We are conscious of the great importance of your personal data protection. We collect and process only the data that is necessary for performance of our activities. We process personal data in a legitimate, transparent and fair manner, for pre-defined purposes and only to the extent necessary for the achievement of the purposes of processing. When processing personal data, we want them to be accurate, safe, confidential, duly stored and protected.
Your personal data is managed in accordance to the General Data Protection Regulation (EU) 2016/679 adopted on 27 April 2016 (the GDPR), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, as well as the requirements for managing personal data as set in any other legal acts.
1. What is this document?
2. Who are we?
2.1. This Website is managed and administered by AAA Law (we), i.e.:
a) UAB AAA Law, legal entity code111593841, residence address A. Goštauto str 40B, Vilnius, Lithuania, contact e-mail: firstname.lastname@example.org, contact phone number: +370 5 252 66 76;
b) Domkute and partners professional law partnership AAA Law, legal entity code 304559463, residence address A. Goštauto street 40B, Vilnius, Lithuania, contact e-mail: email@example.com, contact phone number: +370 5 252 66 76;
3. What principles do we follow?
3.1. When processing your personal data we:
a) will comply with the requirements of the effective and applicable laws, including the GDPR;
b) will process your personal data in a legitimate, fair and transparent manner;
c) will collect your personal data for the established, clearly defined and legitimate purposes and will no longer process them for any method that is not coordinated with such purposes, except to the extent permitted by the laws;
d) will take any reasonable means to ensure that personal data which is not accurate or complete, in view of the purposes of processing, would be immediately corrected or supplemented, the processing of such would be terminated or it would be destroyed;
e) will keep such data in a form which permits to identify you for no longer than it is necessary for the purposes for which personal data is processed;
g) will ensure that your personal data is processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against the accidental loss, destruction or damage, using appropriate technical or organisational measures.
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
4.1. We process your personal data received under the following methods:
a) When you provide data to us. You provide us with your personal data and other information by using the Website and/or by visiting our accounts on social networks, through your active actions when using such networks, i.e. by writing to us or communicating with our team, by submitting your complains and/or enquiries, assignments, comments, etc. Please note that in case you contact us in writing or by e-mail, we will store the data of correspondence.
b) When you use our Website and/or our accounts. When you use our controlled website and/or visit our accounts on social networks, certain information (e.g. internet address (IP), type of used browser, year, number of visits, reviewed websites, time spent on the Website, internet source (that you were redirected from), information on the used device, language, country, internet provider, etc.) is collected automatically.
4.2. We can combine personal data received directly from you with data collected individually from public or available sources. For example, your presented personal data can be combined with data received by using cookies on Websites or social networks, data collected when providing services to you or with data that was legally obtained from third parties. You will always be able to request the correction of erroneous personal data and exercise any other rights granted to you as the data subject.
5. Why and how do we process your personal data?
a) To improve the Website, to offer better and customised services. Your personal data, including personal data received by using our Website and/or visiting our social networks accounts, will be used to improve and develop the Websites and to offer better and more customised services.
For this purpose, we use personal data received from you or created when using the Website and/or received from other persons (including the controllers of social networks).
b) For the purpose of direct marketing. We process your personal data upon the receipt of your consent and in order to provide you with newsletters, including proposals and information on our goods and/or services or the goods and/or services of persons related to us and partners, events or any other information and in order to improve our services.
For this purpose, we process such personal data as e-mail address, first name and last name (if they actually constitute your e-mail address).
In this case, we receive this personal data directly from you.
For this purpose, your personal data may be supplied to or shared with marketing companies, etc.
For this purpose your personal data is stored until we get your withdrawal of the consent regarding relevant data processing.
c) For the purpose of quality control of our activities and ensuring of functionalities of the use of Website and/or account(s) (processing of complaints and/or your submitted enquiries, comments and communication (including the storage). When you contact us (or we contact you in case of receipt of your enquiry), we process information received by phone, e-mail, via Website or any other form of communication.
For this purpose, we process such personal data as first name, last name, internet address (IP), nickname, related company, e-mail address, telephone number, content of complaint and/or enquiry, date and time of your application, communication information, content of comment you wished to publish.
For this purpose, your personal data can be received directly from you, by performing the enquiry or analysing the complaint, we can also create personal data by ourselves (e.g. having received your complaints, we contact third persons regarding the factual circumstances and record them, etc.), the controllers of social networks.
For this purpose, your personal data is supplied or transferred to legal persons providing website maintenance and other IT services, your comments (with your nickname or name) may be published.
For this purpose, your personal data is stored for a period of 2 years from the day of recording, except for the cases, when there are grounds to believe that a crime or any other illegal actions have been committed or internal investigation is initiated until the end of the examination of the respective investigation and/or the case.
d) For the purpose of selection of candidates to join our team. If you contact us regarding the possibility to join our team, we will process your personal data for this purpose as well.
For this purpose, we will process your personal data received directly from you, (e.g. your CV or data filled on the questionnaire, data collected during the interview, such as first name, last name, e-mail address, telephone number, education, fields of activities, information about professional experience, foreign language skills, etc.), and/or received from other persons (e.g. current or former employers or recommendations of acquaintances, public information means, etc.).
For this purpose, your personal data is supplied to or shared with legal persons providing Website maintenance and other IT services.
For this purpose, your data is stored for a period of 1 year from the day when a specific selection procedure is completed, unless we receive your separate consent to process such data for a longer period.
e) To publicise recommendations. If our Clients (or other persons) recommend us and write a public recommendation text, we will publish it.
For this purpose, we process such personal data as first name, last name, job title, (name of) affiliated company, related brand, photo, the content of the comment to be disclosed (including a description of the services provided without specifying the details of a separate instruction and disclosing the confidential information entrusted to us by the Client unless the Client (or other person) clearly instructs otherwise).
In this case, we receive this personal data directly from the data subject.
For this purpose, personal data is supplied or transferred to legal persons providing website maintenance and other IT services, also such personal data may be published in our Website and/or social networks accounts.
For this purpose your personal data is stored until we get your withdrawal of the consent regarding relevant data processing.
f) For any other purposes stipulated in the Rules for Processing of Personal Data and/or other internal documents when we are obliged to process your personal data by the laws or on the basis of any legal interest or on any other grounds for legitimate processing of personal data stipulated by the laws.
6. Do we use your personal data for direct marketing and what are the rules for subscription TO our newsletters?
6.1. Upon the receipt of your additional consent, we can use your personal data for the purpose of direct marketing in order to provide you with our offers and information on our services, which we consider to be interesting for you.
6.2. For this purpose, we process such personal data as stipulated in Article 5.1.b).
6.3. You can choose whether to allow us to use your personal data for direct marketing. You can do so by entering your e-mail address on Website column ‘I accept and confirm the subscription’ and by pressing the approval for subscription.
6.4. We can combine the available information about you with information available from third parties.
6.5. If you give your consent to use your personal data for direct marketing, we can use your personal data for the analysis and improvement of the effectiveness of our Websites, advertising and market research and any other purposes of our marketing and sales. In such case, we will use depersonalised data.
6.6. Even if you gave your consent to process your personal data for direct marketing, this consent can be withdrawn at any time for all or part of actions of processing. In such case, you can:
a) notify us on the withdrawal by the method indicated in electronically received messages and/or proposals (e.g. by pressing the link regarding the refusal of subscription);
6.7. If you withdraw your consent, we will try to terminate the processing of your personal data for the purposes of direct marketing as soon as possible.
6.8. The withdrawal of consent automatically obliges us to destroy your personal data or to provide you with information on our processed personal data, therefore, if you want us to perform these actions as well, you should inform us on such request separately.
7.1. We collect information about you by using cookies and similar technologies. Cookies are small text files which are recorded temporarily to the hard disk of your device and allow us to recognise you during your next visits on the Website, social networks, save the person’s browsing history, options, to adapt the content, to accelerate the searches performed on the Website, to create a comfortable and friendly environment on the Website, to provide it in a more effective and reliable manner. Cookies are a usual practice of browsing on the websites that facilitate the use of website.
7.3. Information obtained by using cookies is used for the following purposes:
a) to ensure the functionality of Website (e.g. in order to use personalisation of specific Website);
b) in order to improve Website or to develop it to better reflect your needs;
c) for the development of services and analysis of the use of Website;
d) for targeted orientation of marketing solutions.
7.4. Without prejudice to the legal acts, we can combine information received by using cookies with information received about the person by other means (e.g. information on the use of Website, your submitted personal data).
7.5. Please note that the following cookies may be used on the Website, social networks:
a) technical cookies – cookies necessary for the functioning of Websites;
b) functional cookies – cookies which, while not necessary for functioning of Websites, considerably improve their functioning, quality and user experience;
c) analytical cookies – cookies used for preparation of statistical analysis of navigation methods of Website visitors; data collected by these cookies are used anonymously;
d) targeted or advertising cookies – cookies used to show offers or other information which could be interesting to you;
e) social network cookies – cookies which are necessary in order to use information of Websites on your social profile account.
7.6. All information on the cookies used on our Website, their purpose of use, validity and used data is provided below:
Place of usage
This cookie is used to know if users already accepted cookies policy
At the moment of Website visit
Information about acceptance
a) without deleting them and/or without changing the settings of website browser to disable cookies;
b) by choosing ‘Accept’ on a specific link (bar) used on the Website.
7.9. In certain cases, especially in cases of disabling technical and functional cookies, non-acceptance of cookies or deletion thereof can slow down the speed of browsing online, restrict the functioning of certain specific functions on the Website or block the access to the Website.
8. How do we share your personal data?
8.1. We guarantee that your personal data will not be sold, supplied or otherwise shared with third parties without any legitimate grounds, as well as used for any purposes other than they were collected for. We will not transfer your personal data in any ways other than pursuant to this Privacy Polity and/or the Rules for Processing of Personal Data and legal acts. However, we reserve a right to provide information about you, if we have to do so in accordance with the procedure established by the laws or if the legally operating institutions or institutions engaged in criminal prosecution request so.
8.2. We can transfer your personal data to companies that help us to perform our activities. We request such partners to process your data only according to our given instructions and according to the valid legal acts ensuring the protection of your personal data. We conclude contracts with these persons in order to oblige them to follow the requirements of protection of personal data in a strict manner.
8.3. The possibility of the aforementioned service providers to use your data is restricted – they cannot use such data for any purposes other than the provision of services to us.
9. How long do we store your personal data?
9.1. We store your personal data for no longer than it is necessary for the purposes of processing of data or stipulated by the laws, if they establish a longer period for the storage of data.
9.2. Our aim is not to store outdated, irrelevant personal data, therefore, in case of update of data (e.g. specification, change of information, etc.), only relevant information is stored. Historical information is stored only if it is necessary in accordance with the procedure established by the laws or for the performance of our activities.
10. How do we store your person data?
10.2. Unfortunately, the transfer of information online is not completely safe. Even if put our every effort in protecting your personal data, we cannot ensure the security of data when you provide such data on the Website – you shall accept the risk related to the transfer of data to the Website. When we receive your data, we will apply strict procedures and security means for the protection of your data from any unauthorised access.
10.3. In case of unlikely circumstances of finding out about the security breach of your personal data, which may cause a considerable risk to your rights and freedoms, we would immediately inform you as soon as we find out and establish what kind of information has been accessed.
11. External websites
11.1. The Website may contain links to external websites – the websites where we have accounts and where our services are advertised. By using such links to reach any of such websites, please note that these websites and services provided through such websites have their own privacy policies and we assume no responsibility or obligations for these policies or any personal data collected on these websites or by providing services, for example, contact or location data. We recommend to review such policies before submitting personal data on such websites or by using any other services. We also recommend to read the privacy statements of third parties having the control of these websites and contact the service providers directly if you have any questions on how they use your personal data.
12. What are your rights?
12.1 By processing your personal data, we guarantee your rights according to the GDPR and the Law on the Legal Protection of Personal Data of the Republic of Lithuania. As the subject of personal data, you have the following rights:
a) to know (be informed) about the processing of your personal data;
b) to familiarise with your personal data that is processed by us;
c) to request rectification or supplement, specification of your incorrect, imprecise, incomplete personal data;
d) to request to destroy personal data when it is no longer necessary for the purposes for which they have been collected;
e) to request to destroy personal data if they are processed illegally or when you withdraw your consent regarding the processing of personal data or do not give a consent, which is necessary;
f) to object to the processing of personal data or to withdraw a previously given consent;
g) to request to terminate the actions of processing of personal data (except for storage) in case of any disputes or it is necessary to inspect the legitimacy of the processing of data, precision of data, as well as in certain cases when we no longer need personal data, but you do not want us to delete such data;
h) to request to submit your personal data, where technically possible, collected according to your consent or for the purposes of performance of contract in an easily readable format or request to send to another data controller.
12.2. We will seek to ensure the realisation of your rights as a personal data subject and to form all the conditions for effective realisation of these rights, however, we reserve a right to refrain from fulfilling your claims when it is necessary to ensure the following:
a) performance of legal obligations that have been set to us;
b) national security or defence;
c) public order, prevention of criminal activities, investigation, detection or criminal prosecution;
d) important economic or financial interests of the state;
e) prevention, investigation and detection of breaches of official or professional ethics;
f) protection of your rights and freedoms as well as those of other persons.
12.3. You can submit your claims related to the realisation of your rights in person, by mail or any means of electronic communication. After the receipt of your application, we may request to submit the documents proving your identity as well as any other additional information related to the application and necessary to us.
12.4. In case of receipt of your claim, we will reply to you no later than within 30 calendar days from the receipt of your claim and the day of submission of all the documents necessary to prepare the reply.
12.6. In case of refusal to perform your claim, we will clearly indicate the reasons of such refusal.
12.7. In case of disagreement with our actions or the answer to your application, you can appeal our actions and decisions by applying to a competent state authority.
13. Where can you submit a complaint?
13.1. If you want to submit a complaint regarding the processing of your data, you shall submit it in writing, by indicating as much information as possible, and according to the contact details provided at the end of this Policy. We will cooperate with you and will seek to solve all the matters immediately.
13.2. If you think that your rights under the GDPR have been breached, you can submit an appeal to our supervisory institutions. More information and contact details are available on the website of inspectorates (www.ada.lt – LT, www.dvi.gov.lv – LV). However, our principal aim is expedient and peaceful settlement of any disputes in cooperation with you.
15. How to contact us?