Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, usage, and disclosure of Your information when You use our Services and tells You about Your privacy rights and how the law protects You.

As we are involved in the provision of compliance services to the clients in the UK and European Union, we use Your Personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

In the performance of our services we do collect and use your personal data we are obligated to use and process your Personal Data only in accordance with this privacy policy (hereinafter – The Privacy Policy), as well as, applicable legislation, including the General Data Protection Regulation (2016/679) (hereinafter –GDPR), The Data Protection Act 2018 (DPA ACT), the Law on Money Laundering and Terrorist Financing Prevention of the Republic of Lithuania, the applicable national data protection laws of the Republic of Lithuania and other applicable legal acts.

On the reference regarding you, as the client, data subject, we mean you as a potential client, our client’s employee, or other parties, such as beneficial owners, authorized representatives, potential employees, and other associated parties. If you provide us with information about any person other than yourself, your employees, counterparties, your advisers, or your suppliers, you must ensure that they understand how their information will be used.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, we may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally, identifiable information may include, but is not limited to and can be grouped into the following categories:

Basic Information such as your name, surname, job title and ect;
Contact Information such as phone number, addresses and email address etc.
Background verification information such as your or your representative’s, ultimate beneficiary owners (hereinafter – The UBO) (of legal entities (natural persons who directly or indirectly own or control a legal entity with the participation of more than 25 percent of shares or votes) name, surname, personal code, date of birth, address, nationality, a copy of passports or ID card. The evidence of the source of funds and wealth of the natural persons, the UBO number of shares held, voting rights or share capital part, function as a person occupying a senior management position, visually scanned or photographed image of your face or image that your provide through a mobile app or camera, video and audio record for identification, telephone to comply with client due diligence/”know your client”/anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures.
Financial data such as books, transactional information whenever it is necessary to identify the potential fraud, amount and number of transactions, income, location, type of concluded agreements etc.
Information related to legal requirements such as facts resulting from investigations made by the authorities, data that enables us to perform anti-money laundering requirements and confirm the compliance with the international sanctions and other sanctions lists, including the purpose of the business relationship and whether you are a politically exposed person and other data that is required to be processed by us in order to comply with the legal obligation to “know your client” ( including, but not limited to visually scanned or photographed image of your face or image that your provide through a mobile app or camera, video and audio record for identification).

And Any other Personal Information connected to you that you may deliver. Additionally, it will fall under the scope of the usage data by the third parties. Usage data can refer to:

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated using the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Retention of Your Personal Data

The Company will retain Your Personal Data for as long as You are using our services. Once Your account is deleted, Personal Data will be deleted. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Security of Your Personal Data

We take our Users’ Personal data very seriously, and we will continue to do everything to keep it safe and secure. Also, we confirm the implementation of suitable technical and organizational measures required to ensure the security of your Personal Data processing to protect it from modification, disclosure, and any other illegal treatment. However, we are not able to fully protect User’s information in unforeseen events, including, but not limited to cyber-attack, theft, loss of information, force majeure, or breach of our security system.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

How Do We Obtain Your Personal Data

We may use third-party Service providers to monitor and analyze the use of your personal data. We may collect or obtain your Personal Information in various customs:

When you provide the information requested either by us or by third party directly, for example, by corresponding with us via email or other straight exchanges with us such as completing a form on our website. Sometimes supplementary information is required to keep information up to date or to verify information we have gathered.
Thought-out the time of our relationship with you or while we are providing services to a third parties.
When it is provided to us by a third party because you are the subject, or your data is otherwise included in an investigation that we are asked to provide to a third-party.
Third party sources, for example, registers held by governmental agencies or where the collected information about you is retained to assist with “know your client” check-ups as part of our client acceptance procedures, such as sanctions list, politically exposed persons list and other databases. Also, when we receive information about you from third parties.
Publicly available sources – we may, for example, use external sources to facilitate us preserve your contact details that we already possess correct and up to date or for professional networking purposes or for providing our legal and other services.

In order to make your identity verification, we are using third parties’ contractual services. Their solution is used for comparing live photograph data or video record of yourself and your ID card/passport to comply with client due diligence/” know your client”/anti-money laundering laws and other legal requirements. The result of the face recognition (match or mismatch) will be retained how long it is necessary to carry out identity verification and for the period required by anti-money laundering laws.

We conduct your identity verification using third party’s solution on a consent basis.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use to serve You ads that are targeted to Your interests.

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, you will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

By email: support@afacomp.com