1. Introduction
1.1 This Data Protection Policy is the overarching policy for data security and protection for
BT Exchange LT (Lithuania) and BT Exchange CZ (Czech Republic) (hereafter
referred to as "us", "we", or "our"). The policy ensures compliance with General Data
Protection Regulation (GDPR - EU Regulation 2016/679), the Lithuanian Law on
Legal Protection of Personal Data, and the Czech Act on Personal Data Processing
(Act No. 110/2019 Coll.).
2. Purpose
2.1 This GDPR Privacy Policy explains how the Company uses client’s Personal Data (defined below)
company provides access and utility through our digital platform via software, API (application
program interface), technologies, products and/or functionalities (“Service”).
2.2 In the course of providing Service, this GDPR is made to abide by the laws in the jurisdictions that
the company operates, and to improve services, company needs to collect and maintain personal
information about the client.
2.3 The purpose of the Data Protection Policy is to support the 10 Data Security Standards, the
General Data Protection Regulation (2016), the Data Protection Act (2018), the common
law duty of confidentiality, and all other relevant national legislation. We recognize data
protection as a fundamental right and embrace the principles of data protection by design
and by default.
Data Protection Policy
2.4 This policy covers:
⮚ Our data protection principles and commitment to common law and legislative compliance.
⮚ procedures for data protection by design and by default.
3. Collection of Personal Data
3.1 Company collects, processes, and stores Personal Data collected from you via client’s use of the Service
or where client has given consent.
3.2 This Personal Data may include contact details, copies of identification documentation provided by client
or derived from publicly accessible databases, government identification number as well as information
relating to devices or internet service (such as an IP address and a MAC number).Company collects
information provided during the onboarding process, which may be a completed, incomplete, or
abandoned process.
3.3 Company collects data on the client for the purpose of processing orders, managing and verifying
accounts, and promotion offers.
3.4 Company collects, uses, stores, and transfers Personal Data, which may include the following:
(i) Operating within the European Economic Area (“EEA”).
(ii) Company collects, stores, and processes personal information in accordance with the Best Practices of
the Data Collection in the EU and GDPR [General Data Protection Regulation- (EU) REGULATION
679/2016].
(iii) Types of client defined in APPENDIX A.
3.5 Right to Data Portability- Client has a right to receive his/ her Data in a coherent, structured and readable
manner.
4. Collection and Storing of Data Outside the EU
4.1 As outlined above, company may collect Personal Data from customers located in the EEA. To facilitate
the services company provides to customers located in the EEA, company requests explicit consent for
the transfer of Personal Data from the EEA to outside of the area. If client is an individual located in the
EEA and declines to consent to such transfer, client will no longer be able to use company services.
4.2 Client will have the ability to withdraw all digital assets; however, all other functionalities will be
disabled.
• BT EXCHANGE (LT) UAB & BT EXCHANGE CZ need to gather and use certain information about
individuals. These can include customers, suppliers, business contacts, employees, and other people the
organization has a relationship with or may need to contact.
• This policy describes how this personal data must be collected, handled, and stored to meet the company’s data
protection standards- and to comply with the law.
• This policy includes in its scope all data that we process either in hardcopy or digital copy, this includes special
categories of data.
This data protection policy ensures BT EXCHANGE (LT) UAB & BT EXCHANGE CZ:
● Comply with data protection law and follows good practice.
● Protects the rights of staff, customers, and partners.
● Is open about how it stores and processes individuals’s data
● Protects itself from the risks of a data breach.
5. Data Protection Law
The Data Protection Act 1998 describes how organizations- including BT EXCHANGE (LT)
UAB & BT EXCHANGE CZ - must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other
materials.
To comply with the law, personal information must be collected and used fairly, stored safely,
and not disclosed unlawfully.
The Data protection Act is underpinned by eight important principles. These say that personal
data must:
✔ Be processed fairly and lawfully.
✔ Be obtained only for specific, lawful purposes.
✔ Be adequate, relevant, and not excessive.
✔ Be accurate and kept up to date.
✔ Not be held any longer than necessary.
✔ Processed in accordance with the rights of data subjects.
✔ Be protected in appropriate ways.
✔ Not to be transferred outside the European Economic Ares (EEA), unless that country
or territory also ensures an adequate level of protection.
6. Definitions
Personal Data: Any information relating to an identified or identifiable natural person, as
defined in the Lithuanian Law on Legal Protection of Personal Data and the GDPR.
Data Subject: An identified or identifiable natural person to whom the personal data relates.
Data Controller: The natural or legal person, public authority, agency, or other body that
determines the purposes and means of the processing of personal data.
Data Processor: A natural or legal person, public authority, agency, or other body that
processes personal data on behalf of the Data Controller.
Data recipient shall mean a legal or a natural person to whom personal data are disclosed.
Disclosure of data shall mean disclosure of personal data by transmission or making them
available by any other means.
The consent shall mean an indication of will be given freely by a data subject indicating his
agreement to the processing of his personal data for the purposes known to him. His consent
with regard to special categories of personal data must be expressed clearly, in a written or
equivalent form or any other form giving unambiguous evidence of the data subject’s free will.
A third party shall mean a legal or a natural person, with the exception of the data subject, the
data controller, the data processor, and persons who have been directly authorized by the data
controller or the data processor to process data.
7. Lawful Bases for Processing Personal Data
BT EXCHANGE (LT) UAB & BT EXCHANGE CZ will only process personal data if at least
one of the following lawful bases is met:
Consent: The Data Subject has given explicit consent for the processing of their personal data
for one or more specific purposes.
Contractual Obligations: The processing is necessary for the performance of a contract to
which the Data Subject is a party or in order to take steps at the request of the Data Subject
prior to entering into a contract.
Legal Obligations: The processing is necessary for compliance with a legal obligation to which
the Company is subject.
Legitimate Interests: The processing is necessary for the legitimate interests pursued by the
Company or a third party, except where such interests are overridden by the interests, rights,
or freedoms of the Data Subject.
8. Rights of Data Subject
Company would like to assure its clients with their privacy rights under GDPR [General Data
Protection Regulation- (EU) REGULATION 679/2016] by informing them on their rights under the
mandated EU Legislation:
8.1 Right to Access- Clients have a right to request copies of their personal data.
8.2 Right to Rectification- Client has a right to request that Company corrects any information that Client
believes to be incorrect, or complete information that is incorrect in the Client's opinion.
8.3 Right to Erasure- Client has a right to request deleting his/her personal data, under conditions mandated
in Art. 17 GDPR [General Data Protection Regulation- (EU) REGULATION 679/2016].
8.4 Right to Restrict Processing- Client has a right to request restriction on his/her personal data processing,
under conditions mandated in Art. 18 GDPR [General Data Protection Regulation- (EU) REGULATION
679/2016].
8.5 Right to Object to Processing- Client has a right to object his/her personal data processing, under
conditions mandated in Art. 19 GDPR [General Data Protection Regulation- (EU) REGULATION
679/2016].
9. People, risks, and responsibilities
This policy applies to:
● The head office of BT EXCHANGE (LT) UAB & BT EXCHANGE CZ
● All branches if any of BT EXCHANGE (LT) UAB & BT EXCHANGE CZ
● All staff and volunteers of BT EXCHANGE (LT) UAB & BT EXCHANGE CZ
● All contractors, suppliers and other people working on behalf of BT EXCHANGE
(LT) UAB & BT EXCHANGE CZ
It applies to all data that the company hold relating to identifiable individuals, even if that
information technically falls of the Data Protection Act 1998. This can include:
● Names of individuals
● Postal addresses
● Email addresses
● Telephone numbers
● …plus any other information relating to individuals
10. Data Protection Risks
This policy helps to protect BT EXCHANGE (LT) UAB & BT EXCHANGE CZ from dome
very real data security risks, including:
● Breaches of confidentiality. For instance, information being given out inappropriately.
● Failing to offer choice. For instance, all individuals should be free to choose how the
company uses data relating to them.
● Reputational change. For instance, the company could suffer if hackers successfully
gained access to sensitive data.
11. Responsibilities
Everyone who works for or with BT EXCHANGE (LT) UAB & BT EXCHANGE CZ has
some responsibilities for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with
this policy and data protection principles.
However, these people have key areas of responsibility:
● The board of directors is ultimately responsible for ensuring that BT EXCHANGE
(LT) UAB & BT EXCHANGE CZ meets its legal obligations.
● The Data Protection Officer, , is responsible for:
o Keeping the board updated about data protection responsibilities, risks, and
issues.
o Reviewing all data protection procedures and related policies, in line with an
agreed schedule.
o Arranging data protection training and advice for the people covered by this
policy.
o Dealing with requests from individuals to see the data BT EXCHANGE (LT)
UAB & BT EXCHANGE CZ hold about them (also called “subject access
requests”).
o Checking and approving any contracts or agreements with third parties that may
handle the company’s sensitive data.
● The IT Manager, , is responsible for:
o Ensuring all systems, services, and equipment used for data meet acceptable
security standards.
o Performing regular checks and scans to ensure security hardware and software
is functioning properly.
o Evaluating any third-party services, the company is considering using to store
or process data. For instance, cloud computing services.
● The Marketing Manager, is responsible for:
o Approving any data protection statements attached to communication such as
emails and letters.
o Addressing any data protection queries from journalists or media outlets like
newspapers.
o Where necessary, working with other staff to ensure marketing initiatives abide
by data protection principles.
12. Marketing
12.1 Company may communicate company news, promotions, and information relating to our products and
services provided. Company may share Personal Data with third parties to help with marketing and
promotional projects, or sending marketing communications. By using our services, client accepts this
Privacy Policy and agrees to receive such marketing communications.
12.2 Customers can opt out from these marketing communications at any moment. If you do not want to
receive these communications, please send an email to [email protected]
12.3 For product related communications, such as policy/terms updates and operational
notifications, client will not be able to opt out of receiving such information.
13. General Staff Guidelines
● The only people able to access data covered by this policy should be those who need it
for their work.
● Data should not be shared informally. When access to confidential information is
required, employees can request it from their line managers.
● BT EXCHANGE (LT) UAB & BT EXCHANGE CZ will provide training to all
employees to help them understand their responsibilities when handling data.
● Employees should keep all data secure, by taking sensible precautions and following
the guidelines below.
● In particular, strong passwords must be used, and they should never be shared.
● Personal data should not be disclosed to unauthorized people, either within the
company or externally.
● Data should be regularly reviewed and updated if it is found to be out of date. If no
longer required, it should be deleted and disposed of.
● Employees should request help from their line manager or the data protection officer
if they are unsure about any aspect of data protection.
14. Data Storage
These rules describe how and where data should be safely stored. Questions about storing data
safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorized people
cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out
for some reason:
● When not required, the paper or files should be kept in a locked drawer or filing
cabinet.
● Employees should make sure paper and printouts are not left where unauthorized
people could see them, like on a printer.
● Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorized access, accidental
deletion, and malicious hacking attempts:
● Data should be protected by strong passwords that are changed regularly and never
shared between employees.
● If data is stored on removable media (like CD or DVD), these should be kept locked
away securely when not being used.
● Data should only be stored on designated drives and servers and should only be
uploaded to approved cloud computing services.
● Servers containing personal data should be sited in a secure location, away from
general office space.
● Data should be backed up frequently. Those backups should be tested regularly, in
line with the company’s standard backup procedures.
● Data should never be saved directly to laptops or other mobile devices like tablets or
smartphones.
● All servers and computers containing data should be protected by approved security
software and a firewall.
14. Personal Data Usage
14.1 Company uses Personal Data to communicate with the client and to administer, deliver, improve, and
personalize the Service. Company might also generate generic data out of any Personal Data collected and use
it for company purposes.
14.2 Company may also use such data to communicate with you in relation to other products or services offered by
company and/or its partners. Company does not share Personal Data with third parties (other than partners in
connection with their services) except where client have given consent and further detailed below.
14.3 Company may share Client Personal Data with third parties:
14.3.1 If company deems that sharing it is necessary to enforce the Terms of Service；
14.3.2 To comply with government agencies, including regulators, law enforcement and/or justice departments
14.3.3 To third parties who provide services to the company (such as administration or technical services)；
14.3.4 In connection with the sale or transfer of our business or any part thereof.
14.3.5 Additionally, company has implemented international standards to prevent money laundering, terrorist
financing and circumventing trade and economic sanctions and will implement final Virtual Financial
Asset rules and regulations when effective, which will likely require us to undertake due diligence on
our customers. This may include the use of third-party data and service providers which we will cross-
reference with your personal information.
●
15 Data Accuracy
The law requires BT EXCHANGE (LT) UAB & BT EXCHANGE CZ to take responsible
steps to ensure data is kept accurate and up to date.
The more important it is that the personal data is accurate, the greater the effort BT
EXCHANGE (LT) UAB & BT EXCHANGE CZ should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps to ensure
it is kept as accurate and up-to-date as possible.
● Data will be held in as few places as necessary. Staff should not create any unnecessary
additional data sets.
● Staff should take every opportunity to ensure data is updated. For instance, by
confirming a customer’s details when they call.
● BT EXCHANGE (LT) UAB & BT EXCHANGE CZ will make it easy for data
subjects to update the information BT EXCHANGE (LT) UAB & BT EXCHANGE
CZ hold about them. For instance, via the company website.
● Data should be updated as inaccuracies are discovered. For instance, if a customer
can no longer be reached on their stored telephone number, it should be removed from
the database.
● It is the marketing manager’s responsibility to ensure marketing databases are
checked against industry suppression files every six months.
16 Subject Access Requests
All individuals who are the subject of personal data held by BT EXCHANGE (LT)
UAB & BT EXCHANGE CZ are entitled to:
● Ask what information the company holds about them and why.
● Ask how to gain access to it.
● Be informed on how to keep it up to date.
● Be informed how the company is meeting its data protection obligations.
If an individual contacts the company requesting this information, this is called a
subject access request.
Subject access requests from individual should be made by mail. Addressed to the data
controller at [email protected]. The data controller cam supply a standard request form,
although individuals do not have to use this.
The data controller will always verify the identity of anyone making a subject access
request before handing over any information.
17 Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed
to law enforcement agencies without the consent of the data subject.
Under these circumstances, BT EXCHANGE (LT) UAB & BT EXCHANGE CZ will
disclose the requested data. However, the data controller will ensure the request is legitimate,
seeking assistance from the board and from the company’s legal advisers where necessary.
APPENDIX "A"
Definition of Clients
Individual clients:
1. Email address
2. Mobile phone number
3. Full legal name (including former name, and names in local language)
4. Nationality
5. Passport number, or any government issued ID number
6. Date of birth (“DOB”)
7. Proof of identity (e.g. passport, driver’s license, or government-issued ID)
8. Residential address
9. Proof of residency
10. Additional Personal Data or documentation at the discretion of our Compliance Team
Corporate clients:
1. Corporate legal name (including the legal name in local language)
2. Incorporation/registration Information
3. Full legal name of all beneficial owners, directors, and legal representatives
4. Address (principal place of business and/or other physical locations)
5. Proof of legal existence
6. Description of the business
7. Percentage of ownership for Individual/corporate owners
8. Contact information of owners, principals, and executive management (as applicable)
9. Proof of identity (e.g., passport, driver’s license, or government-issued ID) for significant individual
beneficial owner of the institutional customer entity
10. Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the
“Individual Customer” section above for details on what Personal Data we collect for individuals)
11. Source of wealth
