Date last revised: July 13, 2022
UAB GMALL, company code 302432563, the company established and operating under the laws of the Republic of Lithuania, address Olimpieciu str. 1-23, LT-09235 Vilnius, Republic of Lithuania, as well as or any of our affiliates (we/us/our). We are committed to protecting and respecting your personal data and your privacy. We recognise that your personal data is your property and that you have provided it to us for specific purposes.

1.1 This Policy, together with our General Personal Data Processing Rules (Rules) and other our contractual documents, explains how any personal data we collect from you, that you provide to us, or that we receive indirectly from third parties (e.g. persons that may represent you, registers, state authorities, etc.) will be processed by us or any processor on our behalf.
1.2 Please read this Policy carefully. Terms used within it shall have the meaning(s) given in the European General Data Protection Regulation (Regulation), as applicable.
1.3 This Policy apply to your use of the website (Website) once you have visited or by registering for user account with us (Account) or by getting any of the services accessible through the Website, you accept the practices described in this Policy.
1.4 Any changes we make to this Policy will be posted on Website and you will be notified when you next visit the Website. You are advised to check back frequently as any changes will be binding on you when you continue to use the website after the date of the relevant change.
1.5 For more information relating to your rights under this Policy, please see section 10.
1.6 If you have any queries relating to this Policy, please contact us at

2.1 We operate the website and we process your personal data together with other group companies (further in this Policy together referred as “we”).
2.2 Your data will be processed on our behalf by subcontractors that we use for carrying out our activities and provision of services that you requested (for example, couriers, payment services, hosting a website and an information technology system, etc.) (Subcontractors). The subcontractors process your data only exclusively in the framework of the latter’s activities. The Subcontractors are not authorised to use your personal data for their own behalf. We contractually impose on Subcontractors to comply with the obligations of security and confidentiality, to implement appropriate technical and organisational measures so that data processing is carried out in a manner that complies with applicable regulations and guarantees the protection of your rights.
2.3 Data controllers may provide us services related to data processing from time to time. We will operate on the terms of a written agreement with these data controllers relating to your personal data.

3.1 By registering for Account and/or otherwise using the Website, you:
3.1.1 provide us and our Subcontractors with the personal data necessary to allow you to use the Website and make transactions through it or to get any of the services accessible through the Website;
3.1.2 confirm that you are aware that the processing of your personal data may be performed by us and/or Subcontractors, and or other data controllers, and/or those specifically listed third parties, in accordance with this Policy; and
3.1.3 confirm that you are aware that your personal data may be transferred to those third parties listed in this Policy, for the reasons specified.
3.2 You may exercise your rights under Clause 11.1 at any time, which includes your objection to our processing of your personal data. However, where this withdrawal prevents us from performing our contract with you, we may not be able to provide our services to you.

4.1 We may generally collect all or some of the following categories of data from you:
Identification Information. Your full name, surname, phone number, mailing address, citizenship, email address, address, postcode, account username, password, copies of any documents you have provided for identification purposes and any other information relating to you which you have provided to us in any forms that you may have submitted to us, or in other forms of interaction with you.

Usage Information. Information about your use of our website and services, including cookies, IP (internet protocol) address, computer and connection information, device type and unique device identification numbers (e. g. IMEI number, MAC address), bandwidth, mobile network information, mobile operating system and type of mobile browser, statistics on page views, and traffic to and from our websites, and other technical data collected through cookies and other similar technologies that uniquely identifies your browser.

Employment Information. Your employment history, education background and income levels.

Financial Information. Your bank account information, credit card information (including the card number, expiry date and CVC), tax identification number, transaction history and trading data.

Correspondence. Responses to promotions and initiatives on our website or app, and interactions with our support team and customer service officers via email, app and/or other communication channels.

4.2 In addition to the above, we will also provide you with your Account Details, which includes your username which is either created by, or assigned to, you. The Account Details should be remembered by you, but will be stored by us in case you forget them.
4.3 Specific categories of processed personal data may also be in separate sections of this Policy.
4.4 All categories of personal data which are collected by us are indicated in procedure for performance and maintenance of records of data processing activities.

The data listed in Section 4 is collected in the following ways:
5.1 By you registering the Account – this is any information you give to us that we request from you when signing-up for an Account to use our Website or by corresponding to us (e.g. by e-mail or via chat functions on the Website).
5.2 Information collected – each time you visit our Website through a network Subcontractors may automatically collect:
5.2.1 technical information – your IP address (used by your device to connect to the internet) and any version details; and
5.2.2 information about your visit – means the links you have clicked on, in the Website; and
5.2.4. Content information – information stored on your device, including if you allow to access contact information (e.g. login information, etc.).
5.3. Received from third parties – we and our Subcontractors work closely to verify your eligibility for an Account, payment services, and etc.
5.4 Additional information provided by you directly – this is any information you provide to us related performance of our services and/or based to other purpose (e. g. provision of the queries, phone calls that may be recorded).

6.1. Cookies are small files, typically of letters and numbers, downloaded onto your computer or mobile device when you visit certain websites or mobile apps. When you return to these websites or mobile apps, or visit other websites that use the same Cookies, the websites or mobile apps recognize these Cookies and your browsing device. A cookie cannot read data off your hard drive or read cookie files created by other websites.
6.2. Cookies set by the website or mobile app operator are called "first party Cookies". Cookies set by parties other than the website or mobile app operator are called "third party Cookies". The parties that set third party Cookies can recognize your computer or mobile device both when you visit our website or mobile app or when you visit certain other websites and/or mobile apps.
6.3. We treat information collected by Cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by applicable laws, we also treat these identifiers as personal information. If we combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
6.4. We use the following types of Cookies:
Strictly Necessary Cookies
These Cookies are essential because they enable you to move around our Services and use certain features on our Services. For example, strictly necessary Cookies allow you to access secure areas. Without these Cookies, some of the Services cannot be provided.
Performance/Analytics Cookies
These Cookies collect information about how you use a website or mobile app. For example, a performance/analytics cookie will collect information about which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages. These Cookies do not gather information that identifies you. The information these Cookies collect is anonymous and is only used to improve how our Services work.
Functionality Cookies
These Cookies allow us to remember the choices you make and to tailor our Services so we can provide relevant content to you. For example, a functionality cookie can remember your preferences (e.g., country or language selection), or your username.
Session Cookies.
We use session Cookies when you access our website, mobile app or content. Session Cookies expire and no longer have any effect when you log out of your account or close your browser or app. These Cookies can contain significant amounts of information about your online activity, preferences, and location.
Cookie name Description Moment of creation Validity period Data used

7.1 Your data is primarily necessary to verify who you are when accessing your Account and to ensure you meet our eligibility requirements in order to submit an Application for an account. We or our Subcontractors also will use all or a part of your data for provision of other related services to you and/or for compliance with a legal obligations to which we or our Subcontractors are subject to and performance of internal administration activities.
7.2 Additionally, we will use all or a part of your data you provide us to notify you about:
7.2.1 services of an interest for you; or
7.2.2 changes to our Website or our services.
7.3 We and our Subcontractors use any data we collect about you (as a result of your visit to our Website) to:
7.3.1 personalise and improve our services (including the Website and its security);
7.3.2 deal with your inquiries and requests;
7.3.3 administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes;
7.3.4 ensure that any part of our Website (including any Content) is presented in the most effective manner for you and your device, and to make improvements (where necessary); and
7.3.5 keep our Website safe and payment devices secure.
7.4 Where we change our services, or any applicable terms and conditions, we will contact you.
7.5 Any data we obtain about you from third parties (Subcontractors or other data controllers) are used for the purposes of verifying your eligibility to submit an application for Account through our Website and/or to perform payment transactions and/or get any of the services accessible through the Website.

8.1 Subject to the rest of Section 8 of this Policy, we will only disclose your personal data to the third parties which shall be considered as data processors for the following purposes:
8.1.1 banking, including Electronic Money Institutions and financial service partners such as banking intermediaries, international payment services providers and regulated distribution agents – in order to perform our services and payments;
8.1.2 our approved email provider - in order to be able to send emails to you (please note that only your email address is provided to approved email provider);
8.1.3 analytics providers – for performance of Website‘s troubleshooting, data analysis, testing, research, usage tracking and for the purposes of fraud detection or protection, or in other situations involving suspicious or illegal activities;
8.1.4 other approved services providers – in order to ensure the proper functioning and provision of the services (e.g. IT services provider, cloud storage providers, auditor, accounting services provider, etc.). In order to provide a proper service for all of our products, we may disclose data to any member of the our company group, so that the data may be provided to any subsidiaries, affiliates or related entities.
8.2 In addition to the transfers contemplated by part 8.1, we or our Subcontractors may transfer or disclose your personal data to:
8.2.2 comply with any legal obligation required under legal requirement (e.g. to state authorities));
8.2.3 enforce any part of our Rules and/or any other agreements between you and us or to investigate potential breaches; or
8.2.4 protect our rights or our property, or those of our other Account holders.
8.3 Any websites which are linked from the Website are outside of our control and not covered by this Policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.

9.1 Each member of the staff can access the systems only by using his unique login credentials. Staff have access to personal data only for the purposes of performing their roles.
9.2 You may have set a password in order to access certain parts of our Website. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.
9.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9.4. We seek to put in place appropriate technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws. Nevertheless, we have to inform you that the transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to our Website, so that any transmission is at your own risk.

10.1 We will not retain your personal data for longer than is necessary and we will hold it only for the purposes for which it was obtained.

11.1 In relation to all of your personal data, you have the following rights (in addition to any rights you may have under the Regulation and the Law):
11.1.1 to access to your personal data, i.e. this enables you to receive a copy of the personal data we hold about you;
11.1.2 to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
11.1.3 to amend any inaccurate data we hold about you;
11.1.4 to delete any of your data (where you no longer think we need to hold it or you think we have obtained it or processed it without your consent at any time);
11.1.5 to object to processing of your personal data, i.e. to process your personal data in limited circumstances or for limited purposes (e.g. process your data for direct marketing purposes);
11.1.6 to forward the personal data you provided (in case it is on the basis of consent or contract, and if they are processed by automated means) to another data controller or transferred to you in a structured, commonly used and computer-readable format, if it is technically possible;
11.1.7 to stop the processing of personal data, except if we process personal data due to the legitimate interest of us or other person to whom personal data are provided, and your interests are not more important;
11.1.8 to withdraw consent at any time where we are relaying on consent to process your personal data;
11.1.9 not to be the subject only to automated processing, including profiling;
11.1.10 to submit an appeal on the actions or inactions of the us, related to the implementation of the data subject's rights to the Lithuanian Data Protection authority that is located in member state of the European Union where you reside; and
11.1.11 you are entitled to compensation, which you must apply for to the competent court that is located in member state of the European Union where you reside, if you have suffered damage as a result of a violation of the data subject's rights;
11.2 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this Policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates. We will try to respond to your legitimate requests within one month. Occasionally it may take us longer than one month if request is complex or you have made a number of requests.
11.3 Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.
11.4 Any data provided to you in accordance with your rights will be in a structured and in machine-readable form.

12.1. You confirm that you have provided correct data about yourself in every required form and that afterwards, when changing or adding any data at the Website, you will enter only correct data. We will not tolerate invalid, false or otherwise incorrect data and will pursue actions in accordance with its legal obligations. You shall bear any losses that occur with regard to the submission of invalid, false or otherwise incorrect data.
12.2 We draw your attention to the fact that email address and any other contact information you have chosen to link to your Account are used for your identification and communication. You undertake responsibility to protect these instruments and logins to them. You are responsible for password disclosure and for all operations performed after you use the password for a relevant account. We recommend to memorize your passwords and not to write them down or enter anywhere where they may be seen by other persons.