Privacy policy
Effective as of: May 1, 2024
Most recent update: May 1, 2024
There are no previous versions of the Privacy Policy.
Lamp is committed to protecting your privacy.
This Privacy Policy (the Policy) describes the type of information we collect, how we use it, with whom we may share it, and choices you can make. We also describe the things we do to protect the security of your information and how you can contact us about our privacy practices.
This Policy conforms to the General Data Protection Regulation (GDPR) requirements in the European Union.
This Policy applies to Lamp Account UAB and our affiliates (Lamp, we or us). It applies to all the products and services offered by Lamp including on our website (the Website) and mobile and web applications (the App) and/or technology platform (collectively, the Services) to users.
When you sign up for an account with Lamp, we may collect, use and provide your personal information to [ ], [ ], [ ] or other partner companies (collectively, the Partners) to facilitate the provision of the Services.
Regulatory requirements in the countries in which we operate require our Partners to provide notice to users to explain what personal information they collect, how they share it, and how users may limit our Partners’ sharing of the information. The privacy practices of our Partners are subject to their privacy policies, which we strongly suggest you review. Lamp is not responsible for our Partners’ information practices or privacy policies.
You should read this Policy together with our other agreements in respect of the Services (the Agreements), which you can find on the Website and in the Apps.
General terms
1.0 Data Controller. The Data Controller is Lamp Account UAB, with company code 306695743 and with registered address at T. Narbuto Street 5-1, 08103, Vilnius, Lithuania.
1.1 This Policy sets out the basis on which we process customers’ (Customers or you) personal data (the Data), which is applied by our internal policies and procedures. Since we collect and use your Data, we are obligated to use and process this Data only in accordance with this Policy and the applicable laws which regulate the protection of your Data.
1.2 Where the Customer is a legal entity, the Customer’s representative who seeks to enter into a relationship with Lamp is under an obligation to inform relevant Customer shareholders or employees (for example, a director or beneficial owner) that their Data will be transferred to us and to provide them with a copy of this Policy.
1.3 Profiling by automated means. This profiling may be used when processing Data for some Services as well as for the purposes of risk management in accordance with Lamp’s legal obligations. Profiling may also be used for our internal assessment and analysis. In the event that a decision is based on automated processing including profiling, you have the right to contact us and provide your objection to such a decision.
Principles in relation to Data processing
2.0 Lamp complies with GDPR provisions as well as the Law on Legal Protection of Personal Data of the Republic of Lithuania.
2.1 This Policy sets out the measures we take to achieve the protection of the Data that is processed for the provision of the Services.
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Data is collected for specified and legitimate purposes and will not be further processed in a way that is incompatible with those purposes established prior to the collection of Data.
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Data is processed in a lawful, fair and transparent way.
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Data is intended to be accurate and updated when necessary.
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Data is stored for the period specified in this Policy and not longer than terms set forth by applicable legal acts. When the storage term has expired, the Data will be destroyed.
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We implement organisational measures designed to secure Data against accidental or illegal destruction, modification, disclosure, and any other illegal acts.
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We implement measures for the prevention of the use of Data by persons seeking to acquire it by fraudulent means.
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The Data is considered as confidential information and may only be disclosed to third parties in accordance with the rules and procedure provided in the Policy and by law.
Legal basis for Data processing
3.0 We only process Data in the circumstances set out below.
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You have given your consent.
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It is necessary in order to fulfil the Agreements to which you are a party.
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It is necessary to take action at your request prior to the entry into force of an Agreement.
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In respect of our legal obligations.
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In the case of our legitimate interest.
3.1 Data processing purposes are as set out below.
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The provision of Services, directly or through a Partner.
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The execution of Agreements.
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The provision of customer support, including responding to questions, feedback, complaints, and the provision of the information in relation to the Services.
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In relation to our legal obligations for anti-money laundering and terrorist financing prevention, including in relation Customer identification, verification of identity, verification of Customer’s data against registries and databases, ongoing monitoring of the Customer’s activity, risk assessment and analysis, risk management activities, inspections of the complex or unusually large transactions and unusual transaction structures.
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In relation to our risk management processes, including data processing for fraud prevention.
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The administration of data of potential customers, including improving the quality of our Services.
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In relation to legal action we may need to take to protect ourselves or you.
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In relation to our marketing activities.
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In order to answer your requests to us.
3.2 Data collected for marketing may be processed only where you give your clear consent. Marketing includes all activities by which Lamp offers its Services to you by post, telephone or direct electronic means. In the event that you refuse to give your consent, your Data will not be processed for marketing purposes. This may mean that you will not eligible for offers from our merchant partners, including rewards.
3.3 You have the right to withdraw your consent in relation to the processing of the Data for marketing purposes. You may withdraw your consent at any point in time by contacting us in the App or via email. See the section How to Contact Us below.
4.0 We collect information about you from different sources and in various ways when you use our Services, including:
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Information you provide directly.
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Information collected automatically.
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Information from third-party data sources.
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Data we infer or generate from other data, including by using artificial intelligence methods.
4.1 The types of personal information we may obtain about you include:
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Identifiers such as your name, date of birth, nationality, postal and email address, and phone number.
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Government-issued photo identity documents, such as a passport, identity card or driver’s license; photograph; and proof of address documentation (such as a utility bill).
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Your political status, if any (including whether you could be designated a politically exposed person).
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Your employment and education data.
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Login credentials for your Lamp account.
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Financial information, including your account details from our Partners, Lamp account transaction history, and information about your linked non-Lamp financial accounts.
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Physical characteristics, demographic information and similar details present in documents you provide (e.g., government-issued identity documents).
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Commercial information, including interest in a product or service, purchasing or consuming tendencies, and receipts or records of purchase or enrolment in Services.
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Voice recordings (such as when you call Lamp’s support desk).
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Biometric information (including a facial image).
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Information you provide through support services interactions and that you provide about your experience with Lamp, including via questionnaires or other feedback.
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Geolocation data.
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Information provided by identity verification and fraud prevention software providers.
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Information provided by marketers and other websites on which Lamp advertises or which are related to our Partners and merchant partners.
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Information you provide through contacts integration, including a list of contacts from your phone’s operating system.
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Other information you choose to provide to us.
4.2 We may infer new information from other data we collect, including using automated means or artificial intelligence methods to generate information about your likely preferences or other characteristics.
Information collected by automated means
5.0 When you visit our Website, we may obtain certain information by automated means, such as cookies, web beacons, web server logs, IP addresses and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits, among other data.
5.1 When you use our App, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, referring emails and web addresses, dates and times of usage, actions taken on the App, and other information regarding use of the App. We may collect your device’s geolocation information. Your device’s operating platform may provide you with a notification when the App attempts to collect your precise geolocation. Please note that if you decline to allow the App to collect your precise geolocation, you may not be able to use all of the App’s features, such as reward offered by our merchant partners.
5.2 We may use these automated technologies on our Services to collect information about your device, browsing actions and usage patterns. These technologies help us to do the following:
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Remember your information so you do not have to re-enter it.
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Track and understand how you use and interact with our Services.
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Customize the Services for your preferences.
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Measure the performance of our Services.
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Manage and enhance our Services.
5.3 Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note that without these technologies, you may not be able to use all of the features of our Services, particularly those related to rewards from merchants or the location of merchants who accept payment by Lamp. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
How we use the information we collect
6.0 We use the personal information we collect for purposes described in this Policy or as otherwise disclosed to you. For example, we use personal information for the following reasons:
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Provide the Services.
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Process and fulfil transactions.
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Create and maintain Lamp accounts.
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Personalise your experience with us.
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Understand your needs better.
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Facilitate transfers between external bank accounts and Lamp accounts.
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Verify your identity.
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Respond to your inquiries.
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Determine your eligibility for, and administer your participation in, certain features of the Services.
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Facilitate and manage referrals from business partners and third-parties.
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Identify recipients and facilitate transfers.
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Advertise and market Services, including by using artificial intelligence methods, and to send you information about products and services from our merchant partners.
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Provide you targeted offers and notify you of the locations of our merchant partners where you may use our Services.
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Provide you with guidance and recommendations, which are for you to decide if this is best for you.
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Provide member support and quality assurance, and conduct customer service training.
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Collect fees and other amounts owed in connection with your Lamp account.
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Operate, evaluate and improve our business.
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Maintain and enhance the safety and security of our Services and prevent misuse.
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Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities.
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Exercise our rights and remedies and defend against legal claims.
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Comply with and enforce applicable legal requirements, requests from our Partners, relevant industry standards and Lamp policies.
Types and sources of processed Data
Analytics services
7.0 We may use analytics in relation to our Services. For example, we use Google Analytics to better understand how you interact with our Website. We also use Google Maps to better understand how our Services are used and to provide you with a map of nearby merchant partners. The information we obtain through our Services may be disclosed to or collected directly by these third parties.
7.1. These analytics may include the use of artificial intelligence methods.
Interest-based advertising
8.0 In relation to our Services, we may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests.
8.1 You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services may track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information advertising services may collect includes data about your visits to websites that serve Lamp advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both in relation to our Services and on third-party websites and apps that participate in these ad services. This process also helps us track the effectiveness of our marketing efforts.
8.2. To learn how to opt out of interest-based advertising, see our “Your choices” section below.
Information we share
9.0 We may share the information we obtain about you with the following:
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Our affiliates.
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Our Partners.
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Our merchant partners.
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Other Lamp users (including in connection with rewards, member referrals and use of the transfer service).
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Other companies in connection with co-branded products, services or programs.
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Joint marketing partners.
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Research study partners, including in relation to artificial intelligence.
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Consumer reporting agencies.
9.1. We also may share the information we obtain about you with vendors and other entities we engage to perform services on our behalf.
9.2. We also may disclose personal information about you in the following circumstances:
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If we are required to do so by law or legal process (such as a court order or subpoena).
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In response to requests by government agencies, such as law enforcement authorities.
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To establish, exercise or defend our legal rights.
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When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss.
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In connection with an investigation of suspected or actual illegal activity.
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Otherwise with your consent.
9.3. We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganisation, divestiture, dissolution or liquidation).
Transfer of Data
10.0 Your Data may be transferred to those entities set out below.
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Lamp’s Partners.
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Payment service users (payees and payers).
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Financial institutions or their agents.
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The European Central Bank, The Bank of Lithuania, or the Swift or SEPA payment organisations.
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Debit card processing service providers, including Visa.
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Identity verification service providers.
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Software development and support services providers.
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Transaction monitoring service providers.
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Risk management tools providers.
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Website domain hosting providers.
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Cloud service providers.
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Accounting and auditing companies.
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Law enforcement entities, in situations where Lamp is required by law to do so.
10.1. Data may be transmitted to third parties not specified above for specified and legitimate purposes only, and only to third parties who have the right established by laws and other legal acts to receive personal data in the countries of the European Union and the European Economic Area (EEA).
10.2. In some cases, the processing of Data described above may involve sending it to countries outside of the EEA. In such circumstances, Lamp will take all reasonable steps to ensure that the Data is treated securely and in accordance with this Policy.
Data retention period
11.0 Lamp stores Data for no longer than is required.
11.1. Data is stored for a maximum of 10 years after the termination of a business relationship in order to comply with legal obligations and protect our legitimate interests. Such records include copies of identity documents, the identity data of a beneficial owner, the identity data of a beneficiary, direct video streaming/direct video broadcasting recordings, other data received at the time of establishing the identity of the Customer and account and/or agreement documentation.
11.2 Correspondence with the Customer in paper or electronic form is stored for 5 years from the date of termination of a business relationship.
11.3 Consent for marketing is valid until such time as you withdraw it or when the business relationship ends.
11.4 Recorded phone calls (for example, calls to the support desk) are stored for up to 10 years after the recording date.
11.5 Video recordings from cameras on Lamp’s property are kept for 60 calendar days.
In the event that a transaction was not concluded (for example, if no agreement is signed by both parties or a business relationship is not started), Data in relation to potential customers are kept for no longer than 2 years. This is due to the 2 year limitation period for filing a complaint with the Data Protection Authority, from the date of receipt of the data, unless the Data subject has provided a written request for the destruction of the Data processed by the Company.
Cookies
12.0 Cookies are small text files, often including unique identifiers, which are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.
12.1 We may use cookies on our Website (including the Web App) to provide you with information, including the Services. We may use the following types of cookies:
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Strictly necessary cookies. These cookies are essential for the Website to function properly. These cookies ensure basic functionalities and security features of the Website, anonymously. These cookies are mandatory and cannot be switched off.
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Functionality cookies. These cookies help to perform certain functionalities like sharing the content of the Website on social media platforms, to collect feedback, and other third-party features.
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Analytical cookies. These cookies are used to understand how visitors interact with the Website. These cookies provide information about the number of visitors, bounce rate, traffic source, etc. No sensitive personal information is collected through these cookies. None of this information can be used to identify or contact the Customer.
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Performance cookies. These cookies are used to understand and analyse the performance of the Website, which helps in delivering a better usage experience for visitors.
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Marketing cookies. These cookies provide visitors with relevant advertising and marketing campaigns. These cookies track visitors across websites and collect information to provide customised advertising.
12.2. The list of cookies we use is displayed on the cookie banner on the Website.
12.3 You can choose to consent or not consent to the use of various cookies.
How we protect personal information
13.0 We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorised access, destruction, loss, alteration, disclosure or use. To help us protect personal data, we request that you only ever access the App by using facial recognition technology (to scan your face).
Links to third-party services and features
14.0 Our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy disclosures of these parties, which we strongly suggest you review. We are not responsible for these third parties’ information practices.
Children’s privacy
15.0 Our Services are not directed at children and you must be 18 or older to open an account with us.
Your rights
16.0 In accordance with statutory regulations on data protection, you have the right to access all Data that has been collected by Lamp and a right to have such Data rectified if such Data is inaccurate or incomplete.
16.1 At any time, you may exercise the rights set out below.
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Right of access. You have the right to obtain confirmation from us about whether or not your Data is being processed, and, where that is the case, access such Data.
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Right of rectification. You have the right to request that we rectify inaccurate Data about you. You can also request that any incomplete Data be completed. We may need to verify the accuracy of any new Data that you provide to us.
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Right to restrict processing. You have the right to request that the processing of your Data be restricted, provided that you can provide a legitimate reason. Where processing has been restricted, such Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the EU or of a Member State.
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Right to data portability. You have the right to receive all Data concerning you that you provided to us. You also have the right to transmit your Data to another data controller.
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Right to be forgotten. You have the right to request that we erase all Data concerning you if there is no good reason that we continue to process it. We may not, for specific legal reasons, always be able to comply with such requests. In such cases, we will inform you of such inability at the time of the request.
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Right to object. You have the right to object at any time to the processing of Data about you which is processed for the purposes of our legitimate interests.
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Right to withdraw consent. You have the right at any time to withdraw your consent that we use of your Data. This will not, however, affect the legality of any processing that was carried out before you withdrew your consent. In some cases, in the event that you withdraw your consent, we may not be able to provide the Services to you.
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Right to submit applications. You have the right to submit applications directly to the State Data Protection Inspectorate (Lamp’s supervisory authority for the protection of personal data) for any issues that arise in respect to the processing of the Data. You may apply in accordance with the procedures for handling complaints that are established by the State Data Protection Inspectorate.
16.2. You can submit any inquiry about the processing of your Data by contacting us as described below. We undertake to ensure that all information requested will be provided within 30 calendar days from the day the request was first received.
Your choices
17.0 We offer you certain choices in connection with the Data we collect from you. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as described below.
17.1. If you are a Lamp member, you may update some of your account details and settings by logging into your account in the App.
17.2. Communications preferences. You can choose to not receive certain promotional communications from us by following the “unsubscribe” hyperlink at the bottom of promotional emails or by replying “STOP” to promotional texts. These choices do not apply to certain informational communications, including certain surveys and mandatory service communications. If you decide you do not want to receive push notifications from Lamp, you can use the settings on your mobile device to turn them off. We also offer push notifications on certain web browsers, which can also be turned off on your browser’s settings.
17.3. Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
17.4. Mobile advertising identity documents controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising identity documents. You can change your preferences on your device.
Updates to the Policy
18.0 We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our personal information practices. Updates will be communicated to you via the Apps and via email.
18.1. We indicate at the top of the Policy when it was most recently updated.
How to contact us
18.0 You can update your privacy preferences directly in the Lamp App.
18.1. You can also update your preferences, ask us to remove your information from our mailing lists, submit a request or ask us questions about this Policy by contacting us at support@lampaccount.com.