any customer-level information. It will not be possible to identify any individual Paladis Business customer.
• Legitimate interests (to develop and improve how we deal with financial crime and meet our legal responsibilities)
• Legal obligations to us and to present content as
effectively as possible for you)
• Consent (where required by law) to us and to present content as
effectively as possible for you)
- Consent (where required by law)
• Legitimate interests (to conduct
research and analysis, including to
produce statistical research and
reports)
• Legal obligations
Improving our products and services
We use your personal data to help us develop and improve our current products and services. This allows us to continue to provide products and services that our customers want to use.
• Legitimate interests (to understand
how customers use our products so
we can develop new products and
improve the products we currently
provide)
Meeting our legal obligations, enforcing our rights and other legal uses
​
We use your personal data:
• to share it with other organisations (for example,
government authorities, law enforcement authorities, tax authorities, fraud prevention agencies)
• if this is necessary to meet our legal or regulatory
obligations (for example, some countries require us to understand which of our customers are vulnerable and require enhanced support)
• in connection with legal claims
• to help detect or prevent crime
You can find out more in the Do you share my personal data with anyone else? section below.
Sometimes, we are legally required to ask you to provide information about other people. For example, we might ask you to explain:
• your relationship with somebody who pays money into your Paladis Business account
• how somebody got the money in the first place to pay it into your Paladis Business account
Where you, or your company, give us personal data about other people, it is your responsibility to ensure they understand how we will process their personal data.
Helping you to provide services to your customers
We may provide payment processing services to you or your company. Where this happens, you, or your company, are responsible for deciding:
• if we collect your customers’ personal data
• how we process your customers’ personal data on your
behalf You, or your company, are the ‘controller’ of your customers’ personal data.
• Legitimate interests (for example,
to protect Paladis during a legal
dispute)
• Substantial public interest (if we
process your sensitive personal
data to keep to legal requirements
that apply to us)
• Legal obligations
• Keeping to contracts and agreements between you and us
• Legal obligations