Privacy policy of UAB AVAD Baltic

Wording of 7 April 2020

1. General provisions

This document (hereinafter referred to as the Privacy Policy) shall set the main principles for collection, processing and storing of your (Client’s) personal data performed by UAB AVAD Baltic (data are collected and stored in the Register of Legal Persons of the Republic of Lithuania, registration number of a legal person 301060619, registered address Raudondvario pl. 131B, LT-47191 Kaunas, Lithuania, e-mail info@avad.lt) (hereinafter referred to as the Company).

Processing of personal data is carried out in compliance with the 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 Personal Data protection as well as instructions and recommendations made by competent authorities.

2. Definitions of the privacy policy

Personal data shall be any information related to a natural person – data subject whose identity is known or who can be identified, directly or indirectly, using respective data;
Client shall be any person who makes orders, buys or uses our Services or who has expressed his or her intention to use or uses the services provided by the Company in any way, intends to buy or buys goods of the Company or is related to the services provided by the Company or to the goods of the Company in any way.
Processing shall be any operation performed in relation to Personal Data (including collection, recording, storing, amendment, access, submission of a request, transfer, etc.).
Login data shall be internet protocol (IP) address and provider of internet services used for connecting the device to the internet, browser type and version, time zone setting, browser add-on type and version, operating system and platform, login location, encoding, Uniform Resource Locator (URL), products viewed by you.
Regulation shall be the 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, and repealing Directive 95/46/EC (General Data Protection Regulation).

3. Principles of personal data processing

The Company shall act in compliance with the following main principles of Personal Data processing:
– Personal Data are collected for explicit and legitimate purposes.
– Personal Data are processed accurately and fairly.
– Personal Data are processed lawfully, i.e. only in the cases where:
a) Personal Data subject grants a consent, e.g. to be provided with promotional information;
b) an agreement, where one party thereto is a Personal Data Subject, is concluded and implemented;
c) the Company is obliged to process Personal Data by laws;
d) Personal Data have to be processed for the legitimate interest sought by the Company or any third person who is provided with personal data unless the interests of the data subject are more important.
– Personal Data are kept up to date.
– Personal Data are kept for no longer than required by the purposes of data processing.
– Personal data are processed only by the staff authorised to do that.
– All and any information on processed Personal Data is confidential.

4. Nature of collected information

Depending on the nature of supplied goods / provided services, the Company may collect the following data of the Client:
– basic Client’s information: name, surname, personal ID number, address, copy of personal identification document (if provided) and its details, telephone number, e-mail address;
– information on the goods / services supplied / provided/ purchased by the Client: information on selected / provided services and duration of their use, any information related to assessment of quality of goods / services, any information on return of goods, warranty service, etc., data on risk assessment of the Client’s insolvency;
– information on settlement of accounts for the goods / services: Details of invoices issued to the Client, data on payments made by the Clients or other persons, information on debt management (including transfer of data to the third persons);
– information on the Clients consent regarding direct marketing: information on the Client’s consent / objection regarding receipt of promotional information (news, offers of a programme, campaigns, etc.), participation in surveys, use of data, provision of the Client’s data to the third persons as well as consent regarding insolvency risk assessment;
– information on communication and Client service: data on searching Company’s websites and self-service websites (collected using cookies and similar technologies); information from records of telephone conversations when calling representatives of the Company, correspondence with the Company (using self-service, e-mail, applicable programmes, etc.), Client’s applications and Company’s responses regarding any issues to be solved;
– other data: information of prize winners, information on participants of a survey, newsletter subscribers.

5. Purposes of the processing

Collected data shall be used by the Company for provision of services / supply of goods, also for provision of assistance, sending messages, offers and information on campaigns, protection of the rights and interests of its own and the third person in compliance with the applicable legislation.

Purposes of the information processing:
– conclusion and implementation of agreements (for supply of goods / provision of services), ensurance of their quality as well as Client service and provision of information;
– direct marketing and provision of general information on new products and services (unless you have opt-out such messages);
– book-keeping;
– fulfilment of legal obligations, for example, debt management and recovery;
– administration and improvement of the Company’s website, keeping it safe and ensuring that its contents are provided in your device in the most efficient manner;
– fulfilment of legal obligations set forth in legislation;
– other purposes that allow the Company to process your Personal Data when you give your consent, when data gave to be processed for the legitimate interest of the Company or when the Company is obliged to perform processing by respective legislation. We can process Personal data for other purpose if we gave obtained a consent of the data subject or are entitled to process data on the basis of a legitimate interest.

6. Methods for data collection

Information on you is collected in the following methods:
– When you provide information to the Company by yourself (e.g. by filling in Company’s applications, agreements and / or other documents (including our partners) on our website electronically, submitting requests, by mail, e-mail, telephone, direct video conversations, other means of communication);
– When we receive information on you from the third parties that we cooperate with (e.g. Partners, state authorities, etc.);
– We collect information about you on our websites using cookies. Cookies stored on a service user’s computer are small text files that can be used on websites to personalize content and ads, provide access to protected areas, provide social media features, analyze data flow, and protect us and service users from cybersecurity threats. We may store cookies on your device only if they are necessary for the operation of this website. We must obtain your consent to use all other types of cookies.

To make the website easier to use, the necessary cookies activate the main functions, such as the language settings selected on the pages, access to protected areas of the website, etc. Without these cookies, the website will not work properly.

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.

7. Duration of the processing

Personal Data will be processed by the Company for the time necessary for reaching and implementation of the purposes specified in this Privacy Policy taking account of the nature of the goods / services supplied / provided to the Clients and agreements concluded with the Clients, except for the cases where longer period for storing Personal data and related documents is set and allowed under applicable legislation and its is necessary (e.g. obligatory periods for storing of documents, limitation period of a lawsuit, etc.).

8. Transfer of data

For the purposes set forth in the Privacy Policy, the Company may transfer your data to the following data recipients:
– Data processors who provide services and process your data on behalf of, in the interest of and by the order of the Company (e.g. Providers of IT services, auditors, consultants, etc.). Data processors process your Personal Data only under clear instructions, by undertaking to ensure proper protection and confidentiality of the Personal Data provided by the Company for processing as well as organizational and technical measures in compliance with the security requirements as specifically negotiated in the agreements concluded by and between the Company and sub-data processors.
– Subjects engaged in administration of debt and debtor database. Data are provided only within the scope and under the terms and conditions allowed under legislation.
– Subjects who are entitled to receive information under requirements of legislation (e.g. courts, state and municipal authorities, etc.) only within the scope which is necessary for proper implementation of applicable legislations.
– ACME Group companies where it is necessary to ensure proper performance of services.
– Other third persons under other lawful basis or under your consentwhich may be obtained in a specific case.

9. What are your rights?

The Client has the following rights:
– to contact us and discuss any issues regarding Personal Data processing performed by the Company;
– to obtain from the Company confirmation as to whether or not Personal Data concerning him or her are being processed, and, where that is the case, access to the processed Personal Data and any information related to them;
– to obtain Personal Data provided by him/herself that are processed on the basis of his or her consent or implementation of an agreement in writing or general electronic form and, where possible, request transfer of such data to another service provider;
– to request rectification of his or her Personal Data where data are inaccurate or supplement of incomplete data.
– to request erasure of his or her, as the Client’s of the Company, Personal Data that is processed under Client’s consent if a respective consent of the Client is withdrawn. This right shall not be applicable where the Client’s Personal Data that are requested to be erased are processed on other legal grounds such as processing necessary for implementation of an agreement or fulfilment of an obligation under applicable legal acts;
– to request restriction of Personal Data processing, e.g. for the period during which the Company analyses if the Client is entitled to such request and if it is practically possible to erase his or her Personal Data;
– to object processing of Personal Data of the Client for legitimate interests of the Company or any third person where the Personal Data processing is based on legitimate interests as well as where Personal Data are processed for direct marketing purposes including profiling related to such purpose;
– to object to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects the Client. This right shall not be applicable where such decision-making is necessary for entering into or performance of an agreement, is authorised by applicable legislation or an explicit consent for this is given by the Client;
– to withdraw his or her consent to Personal data processing.

The Client shall implement his or her rights by providing a specific request to the contacts specified in this Privacy Policy. Any information related to implementation of the Clients’rights shall be provided free of charge. The Company shall provide information on action taken on the Client’s request regarding implementation of his or her rights of specify the reasons for inactivity to the Client within 1 month of receipt of the request.

That period for provision of requested information may be extended by 2 further months where necessary, taking into account the complexity and number of the requests. Where the Client makes the request by electronic form means, the information shall also be provided by electronic means.

The Client’s request regarding implementation of his or her rights may be refused or a reasonable fee may be charged for this, where the request is manifestly unfounded or excessive as well as in other cased prescribed by laws.

If the Client believes that his or her Personal data are processed in violation of his or her rights and legitimate interests under applicable legislation, the Client shall be entitled to submit a complaint with regard to Personal data processing to the State Data Protection Inspectorate.

10. Update of the privacy policy

This Privacy policy may be updated, if necessary. In case of any amendments made to the Privacy policy, information will be published on www.avadbaltic.com.

11. Contact details

If you have any questions, requests or comments regarding Privacy policy of the Company or data processing performed by the Company, please contact us by email info@avad.lt.

12. Other information

References to the websites of the third persons may be found on the website and products of the Company. Such websites of the third persons have their own privacy policies. If you visit these websites, their respective policies shall be applied.