TERMS 
When you use LIGHTSPEED’s SMART CLOUD BANKING service, you trust us with your personal data. We are committed to keeping that trust. That starts with helping you understand our privacy practices. This privacy policy (the “Privacy Policy“) describes the information we collect, how it is used and shared, and your choices regarding this information when using our service or websites (the “Service“). When using the Service, we will process your personal and business data in accordance with this Privacy Policy. 

LIGHTSPEED DIGITAL LLC (Thereafter LIGHTSPEED) Company ID 404560970, is responsible for processing of the personal data that is collected by it when using the Service and is therefore data controller. We process your personal data to make it available to the company you have agreed to share your data with and which is a customer of ours. A more detailed description of the Service is available in our Terms and Conditions. Our legal basis for the processing is described under “How do we use your personal data” below. 

PERSONAL DATA WE COLLECT 
LIGHTSPEED may collect and process the following information that you share with LIGHTSPEED or that LIGHTSPEED collects when you are using the Service: 
a) Personal and contact details such as personal identification number or similar, name, address, age, gender, telephone number, e-mail address; 
b) Financial information such as the name of your bank, bank account number, number of accounts, loans and up to 12 months of transactional history (transaction, payer and recipient of payments, amount, balance and date), including monthly cash flow (salary and expenses), overdrafts, and occasionally information on loans, mortgages and trading accounts; 
c) Technical information related to your device that you are using when using the Service, such as type of browser, IP address, and type of device, operating system; 
d) Information about queries and complaints: Information you chose to share with as in connection with submitting a query or request to us; and 
e) Information used to administer the contractual relationship with you and B2B marketing: If you are a representative of a company who is a customer or potential customer of LIGHTSPEED, we may collect information that you share with us via e.g. contact form, your interaction with our websites, or which you have agreed to share with us via our partners. This information may include your name, title, professional details, the company you represent, technical data (as defined above) and website history. 
WHICH ARE THE SOURCES OF INFORMATION? 
Personal and contact details as well as the financial information (together “Account Data”) are collected from your Internet bank, public and private registry, revenue service, when you designate via the Service upon your consent. Technical information is collected when you interact with the Service or our websites. 
HOW DO WE USE YOUR PERSONAL DATA? 
We will use your information in accordance with this Privacy Policy and applicable laws, including data protection laws and laws on payment services, for the following purposes: 
• With your consent, we will use your Account Data to deliver the Service. This also includes measuring your use of the Service, detection and resolution of technical issues, ensuring and optimizing quality, keeping the service safe and secure, preventing and investigating illegal activities on the Service and enforcing our Terms and Conditions; 
To pursue our legitimate interests, we may use technical information (described above) to analyze use of and improve the Service; We will also process your information in a de-identified format, for analytical purposes and for future improvement of the Service. 
• To establish, exercise or defend against legal claims; to respond to legal process (e.g. court order or subpoena) if we believe in good faith that it is necessary to do so; and to comply with legislation that applies to LIGHTSPEED business, such as accounting and tax laws; and to respond to queries, requests and complaints; 
HOW DO WE DISCLOSE YOUR PERSONAL DATA? 
Personal data collected through the Service may be disclosed to the following categories of recipients: 
• Our customers that you have agreed to share your data with via the Service. Note that after our disclosure of your data to the agreed recipient, the recipients are independently responsible for their own further processing of your personal data in accordance with their respective privacy policies. 
• Other companies within our group of companies, or any successors in title to our business or assets. A list of our group companies is available upon request. 
• To the extent necessary to provide the Service, we may also disclose your personal data to distributors of the Services, as well as service providers and subcontractors retained to perform functions on our behalf or to provide services to us, such as infrastructure providers and providers of legal, accounting, audit and other professional services. All service providers and subcontractors are prohibited from using personal data for purposes other than providing such services to us or as otherwise required by law. 
• We may also disclose personal data to external parties if required by law, or in response to legal requests, for example court orders, subpoenas or specific requests from law enforcement agencies, if we believe in good faith that it is necessary to do so. 
Additionally, we may use and disclose information in anonymous or aggregate form (so that no individuals are personally identified) for marketing and strategic development purposes. 
We take all reasonable legal, technical, and organizational measures to ensure that your data is treated securely and with an adequate level of protection when transferred to or shared with such selected third parties. 
SECURITY 
We are committed to protecting your personal data and take appropriate measures to keep it secure and to prevent unauthorized access or use. For example, all personal data collected will be treated with confidentiality as far as possible and will, where appropriate, be transmitted and handled by applying SSL (Secure socket layer) and secure encryption procedures. 
Right to rectify and restrict: You have the right to, without undue delay, have inaccurate or incomplete personal data about you corrected. Furthermore, you have the right to request that LIGHTSEED restricts the processing of your personal data under certain conditions where, for example, you contest the accuracy of the personal data or LIGHTSPEED no longer needs the personal data for the purposes of the processing described herein. 
LIGHTSPEED reserves the right to from time to time update and make changes to this Privacy Policy. Prior to making any material changes to this Privacy Policy, we will inform you about the changes on our website. Please check here regularly for any updates to this Privacy Policy. 
PROCESSING CARRIED OUT AS A DATA PROCESSOR 
Our service to our customers include that we, on behalf of the respective customer, store the information that you have agreed to share with that customer. We provide this storage for our customers and we will not use the stored personal data for our own gains. Our customers are generally using this service for the purpose of facilitating record keeping and traceability of the information they used in connection with a decision to enter into a contract with or to provide you with a service online. It is our customers’ responsibility to use the personal data in accordance with applicable laws and they are free to delete the information from our storage at any time. For this processing of your personal data, our customers (i.e. the company you have agreed to share your information with) are data controllers. We are our customers’ data processor as we store the data on their behalf and will only use the data as instructed by our customers. For these purposes, we will always enter into a data processing agreement with our customers. If you do not want that the company you have shared your data with to store the data, please contact the relevant company.