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Site Administrator -The Company is responsible for the administration of the Website;
User -every person using the Website, regardless of whether he is a registered User or uses the Website without registration;
Direct Marketing -all activities that enable the Site Administrator to offer services or transmit any other information to the User by mail, telephone or other direct means in order to inform the User or to obtain a response from him, as well as all related services.
Account – The result of the user’s registration on the Website, which creates a User profile that stores his personal data and use of Website services.
EU Regulation 2016/679 -European 2016 April 27 Regulation (EU) 2016/679 of the European Council and Parliament on the protection of natural persons in the processing of personal data.
Processing of personal data (EU Regulation 2016/679) -Any operation or sequence of operations performed by automated or non-automated means on personal data or sets of personal data, such as collection, recording, sorting, systematization, storage, adaptation or modification, extraction, access, use, disclosure by transmission, distribution or otherwise making it possible to use them, as well as juxtaposition or combination with other data, restriction, deletion or destructions.
Assigning pseudonyms (EU Regulation 2016/679)– processing of personal data in such a way that personal data can no longer be assigned to a specific data subject without the use of additional information if such additional information is stored separately and technical and organizational measures are applied in relation to it in order to ensure that personal data are not assigned to a natural person whose identity is established or whose identity can be identified to determine
Consent of the data subject (EU Regulation 2016/679)– any freely given, specific and unambiguous expression of the will of a properly informed data subject by means of a statement or unequivocal actions by which he consents to the processing of personal data related to him.
Data security regulations – Data security provisions of the Company’s Information Systems.
User administration rules– Administration rules for users of the Company’s Information Systems.
Information management rules – Rules for the safe handling of electronic information in the Company’s Information Systems.
Other concepts used in this policy are understood as they are defined in the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts regulating the processing of personal data.
2. The Company appoints a responsible person who ensures that the rights of the Users as data subjects are ensured, properly implemented, and that all information is provided correctly, on time, and in a form acceptable to the Users.
9. The Company collects, stores, and processes any Personal Data provided in the User Account and received by Users using the Website for the following purposes:
9.1 For the proper execution of the Company as a service provider, as defined in legal acts;
9.2 enabling Users to use the Website;
9.3 for the purposes of efficient service provided by the Company. The Company makes sure that the use of the Website is efficient, as well as that it is possible to avoid cases of identity theft and fraud and/or dishonest behavior;
9.4 to ensure continuous improvement and development of the Website, the Company has the right to use Personal Data for the purposes of Direct Marketing of its services when the User expresses his consent without objection.
10. Users’ personal data is stored only to the extent and for as long as it is necessary to achieve the set goals.
11. The Company does not transfer Personal Data to third parties, either for a fee or free of charge or in any other way, located both in the territory of the Republic of Lithuania and in the countries of the European Union and other foreign countries, except for the following specified cases;
11.1 for law enforcement institutions – the procedure provided by the legal acts of the Republic of Lithuania;
11.2 for other institutions and organizations – in the cases provided by the laws of the Republic of Lithuania.
12. Data on cookies used on the Websites:
|Title||Description||Creation moment/ Expiration date|
|TawkConnectionTime||Manages visitor connection||When the browsing session starts /When the browsing session ends|
|twk_idm_key||Visitor connection management||When the browsing session starts/When the browsing session ends|
|twk_uuid||HTTP cookie||When the browsing session starts/After 7 days|
|wp-wpml_current_language||Manages visitor selected language||When the browsing session starts/When the browsing session ends|
13.1 at any time access the Personal Data you have provided by logging into your Account;
13.2 after submitting a request to the Company in writing to receive information from which sources and which personal data was collected, for what purpose it is processed, to which recipients of data it is provided and has been provided during the last 1 year. Information shall be provided to the User in writing by the e-mail indicated by him no later than within 30 calendar days from the date of the User’s request to provide such data. The Company provides such data to the User free of charge once per calendar year;
13.3 after submitting a request to the Company in writing, by e-mail, the User may demand the correction of incorrect, incomplete, or inaccurate personal data and/or stop the processing of such personal data, except for storage, if the User determines that his personal data is incorrect, incomplete or inaccurate or processed illegally and unfairly. The Company undertakes to notify the User about the rectification, destruction, or suspension of personal data processing actions performed or not performed at his request within 5 days from the date of performing these actions;
13.5 does not consent to the processing of his Personal Data for Direct Marketing purposes.
When protecting personal data, the Company implements and ensures appropriate organizational and technical measures to protect personal data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing, in accordance with the following documents approved by the Company:
14.1 Data security regulations – describes general information security requirements applied to the Company’s information systems;
14.2 User administration rules – describes the user administration rules;
14.3 Information management rules – describes the main principles of safe information management;
15. Basic principles and rules ensuring safe use of personal data:
15.1 The company ensures proper storage of documents, data files, and takes measures to prevent accidental or illegal destruction, alteration, and disclosure of personal data, as well as any other illegal processing. Copies of documents containing the personal data of customers must be destroyed in such a way that these documents cannot be reproduced and their contents cannot be identified;
15.2 In the company, only those persons who have been authorized to access such data have the right to get acquainted with the personal data of Users, and only when it is necessary to achieve the goals set out in this policy;
15.3 The company ensures the security of the premises where personal data is stored, proper placement and review of technical equipment, compliance with fire safety rules, proper network management, maintenance of information systems and the implementation of other technical measures necessary to ensure the protection of personal data;
15.4 The company takes measures to prevent accidental or illegal destruction, alteration, disclosure of personal data, as well as any other illegal processing, by properly and securely storing the documents and data files entrusted to it;
15.5 if an employee or other responsible person doubts the reliability of the installed security measures, he must contact his immediate supervisor to assess the available security measures and, if necessary, initiate the purchase and installation of additional measures;
15.6 employees or other responsible persons who automatically process personal data or from which computers can access areas of the local network where personal data are stored, use passwords created in accordance with the relevant rules. Passwords are changed periodically, at least once every three months, as well as when certain circumstances arise, for example: when an employee changes, when there is a threat of hacking, when there is a suspicion that the password has become known to third parties, etc.;
15.7 an employee working on a specific computer can only know his password;
15.8 personal data can be stored only in the Company’s service stations, where proper auditing of personal data processing (EU Regulation 2016/679) is ensured;
15.9 personal data cannot be used for the purposes of testing information system updates. Pseudonymization (EU Regulation 2016/679) must be used in testing systems;
15.10 upon detection of personal data security violations, the Company takes immediate measures to prevent illegal processing of personal data.
17. This policy is reviewed and updated periodically once a year or when the legal acts that regulate the processing of personal data change.
18. The Company reserves the right to change this policy in whole or in part. Users and other responsible persons are informed of the changes by means of information technologies (e-mail, etc.).
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