Privacy policy

This privacy policy (the “Privacy Policy” or the “Policy”) explains how ŠYPSENOS RŪMAI, UAB (the “Company”, “we” or “us”) collects and uses information when you use any services offered on our website www.identite.lt (the “Website”) or any other services we provide (the “Services”).

ŠYPSENOS RŪMAI, UAB is committed to handling your personal data responsibly and securely in its work. Guided by this essential principle, we will always seek to ensure an adequate level of protection for your data and for your rights. We process Personal Data in accordance with this Privacy Policy and the applicable law, including the General Data Protection Regulation (2016/679) (the “GDPR”) and the applicable Lithuanian national data protection law.

In this Policy, “your Personal Data” means any information from which your identity can be established (the “Personal Data”).

We are the controller of the Personal Data that falls within the scope of this Policy.

We use your personal data to carry out our activities and to provide services to you. Our aim is to process only the personal data that you have given us voluntarily after receiving full information about the purposes of processing, and the data that is necessary to perform contracts with you, to meet legal requirements and to carry out our activities.

Please read this privacy policy to learn how we collect, use, transfer and store your personal data.

1. Collection and use of personal data

1.1 What information we collect

We process your personal data if you give it to us voluntarily, for example in an email to us, when ordering our services, when filling in a form on the website or when contacting us by phone or text message. In some cases we already process personal data you gave us earlier, for example if you are a current or former client. We will process the personal data you provide in accordance with this Policy and the law that applies to us. Your personal data will not be used for purposes other than those stated when the data was obtained, unless we receive your additional consent or such use is provided for by law. If you send us your curriculum vitae (CV), we will use the information you provide to offer you the most suitable position in our company.

1.2 The legal basis for processing your personal data

As a rule, we collect your personal data only to the extent necessary to provide services to you. EU law requires us to inform the people whose data we process about the legal bases for processing. When processing your personal data, we rely on one of the following legal bases:

Performance of a contract. This applies when processing your data is necessary to fulfil our obligations to you under a contract, for example to issue you a loyalty card or to make or receive a payment for services.

Legal obligation. This applies when laws or other legal acts require us to process your personal data, for example

for tax accounting purposes, or providing data to public authorities or the police.

Consent. In some cases we will process your personal data only if we have first received your consent. You can withdraw your consent to data processing at any time by contacting us at [email protected].

Legitimate interests. We will process your personal data where we have a legitimate interest in doing so and such processing does not override the protection of your interests and rights.

Because of the legitimate interest mentioned above, we, for example:

• Give visitors to our website information about the Company’s services or job offers;
• Seek to prevent fraud and crime, and to protect our property and the IT systems we use;
• Organise and monitor the advertising solutions we use;
• Seek to ensure that the Company’s corporate and social commitments are met;

We ensure that the rights provided for in Articles 16 and 17 of the Charter of Fundamental Rights of the European Union are exercised, including the freedom to conduct a business and the right to property.

In some cases the personal data we process may also include special categories of personal data, that is, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health, or data concerning a natural person’s sex life or sexual orientation. We process this data only with your consent or where such processing is required by law.

1.3 Automatic collection of personal data

The website www.identite.lt does not use cookies, web beacons, analytics or location tools, and shows no cookie notice.

The website’s hosting provider keeps server request logs (for example the IP address, the time of the request and the browser type) for a short time for technical and security purposes. We do not use this data to identify you.

1.4 Social media tools and applications

Our websites may have features that let you share information through social platforms run by third parties, for example Facebook’s “like” and “share” features. These social platforms may store data about your use of our website. Personal data that you provide through such social platforms may often also be passed on to other users of the social platform. Such transfers are governed by the privacy policy of the social platform’s operator. We do not control how this personal data is processed and therefore cannot accept any responsibility for it.

1.5 Children’s personal data

We understand how important it is to protect the privacy of children’s personal data properly. Our website and our services are not designed for children under 16. We will never knowingly collect or store information about children under 16, unless this information is needed to provide our services to you.

2. Transfer of personal data to third parties

We do not share your personal data with third parties unless this is necessary to provide services to you, to carry out your requests, for our legitimate interests and business needs, or where specific laws require it. You can find more information about the third parties we use by clicking this link.

We do not transfer your personal data to any third parties that could use this data for direct marketing.

3. Your choices

As a rule, we will not ask you to provide personal data when you use our services, unless this is necessary to provide the services, for example to conclude a contract or to stay in contact with you. When we receive your request for information about the services we provide to you, we may ask you to provide additional personal data. In some cases we may ask for your additional consent to the processing of personal data, and you have the right to refuse to give consent to processing for these purposes. If you give consent to receive certain services or information messages, we will give you the option to withdraw this consent at any time. If you withdraw your consent, we will try to stop using your personal data for the purposes stated in the consent as soon as possible.

As stated earlier in the “Cookies” section, if you wish to prevent being tracked with cookies on our website, you can delete cookies from your web browser and block further storage of such cookies. In this case some features of our website may not work properly.

4. Your rights

If we process your personal data, you can exercise the following rights:

Access and rectification. You have the right to access the personal data we process about you. To access the personal data we process about you, you can submit a request to us. If, after assessing your request, we decide that we must grant you this right, we will provide the information free of charge. To protect the rights of other people and to answer your request properly, we may ask you to provide information proving your identity and other information about your relationship with us before we reply. If the data we process about you is inaccurate, you have the right to ask us to correct it.

Right to object to data processing. You have the right to object to our processing of your personal data if we can no longer use it.

Other rights. If you believe that we should not be processing your personal data or are keeping it for too long, you have the right to ask for your personal data to be deleted or for its use to be restricted. In some cases you also have the right to ask for a copy of information stored electronically.

To exercise your rights, you can contact us by email at [email protected].

When we receive your request, we will make every possible effort, in accordance with the applicable law and professional practice, to help you exercise your rights.

5. Data security and integrity

When processing your personal data, we use organisational and technical data protection measures and procedures designed to protect your personal data from unlawful loss, misuse, alteration or destruction. Despite all our efforts, it is not possible to take every possible threat into account and guarantee absolute security of personal data. To ensure the greatest possible protection of personal data, access to your data is limited to our employees on a “need to know” basis. People who process data are bound to follow strict personal data processing requirements.

We make every possible effort to ensure that your personal data is processed only:

• while this information is necessary to provide services or information to you;

while we are required to keep this information by law or for business necessity, or until you ask us to destroy your personal data. The specific retention period depends on the circumstances in which the information was collected and the purposes for which it is used; however, taking into account the requirements set out in I)–III) above, personal data will not be kept for longer than 2 years.

6. Links to other websites

Please note that our website contains links to other websites, including websites run by third parties, to which this Privacy Policy does not apply and whose privacy terms may differ substantially. We encourage you to read the privacy policy of each such website before providing any information that identifies you.

7. Changes to this policy

We may review and update this Privacy Policy in light of our personal data protection measures. Each time the Privacy Policy is updated, we will update the “Last updated” field at the top of the Policy. You will be informed of changes to the Privacy Policy that apply to you through the means of communication usual between you and us.

8. Enforcement of the privacy policy

We are committed to protecting your personal data. If you have any questions or comments about the processing of your personal data, please contact us by email at [email protected].

You can also send any comments on this Privacy Policy to this address.

When we receive your request, we will confirm receipt within 14 days and will try to reply within one month of receiving it. If your request is complex or we have received a very large number of requests at that time, we may, after informing you, extend the deadline for replying to up to three months from receiving the request.

Finally, you always have the right to lodge a complaint about improper processing of your data with the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).

Annex

Transfer of data to third parties

We do not share your personal data with third parties unless this is needed to provide services to you, to carry out your requests, for our reasonable business needs and/or where this is provided for by law. This includes:

Our service providers: We share your personal data with third parties that provide services to us, for example our IT maintenance providers, our website hosting providers, our accounting service providers, consultants, lawyers and other suppliers of goods and services. We work with these third parties and pass your personal data to them for processing. We pass your personal data to these third parties only if they meet the strict personal data processing and security requirements we apply. We share your personal data only to the extent necessary for these third parties to provide their services.

If we or part of our business were sold, reorganised or transferred to another company: we would transfer the personal data related to the sale or reorganisation to the extent that it is directly related to running the business being sold or transferred.

Pre-trial investigation authorities, courts or other authorities empowered by the state: we will transfer the personal data requested by courts, pre-trial investigation authorities or other authorised bodies when this is necessary to fulfil our legal obligations or when there is another legal basis for the transfer provided for by law.

Audit: we will transfer personal data if it is needed to carry out a financial, data privacy or security audit, or to investigate and respond properly to a complaint or a security threat.