VIKONDA GROUP, UAB (hereinafter referred to as “the Company” or “we”) seek to inform you in detail about the processing of your personal data, whether you communicate with us by meeting us in person, by visiting us or by electronic means, submitting requests, complaints, applications, statements, information about violations and/or feedback (hereinafter referred to as “the Request”), or when concluding Contracts, or in any other manner chosen by you. This document applies to you if we process your personal data.
We care about the protection and privacy of your personal data. In this Privacy Policy (hereinafter referred to as “the Policy”), you will find information about how we process your personal data, to whom we use it, how long we store it, how we share it, etc. Thereby, we seek to ensure the fair and transparent collection and use of information about you.Your personal data are processed in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “the General Data Protection Regulation” or “GDPR”), the Personal Data Legal Protection Act, as well as other legal acts.
Application is your written request to learn about your data processed by us, your requirement to adjust the data, discontinue the collection of data or delete your existing personal data (“forget you”).
This information is important; therefore, please read it carefully. We reserve the right to change our Policies to keep up with the arising or changing demands and the progress in process, so we ask you to read it regularly.
- WHAT DATA WE PROCESS?
Personal data (hereinafter referred to as “Personal Data” or “Data”) is any information that may be used to identify a person, as well as any other information necessary to properly fulfill pre-contractual and contractual obligations in so far as necessary to respond properly to the Request, the Application, for marketing purposes, and to perform other, not precluding by the legislation or binding obligations, actions.
Personal Data referred to in the Policy include:
- Identification and contact information you have provided: name, surname, personal identification number, telephone number, email address, address.
- Other information: which is necessary for the performance of the Contract and the collection of which you will be informed about in the specific contract concluded with you.
- A recording of the telephone conversation (if any);
- Video data captured by video surveillance equipment (if any);
- Information about your IP address or its device ID (if you have contacted us by electronic means).
- ON WHAT BASIS AND FOR WHAT PURPOSE DO WE PROCESS YOUR DATA?
We only use your data for: i) the proper performance of the Contract; ii) the resolution of your requests or claims arising in the course of the performance of the Contract; and iii) to respond to enquiries. We may also analyse the data/information obtained on the basis of these documents and systemise it in order to improve the quality of our operations and the quality of the services we provide to you and to expand the range of services we provide to you, taking into account your opinions and suggestions; iv) to provide you with tailored direct marketing offers that meet your needs.
If you do not consent to the use of your personal data for direct marketing purposes, please notify us immediately; v) to ensure our and your security, property security, we carry out video surveillance and process your video data (this provision applies only when you visit the Company’s premises or other Company’s facilities equipped with video surveillance cameras); vi) to ensure the provision of services remotely, we may record phone conversations or other communication between you and us. For this purpose, we also store your phone number, IP address, and other identifying data, conversation content, duration, time, and other technical data (you will be immediately informed about the recording of telephone calls upon contacting us. If you do not agree with this, you have the right to terminate communication by phone and communicate with us in another acceptable way).
- HOW LONG DO WE PROCESS AND STORE YOUR DATA?
3.1. We process and protect your data:
- for as long as the Agreement is in force
- during the Enquiry Response Period;
- for the period laid down by national law;
- marketing period.
3.2. Upon expiry/termination of the contract, we will, in response to an Enquiry, either destroy or securely and irretrievably depersonalise your data in accordance with the following procedures and time limits:
- we shall destroy the specific personal data necessary for the performance of the Contract for the purpose of responding to the Enquiry no later than 10 working days after the expiry of the Contract, after the response to the Enquiry, provided that such data is not required to be retained in accordance with the laws of the Republic of Lithuania and there are no grounds for any legal disputes. In the event of any presumption of litigation, this data shall be deleted within the time limits set out in paragraph (ii) of this clause;
- other personal data that do not need to be stored in accordance with the archiving procedure established by the legislation of the Republic of Lithuania and you have paid in full for the services provided under the Contract shall be destroyed by us no later than 6 months after the expiry of the Contract. In the event of legal disputes, we shall retain it for a further 30 working days after the date on which the specific legal dispute has been resolved and the final judgment has entered into force, and in the event of enforcement/collection, after the date of such enforcement/collection period;
- telephone call recordings (if made) and video surveillance equipment-captured video data (if made) are destroyed within 30 days after the termination/expiration of the Agreement (if the above-mentioned equipment allows such storage, we will destroy it after each 30-day calendar period), unless there are grounds for a legal dispute, in which case we will destroy it within the terms specified in this point ii);
- we shall destroy information about your IP address or its device ID (if you have contacted us by electronic means) within 60 days after the date of such contact, provided that this data is not required for the purposes of ongoing legal disputes between the Parties, in which case it shall be destroyed in accordance with the procedure set out in paragraph (ii);
- We keep the data we collect for marketing purposes for as long as you use our services and for 1 year after you stop using our services. In the event of your request to “forget you”, we will destroy, within 30 days of such request, the data used for marketing purposes only;
- personal data that must be compulsorily archived in accordance with the legislation of the Republic of Lithuania are stored and processed in accordance with the time limits set out in such legislation.
- FROM WHAT SOURCES DO WE COLLECT YOUR PERSONAL DATA?
We usually receive your data directly from you when you contact us to enter into a Contract, to amend a Contract, or by submitting an Enquiry by any of the methods you have chosen. In the context of the conclusion and performance of the Contract, and in the event of legal proceedings or recovery following the conclusion of the Contract, we may collect Your Data in response to an Enquiry: a) from publicly available data about You or third parties; b) from legal entities where You are an agent, employee, contractor or the like of those legal entities; c) from partners or other legal entities who engage us or who are engaged by us to provide you with services.
If we need to collect additional information or investigate relevant circumstances in order to provide quality and objective services under the Contract or to investigate your Request, we may link the data you provide to the data we hold and/or collect during the performance of the Contract or during the investigation of your Request, e.g., by inspecting CCTV footage, by interviewing our employees etc.
If the information (including documents) for the conclusion or modification or termination of the Contract, the Request is submitted from a computer on the Company’s or a third party’s network, there is a risk that the visited web pages will be recorded in the browser’s history and/or in the Company’s or the third party’s network registry, respectively. This can be avoided by submitting the information on a computer that is not on the network.
It is also important to note that, together with the information to enter into or modify or terminate the Contract, the Request may contain data that may reveal personal information of the notifier that is not related to the information he or she provides. Therefore, it is important to remove meta-data that is not relevant to the Enquiry before submitting information.
- IN WHICH CASES AND TO WHICH THIRD PARTIES DO WE DISCLOSE YOUR DATA?
We may transfer your data to third parties who provide us with legal services and services related to bookkeeping, accounting and data administration. Such persons may include website and social profiles developers and administrators, database software providers and administrators, data centre, hosting and cloud service providers, etc. In each case, we only provide the data processor with the amount of data that is necessary to carry out a specific order or provide a specific service. The processors we use may only process your personal data on our instructions and may not use it for other purposes or transfer it to other persons without our consent. They are also obliged to ensure the security of your data in accordance with applicable legislation and written agreements and contracts concluded with us.
If the event described in your Enquiry can be considered insurable, we will forward your Enquiry and the data to the insurance company(ies) with which we have insured our liability, property or otherwise provide us with insurance cover in relation to the event identified in your Enquiry. The insurance companies act as independent data controllers and process your data in accordance with the terms and conditions set by the insurance company.
Your data may also be disclosed to competent governmental or law enforcement authorities, such as the police, law enforcement or supervisory authorities, the State Register Centre, but only upon their request, or as required by applicable law, or in the cases and according to the procedures provided by law, in order to safeguard our rights, the safety of our other customers, our employees and our resources, and to assert, bring, submit and defend legal claims.
We may combine the information we have about you from different sources.
The request (information about an infringement, complaint, etc., i.e. something you do not want answered) can be made anonymously or with your personal data. In the latter case, the personal details of the whistleblower will only be known to the persons investigating the information received. However, the whistleblower may, if necessary, be called as a witness in court and thus lose his or her anonymity.
- IN WHICH TERRITORIES AND JURISDICTIONS DO WE PROCESS YOUR PERSONAL DATA?
We generally process and store your personal data within the territory of the European Union or the European Economic Area (EU/EEA), but we may transfer your personal data outside the EU/EEA, for example, where this is necessary for the conclusion and performance of a contract or where you have given your consent to such transfer. We will transfer your personal data outside the EU/EEA if at least one of the following measures is implemented:
- The European Commission has recognised that the State ensures an adequate level of protection of personal data.
- The recipient located in the United States is certified in accordance with the requirements of the EU-US agreement known as the “Privacy Shield”.
- The contract is based on standard terms and conditions approved by the European Commission;
- Compliance with codes of conduct or other safeguards under the General Data Protection Regulation.
- HOW SECURE IS YOUR DATA?
When processing personal data, we comply with the requirements of data protection legislation, including the GDPR. We use a range of security technologies and procedures to protect your personal information from unauthorised access, use or disclosure. We carefully select data processors and require them to use appropriate measures that can protect your confidentiality and ensure the security of your personal information. However, the security of transmission of information over the Internet or by mobile communication cannot be absolutely guaranteed, and any transmission of information to us by these means is at your own risk.
- WHAT RIGHTS DO DATA PROTECTION LAWS GIVE YOU?
Right of access to your personal data processed by us: you have the right to obtain our confirmation as to whether we are processing your personal data, as well as the right to have access to your personal data processed by us and to information about the purposes of the processing of the data, the categories of the data processed, the categories of recipients of the data, the duration of the processing of the data, and the sources of the da
Right to rectification of personal data: if the data you have provided to us has changed, or if you believe that the information we are processing about you is inaccurate or incorrect, you have the right to request that this information be amended, clarified or rectified.
Right to complain: If you believe that we are processing your data in breach of data protection law, we always ask you to contact us directly in the first instance. If you are not satisfied with the solution we propose to resolve the problem, or if you do not think that we will take the necessary action to comply with your request, you will have the right to lodge a complaint with the supervisory authority, which in the Republic of Lithuania is the State Data Protection Inspectorate (A. Juozapavičiaus g. 6, 09310 Vilnius; tel. (8 5) 271 2804, 279 1445; e-mail: ada@ada.lt).
Right to erasure (right to be forgotten): in certain circumstances listed in the data processing legislation (where personal data are processed unlawfully, where the basis for processing has ceased to exist, etc.), you have the right to request in writing that we erase your personal data.
Right to restrict processing: in certain circumstances listed in the data processing legislation (where the processing of personal data is unlawful, where you contest the accuracy of the data, where you have objected to the processing of the data on the basis of our legitimate interest, etc.), you also have the right to inform us in writing of the restriction of the processing of your data.
- WHAT ARE THE PRINCIPLES OF PERSONAL DATA PROTECTION THAT WE FOLLOW?
We comply with the following principles when collecting and using the personal data entrusted to us by you, as well as personal data received from other sources:
9.1.Your personal data shall be processed in a lawful, fair and transparent manner (principle of lawfulness, fairness and transparency).
9.2.Your personal data is collected for specified, explicit and legitimate purposes and is not further processed in a manner incompatible with those purposes (purpose limitation principle).
9.3.Your personal data is adequate, relevant and only necessary for the purposes for which it is processed (data minimisation principle).
9.4.The personal data processed is accurate and, where necessary, kept up to date (principle of accuracy).
9.5.Your personal data shall be kept in a form which permits identification of an individual for no longer than is necessary for the purposes for which your personal data are processed (the principle of limitation of storage period).
9.6.Your personal data shall be processed in such a way as to ensure, by means of appropriate technical or organisational measures, adequate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage (integrity and confidentiality principle).
- WHAT DO WE COMMIT TO?
In collecting and using the personal data you have entrusted to us, as well as personal data obtained from other sources, we undertake to:
10.1. Process your personal data only for clearly defined and legitimate purposes.
10.2. Not to process your personal data for purposes other than those set out in this Privacy Policy of the Company, except as provided by law.
10.3. To process your personal data lawfully, accurately, transparently, fairly and in such a way as to ensure the accuracy, identity and security of the personal data processed.
10.4. Ensuring that redundant personal data are not processed.
10.5. To process your personal data for no longer than is necessary for the purposes for which the personal data are processed.
10.6. Be responsible for, and be able to demonstrate compliance with, the principles set out in this Company Privacy Policy.
10.7. Carry out other duties as required by law.
- HOW CAN YOU CONTACT US AND HOW WILL WE GET BACK TO YOU?
11.1. You can make all Data Processing Requests to us in the following ways:
– E-mail: elena@vikonda.lt
– Website: www.vikonda.lt
– Postal correspondence address: Didžioji g. 22, LT-57255 Kėdainiai
Address your message to:Vikonda group, UAB teisininkui
11.2. Our details as data controller and processor:
– Vikonda group, UAB
– Legal entity code 261592650
– Registered office address: Didžioji g. 22, LT-57255 Kėdainiai, Lithuania
11.3. We will respond to your Request for Processing within 30 (thirty) calendar days from the date of receipt of the Request. In exceptional cases requiring additional time, we shall have the right, upon notice to you, to extend the time limit for the provision of the requested data or for the processing of the other requirements set out in your Request by up to 60 (sixty) calendar days from the date of your request.
- COOKIE POLICY
This Website (www.vikonda.lt) uses cookies, which are small data files that store information about your browsing on this website. Their purpose is to improve the quality of your visit to our website. Read on to find out more about the cookies we use, the purposes for which we use them and other relevant information.
Cookie – what is it?
A cookie is a small file of information sent to your computer, phone or other device when you visit a website and stored in your browser. Cookies are of different types and therefore also have different uses. Cookies can be categorised according to their purpose, how long they are stored and their location on the website.
What are cookies used for on this website?
Cookies allow the website to remember information about your browsing habits, actions and settings so that you can use the full functionality of the website. Cookies also allow us to monitor the frequency of visits to the website and to collect general statistical information about the number of visitors to the website.
In individual cases, the use of cookies may be temporarily activated on web pages, etc. in order to provide users with the most relevant information, but in this case you will be notified in advance. In this case, we will use session cookies to improve the performance of the website and to collect anonymous general information about the use of the website. Session cookies are temporary and disappear when you leave the website or close your browser You can set your browser to accept all cookies, reject all cookies or to notify you when a cookie is sent. Each browser is different, so if you do not know how to change your cookie settings, please refer to your browser’s user guide. Your device’s operating system may have additional cookie controls. If you do not want cookies to collect information, you can refuse the use of cookies in your browser settings.
In some cases, deleting cookies may slow down your internet browsing speed, restrict certain features of the website or block access to the website.
Why are cookies NOT used on this website?
The cookies we use do not contain sensitive personal information such as your address, password, credit or debit card details, etc.
Who uses the information in cookies?
The information contained in cookies on our website is used exclusively by our authorised personnel, with the exception of the “third-party cookies” listed below, which are used and managed by external entities that provide services at our request in relation to improving our services and facilitating the user’s navigation on our website. These “third party cookies” are mainly used to obtain statistical information about visits.
How do I change my cookie settings?
You can choose to accept cookies or refuse certain cookies by changing your browser settings. You can set your browser to reject all or some cookies immediately. You can also remove cookies that have already been stored on your computer or other device. It is important to note that each browser has a different method of adjusting its settings. If necessary, please use your browser’s help function to select the correct settings.
Our website contains links to the websites of other companies or organisations. Please note that we are not responsible for the content of such websites or their privacy practices. Therefore, if you access other websites from our website, you should consult their privacy policies separately.
Descriptions of the cookies used on the VIKONDA Grupa, UAB website (www.vikonda.lt):
| Cookie name | Purpose | Period of validity |
| _ga | Allows you to monitor your website using the Google Analytics analytics tool. | 2 years |
| _gat | Does not store any information. Used only for the restriction of sending information to “Google Analytics”. | Until the end of the session |
| _gid | “Google Analytics” cookie to distinguish users. | 1 year |
These provisions may be subject to change without notice as we comply with the legislation governing the use of cookies and take into account generally accepted practices relating to the use of cookies.