Welcome to Pixtub! We respect your privacy and are committed to protecting your personal data. This Privacy Policy (also “Policy”) explains how we collect, use, and safeguard your information when you interact with us, whether through our website, products, or services.

We are dedicated to complying with the General Data Protection Regulation (GDPR) and other relevant data protection laws. Our goal is to be transparent about the data we collect, how we use it, and the rights you have concerning your personal information.

Please read this document carefully. By using our services, you acknowledge that you have read, understood, and accepted the terms outlined in this Privacy Policy. If you have any questions or concerns about this Privacy Policy or how we handle your personal data, please contact us.

DATA CONTROLLER INFORMATION

We value your privacy and are committed to ensuring your personal data is handled with care and transparency. Under the GDPR, we act as the Data Controller for the personal data you provide to us. As the Data Controller, we determine the purposes and means of processing your personal data, ensuring it is used lawfully, fairly, and transparently.

Who We Are:

PIXTUB UAB
Registration No. 305964272
Legal address: Paliūniškio g. 13, 35114, Panevėžys, Lithuania
Email: support@pixtub.io.

If you have any questions or concerns about how we process your personal data, please do not hesitate to contact us. We are committed to safeguarding your personal data and ensuring compliance with GDPR. Thank you for trusting us with your information.

WHAT DATA WE COLLECT

We may gather the following categories of personal data:

(a) Account Information: This includes your login credentials (username and password), activity logs (e.g., login times and pages visited), account settings (preferences, language), etc.
(b) Identity Information: This consists of your full name, details of your ID documents (like ID card or passport), government-issued ID numbers, and authentication details (such as security questions and two-factor authentication data).
(c) Contact Information: This covers your phone number, email address, physical address, and any other contact details you provide.
(d) Compliance Data: This includes data required for legal compliance, such as Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), Know Your Customer (KYC), taxation and other similar measures and obligations.
(e) Representation and Company Data: This contains information related to the represented a company, such as the company name, registration number, VAT number, legal address, and other related details.
(f) Support Data: This comprises information related to issues you raise with our support team, such as descriptions of problems, troubleshooting steps, resolution status (open, resolved, pending), and related details (support tickets, communication logs).
(g) Technical Data: This includes information about the devices you use to access our services, such as device type, operating system, IP address, browser type and version, and technical settings.
(h) Transaction Data: This involves details of your orders and purchases (e.g., items purchased, order history, order status), account balance information, and transaction timestamps.
(i) Payment Data: This encompasses your payment history (dates and amounts of payments made), payment status (completed, pending, failed), and preferred payment methods (e.g., credit card information, bank account details).
(j) Communication Records: This includes records of phone conversations (call logs and recordings), chat histories (messages exchanged through our platform), and email correspondence (emails sent and received).
(k) Visitor Data: This includes data collected during visits to our physical locations, such as video surveillance footage (entrances, exits, common areas), visitor logs (names, visit times), and access control records (badge swipes, entry permissions).
(l) Marketing Data: This covers your marketing preferences (opt-in/opt-out status).

LEGAL BASES FOR PROCESSING PERSONAL DATA EXPLAINED

Under the GDPR, we are required to inform you about the legal grounds we rely on to process your personal data. The legal bases we use include:

(a) Consent: Your consent allows us to process your personal data for specific purposes. This means you have explicitly agreed to our processing of your data. Consent is typically used for:
- Sending marketing communications;
- Using cookies and similar technologies;
- Collecting data for specific optional services.

Your consent is obtained in a clear and transparent manner, and you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

(b) Contract Performance: We process your personal data when it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract. This includes:
- Managing your user account;
- Providing and delivering the services you request;
- Handling transactions and payments.

(c) Legal Obligation: We process your personal data to comply with our legal obligations. This includes:
- Anti-Money Laundering (AML) requirements;
- Counter-Terrorist Financing (CFT) measures;
- Know Your Customer (KYC) obligations;
- Compliance with tax laws and other regulatory requirements.

(d) Legitimate Interests: We process your personal data based on our legitimate interests, provided that these interests are not overridden by your fundamental rights and freedoms. Legitimate interests include:
- Improving our services;
- Securing our network and information systems;
- Fraud prevention;
- Direct marketing (in certain cases);
- Business operations and analysis.

(e) Public Task: In some instances, we process your personal data in the exercise of official authority or to perform a specific task carried out in the public interest as set out by law.

(f) Vital Interests: We may process your personal data when it is necessary to protect your vital interests or the vital interests of another person. This would typically apply in emergency situations where your life or health is at risk.

PURPOSES AND LEGAL BASES

We process your personal data for various reasons, each supported by a specific legal basis:

(a) Providing Services: To deliver the services you have requested, ensuring they are effective and meet your requirements. (Legal Basis: Contract performance)
(b) Account Management: To establish and manage your user account, ensuring you can access and use our services. (Legal Basis: Contract performance)
(c) Identity Verification: To confirm your identity and secure your account, protecting against fraud and unauthorized access. (Legal Basis: Legal obligation, legitimate interests)
(d) Legal Compliance: To comply with applicable laws and regulations, including those related to Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), Know Your Customer (KYC), and other regulatory requirements. (Legal Basis: Legal obligation, public task)
(e) Order Fulfilment: To process and complete your orders, including handling payments and deliveries efficiently. (Legal Basis: Contract performance)
(f) Transaction Management: To manage and facilitate transactions, ensuring accuracy and security. (Legal Basis: Contract performance, legitimate interests)
(g) Risk Management: To assess and manage business risks, ensuring the smooth operation of our services. (Legal Basis: Contract performance, legal obligation, legitimate interests)
(h) Fraud Prevention: To detect, prevent, and respond to fraud and other illegal activities, safeguarding our services and your data. (Legal Basis: Legal obligation, legitimate interests)
(i) Marketing: To send you marketing communications and personalized content based on your preferences, with your consent. (Legal Basis: Consent, legitimate interests)
(j) Customer Communication: To communicate with you, provide customer support, and address any inquiries or issues you may have. (Legal Basis: Contract performance, legitimate interests)
(k) Security: To protect our information systems and assets from unauthorized access, ensuring data integrity and confidentiality. (Legal Basis: Contract performance, legal obligation, legitimate interests)
(l) Technical Support: To identify and resolve technical issues, maintaining the functionality and reliability of our services. (Legal Basis: Contract performance)
(m) Service Improvement: To enhance and develop our services based on user feedback and usage patterns, ensuring they meet your evolving needs. (Legal Basis: Legitimate interests)
(n) Dispute Resolution: To manage and resolve legal claims and disputes, protecting our interests and complying with legal obligations. (Legal Basis: Contract performance, legal obligation, legitimate interests)

DATA COLLECTION SOURCES

We are committed to transparency regarding how we collect your personal data. Our data collection sources include:

(a) Direct Interactions: We collect data directly from you whenever you interact with us or our website. This includes activities such as registering an account, applying for services, or contacting us with inquiries.
(b) Indirect Interactions: We may also receive data from external sources that support our services. These sources include business partners (such as payment processors), state authorities, and publicly available resources.
(c) Cookies and Similar Technologies: We utilize cookies and similar technologies to enhance your experience on our website. These technologies help us understand your usage patterns, remember your preferences, and improve our services. For more detailed information, please refer to our Cookie Policy available on our website.

We strive to ensure that all data collection processes respect your privacy and adhere to relevant data protection regulations.

DATA NECESSITY

Certain data is mandatory for our services, and it will be marked accordingly. Optional data can be controlled through settings and provided in line with your preferences. Non-provision of optional data does not affect your access to our services.

DATA SHARING

We may share personal data with trusted partners to provide our services and with state authorities to comply with legal requirements. Please rest assured that we never sell personal data.

DATA RETENTION

We are committed to retaining your personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws. Our data retention policy includes the following key points:

We keep your data for the duration needed to achieve the purposes outlined in our Privacy Policy. Additionally, we store your data for as long as there are ongoing legal or transactional relations with you. This ensures that we can provide you with continuous service and meet any contractual obligations. Certain legal requirements, such as those related to Anti-Money Laundering (AML) regulations, mandate that we retain data for up to 5 years. In other situations, we establish retention periods based on our business needs and legal responsibilities, often aligning with statutory limitation periods for potential claims against us, which may extend up to 10 years.

Once the relevant retention period has expired, we take appropriate measures to ensure your data is handled securely. This involves either securely deleting the data or anonymizing it to protect your privacy. We strive to handle your personal information with the utmost care and respect, ensuring compliance with all relevant legal and regulatory requirements.

SECURITY MEASURES

The protection of your personal data is of utmost importance to us. We implement a variety of measures to safeguard your information, including:

(a) Encryption: We use advanced encryption methods to secure your data during transmission and storage, ensuring protection against unauthorized access.
(b) Regular Training: Our employees receive ongoing training on data protection and privacy best practices to maintain awareness of their responsibilities and the significance of data security.
(c) Access Controls: Strict access controls are in place to ensure only authorized personnel can access your data. This includes multi-factor authentication and role-based access permissions.
(d) Security Audits: We regularly perform security audits and assessments to detect and address potential vulnerabilities in our systems and processes.
(e) Data Minimization: Adhering to the principle of data minimization, we collect only the data necessary for our purposes and retain it only for the required duration.
(f) Incident Response: We have an incident response plan to quickly address and mitigate any data breaches or security incidents.

To further protect your data, we recommend you take at least the following steps:

(1) Use Strong Passwords: Create unique, complex passwords for your accounts and update them regularly.
(2) Enable Two-Factor Authentication (2FA): Add an additional layer of security to your accounts by enabling 2FA where available.
(3) Be Vigilant: Stay alert to phishing attempts and avoid sharing your passwords or personal information with untrusted sources.
(4) Keep Software Updated: Regularly update your devices and software to guard against security vulnerabilities.

By taking these precautions, you can help ensure the security of your personal information.

INTERNATIONAL TRANSFERS

In certain circumstances, it may be necessary for us to transfer your data outside the European Union (“EU”) and the European Economic Area (“EEA”) to achieve the purposes outlined in this Policy. We want to assure you that any such international transfers are conducted with the utmost care and in strict compliance with the General Data Protection Regulation (“GDPR”) as well as all other applicable laws concerning personal data protection and information security.

To ensure your data is protected during these transfers, we employ several mechanisms. These include Standard Contractual Clauses (SCCs) approved by the European Commission and adequacy decisions for countries that provide an adequate level of data protection. Your privacy and the security of your information are our top priorities.

YOUR RIGHTS

As a valued user, you have several rights regarding your personal data, which we are committed to upholding:

(a) Access: You have the right to request access to your personal data.
(b) Rectification: You can request corrections to any inaccurate or incomplete data we hold about you.
(c) Erasure: You may request the deletion of your personal data under certain conditions.
(d) Restriction: You can ask us to limit the processing of your personal data in specific circumstances.
(e) Objection: You have the right to object to certain uses of your personal data, including for direct marketing purposes.
(f) Data Portability: You can request the transfer of your personal data to another service provider where technically feasible.
(g) Withdrawal of Consent: If you have given consent for the processing of your personal data, you have the right to withdraw it at any time. Please note that the revocation of consent does not affect the legality of the processing based on the consent before its withdrawal.

To exercise any of these rights, please contact us at support@pixtub.io.  We are here to assist you.

Please note that the exercise of certain rights may be subject to legal requirements and verification of your identity. Upon receiving your request, we will inform you of any applicable restrictions or conditions that may apply. Your privacy and trust are paramount to us, and we are committed to handling your requests with the utmost care and respect.

AUTOMATED DECISIONS

We want to assure you that we do not make any automated decisions that have legal or similarly significant effects on you. However, we may use profiling techniques to personalize your experience and provide you with content and services that are better tailored to your preferences and interests.

COMPLAINTS

We value your feedback and are committed to addressing any concerns you may have regarding your personal data or this Privacy Policy. If you have any complaints, questions, or issues, please do not hesitate to contact us. We will make every reasonable effort to resolve your concerns promptly and efficiently.

Should you feel that your concerns have not been adequately addressed or contacting us first is not feasible for any reason, you have the right to lodge a complaint with the relevant supervisory authority. For residents of Lithuania, this is the Lithuanian State Data Protection Inspectorate.

UPDATING THIS POLICY

We may update this Privacy Policy to reflect changes in our practices or applicable laws. The latest version will always be available on our website (https://pixtub.io). Please review this Policy periodically for any updates. If there are significant changes, we may notify you using the contact details you provided. Your continued use of our services after the effective date of any changes constitutes your acceptance of the revised Policy.

CONTACT US

If you have any questions, require further information, or would like to discuss any aspect of this Privacy Policy, please do not hesitate to reach out to us. You can contact our support team at support@pixtub.io. We are here to assist you and ensure that your inquiries are addressed promptly and thoroughly.
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