Release date: 21.08.2022
Last update: 30.05.2025
Introduction
This Privacy Policy ('Policy') describes how Skailenga UAB ('Skailenga', 'we', 'our', or 'us'), as a Crypto-Asset Service Provider (CASP), processes personal data in accordance with the General Data Protection Regulation (GDPR) and the Markets in Crypto-Assets Regulation (MiCA). This Policy applies when users access Skailenga's website, platform, or services. By using our services, you agree to the processing of your personal data as described in this Policy.
Definitions
- 'Personal Data' means any information relating to an identified or identifiable natural person.
- 'Processing' means any operation performed on personal data.
- 'Data Controller' means the legal entity that determines the purposes and means of processing personal data.
- 'CASP' refers to a Crypto-Asset Service Provider regulated under MiCA.
Data We Collect
We may collect:
- - Identification data (name, photo, birth date, address)
- - Contact details (email, phone)
- - KYC/AML data (source of funds, PEP status)
- - Technical data (IP address, browser type)
- - Transaction data (wallet addresses, amounts, counterparties)
- - Usage data (how you use our platform)
Legal Bases for Processing
We process your data based on:
- - Your consent (Article 6(1)(a) GDPR)
- - Contractual necessity (Article 6(1)(b) GDPR)
- - Legal obligation (Article 6(1)(c) GDPR, including AML/KYC laws under MiCA)
- - Legitimate interests (Article 6(1)(f) GDPR)
Data Sharing and Disclosure
We may disclose your data to:
- - Data processors under contract
- - Regulatory authorities (e.g. Bank of Lithuania, FIU)
- - Legal representatives
- - In case of mergers or acquisitions
We do not sell your data to third parties.
Data Transfers
Data may be transferred outside the EEA. We ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) where necessary.
Data Retention
We retain personal data for a minimum of five (5) years in accordance with AML and MiCA obligations, or longer where legally required.
Your Rights
You have the right to:
- - Access your data
- - Rectify inaccurate data
- - Erase your data
- - Object or restrict processing
- - Lodge a complaint with the State Data Protection Inspectorate or the Bank of Lithuania
In case of the User’s rights violation, the User has a right to ask State Data Protection Inspectorate or court to protect the User’s rights. The State Data Protection Inspectorate can be contacted as follows:
Phones: +370 5 271 2804 / 279 1445
Fax: +370 261 9494
Email: [email protected]
Address: L. Sapiegos str. 17 (Left-hand entrance), LT-10312 Vilnius
Security Measures
We implement appropriate technical and organizational measures to ensure data security. In the event of a breach, we will notify authorities and affected individuals as required by GDPR.
Third-Party Links
Our website may contain links to third-party websites. We are not responsible for their privacy policies.
Policy Updates
We may update this Policy to reflect changes in law, MiCA requirements, or regulatory guidance. Updates will be published on our website.
Contact details and questions
Any questions about this Policy, the processing of Personal Data or data subject’s requests please contact Skailenga via the Ticket system available on the Website or via email at [email protected].