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GDPR means regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Personal Data means any information which Paybilla directly relates to you (a legal or natural person or an organization legally engaged in business activities or any other business). In particular by reference to an identifier such as a name, date of birth, contact information, location data, an online identifier etc;
Processing means any operation carried out with Personal Data (collection, recording, storing etc.).
For implementation of Money Laundering and Terrorist Financing Prevention Act and implementation of International Sanctions Act
These rules of procedure (hereinafter the Rules of Procedure) regulate the activities of PAYBILLA Estonia OÜ for the implementation of the Money Laundering and Terrorist Financing Prevention Act (hereinafter the MLTFPA) and the implementation of the International Sanctions Act (hereinafter the ISA). The Rules of Procedure have been established by a resolution of shareholders of PAYBILLA Estonia OÜ.
In these Rules of Procedure, the following definitions have the following meaning:
Money laundering means:
Terrorist financing means the financing and supporting of an act of terrorism and commissioning thereof within the meaning of § 2373 of the Penal Code.
Beneficial owner means a natural person who, taking advantage of their influence, makes a transaction, act, action, operation or step or otherwise exercises control over a transaction, act, action, operation or step or over another person and in whose interests or favour or on whose account a transaction or act, action, operation or step is made.
Private limited company means the virtual currency wallet service provider, which is an obliged entity for the purposes of the MLTFPA.
Business relationship means a relationship that is established upon entry into a long-term contract by an obliged entity in economic or professional activities for the purpose of provision of a service or sale of goods or distribution thereof in another manner or that is not based on a long-term contract, but whereby a certain duration of the relationship could be reasonably expected at the time of establishment of the contact and during which the obliged entity repeatedly makes separate transactions in the course of economic or professional activities while providing a service or professional service, performing professional acts or offering goods.
Customer means a person who has a business relationship with an obliged entity.
Staff means an employee of the Private Limited Company, head of the Private Limited Company, members of the management board, members of the supervisory board.
Compliance officer means a person appointed by the management board to act as a contact person of the Financial Intelligence Unit. A member of the management board or another Staff member of the Private Limited Company may act as a compliance officer.
Person means a natural or legal person who wants to enter into a contract with the Private Limited Company for using the Services provided by the Private Limited Company, but who has not yet been identified by an Employee of the Private Limited Company.
Financial Intelligence Unit means an independent structural unit of the Police and Border Guard Board (an up-to-date definition in accordance with § 53 of the MLTFPA).
Politically exposed person means a natural person who is or who has been entrusted with prominent public functions, including a head of State, head of government, minister and deputy or assistant minister; a member of parliament or of a similar legislative body, a member of a governing body of a political party, a member of a supreme court, a member of a court of auditors or of the board of a central bank; an ambassador, a chargé d'affaires and a high-ranking officer in the armed forces; a member of the management board and an administrative or supervisory body of a State-owned enterprise; a director, deputy director and member of the board or equivalent function of an international organisation, except middle-ranking or more junior officials.
Risk appetite means the total of the exposure level and types of the Private Limited Company, which the Private Limited Company is prepared to assume for the purpose of its economic activities and attainment of its strategic goals and which is established by the management board of the Private Limited Company in writing.
The Private Limited Company as a virtual currency wallet service provider agrees to follow these rules of procedure as provided by clause 2 (1) 11) of the Money Laundering and Terrorist Financing Prevention Act and clause 6 5) of the International Sanctions Act.
The management board of the Private Limited Company agrees to ensure that each Staff member comply with the requirements provided by these Guidelines, the MLTFPA and legal acts issued on the basis thereof. Staff members of the Private Limited Company must know and comply with legal acts and relevant guidelines of authorities and independently examine amendments to legal acts and guidelines.
A Staff member is personally responsible for the compliance with the requirements arising from the MLTFPA and these Guidelines. Failure to comply with the requirements may result in the termination of the employment contract as well as punishment pursuant to misdemeanour or criminal procedure.
ANNEX 1 – Guidelines Regarding Characteristics of Transactions Suspected of Money Laundering
Suspicious transactions in the case of a suspicion of money laundering are the Customer’s transactions and operations that have no clear economic or legal reason and that cannot be regarded as the Customer’s ordinary economic activities.
Indicators of suspicious transactions in the case of transactions of more than 10,000 euros in cash:
Arousal of suspicion upon entry into customer agreement:
ANNEX 2 – Guidelines Regarding Characteristics of Transactions Suspected of Terrorist Financing
Suspicious transactions in the case of a suspicion of terrorist financing are the Customer’s transactions and operations that have no clear economic or legal reason and that cannot be regarded as the Customer’s ordinary economic activities.
Indicators of suspicious transactions in the case of transactions of more than 10,000 euros in cash:
ANNEX 3 – List of Equivalent Third Countries in Accordance with Anti-Money Laundering Directive (Directive 2005/60/EC)
At the moment the Rules of Procedure are adopted, the following third countries are regarded as countries having AML/CFT systems equivalent to those of the European Union:
Republic of South Africa
The Rules of Procedure have been approved by a resolution of the management board of PAYBILLA Estonia OÜ, in accordance with which Robert Günter Knapp is appointed compliance officer.
You may link to our Website provided you follow certain rules. You may link to our Website, provided:
a) you do so in a way that is fair and legal and does not damage our reputation or take advantage of it;
b) you do not suggest any form of association, approval or endorsement on our part where none exists;
c) you do not frame our Website on any other site; and
We reserve the right to withdraw linking permission without notice.
At Paybilla S.R.L., REGELE FERDINAND No. 22-26, Central Commercial Center, Paybilla Space, Cluj, Romania (hereinafter referred to as "PAYBILLA"), data protection and security play an important role. Below is a presentation of our directives concerning the protection of your personal data. Please read the information carefully.
PAYBILLA respects your privacy. We collect, store and use your personal data only in accordance with the EU Directive on Data Protection 95/46/CE and the law 677/2001. We are exclusively using the personal data made available to us as part of an order (your name, address, e-mail) in order to process it or to offer you service and assistance.
Without your express consent we will not use these data to other purposes. We will communicate your data to other third parties only to the extent that this is necessary for concluding and executing a contract with you or in order to capitalize on or defend your rights, or if we have such obligation as per legal provisions or measures released by authorities or courts of law.
By using the e-mail address firstname.lastname@example.org you can get in touch with PAYBILLA right away with any questions or suggestions you might have on the policy we apply in the field of data protection. Also, you can ask PAYBILLA, at any time, to tell you which are the personal data we store and you can make corrections thereof or request their deletion, subject to the observance of the legal terms on archiving. We are using appropriate measures and procedures to ensure the protection of your personal data in order to efficiently prevent an abusive use thereof by any third parties.
PAYBILLA needs, for invoicing and delivery addresses, some of your personal data, that is required when executing the contract and validly concluding and processing your order, from a legal point of view, so as to provide services, as well as to respond to your requests, to offer you assistance in case of any technical problems or to get in touch with you when demanded. Furthermore, PAYBILLA will store the usage data thus generated in connection with your orders, with a view to deducting the performed services. This category includes all your identification data, as well as the ordered product. The registration of such data is a necessary condition for using and deducting the services we offer to you.
Your personal banking data as well as other payment information are excluded from this category, considering the fact that we are working with payment services providers only. For the making of payments, we currently collaborate with the following trusted partners:
Additional information regarding the security of the data can be found on the internet pages of the respective providers of payment services.
The websites may contain links to other websites that are beyond PAYBILLA's power of control, but which we think might be of interest to you. If you access these links you will enter websites which might have a confidentiality policy that is different than the one of PAYBILLA, and for which PAYBILLA cannot be held liable.
Further to your written request, we will inform you, in all legal terms, on your personal data that are going to be processed, the available information related to the origin of such data, the possible recipients or categories of recipients of such communications, the purpose for using them, as well as the relevant legal grounds. Upon request and within the legal terms, we correct, delete and/or block your personal data against any future processing, in case that these information prove to be incorrect from an objective point of view, incomplete or irrelevant for processing. The simplest thing to do is to send us a request in this sense at our e-mail address email@example.com.
PAYBILLA gives a special attention to safely archiving registered data referring to clients. PAYBILLA applies, through your browser, standard security measures - the so-called SSL codification.
The confidentiality policy is subjected to the Romanian laws in force. The provisions of the Romanian laws shall be enforced in the case at hand.
Please go also to the Terms and conditions of use section which is applicable to your access/visit to this website.