GENERAL PRIVACY PROVISIONS
We are aware of the particular importance we attach to the protection of your personal data, and we only collect and process your data that is necessary for the performance of our activities. We process personal data lawfully, transparently and fairly, for predefined purposes and only to the extent necessary to achieve those purposes. When we process personal data, we aim to keep it accurate, secure, confidential, properly stored and protected.
When processing your personal data, we comply with the requirements of the General Data Protection Regulation (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as with the requirements for the processing of personal data set out in other legal acts.
1. WHAT IS THIS DOCUMENT?
1.1. This privacy policy (hereinafter referred to as the “Privacy Policy”) sets out the privacy terms and conditions for your use of the website vytautasn8.sg-host.com (hereinafter referred to as the “Website”) and our accounts on the social networks Facebook (vilniuskatamaran), Instagram (vilniuskatamaran).
1.2. Please read this Privacy Policy carefully to find out how we process your personal data, where we get it from and what your rights are as a personal data subject.
1.3. The Privacy Policy applies to all persons who visit the Website and/or our social media accounts.
1.4. If you use the Website or our accounts in social networks, it means that you have read and agreed to this Privacy Policy and the purposes, methods and procedures for processing your personal data set out therein. If you do not agree to this Privacy Policy, you may not use the Site or our social media accounts.
1.5. As used in this Privacy Policy, “personal data” means any information from which you can be identified, whether directly or indirectly. Personal data includes name, surname, date of birth, postal or e-mail address, location data and internet identifier, characteristics specific to you, etc.
2. WHO ARE WE?
2.1. The website is managed and administered by UAB “Staroil”, legal entity code 304031409, business address Linksmoji g. 36-33, Vilnius, telephone number: +370 619 17 157, e-mail address: info@vytautasn23.sg-host.com.
2.2. In accordance with the provisions of the legislation, we are the controller of your personal data.
3. WHAT PRINCIPLES DO WE FOLLOW?
3.1. When we process your personal data, we:
a) we will comply with the requirements of current and applicable legislation, including the GDPR;
(b) we will process your personal data in a lawful, fair and transparent manner;
(c) we will collect your personal data for specified, explicit and legitimate purposes and will not further process it in a way that is incompatible with those purposes, except to the extent permitted by law;
(d) we will take all reasonable steps to ensure that personal data which are not accurate or complete in relation to the purposes for which they are processed are rectified, supplemented, suppressed or erased without delay;
(e) we will keep them in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;
(f) we will not provide personal data to third parties or disclose it to the public, except as provided in the Privacy Policy or applicable law;
(f) we will ensure that your personal data is processed in such a way that appropriate technical or organisational measures are taken to ensure adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
4. HOW DO WE COLLECT YOUR DATA?
4.1. We process your personal data received in the following ways:
(a) when you provide personal data to us. You provide us with your personal data and other information by using the Website, visiting our social media accounts, writing to us or communicating with our team, submitting your complaints and/or queries, comments, etc. Please note that if you contact us in writing or by email, we will retain the details of the correspondence.
b) when you use our Website and/or our social media accounts. When you use our Website and/or visit our accounts on social networks, certain information (such as your Internet Protocol (IP) address, the type of web browser you are using, your age, the number of times you have visited, the web pages you have viewed, the amount of time you have spent on the Website, the online source from which you came, the information about the device you are using, the language you are using, the country you are in, the internet service provider you are using, and so on) is collected automatically;
c) when we receive your personal data from other persons in accordance with the procedure established by legal acts and/or this Privacy Policy.
5. WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?
5.1. We process your personal data for the following purposes:
(a) for the purpose of registration, identification and provision of services on the Website. You provide us with your personal data when you register (create an account) on the Site and use the features of the Site. For this purpose, we process the following personal data: name, surname, email address, city, residential address, telephone number.
For this purpose, we obtain your personal data from you when you register (create an account) on the Site and use the Site’s features.
We do not transfer or disclose your personal data processed for this purpose to anyone.
For this purpose, we process your personal data until you yourself cancel your account on our Website.
(b) for the purpose of conducting e-commerce, making reservations on the website. In order to enter into a sales contract with you and to carry out the contract (e.g. to fulfil service orders and bookings, to receive and administer payments, etc.), we process the following personal data: name, surname, email address, telephone number, place of residence (city), IP address.
For this purpose, we receive your personal data from you and from third parties involved in the process of selling and delivering goods to you (e.g. payment intermediaries, financial institutions, postal and courier service providers, etc.).
For this purpose, we process your personal data for as long as you have the right to make claims against us in connection with the purchase of services in accordance with the statutory procedure.
(c) for the purpose of applying and administering discounts to your purchases. If you wish to take advantage of our discounts (e.g. student discount), we process the following personal data for this purpose: name, surname, email address, telephone number, place of residence (city), date of birth or personal identification number.
For this purpose, we obtain your personal data from you.
For this purpose, we process your personal data until we determine whether you are eligible for a discount.
(d) for the purpose of carrying out other transactions with you. We process your personal data where this is necessary for the performance of our duties and the exercise of our rights in connection with other transactions between us. For this purpose, we process the minimum necessary personal data we receive from you and from third parties, and we keep it for as long as you have the right to make claims against us in relation to these transactions in accordance with the law.
(e) for direct marketing purposes. We process your personal data with your consent in order to provide you with newsletters, offers and information about our, our affiliates’ and our partners’ services and/or goods or other information, to improve our services. The personal data processed for this purpose includes: name, surname, telephone number, e-mail address, details of goods and services ordered on the Website (e.g. date and time of services ordered, name of the services, quantity of services, type of services ordered), history of personalised offers made to you, and information about the use made of them.
For this purpose, we receive your personal data from you and collect it when you use the Website.
For this purpose, we transfer (provide) your personal data to companies providing newsletter services, information business management systems, and website administration services.
For this purpose, we process your personal data for a period of 2 years from the date of your consent to receive newsletters, offers and information from us, unless you withdraw your consent earlier.
For more information on the processing of personal data for direct marketing purposes, please refer to Section 6 of this Privacy Policy.
(i) for the purpose of improving our websites and offering better and more tailored services and/or services. We use your personal data, including personal data and cookies that we receive when you use our Website and/or visit our accounts (social networks), to improve and develop the Website and to offer you better and more personalised services.
For this purpose, we use the personal data we receive from you, generated by your use of the Website and/or received from others.
Please see section 7 of this Privacy Policy for more information on how we use cookies and similar technologies.
(j) for the purpose of monitoring the quality of our activities and ensuring the functionality of the Sites and/or social networking account(s). When you contact or communicate with us at our offices or by means of communication, we process information from telephone, email, Website or other communications. For this purpose, we process the following personal data about you: name, surname, email address, telephone number, place of residence (address), content of the complaint and/or enquiry, telephone number, date and time of contacting us, details of the communication, the content of the comment you wish to make public.
For this purpose, we obtain your personal data from you, and we may create personal data ourselves in the course of fulfilling a query or analysing a complaint (e.g. we contact third parties about the factual circumstances after receiving your complaint and record them, etc.).
For this purpose, we transfer/provide your data to persons we use to provide repair or related services, insurers and insurance intermediaries, suppliers of after-sales service, as well as manufacturers and suppliers of goods.
k) for other purposes provided for in our Personal Data Processing Rules and/or other internal documents, where we are obliged to process your personal data by law, or where there is a legitimate interest or other grounds for the lawful processing of personal data.
5.2. We do not ask for or process your special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or data concerning your health or data concerning your sex life and sexual orientation. In the event that you provide us with such data through the Website, or otherwise (in writing, by e-mail, by telephone), it will be deemed to have been provided with your consent. Accordingly, we will process this data together with other data that you have provided in the ways set out in point 5.1 of this Privacy Policy, unless such data cannot be separated or would require a disproportionate effort.
6. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING?
6.1. With your consent, we may use your personal data for the purpose of direct marketing in order to provide you with newsletters, offers and information about our, our affiliates’ and our partners’ services and/or products that we think may be of interest to you. However, we will only use your personal data for this purpose with your additional consent.
6.2. For this purpose, we process your personal data as specified in Section 5.1 of the Privacy Policy.
6.3. By granting us the right to process your data for direct marketing purposes, you also grant us permission to contact you for this purpose by appropriate means of communication (e.g. email, telephone, SMS or other means of communication (e.g. Skype, Viber, etc.).
6.4. We may combine the information we hold about you with information held by third parties.
6.5. If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyse and improve the effectiveness of our websites, advertising and market research, and for other company marketing and sales purposes. In this case, we will use your personalised data.
6.6. Even if you have given your consent to the processing of your personal data for direct marketing purposes, you can easily withdraw this consent at any time for all or part of the processing of your personal data. To do so, you can:
(a) by clicking on the unsubscribe link in the newsletter itself, or
b) send us a request by email to info@vytautasn23.sg-host.com. In order to enable us to identify you, please clearly state your name, email address and other registration details (if any) in your request. If we have reasonable doubts about your identity, we may ask you to provide additional proof of identity.
6.7. If you withdraw your consent, we will endeavour to stop processing your personal data for the purpose of direct marketing as soon as possible.
7. HOW DO WE USE COOKIES?
7.1. We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device’s hard drive and allow us to recognise you on subsequent visits to the Site, save your browsing history, preferences, customise content, speed up searches on the Site, make the Site more user-friendly and friendly, and provide a more efficient and reliable Site environment. Cookies are a common practice on websites that make it easier to use the website.
7.2. We may collect the following information through cookies: the IP address, the type of web browser used, the number of visits to the Site, the pages viewed on the Site, the amount of time spent on the Site, demographic data, and, if you have come to the Site from a third-party website, the URL link of the page.
7.3. We use the information we receive from cookies for the following purposes:
(a) to ensure the functionality of the Site (e.g. to enable you to use the Site’s personalisation);
(b) to improve and develop the Website to better meet your needs;
(c) for the development of services and analysis of the use of the Website;
(d) targeted marketing guidance.
7.4. We may, without prejudice to the law, combine information obtained through the use of cookies with information obtained about you by other means (e.g. combining information about your use of the Website with personal data that you have provided).
7.5. The following cookies may be used on the Website:
a) technical cookies – these are cookies that are necessary for the operation of the Website;
b) Functional cookies – these are cookies that, although not essential to the operation of the Website, significantly improve its performance, quality and user experience;
c) analytical cookies – these are cookies that are used to compile a statistical analysis of the navigation methods of visitors to the Website; the data collected by these cookies is used anonymously;
(d) Targeting or advertising cookies – cookies that are used to show you offers or other information that may be of interest to you;
e) social network cookies – these are cookies that are necessary for you to use the Site information in your social profile account.
7.6. Full information about the cookies used on the Website, their purpose, validity and the data used is provided below:
__cfduidl. 1 year. Cookie used to identify reliable website traffic, which does not record personal data of the user.
frontend. frontend_cid. Until the website window closes. Cookies used for the operation of the vytautasn8.sg-host.com website.
_ga. IDE. 2 years. “Google cookie that collects information about user behaviour on the website and is used to store statistical information.
_gid. ads/user-lists/#. ads/ga-audiences. collect. Until the website window closes. “A Google cookie that collects information about user behaviour on the website and is used to store statistical information.
test_cookie. Until the website window closes. “A Google cookie that determines whether you allow cookies in your browser.
_gat. Until the website window closes. “A Google cookie that is used to identify new sessions/visits.
fr. 3 months. “Facebook cookie that collects information about user behaviour and is used for remarketing.
tr. Until the website window closes. “Facebook cookie that collects information about user behaviour and is used for remarketing.
zte#. Until the website window closes. Used by the Zendesk tool, which detects devices between different chat sessions.
AWSALB. 6 days. Used by the Zendesk tool that supports chat sessions.
__zlcmid. 1 year. Used by the Zendesk tool to identify the device from which you are connecting during a session.
7.7.You can give your consent to the use of cookies in the following ways:
(a) by not deleting them and/or changing the settings on your internet browser so that it does not accept cookies;
b) by clicking on the “I agree” link (bar) on the website about cookies;
7.8. You can withdraw your permission to use cookies at any time. You can do this by changing the settings on your web browser so that it does not accept cookies. How you do this depends on the operating system and web browser you are using. For detailed information on cookies, their use and how to refuse them, please visit http://AllAboutCookies.org or http://google.com/privacy_ads.html.
7.9. In some cases, in particular the disabling of technical and functional cookies, the refusal to accept cookies or their deletion may slow down the speed of your browsing on the Internet, restrict the functioning of certain functions of the Website, or block access to the Website.
8. WHO DO WE PROVIDE YOUR PERSONAL DATA TO?
8.1. We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without lawful basis, or used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy or applicable law. However, we reserve the right to disclose information about you if we are required to do so by law or if we are requested to do so by lawful law enforcement authorities or prosecuting authorities.
8.2 We may transfer your personal data to companies that assist us in the performance of our business activities, including direct marketing. We require such partners to process your data only in accordance with the instructions we have given them and the applicable data protection legislation. We enter into contracts with these individuals which oblige the parties to strictly comply with the requirements for the protection of personal data.
8.3 We may disclose the data we collect about you to the following third parties:
(a) third party service providers (e.g. technical service providers in the performance of our contracts with these service providers, including the performance of services for sending newsletters or other marketing activities);
(b) third-party service providers whose services we generally use for data storage, telecommunications and website hosting purposes;
c) other persons specified in the Privacy Policy.
8.4. The above service providers are limited in their ability to use your data and cannot use it for purposes other than to provide services to us.
8.5. The list of persons and categories of persons to whom we transfer your personal data (non-exhaustive) is set out in Section 5.1 of this Privacy Policy separately for each purpose of use of personal data.
9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
9.1. We will not keep your personal data for longer than the purposes of processing or the law requires, unless a longer retention period is specified in the law.
9.2. We aim not to store outdated, irrelevant personal data, so only relevant information is stored when it is updated. Historical information is retained where required by law or for the purposes of our activities.
9.3. Section 5.1 of the Privacy Policy specifies the retention periods of your personal data separately for each purpose of personal data use.
10. HOW DO WE PROTECT YOUR PERSONAL DATA?
10.1. The data we collect from you will be located within the European Union (EU), but may be transferred or stored outside the EU. It may also be processed by our or our suppliers’ staff working outside the EU. When we transfer your data outside the EU, we will take all reasonable steps to ensure that your data is processed securely and in accordance with this Privacy Policy.
10.2. Unfortunately, the transmission of information over the internet is not completely secure. Although we take great care to protect your personal data, we cannot guarantee the security of the data when you transmit data to the Website – you assume the risks associated with the transmission of data to the Website. Once we receive your data, we will implement strict procedures and security measures to protect your data from unauthorised access.
10.3. In the unlikely event that we become aware of a breach of security of your personal data which may pose a serious threat to your rights or freedoms, we will inform you immediately upon becoming aware of it and identifying the information accessed.
11. EXTERNAL WEBSITES
11.1. The Website may contain links to external websites, such as those of our business partners or websites advertising our services and/or goods. If you follow such links to any of these sites, please note that these sites and the services available through them have their own separate privacy policies and we do not accept any responsibility or liability for these policies or for the personal data, such as contact or location data, collected on these sites or through these services. Please review these policies before submitting personal data to these websites or using any services.
12. WHAT RIGHTS DO YOU HAVE?
12.1. When processing personal data, we ensure your rights in accordance with the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a personal data subject you have the following rights:
(a) to know (be informed) about the processing of your personal data;
(b) to have access to your personal data that we process;
(c) to request the rectification or completion, clarification of inaccurate, incomplete or incorrect personal data;
(d) require the destruction of personal data when they are no longer necessary for the purposes for which they were collected;
(e) require the destruction of personal data where the processing is unlawful or where you withdraw or withhold your consent to the processing of personal data, which is necessary;
(f) to object to the processing of personal data or to withdraw consent previously given;
(g) to request the suspension (other than storage) of the processing of your personal data in the event of disputes or to verify the lawfulness of the processing, the accuracy of the data, or where we no longer need your personal data, but you do not want us to delete them;
(h) require the provision, where technically feasible, of your personal data collected pursuant to your consent or for the purposes of the performance of a contract, in an easily readable format, or request that it be transmitted to another controller.
12.2. We will endeavour to guarantee the exercise of your rights as a data subject and to provide all the conditions for the effective exercise of those rights, but we reserve the right not to comply with your requests where it is necessary to ensure:
(a) fulfilling the legal obligations imposed on us;
(b) national security or defence;
(c) public policy, the prevention, investigation, detection or prosecution of criminal offences;
(d) important economic or financial interests of the State;
(e) the prevention, investigation and detection of breaches of official or professional ethics;
(f) the protection of your rights and freedoms or the rights and freedoms of other persons.
12.3. You may submit claims relating to the exercise of your rights to us in person, by post or by electronic communication. Upon receipt of your request, we may ask you to provide proof of identity, as well as other additional information we require in connection with your request.
12.4. Once we have received your request, we will respond to you no later than 30 calendar days from the date of receipt of your request and the submission of all the documents necessary to provide the response.
12.5. If we deem it necessary, we will suspend the processing of your data, with the exception of storage, until your request is resolved. If you lawfully withdraw your consent, we will cease processing your personal data immediately, but no later than 30 calendar days, except in the cases set out in clause 12.2 of this Privacy Policy and in the cases provided for by law, i.e. where we are obliged to continue to process your personal data by applicable law, by a legal obligation incumbent on us, by a judicial decision or by a binding order from the authorities.
12.6. If we refuse to comply with your request, we will clearly state the reason for such refusal.
12.7. If you disagree with our actions or our response to your request, you may complain about our actions and decisions to the competent public authority.
13. WHO CAN YOU COMPLAIN TO?
13.1. If you wish to make a complaint about our processing, please submit it in writing, providing as much information as possible, using the contact details provided at the end of this policy. We will co-operate with you and endeavour to resolve any issues promptly.
13.2. If you believe that your rights have been infringed under the GDPR, you can lodge a complaint with our supervisory authority, the State Data Protection Inspectorate, for more information and contact details, please visit the Inspectorate’s website (www.ada.lt). Although, first and foremost, we aim to resolve any disputes promptly and amicably with you.
14. HOW WILL THIS PRIVACY POLICY BE AMENDED?
14.1. Any changes to our Privacy Policy will be posted on the Website. We will notify you of such changes as necessary. New terms of our Privacy Policy may also be posted on the Site and you may need to read and agree to them in order to continue using the Site and/or our services.
15. HOW TO CONTACT US?
15.1. Please send all documents related to this Privacy Policy to or contact us at the following contact details:
a) by post – UAB “Staroil”, address Linksmoji g. 36-33, Vilnius;
(b) by email – info@vytautasn23.sg-host.com;
Date of publication of the Privacy Policy 01 April 2019
