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Privacy Policy

LamaTechnology FS UAB (“Lama”, “we”, “our”) takes data privacy very seriously and recognise the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how we use that information, to whom we pass the information, your rights and key contact information.

Lama is a company registered and incorporated in Lithuania with company number 305833209 and registered office at Mėsinių str. 5, LT-01133 Vilnius, Lithuania. By visiting this website, or providing your personal information to one of our employees, for example by email, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

This Privacy Policy is an integral part of Lama’s Terms of Service.

1. What Information we collect

1.1. Information we may collect from you

You may provide us with information by filling in forms on our website, or by talking with us via email or otherwise. This includes information you provide when you browse our website, register for an account via our app, enter into a contract for the supply of cryptocurrency services, promotion or survey and when you contact us for other reasons.

1.1.1. Initial Information

To meet our legal requirements and regulatory obligations and to proceed with your account opening and use Lama Services, we collect the following Personal Data such as:

1.1.2. Additional verification information:

We may ask you to send us additional information if:

The additional information may include a copy of your driving license, passport, and/or a recent utility bill, or other information verifying your identity and address, or to answer additional questions to help verify your information or transaction.

We may also ask for evidence of source of funds or wealth, for example bank statements, investment statements, proof of property sale or probate documents.

1.1.3. When we communicate

When you communicate with us for customer service or other purposes, including by email or using other methods, we retain that information and our responses to you.

1.1.4. Transaction information

When you use Lama Services to send currency, we may ask you to provide information related to that transaction. For crypto transactions, this information will include amount, crypto, source of funds and external wallet. For fiat transactions, this information includes the amount, currency and type of the transaction, source of funds, exchange rate, recipient name and bank details ((account number, sort code and IBAN), recipient address for some jurisdictions and, optionally, the recipient’s email address and phone number.

1.2. Information we collect when you use our website

When you arrive at or leave Lama website, whether connected by a fixed line or wirelessly, we receive the web address of the site that you came from or are going to.

While you are using our site we collect information on the services you search for or view, page response times and length of visits to specific pages, how you interacted with each page (including scrolling, clicks and mouse-overs), and methods used to browse away from the page.

We collect information about the device you are using, such as the type of device, operating system and platform, the type and version of browser, browser plug-in types and versions, the times you access our website/app and the time zone setting, mobile network information and unique device identifier, which may include your Device’s IMEI number and/or MAC address, or the mobile phone number used by the Device. We do not capture GPS information about you.

1.3. Information about you that we receive from third parties

1.3.1. Identity verification using Photographs and facial imaging

To protect ourselves and our customers against fraud, we verify the information you provide with identity verification agencies to undertake required verification, regulatory and fraud prevention checks. In the course of verification, we may ask you to upload a photograph of your identity document and/or use the Device’s camera to verify your identity using facial recognition in order to provide these specific services. We receive information about you from such services.

1.4. Sensitive data

Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’ unless you have given your consent.

Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.

To avoid infringing these restrictions, it is Lama’s policy that we do not ask for or collect any of the above data from you or any other party, so we therefore ask that you please do not reveal any sensitive data about yourself or others in any communication with us.

If you do reveal sensitive data, for example by phone or in an email, you will be giving express consent for us to process that information by storing the recording of the telephone call, or the email or other communication.

2. How we use your information?

By submitting your information to Lama you agree that we may use your information for the following purposes:

2.1. Fulfilling your requests

We will use your information to:

2.2. Compliance and risk management

As a registered cryptoasset provider, we are obliged to carry out background checks on individuals and connected parties, and to monitor ongoing transactions. This is to prevent fraud and money laundering, including to help protect your accounts from fraudulent activity.

We carry out checks to ensure we do not deal with countries, entities or individuals that are subject to sanctions, to comply with counter-terrorist financing and anti-money laundering regulations and to identify high-risk individuals where we need to add additional controls. We also conduct investigations into actual or suspected violations of our Terms of Service.

2.3. Communication and customer service

We communicate with our users on a regular basis via email to provide requested services and help you manage your account. These activities may include:

We use your email address and phone number to:

Users cannot opt out of these communications, as we are obligated to send these communications to current customers, but they will be primarily service-oriented rather than promotional.

2.4. Marketing

We also use your email address to send you other types of communications that you can control, including newsletters and special promotions. These communications are to:

You can choose whether to receive some, all or none of these communications.

2.5. Service improvements and account management

We will use your information to deliver and improve Lama Services and manage your account, including:

2.6. Third party information

We will combine third party information with information you give to us and that we collect about you. We will use all of this information:

3. Sharing Information with third parties

3.1. To support our business and provide services to you

Just like most financial service providers, Lama works with third-party service providers who support our business operations, such as fraud prevention, customer service and technology services. We need to disclose user data to them from time to time so that the services can be performed. Our contracts dictate that these business partners only use your information in connection with the services they perform for us and not for their own benefit.

By accepting this Privacy Policy and maintaining an account with Lama, you expressly consent to the transfer of your data to those third parties for the purposes listed.

3.2. Banks

When withdrawing fiat currency, we will provide your information to the business partners who are contracted to Lama to complete this transaction, for example passing bank details to correspondent bank(s) or payment provider(s) involved in the transaction.

3.3. Anti-fraud, anti-money laundering, sanctions and risk management

To carry out the checks described above, we will provide your information to our third-party business partners who carry out these checks.

3.4. Where required by law

We may disclose necessary information to the police and other law enforcement agencies, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies, departments or regulatory authorities, where we are legally compelled and/or permitted to do so.

4. Transferring data overseas

Lama is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.

The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. These staff may be engaged in the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

By submitting your information and making use of Lama Services, you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

5. Data Retention Policy

We are obliged by financial markets laws to retain account data for 5 years after the closure of an account. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.

6. Systems Security Policy

Lama has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data. Only authorised employees of Lama and our business partners processing data on our behalf have access to your personal data. All Lama employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by Lama to ensure that any of their employees who have access to your personal data have signed non- disclosure agreements. Contracts with business partners acting as data processors for Lama involving personal data require an adequate level of security and require that personal data is processed only as instructed by Lama.

To ensure data privacy, confidentiality and integrity, all information disclosed, shared, stored or used and any transactions performed by you through our website are encrypted.

To provide a secure environment for our website, we hold your data in secure data centres with high levels of physical and technical security, including using firewall systems, data encryption and anti- virus protection. We use security surveillance systems to detect and prevent illegitimate access to and activities on our systems.

7. Customers rights

You have the following rights:

● To ask us to correct any information we hold about you if it is incorrect.

Whilst we endeavor at all times to keep your information accurate, we welcome your corrections. We may ask you for additional verification information if you are changing certain details such as your name or your address.

● To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.

Our Data Retention Policy explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.

● To ask us to return to you information you provided to us, also known as ‘data portability’.

You can ask us to send you in electronic format the information you provided to us under our Terms of Service or under consent.

● To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest.

If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.

You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.

● To ask not to be subjected to automated decision making and profiling.

At Lama there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.

● To ask for a copy of the information we hold about you.

We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.

8. Contacting Us

8.1. Data Controller

The Data Controller is LamaTechnology FS UAB a company registered and incorporated in Lithuania with company number 305833209 and registered office at Mėsinių str. 5, LT-01133 Vilnius, Lithuania.

8.2. Contacting us with questions or requests

If you want to exercise your right to access your information or have any questions about this Privacy Policy, you can contact us at support@mylama.eu

8.3. Complaints to the Data Protection Officer

If you believe that we have breached a privacy law with which we should comply, please send an email to complaints@mylama.eu. We aim to respond in a reasonable time, normally within 30 days. Our Compliance team and Data Protection Officer will look after your complaint and will give you additional information about how it will be managed.

8.4. Complaints to the Lithuanian Data Protection Authority

If your complaint is in relation to Data Protection related to Lama Services , you have the right to complain to the State Data Protection Inspectorate (the “Inspectorate”), if you believe we have not handled your request in an appropriate manner. For information on contacting the Data Protection Authority please see their website (https://vdai.lrv.lt/en/)

9. Changes to this privacy policy

We may amend this Privacy Policy at any time, as new features are added to Lama Services or as we incorporate suggestions from our customers. Any changes we may make will be posted on our website, so please check back frequently.

Your continued use of our website and the Lama app after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, you may close your account at any time.