Privacy Policy
Version: 11.04.2025
1. General Provisions
This Privacy Policy (hereinafter – "Privacy Policy") provides information about how we, Loyalty Vault S.R.L. (hereinafter – "COMPANY" or "we"), processes personal data when you use the website www.aceb.com (hereinafter – the "Website"), use our services or otherwise provide personal data to us.
Scope of the Privacy Policy
The Privacy Policy describes the principles we follow, the personal data we collect, how we obtain the data, on what grounds, for what purposes, and how we use it, how long we store your personal data, with whom it is shared, how we ensure the protection of your personal data, what your rights have and how to make a complaint.
It is very important that you read this Privacy Policy carefully, because every time you visit Website or otherwise provide personal data to Loyalty Vault S.R.L., you will give your consent to the terms and conditions described in this Privacy Policy. This means that you are legally committed to comply with this Privacy Policy. If you do not agree to these conditions, you should not provide your personal data to Loyalty Vault S.R.L..
Legal background
We respect your privacy and seek to protect your personal data. Loyalty Vault S.R.L. will process your personal data in accordance with the applicable legal requirements of the European Union and the Republic of Lithuania, including Regulation (EU) No 2016/679 (General Data Protection Regulation, hereinafter – "GDPR") and other applicable legislation on the protection of personal data, and instructions from competent authorities. The terms used in the Privacy Policy are understood as they are defined in the GDPR. When processing your personal data, we implement organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.
2. Data Controller of Your Personal Data
We, Loyalty Vault S.R.L., are the data controller of your personal data specified in this Privacy Policy.
Our details:
Loyalty Vault S.R.L. is the private limited liability Loyalty Vault S.R.L. incorporated under the laws of the Republic of Lithuania, with its place of business at Bdul. Unirii 32 BL.73B ET. 2 AP. 10 ZIP Code 130082, Targoviste, Romania, code 51229859.
Our email address is support@aceb.com, phone No +40 123 456 789.
3. The Principles
When processing personal data, we are committed to the principles relating to the processing of personal data set out in Article 5 of the GDPR and to making every effort to ensure that the data of individuals are:
- processed in a lawful, fair and transparent manner in relation to the data subject;
- collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes, except for the exceptions provided for in the GDPR;
- adequate, relevant and limited to the extent and to the extent necessary to achieve the stated purposes;
- accurate and kept up to date as necessary;
- kept in such a form as to permit identification of data subjects for no longer than is necessary for the predefined purposes (subject to the exceptions provided for in the GDPR);
- processed in such a way as to ensure, through appropriate technical or organisational measures, adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
4. The Purposes
The personal data we collect, the purposes for which it is collected, the legal basis for collecting it, and the retention period are as follows:
4.1. Provision of Services
| Purpose of data processing | Loyalty Vault S.R.L. has the purpose of providing you with the services you have ordered and ensuring the smooth provision of such services. |
|---|---|
| Data subjects | The representatives of business clients who purchase these services. |
| Personal data |
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| Source of personal data | Loyalty Vault S.R.L. receives personal data directly from you, or from payment collection or administration service providers, financial institutions, or other payment intermediaries, depending on your chosen method of payment for services. |
| Legal basis | Performance of the contract between you and Loyalty Vault S.R.L. regarding the provision of the services (Article 6(1)(b) of the GDPR) or our legitimate interest to conclude a contract regarding the provision of the relevant services with the legal person you represent (Article 6(1)(f) of the GDPR). |
| Consequences of failure to provide data | If you do not provide this personal data, Loyalty Vault S.R.L. will not be able to provide the services you request. |
| Storage | The data contained in the documents for which minimum retention periods are provided in legal acts (e.g. Index for Retention Terms of General Documents), will be stored for the retention periods set in the relevant legal acts, e.g. accounting documents certifying an economic operation or an economic event (invoices, payment orders, etc.), and the personal data contained therein will be stored for 10 years. In individual cases, in accordance with the applicable requirements of legal acts, or in the case specified in Paragraph 4.5 of this Privacy Policy, your personal data may be stored for a longer period. |
4.2. Direct Marketing
| Purpose of data processing | Loyalty Vault S.R.L. has the purpose of providing news and other information about our Services and/or offers to you. |
|---|---|
| Data subjects | Persons who have purchased Loyalty Vault S.R.L. services and at that time or at any time thereafter did not object to the use of their personal data for direct marketing purposes in the context of marketing similar goods and/or services by Loyalty Vault S.R.L.; Persons who have provided their consent to the processing of their personal data for the purpose of direct marketing. |
| Personal data |
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| Source of personal data | Loyalty Vault S.R.L. obtains personal data directly from you. |
| Legal basis | Your consent to the processing of personal data for direct marketing purposes (Article 6(1)(a) of the GDPR), or Our legitimate interest to notify our customers about similar goods and/or services offered by Loyalty Vault S.R.L. (Article 6(1)(f) of the GDPR). |
| Additional conditions | Based on our legitimate interest in notifying customers about similar goods and/or services offered by Loyalty Vault S.R.L., Loyalty Vault S.R.L. will process your personal data for direct marketing purposes only if all of the following conditions are present (Email and SMS direct marketing):
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| The data subject's right to object to or withdraw consent | The data subject may object to or withdraw they consent to the use of his or her data for direct marketing purposes at any time. If the data subject does not consent to the use of their personal data for direct marketing purposes or withdraws such consent, their data will no longer be processed for such marketing purposes, but the data subject will not lose the possibility to use our other Services. |
| Storage | Your personal data will be processed for the purpose specified in this Paragraph for 2 years from the date of its collection, or until you object to such processing of personal data, or until your consent to the processing of personal data for this purpose is withdrawn, whichever of these circumstances occurs first. In individual cases, your personal data may be stored for a longer period in accordance with the requirements of applicable legal acts or in the case specified in Paragraph 4.5 of this Privacy Policy. |
4.3. Direct Communication
| Purpose of data processing | Loyalty Vault S.R.L. has the purpose of responding to your inquiries which you provide by email or standard mail, writing or calling by phone using a special form at Website, or contacting us directly. |
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| Data subjects | Persons who submit inquiries to Loyalty Vault S.R.L. by email or standard mail, by writing or calling by phone, using a special form at Website, or by contacting us directly in person. |
| Personal data |
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| Source of personal data | Loyalty Vault S.R.L. receives personal data directly from you. |
| Legal basis | Our legitimate interest to respond to your inquiries and/or provide you with detailed information about Loyalty Vault S.R.L. services (Article 6(1)(b), (c) and/or (f) of the GDPR). |
| Consequences of failure to provide data | If you do not provide this personal data, Loyalty Vault S.R.L. will not be able to respond to your inquiries. |
| Storage | Personal data provided to us in various requests from data subjects, which is retained for 6 months after the resolution of the request, but for at least one year after the request. In individual cases, your personal data may be stored for a longer period in accordance with the requirements of applicable legal acts or in the case specified in Paragraph 4.5 of this Privacy Policy. |
4.4. Social Networks
| Purpose of data processing | Loyalty Vault S.R.L. has a purpose to manage its social network accounts and to communicate with users of social networks. |
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| Data subjects | Users of social networks (Facebook, LinkedIn) who interact with us through Loyalty Vault S.R.L. accounts. |
| Personal data |
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| Source of personal data | Loyalty Vault S.R.L. obtains personal data directly from you and/or from the relevant social network. |
| Legal basis | Our legitimate interest to communicate with the users of our social network accounts (Article 6(1)(f) of the GDPR). |
| Consequences of failure to provide data | If you do not provide this personal data, Loyalty Vault S.R.L. will not be able to communicate with you, to respond to your inquiries. |
| Storage | Given that Loyalty Vault S.R.L. does not administer the above social networks, but only its accounts on these networks, and acts as a joint data controller together with the companies that administer the said social networks, please familiarize yourself with the information about the storage of your personal data in the privacy documents of the following social networks:
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4.5. Legal Requirements and Dispute Resolution
| Purpose of data processing | Loyalty Vault S.R.L. may process all the above personal data in order to make claims and enforce or defend itself against legal claims. |
|---|---|
| Data subjects | The person who filed the complaint |
| Personal data |
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| Source of personal data | Loyalty Vault S.R.L. receives personal data directly from you, or from payment collection or administration service providers, financial institutions, or other payment intermediaries, depending on your chosen method of payment for services. |
| Legal basis | Article 6(1)(f) of the GDPR. |
| Consequences of failure to provide data | The data subject is not obliged to provide his or her personal data for the above processing purposes. However, the failure to provide certain data may result in the data subject's request not being fulfilled. |
| Storage | If we believe that a dispute may arise in a particular case, we will keep the data relating to that case for the full duration of the relevant period of limitation prescribed by applicable law (depending on the nature of the potential claim), provided that it is not shorter than the relevant time limit set out above. |
5. Data Recipients
We may disclose information about you to our employees, representatives, intermediaries, suppliers, or subcontractors if this is reasonably necessary, e.g. to our providers of payment services who administer financial operations at Website, Website hosting service providers, providers of maintenance services of servers, email service providers, etc.
In addition, we may disclose information about you to:
- courts, arbitrators, mediators, counterparties, and their lawyers (if required for the purpose of judicial or other similar proceedings);
- police, law enforcement authorities, tax authorities, other state or municipal authorities (if it is expressly required by the relevant legal acts), or other persons performing official duties assigned to them (e.g. notaries, debt recovery companies);
- professional consultants, such as lawyers, advisers, auditors, or accountants (if this is necessary to ensure our legitimate interests);
- service providers who provide information technology, cloud computing, and system administration services, payment collection or administration, marketing, and accounting services, postal or courier services only to the extent necessary for the proper provision of services;
- other entities within the same group of companies, only to the extent this is necessary for the proper administration of the group of companies;
- when performing business transactions (sale of Loyalty Vault S.R.L., its assets (part thereof) or its shares (part thereof), merger or division of Loyalty Vault S.R.L., etc.), to potential or final acquirers (their representatives), persons performing inspection of Loyalty Vault S.R.L. or otherwise participating in the relevant business transaction. In this case, Loyalty Vault S.R.L. will transfer only as much personal data as is necessary for the purposes of the business transaction and will ensure the confidentiality of personal data.
Also, in each case, if we transfer your personal data to a third country (outside the EU/EEA), one of the following conditions must be met:
- the data shall be transferred to the country, with respect to which the decision on adequacy has been adopted;
- the transfer of data is carried out using appropriate safeguards as specified in legal acts;
- the derogations provided for in legal acts are complied with if it is not possible to transfer the data under the above conditions.
Loyalty Vault S.R.L. will make every effort to ensure that the transfer of data takes place in accordance with the GDPR requirements and will take appropriate measures to ensure that your personal data is secure. For more information about such measures, please contact us directly using the contact details specified in Paragraph 2 of this Privacy Policy.
Our Website may contain third party banners, links to their websites and services over which we have no control. We are not responsible for the security and privacy of data collected by third parties. The data subject must inquire about the privacy protection of such data with the relevant third parties whose websites or services they use.
6. Your Rights
The data subject has the right to contact us regarding questions related to the processing of his personal data, i.e. have the following rights:
- the right to receive information about data processing;
- the right to access your data (request our confirmation as to whether your personal data is processed, and if so - to access your data and how they are processed);
- the right to demand correction of data or, taking into account the purposes of personal data processing, to supplement incomplete personal data of a person;
- the right to demand the deletion of data or the suspension of their processing actions (except for storage) (the right to destruction and the right "to be forgotten");
- the right to restrict data processing;
- the right to data portability;
- the right to object to the processing of personal data;
- the right to submit a complaint to the supervisory authority;
- other rights established by the legal acts applicable to the processing of personal data.
Any request related to the processing of personal data can be submitted by the data subject to us by e-mail at support@aceb.com or by sending the request by post or by coming to our office at the address below. Taking into account the subject of the data subject's request, in order to ensure the confidentiality of the personal data we process, we may require the person who submitted the request to provide additional information necessary to determine the identity of the personal data subject and/or confirm his identity in a specific way (for example, signing the request with a secure electronic signature, personally coming to location and provide a valid identity document, send a duly certified copy of such document, etc.). If a person does not comply with such a request from us, the requested information may not be provided.
We undertake to respond to all requests related to the processing of personal data in accordance with the procedure established by the GDPR within one month of receiving the request.
7. Privacy Policy Updates
We have the right to update or change this Privacy Policy at any time. Such an updated or amended Privacy Policy will enter into force upon its publication at Website.
8. Filing Complaints
If you believe that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with the supervisory authority of the EU Member State of your habitual residence, your place of work, or the place of the alleged infringement.
The supervisory authority in Lithuania is the State Data Protection Inspectorate:
Address: L. Sapiegos str. 17, LT-10312 Vilnius, Lithuania
Email: ada@ada.lt
Tel: (8 5) 271 28 04, (8 5) 279 1445
Website: https://vdai.lrv.lt/
Before submitting a complaint to the supervisory authority, we would appreciate it if you would contact us and explain your concerns to us. We will make maximum efforts to resolve your question expeditiously and carefully. You may at any time contact us by e-mail to support@aceb.com.
Loyalty Vault S.R.L. will examine your request to exercise the rights of the data subject within 1 month. This period may be extended, if necessary, for a further period of 2 months, taking into account the complexity and number of requests. In this case, Loyalty Vault S.R.L. will notify you of any such extension within 1 month of receipt of the request, together with the reasons for the delay.
If upon the receipt of a request, complaint, or claim, we have suspicions regarding your identity, we have the right to request additional information necessary to confirm your identity.
Last updated: May 2025
Table of Contents
Contact Information
Email: support@aceb.com
Company: Loyalty Vault S.R.L.
Registration: 51229859
Need Help?
Contact us at support@aceb.com for any questions about our privacy policy.