Solaris Privacy Policy

Solaris is the brand name for the regulated entities Contis Financial Services Limited and UAB „Finansinės paslaugos „Contis“, which are part of the Solaris Group.

Contis Financial Services Limited and/or UAB “Finansinės paslaugos „Contis“ (“we”, “us” or “our”) is committed to protecting and respecting your privacy.

This policy together with our Terms and Conditions for your account and any other documents referred to in them, sets out the basis on which any personal data will be processed by us. We may collect personal data from you on any Websites or Apps we, or our distributors provide, or when you communicate with us by email, telephone or post.

We will be the data controller of your personal data which you provide to us, or which is collected by us about you. This means that we are responsible for deciding how we hold and use personal data about you and that we are required to notify you of the information contained in this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The terms and conditions of your account will identify which company is the controller of your personal data.

We may be provided with this data by a distributor of ours who provides the website or app for the purposes of applying for the account and providing some account services. The distributor is an independent data controller and will also be acting as a processor of ours. For further information as to the type of personal data we share with the distributor and the uses made by them of that data see the data sharing section of this policy below. You should also read the distributor privacy policy which is available on their website or app. The distributor is the company with whom you have applied for your account and/or card.

If you have any queries, you can contact us using the details provided at the end of this policy in the “Contacting Us” section.

Ensuring the lawful use of your personal data

We will only use your personal data where we have a lawful basis to do so. We will usually only use your data:

where it is necessary for us to enter into and/or perform a contract with you (for example, to create your account and provide our services to you).
in a way which might reasonably be expected as part of running our business, and which does not materially impact your interests, rights or freedoms. For example, we might collect technical information about you when you visit our Website or App to improve your experience on our Website or App. Please contact us using the details below if you would like further information about this.
to comply with our legal obligations. For example, to pass on details of people who are involved in fraud and to carry out anti-money laundering checks.
In some cases, where you have consented to us using your data, for example, where you subscribe to our email newsletter.

Further details of how we will use your personal data are provided below.

What information we collect from you and how we use it

When you apply to create an account on the Website or App, we will need to collect some or all of the following details about you:

Name
Residential addresses (current and previous)
Nationality
Citizenship
Country of birth
Business name
Business address
Date of birth
Occupation and/or employment status
Gender
Email address
Telephone numbers
ID document numbers such as passport, driving licence or ID card.
Image or photo of you
Anticipated activity
Purpose of account

We will use this information for the purposes of processing your application and, if your application is successful, creating and managing your account and providing any products or services you request to you. If you have consented, we will also send our newsletter to you by email.

You will not be able to apply to create an account or order products or services from us without providing the mandatory elements of this information which will be requested as part of your specific account application.

This information may be provided to us by the distributor, we will become data controller of this information once we receive it from them.

Fraud and money laundering checks

In order to process your application and before we fulfil your order and provide services, goods or financing to you, we will use the information you provided to create your account to undertake checks for the purposes of preventing fraud and money laundering, and we may need to verify your identity. This may involve sharing your personal data with fraud prevention agencies. We will continue to carry out these checks on a regular basis while you are a customer of ours.

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to eight years.

We may also carry out additional checks on you and your payment instructions using third parties. See disclosures of your information section for more information.

Automated decisions

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if:

our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or is inconsistent with your previous submissions; or
you appear to have deliberately hidden your true identity.

You have rights in relation to automated decision making: if you want to know more, please contact us using the details below.

Consequences of processing

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details below.

Other than the automated processing set out above, we shall not carry out solely automated decision-making using your personal data.

When you contact us

When you contact us, we will need to collect personal data about you to verify your identity before we disclose any information to you, for data security purposes. We will be unable to deal with your query unless you provide the information we request. We may also collect any other personal data you choose to provide to us when communicating with us. We will only use that personal data for the purposes of dealing with your enquiry.

How we use data about you, for what purpose and legal basis

We use your personal data for various purposes connected with your use of the account and services. We will only do so where we have a lawful basis to do so. We will usually only use your data:

where it is necessary for us to enter into and/or perform a contract with you. For example, to create your account and provide payment services to you.
in a way which might reasonably be expected as part of running our business, and which does not materially impact your interests, rights or freedoms. For example, to improve how we manage and process your payments.
to comply with our legal obligations. For example, to pass on details of people who are involved in fraud and to carry out anti-money laundering checks.

We use your personal data for the following purposes:

to create and manage your account with us;
to process payment transactions from and to your account;
to carry out the required checks on your identity and monitor your use of your account to check for fraud;
to facilitate your use of your account;
to communicate with you and provide you with customer support; and
to share information with our suppliers and other third parties (such as banking institutions, payment facilitators, and card operators) where required.

find out more…

The table below sets out further information about the purposes for which we use data about you, with the corresponding methods of collection and legal basis that we rely upon for its use.

Purpose	Lawful basis for processing
Creating and managing your account to apply and create your account to administer and manage your account to retain your account profile information	To fulfil our contractual obligations to you in providing the account and services. Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us.
Carrying out identification and fraud checks to carry out the required checks on your identity and enable you to use your account and card	To fulfil our contractual obligations to you in providing the account and services correctly. Our legitimate interests in operating and improving our services to you and how we deal with financial crime. Our legal obligations to comply with regulations that apply to us.
Facilitating your use of your account and card to administer your financial transactions (e.g., payment, refunds, cashback, transfers, etc.) to provide details of your transactions to retain records of your transactions and spending activities	To fulfil our contractual obligations to you in providing the account and services. Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us.
Monitoring your use of the account and card to detect fraudulent behavior to detect, and prevent financial crime to satisfy our legal and regulatory obligations to manage risk for us, you and our other users	To fulfil our contractual obligations to you in providing the account and services correctly. Our legitimate interests in operating and improving our services to you and how we deal with financial crime. Our legal obligations to comply with regulations that apply to us.
Communicating with you and providing you with customer support to investigate your complaint or query to inform you of important information or changes to your terms and conditions	To fulfil our contractual obligations to you in providing the account and services. Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us.
Sharing data with our suppliers and other third parties (such as banking institutions, payment facilitators, and card operators) where required see the Disclosures of your information section for more information	To fulfil our contractual obligations to you in providing the account and services. Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us.
Sharing data with the distributor in order for them to: administer, manage & provide the Website and/or App, manage their relationship with you and deliver relevant content to you analyse and develop other products and services provide customer support to you regarding the account, card and payments	To fulfil our contractual obligations to you in providing the account and services. Our legitimate interests in operating and improving our services to you. Our legal obligations to comply with regulations that apply to us.

Creating and managing your account

to apply and create your account
to administer and manage your account
to retain your account profile information

To fulfil our contractual obligations to you in providing the account and services.

Our legitimate interests in operating and improving our services to you.