1. GENERAL PROVISIONS
Policy describes what personal data we collect, how we obtain it, on what basis and for what purposes we use your personal data, how we use it, how long we store your personal data, who we share your personal data with, how we protect your personal data, and what are your rights. The Company respects your privacy and is committed to protecting the safety of your personal data.
While processing personal data, the Company also acts in accordance with the legal acts regulating the protection of personal data, including the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the GDPR).
By using any of the services on the Website or by providing the Company with any information about yourself by submitting inquiries or contacting us (including via LinkedIn or Facebook), you understand that your personal data will be used as set out below.
Please be informed that this Policy may be updated at any time at the sole discretion of the Company. Any changes to this Policy are effective from the date of their publication on the Website. You undertake to review this Policy periodically to become aware of any changes. In case of any major changes to this Policy, we will inform you separately or provide an announcement on our Website.
2. DATA CONTROLLER AND CONTACT DETAILS
The controller of personal data is the Company, i.e.:
|Name||“Estina LT”, UAB|
|Legal entity code||304614924|
|Address||Paupio g. 46, Vilnius, Lithuania|
Should you have any questions in connection with this Policy or the processing of your personal data, please feel free to contact the Company using the contact details given above. Please submit your enquiries in writing (for example, by e-mail: firstname.lastname@example.org) so that we could properly consider your enquiry and reply to you.
3. PERSONAL DATA
Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to identification of the particular person, also constitute personal data.
Please do not send us any personal data, especially sensitive personal data, about yourself if you do not want such information to be used in any way.
The Company does not collect data from individuals under 14, so if you are under 14, you should not use this Website and should not provide your personal data to the Company.
4. PERSONAL DATA COLLECTED, ITS PURPOSES AND LEGAL GROUNDS
The Company will process your personal data for the following purposes and based on the related lawful basis:
4.1. Direct interactions and management of enquiries
|Purpose||The Company processes personal data received together with your enquiry (via e-mail) in order to properly administer enquiries (e.g. submit you an offer according to your request or answer questions), where necessary, fulfil various legal requirements and defend the legitimate interests of the Company.|
|Data subjects||Persons submitting enquiries or contacting the Company via our e-mail.|
If it is not necessary to disclose certain personal data for the respective purpose (for an enquiry or request), therefore you should not provide excess data.
If you fail to provide your personal data, we may not be able to process your enquiry properly and provide you with the information you seek.
The time limit for the storage of personal data specified in your enquiry is up to 3 years, depending on the nature of received personal data and other circumstances. In some individual cases, in accordance with the applicable legal requirements, your personal data might be stored longer.
4.2. Representatives of our (potential) clients and vendors
|Purpose||Communication with the representatives of our (potential) clients and (potential) vendors. Day to day business communication related to the services provided.|
|Data subjects||Representatives of our (potential) clients and (potential) vendors.|
|Legal basis||The execution of a contract (or if needed to take steps at your request before entering into a contract) and processing of your requests (Article 6(1)(b) of the GDPR).|
|Storage||Data will be stored for 10 years following the respective communication if we enter into a contract. If personal data are indicated in the contract between the Company and its client / vendor, then personal data will be stored for 10 years as of the date of expiration of the contract. If no contract is concluded, data will be stored for 5 years following the respective communication.|
4.3. Contacts via social networks
|Purpose||Managing and administering Company’s social network (i.e. LinkedIn and /or Facebook profiles).|
|Data subjects||Users of LinkedIn and Facebook interacting with Company’s LinkedIn and / or Facebook accounts.|
|Legal basis||Your consent (Article 6(1)(a) of the GDPR) or our legitimate interests to communicate with our followers (Article 6(1)(f) of the GDPR).|
|Storage||Personal data will be stored until the Company’s LinkedIn and / or Facebook accounta are used by the Company, unless you by yourself at any time delete (or ask us to delete) your personal data earlier on.|
4.4. Recruiting (Candidates)
|Purpose||Recruiting. Handling the personal data of the candidates to work at the Company.|
|Data subjects||Candidates of the Company|
|Storage||Company will store the personal data about the candidate for as long as the selection to the specific position is taking place and 6 months after that. Based on your consent such personal data may be stored longer.|
4.5. Functions of the Website
Cookies are small text files placed on the web browser used and saved on the visitor’s device. Cookies are placed on the visitor’s computer the first time that they visit the Website. Cookies are used to ensure a convenient and safe functioning of the website. This enables to constantly improve the functionality of the Website and to better adapt it to the needs of visitors.
You can delete all cookies stored on your computer, and in most browsers, you can set cookies not to be saved. First of all, you can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).
Please be aware that if cookies are disabled, you may lose the ability to use the many features necessary to make the Website work as well. In order to remove cookies from your mobile phone, you should find this information in the user guide for your phone.
5. RECIPIENTS OF PERSONAL DATA, DATA TRANSFER
Any information that you provide may be processed by the Company and shared with third parties (data processors), which provide the Company with services and act on its behalf (e.g. companies providing data centre services, IT service providers, accounting service providers). The Company ensures that processing of personal data by such third parties will be based on legitimate legal ground and will be performed in accordance with lawful instructions of the Company and in compliance with the GDPR and other legal requirements. Your personal data will be provided to these data processors to the extent that is necessary for the provision of their respective services.
We ensure that the data processors of your personal data follow the instructions for the processing of personal data (where applicable) and implement appropriate organizational and technical measures to protect such personal data from accidental or unlawful destruction, alteration, disclosure or any other unlawful processing.
The personal data may also be transferred to the relevant personal data recipients / external third parties. The Company may share personal data with the following categories of third parties, as necessary:
The Company does not transfer your personal data to third countries (outside the EU / EEA). In case any transfer outside the EU / EEA becomes necessary, we will make every effort to ensure that such data transfer comply with the requirements of the GDPR and implement appropriate measures to ensure that your personal data remains protected and secure. You may find more about such measures by contacting us directly via e-mail as indicated above.
6. YOUR RIGHTS
With respect of your personal data, you have the following rights provided for in the legislation, namely:
With a view to exercise your rights, or if you have any questions related to the protection of your personal data, please contact the Company using the contact details provided above in this Policy. In order to properly examine your enquiry and provide a detailed reply, please submit your enquiries in writing (by e-mail: email@example.com).
We will exercise your rights within 30 days. If the request is very complex or the number of received requests is very high, this term may be extended for another 60 days. In this case, we will notify you about this extension and reasons for it within 30 days from your request. In order to ensure data protection and properly exercise your rights, we have the right to ask you to provide proof of your identity.
The Website and its contents are provided for general information purposes only. The Company assumes no responsibility for the information and material on the Website.
To the extent permissible by applicable laws the Company is not responsible or liable for any matter relating to you or any third parties accessing or using this Website and its contents.
8. DETAILS OF THE WEBSITE
The Website, content of the Website, code of the Website, design, domain name, all copyrights, trademarks, databases, corporate names and other intellectual property or other property related to the Website and / or its contents are fully owned by the Company and are protected by national and international intellectual property laws and other legislation.
Unless expressly permitted by the Company, you have no right, in any form and by any means, to copy, capture, reproduce in any form or manner, launch, publish, transfer, sell, translate, reprocess, submit, licence, modify, create derivative works from or based upon, republish, edit, transmit, retransmit or otherwise make public, publicly perform or display, frame, distribute or use, in part or in its entirety, the Website, the Website content or Website code.