Privacy notice of UAB AVAD Baltic
VERSION 1.2. (2024/12/20)
1. General provisions
This document (hereinafter referred to as the Privacy Notice) sets out the main principles of the collection, processing and storage of your (Customer’s) Personal Data by UAB AVAD Baltic, (data collected in the Register of Legal Entities of the Republic of Lithuania, legal entity code – 301060619, registered office address – Raudondvario rd. 131B, LT-47191 Kaunas, Lithuania, email – info@avad.lt (hereinafter referred to as the Company).
The Privacy Notice is intended to protect and defend the Customer’s Personal Data against unauthorised use.
When processing Personal Data, the Company complies with the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania and other directly applicable legal acts regulating the protection of Personal Data, as well as with the instructions and recommendations of the competent authorities.
Information on how the Company handles the personal data of its Partners in connection with the completion and submission of the Partner Questionnaire can be found in the Company’s Partner Questionnaire Privacy Notice.
2. Privacy Notice terms
Personal data means any information relating to a natural person – the data subject – who is known or identifiable, directly or indirectly, by reference to the data concerned;
Customer means any person who orders, purchases or uses our Services, or who has expressed an intention to use or is using the Company’s services in any way, or who intends to purchase or is purchasing the Company’s goods, or is otherwise connected with the services or goods provided by the Company, including the use of digital services provided by the Company by participating in the e-commerce system.
Processing means any operation (including collection, recording, storage, modification, access, querying, transfer, etc.) of Personal Data.
Login data means the Internet Protocol (IP) address and the Internet Service Provider (ISP) used to connect your device to the Internet, browser type and version, time zone preferences, browser plugin type and version, operating system and platform, location of the connection, font encoding, any Uniform Resource Locator (URL), and the products you view.
Regulation means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
3. Principles for processing personal data
The Company applies the following main principles for the processing of Personal Data in its activities:
– Personal data is collected for specified and legitimate purposes.
– Personal data is processed accurately and fairly.
– Personal data is processed lawfully, that is, only in cases when:
a) the data subject gives consent, for example to receive promotional information;
b) a contract is concluded or performed where one of the parties is the Personal Data Subject;
c) the Company is obliged to process Personal Data in accordance with the law;
d) the processing of personal data is necessary for the purposes of the legitimate interest pursued by the Company or by the third party to whom the personal data are provided and where the interests of the data subject are not overriding.
– Personal data is constantly updated.
– Personal data are kept for no longer than the stated purposes of the processing require.
– Personal data is processed only by those employees who have the right to do so.
– All information about the processing of Personal Data is confidential.
4. Nature of the information collected
Depending on the nature of the goods/services provided, the Company may collect the following Customer Data:
– basic Customer information: name, surname, personal identification number, address, copy of identity document (if provided) and details, telephone number, email address;
– information about the goods/services purchased by the Customer: information on the services selected/offered and their duration of use, information related to the assessment of the quality of the services provided, information on the return of goods, warranty service, etc., data on the Customer’s insolvency risk assessment;
– information on payments for goods/services: details of invoices submitted to the Customer, details of payments made by the Customer or others, information on debt management (including the transfer of data to third parties);
– information about the Customer’s consent to direct marketing: information about the consent/non-consent given by the Client to receive promotional information (news, programme offers, promotions, etc.), to participate in opinion polls, to use data, to provide Customer data to third parties, and to consent to insolvency risk assessment;
– communications and Customer service information: data about browsing on the Company’s websites and self-service websites (collected using cookies and similar technologies); recordings of telephone conversations when calling the Company’s representatives, information about correspondence with the Company (via self-service, email, customised applications, etc.);
– other data: prize winners’ information, information about survey participants, newsletter subscribers.
5. The purpose of data processing
The Company uses the collected data to provide you with its services/products, as well as to provide assistance, to send you notifications, offers and information about promotions, to protect its rights and interests and the rights and interests of third parties, and to comply with the applicable law.
Purposes of information processing:
– conclude and execute the contract (provision of goods/services), to ensure their quality, and to provide Customer service and information. Failure to provide Personal Data will prevent the Customer from entering into the Contract and performing its obligations;
– for direct marketing and general information about new products and services (unless you have opted out of such communications);
– for accounting purposes;
– for legal obligations, such as debt management and debt collection;
– to administer and improve the Company’s website, to keep it secure and to ensure that content is presented in the most effective way on your device;
– for the fulfilment of legal obligations under the law;
– for other purposes for which the Company has the right to process your Personal Data, where you express your consent, where the processing is necessary for the Company’s legitimate interest or where the Company is obliged to process the data by the relevant legal acts. We may also process Personal Data for other purposes if we have obtained the data subject’s consent or if we are entitled to process the data on the basis of legitimate interest.
6. Data collection methods
We collect information about you in the following ways:
– When you provide information to the Company yourself (e.g. by completing Company applications, contracts and/or other documents (including through our partners), on our website, electronically, by submitting enquiries, by post, by email, by telephone, by live video chat, by other means of communication);
– Information about you that we have received from third parties with whom we cooperate (e.g. partners, public authorities, etc.).
7. Duration of data processing
The Company shall process Personal Data only for the period of time necessary to achieve and implement the purposes set out in this Privacy Notice, taking into account the nature of the goods/services provided to Customers and the nature of the contracts concluded with them, except where a longer retention period for the Personal Data and related documents is established or permitted by the applicable regulatory enactments and is necessary (e.g., mandatory retention periods for the documents, limitation periods for legal action etc.).
8. Data transfer
For the purposes set out in the Privacy Notice, the Company may transfer your data to the following data recipients:
– Data processors who provide services and process your data in the interests of and on behalf of the Company (e.g. IT service providers, auditors, consultants etc.). Data processors shall process your Personal Data only in accordance with the instructions expressly given to them, undertake to ensure adequate protection, confidentiality and organisational and technical measures complying with the security requirements for the processing of the Personal Data received from the Company, as more specifically discussed in the contracts concluded between the Company and the subcontractors for the processing of the data.
– Entities involved in the administration of the debts and debtor’s database. The data shall be provided only to the extent and under the conditions permitted by law.
– Entities entitled to receive information in accordance with legal requirements (e.g. courts, state and municipal authorities, etc.), only to the extent necessary for the proper enforcement of applicable law.
– ACME Group, to which the Company belongs, to companies where this is necessary to ensure the proper provision of services.
– Other third parties on any other lawful basis or with your consent, which may be obtained on a case-by-case basis.
The data processors to whom the Company transfers your personal data may be established outside the Republic of Lithuania, the European Union or the European Economic Area. Data is only transferred to such processors where this is permitted by law and only if appropriate or adapted safeguards and methods are in place to protect your privacy.
9. What rights does the Customer have?
The Customer has the following rights:
– contact us to discuss any questions arising from the Company’s processing of Personal Data;
– obtain confirmation from the Company as to whether Personal Data relating to him or her are being processed and, if such Personal Data are being processed, to have access to the Personal Data processed and the information relating to them;
– receive Personal Data provided by him or her which is processed on the basis of his or her consent or for the performance of a contract, in writing or in a commonly used electronic form, and, where possible, to request the transfer of such data to another service provider;
– request the rectification of Personal Data if it is inaccurate or the completion of incomplete data;
– request the deletion of his/her Personal Data as a Customer of the Company, which is processed with the consent of the Customer, if the Customer withdraws the relevant consent. This right does not apply if the Customer Personal Data requested for erasure is also processed on another legal basis, such as processing necessary for the performance of a contract or the performance of an obligation under applicable law;
– request the restriction of the processing of their Personal Data, e.g. for a period of time during which the Company will analyse whether the Customer has the right to request, and it is practicable to request, the erasure of their Personal Data;
– object to the processing of the Customer’s Personal Data for the purposes of the legitimate interests of the Company or third parties where the processing of the Personal Data is based on legitimate interests, as well as where the Personal Data is processed for the purposes of direct marketing, including profiling for this purpose;
– object to being subject to a fully automated decision, including profiling, where such decision-making has legal consequences or similar significant effects on the Customer. This right shall not apply where such decision-making is necessary for the purpose of entering into or performance of a contract with the Customer, is permitted under applicable law or is expressly consented to by the Customer;
– withdraw consent to the processing of Personal Data.
The Customer shall exercise his/her rights by submitting a specific request to the contacts specified in this Privacy Notice. Information relating to the exercise of their rights is provided free of charge to Customers. The Company shall provide the Customer, no later than 1 month after receipt of the request, with information on the actions taken following the Customer’s request to enforce his/her rights, or the reasons for inaction.
The time limit for submitting the requested information may be extended by a further 2 months if necessary, depending on the complexity and number of requests. When the Customer submits a request by electronic means, the information shall also be provided to the Customer by electronic means.
A request for the exercise of rights received from a Customer may be refused or charged an appropriate fee if the request is manifestly unfounded or excessive, as well as in other cases provided for in the regulatory framework.
If the Customer believes that his Personal Data is being processed in violation of his rights and legitimate interests under applicable law, the Customer shall have the right to lodge a complaint regarding the processing of Personal Data with the State Data Protection Inspectorate.
10. Renewal of the Privacy Notice
If necessary, the Privacy Notice may be updated, that is, the Company shall have the right to change the terms of the Privacy Notice for justified reasons, and upon updating the Privacy Notice, the information will be published on the websites administered by the Company, indicating the version number and the date of approval of the Privacy Notice.
11. Contact details
Please feel free to contact us with any questions, requests or comments regarding the Company’s Privacy Notice, the processing of Personal Data or the exercise of the rights of data subjects at info@avad.lt.
12. Other information
The Company’s websites and products may contain links to third party websites. When you use third-party applications, services or websites, even if they are accessible through the Company’s websites and products, this Privacy Notice does not apply to the processing of data by such third parties, applications, services or websites. Data processing and collection by third parties and their services are subject to those third parties’ privacy notices or policies and terms of service, which we recommend that you review before taking any action.
13. Information about cookies
Cookies are small text files containing a small amount of information that are sent to your browser from a server and stored on your computer, mobile phone or other device when you visit a website. Each time you visit the same website, cookies send information back to this website. We use cookies to personalise content and ads, provide access rights to protected areas, social media features and analyse web traffic. We share website usage information with our social media, advertising and analytics partners, who may add it to other information you provide or collect through the Services. Cookies are used to process your IP address, browsing information such as areas of the website visited, time spent on the website, etc. Some cookies are placed by third-party services used on our pages.
We may only store cookies on your device in accordance with the law if they are necessary for the operation of this website. For all other types of cookies we need your consent.
Necessary cookies:
You also have other means of managing the data collected by additional cookies, web indicators, and similar technologies, for example, you can use your browser settings to restrict the use of third-party cookies or disable them altogether.
For more information on how the websites you visit can use cookies, and how to withdraw your consent by deleting or blocking cookies directly on your web browser, visit publicly available online resources, e.g. Internet addresses:
http://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html
http://www.consilium.europa.eu/lt/about-site/cookies/
https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies.