LAST REVISED: December 21, 2022
• who we are;
• when we collect your personal data;
• how we collect your personal data;
• what personal data we collect about you;
• why we process your personal data;
• with whom we share your personal data;
• for how long we store your personal data;
• what your rights are;
• Contact and complaints; and
1. WHO WE ARE
Tirnu,UAB. Registration Code:306119815. Registered in Lithuania. Tirnu Ltd is a company registered in England and Wales with the registered company number 13920973 and its registered address 71-75 SHELTON STREET, COVENT GARDEN LONDON WC2H 9JQ.
Tirnu has created the Tirnu App and the Tirnu web platform (jointly the “Platform”) through which customers in the European Economic Area can access and use a personal payment account and use virtual and physical card services for the purpose of, among other things, enabling transactions with electronic money.
We have partnered with Intergiro Intl AB (“Intergiro”), a Swedish fintech company that provides electronic money account services and payment card services. Intergiro provides payment services and we provide you with a first class Platform through which you access and use the payment services.
You sign up with Tirnu and within our Platform you apply to become a customer of Intergiro to utilise the Card Services. Generally you are provided with a payment account and a payment card. You can read more about the payment services in the Tirnu Terms and Conditions. You need to accept the Tirnu Terms and Conditions and if you are onboarded as a customer of Intergiro in accordance with such terms and conditions, you will be able to access and use the payment services using our Platform. When you use the Card Services within our Platform, Intergiro will process your personal data.
2. WHEN WE COLLECT YOUR PERSONAL DATA
Tirnu will start processing your personal data when you register your Tirnu account.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data about you from different sources, including:
(i) personal data received from you, such as when you sign up for a platform account, including contact information;
(ii) personal data about you received from external sources, e.g. third party service providers and partners, or if you sign up using Google or Apple;]
(iii) personal data that is shared with us by Intergiro, mainly customer support information which we need to be able to assist you with customer support matters but also personal data related to your use of Intergiro’s payment services;
4. WHAT PERSONAL DATA WE COLLECT
We have divided the personal data we process into the following categories:
(i) Contact information – such as name and other information about yourself (e.g. address, telephone number, e-mail address, etc.);
(ii) Information about how you interact with Tirnu – for example how you use the Tirnu account;
(iii) Device information – for example IP address, language settings, browser settings, time zone, operating system, platform and screen resolution;
(iv) Customer support information – information that you provide to our customer support so we can help you with resolving your enquiries.
5. WHY WE PROCESS YOUR PERSONAL DATA
According to the GDPR we need to have a purpose and a legal basis for the processing of your personal data. Read more about our purpose for processing your personal data below.
At Tirnu, the legal basis for processing your personal data is either:
(i) the agreement you have, or is about to enter into, with us by accepting our terms and conditions or, the agreement you have, or is about to enter into, with the Intergiro by accepting Intergiro’s terms and conditions;
(ii) legal obligations we are bound by, such as to comply with bookkeeping laws, and to prevent fraud and misuse of our services; or
(iii) our legitimate interest, such as providing customer support or keeping you informed about product updates.
In very rare cases we may also process your personal data if we have received your explicit consent to do so. In such a case you can always withdraw your consent at any time.
We use the personal data we collect for the following purposes:
the administration and management of our relationship with you, such as reviewing your application to become Tirnu’s customer, setting up your platform account, conducting performance analytics and keeping you informed about product updates;
The legal basis for such processing is (i) the agreement you have entered into, or is about to enter into, with us or (ii) our legitimate interest. Our view is that keeping you up to date on the products and services available to you creates meaningful knowledge to you.
provision of our services, updates, security alerts and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, the Platform and to enforce our Terms & Conditions and other policies;
The legal basis for the provision of our services is the agreement you have entered into with us.
accounting and auditing requirements;
The legal basis for such processing is mandatory law, such as the Swedish accounting act (Sw. bokföringslagen) and the Swedish annual reports act (Sw. årsredovisningslagen).
business development, such as compiling statistics and analysing the data in order to improve our services;
The legal basis for such processing is our legitimate interest in maintaining our relationship with you and to improve our services. Our view is that you as our customers benefit from improvements to the services;
assess or defend legal claims against us or to protect ourselves from fraud and in connection with a reorganisation, transfer of business, merger, IPO or acquisition.
The legal basis for such processing is our legitimate interest to defend us against legal claims, to protect our company from fraud, and to be able to reorganise or scale-up our business.
6. WITH WHOM WE SHARE YOUR PERSONAL DATA
We may share your personal data with our affiliates and trusted third party service providers in order to be able to provide our services. These trusted third party service providers may include services of delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your personal data. Where any of your personal data is required for such a purpose, we undertake steps to ensure that your personal data is processed in accordance with the requirements of the applicable data protection laws.
We also share data with our other trusted third party service providers, who act as our processors:
Suppliers of IT systems and cloud services
Third-party investigators, authorities, or law enforcement bodies when required
We have carefully reviewed our service providers and secured that their processing of your personal data is compliant with EU standards and the GDPR.
Your personal data will also, when applicable, be shared with the following parties which themselves are data controllers of the processing of personal data:
Intergiro, for the purposes of providing the second line customer support to you
The legal basis is the agreement you have entered into with Intergiro
The legal basis is the agreement you have entered into with Intergiro
We are sometimes required to share personal data with parties operating outside the EU. In these cases, we ensure that the data is transferred in accordance with the applicable requirements of the GDPR, primarily the standard contract clauses (SCC) and complementary safety measures, or if available, other means in compliance with the GDPR.
If Tirnu engages in a merger, acquisition, reorganisation or sale of some or all of Tirnu’s assets or shares, financing, initial public offering or similar transactions or proceedings, or steps in contemplation of such activities (such as due diligence), Tirnu may share personal data with third parties, subject to standard confidentiality arrangements.
7. FOR HOW LONG?
We store your personal data for the purposes set out above during the term of our contractual relationship with you, for as long as we otherwise have a meaningful contact with you or as may otherwise be required by law.
When the purpose for which your personal data was collected is no longer relevant, we will stop processing your personal data and either delete or anonymise it in a secure manner. We may retain your personal data for a longer period of time to the extent required by law, by our automated disaster recovery backup systems or if we deem it necessary to assess or defend legal claims.
Under mandatory law, we are required to keep your personal data due to:
* Bookkeeping legislation, for a period of seven years.
8. YOUR RIGHTS
As a data subject, you have the right to request access to and information about the personal data that we process about you. Additionally, you may also request that we correct (rectify), complete, erase or restrict the processing of personal data regarding you. You also have the right to request a copy of the personal data we process regarding you free of charge. For any request in accordance with these rights email us at request@Tirnu.com.
Where Tirnu processes your personal data on the legal ground of consent or fulfilment of contract, you have the right to data portability which means that you can receive the personal data in a commonly used, structured and machine-readable format and you have the right to transfer it to another controller.
You have an absolute right to object to personal data processing done for the purposes of direct marketing.
9. CONTACTS AND COMPLAINTS
Please be informed that you have the possibility to lodge a complaint with a supervisory authority if you are not satisfied with our processing of your personal data. You may find your local supervisory authority by following this link: