Website Privacy Policy

Personal Data

Personal Data means data about a identified or identifiable living individual who can be identified directly or indirectly by reference to an identifier (or from those and other information either in our possession or likely to come into our possession).

Data Subject (or User)

Data Subject is any living individual who is using our Website and is the subject of Personal Data.

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processor (or Service Provider)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Contact Details

First and last name Email address

Usage Data

This Usage Data is sent by your browser whenever you visit our Website and may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website 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 Website with a mobile device, this Usage Data may include information such as 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.

Location Data

We may use and store information about your location if you give us permission to do so. We use Location Data to provide features of our Service, to improve and customise our Service. You can enable or disable location services when you use our Service at any time by adjusting your device settings.

Tracking and Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Please refer to our Cookie Policy for an overview of the cookies that we use.

Your use of the Website

We keep track of certain information about you when you visit and interact with our Website.

This information includes the Usage Data (as defined above in the Section “Personal Data We Collect”).

Device and connection information

We collect information about your computer, phone, tablet, or other devices you use to access the Website.

This information includes the Location Data and Usage Data (as defined above in the Section “Personal Data We Collect”). How much of this information we collect depends on the type and settings of the device you use to access the Website.

Cookies and other tracking technologies

We and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices.

This information includes the Tracking and Cookies Data (as defined above in the Section “Personal Data We Collect”). For more information, please refer to our Cookie Policy.

Other users of the Website

Other users of our Website may provide information about you when they submit content through the contact form.

This information includes the Contact Details (as defined above in the Section “Personal Data We Collect”). For example, you may be mentioned in technical support issue opened by someone else. We also receive your email address from other Service users when they provide it in order to invite you to register as a SONECT Shop.

Other partners

We receive information about you and your activities on and off the Website from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.

This information includes the Usage Data and Tracking and Cookies Data (as defined above in the Section “Personal Data We Collect”). For more information, please refer to the Section “Service Providers”.

Website browsing and security

IP address, browser type, device data, log data, time and date of visit, pages viewed

To operate the website, maintain availability, prevent abuse and investigate security incidents

Hosting provider, IT/security providers, Sonect UAB Europe

Contact forms and general enquiries

Name, email address, company, role, message content and related correspondence

To respond to the enquiry

Email/CRM providers, relevant Sonect UAB Europe staff, IT providers

Bank, merchant and partner enquiries

Name, business contact details, company, role, message content, due diligence context where provided

To assess and respond to partnership, merchant or banking enquiries

CRM/email providers, internal business, legal, compliance and onboarding teams, Sonect UAB Europe

Newsletter and direct marketing emails

Email address, name, subscription status, consent record, unsubscribe record

To send marketing communications and manage opt-outs

Email marketing provider, CRM provider, internal marketing staff

Essential cookies

Cookie identifiers and technical website-session data

To provide essential website functionality and security

Hosting provider, consent-management provider, IT providers

Analytics cookies and analytics tags

Cookie IDs, device data, usage events, page views, referral data

To measure website use and improve website performance

Google Analytics 4 or other analytics provider listed in the Cookie Policy, consent-management provider, IT providers

Advertising, remarketing and social-media pixels

Cookie IDs, pixels, ad identifiers, page events, campaign data

To measure advertising performance and conduct remarketing

Meta, Google Ads, TikTok, LinkedIn or other advertising providers listed in the Cookie Policy, consent-management provider

Embedded third-party content

IP address, device/browser data, cookie IDs or similar identifiers where the embedded provider sets them

To display embedded content such as videos or maps

YouTube/Google or other embedded-content providers listed in the Cookie Policy

Legal claims and regulatory requests

Relevant website enquiry data, correspondence, logs and records

To establish, exercise or defend legal claims, respond to lawful authority requests and comply with applicable legal obligations

Courts, regulators, law enforcement authorities, external counsel, auditors, Sonect UAB Europe

Website browsing and security

Art. 6(1)(f) GDPR: legitimate interest in secure website operation

12 months, unless needed longer for a security investigation, legal claim or lawful regulatory request

Contact forms and general enquiries

Art. 6(1)(f) GDPR for B2B/general enquiries. Art. 6(1)(b) GDPR applies only where the individual requests pre-contractual steps in their own name

24 months after last interaction

Bank, merchant and partner enquiries

Art. 6(1)(f) GDPR: legitimate interest in business development and partner assessment. Art. 6(1)(c) GDPR applies only where a specific legal or regulatory recordkeeping obligation is triggered

36 months after last interaction, unless a contract or regulated onboarding process begins

Newsletter and direct marketing emails

Art. 6(1)(a) GDPR: consent

Until unsubscribe or withdrawal, plus 3 years for suppression records

Essential cookies

Art. 6(1)(f) GDPR for related personal data processing. Cookie consent is not required where the cookie is strictly necessary

As listed in the Cookie Policy

Analytics cookies and analytics tags

Art. 6(1)(a) GDPR: consent, where non-essential cookies or similar tracking are used

Maximum 26 months unless aggregated or anonymised earlier

Advertising, remarketing and social-media pixels

Art. 6(1)(a) GDPR: consent

As listed in the Cookie Policy

Embedded third-party content

Art. 6(1)(a) GDPR where non-essential cookies or tracking are used

As listed in the Cookie Policy

Legal claims and regulatory requests

Art. 6(1)(c) GDPR where a legal obligation applies. Art. 6(1)(f) GDPR for legal claims and defence

For the legally required period or until the claim/request is resolved, then deleted or archived according to the retention schedule

Right to get familiar with your Personal Data and how it is processed

You have the right to know about processing of your Personal Data as well as to have the access to your Personal Data and processing. Your right to access may, however, be restricted by legislation, protection of other persons’ privacy and consideration for the Company’s business concept and business practices. The Company’s know-how, business secrets as well as internal assessments and material may restrict your right of access.

Right to obtain a copy of your personal data

You have a right to request a copy of the Personal Data held by us as a data controller, which we will provide to you in an electronic form, except in the cases when the provision of such data may affect and harm rights and freedoms of others.

Right to amendment

You have the right to ask us to correct our records if you believe they contain incorrect or incomplete information about you.

Right to withdraw consent

If you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. This includes cases where you wish to opt out from marketing messages. However, such consent withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another Legal Basis for the processing. To stop receiving emails from us, please click on the “unsubscribe” link in the email you received from us or contact us at [email protected].

Right to erasure

You have the right to request that we delete your Personal Data when it is no longer necessary for the Purposes for which it was collected, or when it was unlawfully processed, however, in certain cases we may not be able to erase all of your Personal Data, due to the fact that we need to store your Personal Data due to a contractual relationship or law.

Right to restriction of processing

You have the right to request the restriction of our processing of your Personal Data where you believe it to be inaccurate, our processing is unlawful, or where we no longer need to process it for the initial Purpose, but where we are not able to delete it due to a legal obligation or because you do not want us to delete it. It can also pertain to a situation where you object to processing that we base on a legitimate interest. In such case we must verify if our grounds override yours.

Right to portability

You have the right to request that we transmit your Personal Data to another data controller in a common format such as Excel, where this is data which you have provided to us and where we are processing it on the Legal Basis of your consent or in order to perform our contractual obligations (e.g. to provide our Services).

Right to object to processing

Where the Legal Basis for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate Legal Basis for the processing which override your interests, or if we need to continue to process the Data for the establishment, exercise or defense of a legal claim.

Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates data protection law. In Lithuania: State Data Protection Inspectorate, L. Sapiegos str. 17, 10312 Vilnius. You may also complain to the supervisory authority in the EU/EEA country of your habitual residence, place of work or the alleged infringement.

Functional Services Providers

Airship

Airship Services Ltd

We use Airship in order to improve our Website and detect bugs in our system. To that end, we process Usage Data. For more information, please refer to the Airship Privacy Policy: https://airship.co.uk/privacy- policy/

Mixpanel

Mixpanel Inc.

We use Mixpanel to analyze how visitors interact with our website and to support troubleshooting, performance and stability improvements. To that end, we process Usage Data. For more information, please access their privacy policy: https://mixpanel.com/legal/privacy-policy/

Segment

Segment.io Inc.

Segment links the anonymous IDs to merge information from the above apps. For more information on Segment, please visit their Privacy Policy: https://segment.com/docs/legal/privacy/

Marketing Services Providers

MailChim

The Rocket Science Group LLC

We use Mailchimp to manage email marketing subscriber lists and send emails to our subscribers. For more information on The Rocket Science Group, please read their Privacy Policy: https://mailchimp.com/legal/privacy/

Analytics Services Providers

Google Analytics

Google Inc.

Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Remarketing Services Providers

Google Adwords

Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adsGoogle also recommends installing the Google Analytics Opt-out Browser Add-on — https://tools.google.com/dlpage/gaoptout — for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on Google’s privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Facebook

Meta Platforms Ireland Limited

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/247395082112892/?helpref= uf_share. To opt-out from Facebook’s interest-based ads, follow these instructions: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on Facebook’s privacy practices, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.