PRIVACY POLICY

General information

This privacy policy (hereinafter referred to as the Policy) explains how UAB Vilniaus prekyba (hereinafter referred to as the Company) processes personal data and handles privacy of its customers, website visitors and other persons (hereinafter referred to as you, Visitors).

In all cases referred to in the Policy, your personal data controller is UAB Vilniaus prekyba, legal entity code 302608755, address of the registered office: Ozo 25, Vilnius.

It is very important that you carefully read the Policy, as each time when you visit the website owned by the data controller and submit your personal data to it, you accept the terms described in this Policy. If you do not agree to these terms, please do not visit our website, do not use our content and/or services and do not submit your personal data to us.

Persons under 16 years of age may not submit any personal data through our website or in any other manner. If you are under 16 years of age, before submitting your personal information, you must obtain consent of your parents or other lawful guardians.

The terms used in the Policy are understood as they are defined in the EU General Data Protection Regulation No. 2016/679 (hereinafter referred to as the GDPR).

Processing personal data to manage requests and complaints

The Company processes your personal data when you submit a request and/or complaint by e-mail, post or phone.
In the above cases, the Company processes your personal data:

  • in order to manage requests and/or complaints, ensure the quality of provided services;
  • based on your consent that you express by submitting a request and/or complaint.

The Company will store personal data submitted by you and processed in order to manage requests and/or complaints and to ensure the quality of provided services as long as necessary to examine and reply to your request and/or complaint, as well as according to requirements for storage of such documents set in legal acts, the periods of limitation for establishment or defence of legal claims, and if they are made – as long as necessary for such purpose.

Processing personal data of Company’s shareholders and beneficiaries

The Company during its activities processes personal data of shareholders and beneficiaries:

  • For internal administration purposes;
  • In order to fulfil legal obligations to which the Company is subject, in connection with registration and processing of the Company’s shareholders’ data, accounting of shares, fulfilment of tax and other applicable obligations;
  • In order to fulfil legal obligations to which the Company and its providers of financial, other regulated services are subject in connection with requirements of legal acts on prevention of money laundering and terrorist financing.

The Company stores personal data of its shareholders, beneficiaries for as long as necessary to achieve the purposes for which they are processed, as well as according to requirements for storage of such data set in legal acts, the periods of limitation for establishment or defence of legal claims, and if they are made – as long as necessary for such purpose.

Processing personal data of Company’s management bodies and their members

The Company processes personal data of the Company’s sole-person and collegial management bodies and their members (directors, board members):

  • For internal administration purposes;
  • In order to fulfil legal obligations to which the Company is subject in connection with formation of the Company’s sole-person and collegial management bodies (appointment of directors, formation of the board), organisation of their activities, submission and registration of data of the Company’s sole-person and collegial management bodies and their members to public registers, fulfilment of requirements of the Law on Financial Reporting by Undertakings of the Republic of Lithuania (e.g. the requirement to include data of the board and its members in the annual report), etc.;
  • In order to fulfil legal obligations to which the Company and its providers of financial, other regulated services are subject in connection with requirements of legal acts on prevention of money laundering and terrorist financing.

Processing of personal data of the Company’s sole-person and collegial management bodies and their members is a mandatory obligation set in legal acts.

The Company stores personal data of its management body members for as long as necessary to achieve the purposes for which they are processed, as well as according to requirements for storage of such data set in legal acts, the periods of limitation for establishment or defence of legal claims, and if they are made – as long as necessary for such purpose.

Processing personal data of Company’s counterparties, guests, other persons

The Company processes personal data of various categories of data subjects (for example, clients, business partners, suppliers, other counterparties, also their employees, representatives and agents, other persons visiting the Company). This data (first name, surname, employer, job title, contact information and other related information) is collected and processed for the following purposes and on appropriate relevant legal grounds:

  • When data subjects create, maintain and develop business, professional or other lawful relationships with the Company;
  • When concluding, executing, managing transactions, contracts and agreements;
  • When organising and registering a person’s visit to the Company, creating, maintaining of business relationships and communication with Company’s employees and representatives, providing a temporary access card, filling out the register of guests;
  • When developing and ensuring legitimate interests of the Company and its group companies;
  • When the Company defends from legal actions, demands, claims made against it;
  • When the Company performs the duties and obligations imposed on it according to applicable legal acts.

For group’s internal administration and management purposes, the Company processes its subsidiaries’ employees’ data (e.g. first name, surname, job title, contact information).

The Company stores personal data of these persons as long as a contract, business relationships continue in effect, or as long as necessary to achieve the purposes for which they are processed, as well as according to requirements for storage of such data set in legal acts, the periods of limitation for establishment or defence of legal claims, and if they are made – as long as necessary for such purpose.

Personal data processed for employee recruitment purposes

We process personal data you submit for personnel recruitment purposes based on your consent, expressed by submitting the data, and we will store such data until the end of a specific recruitment process. To assess your application, we may contact your former employers indicated by you for recommendations and ask for information on your qualification, professional skills and business qualities. We may only ask your current employer for such information if you expressly agree to it. We also note that we may check data made public by you for professional purposes (e.g. in LinkedIn or similar professional portals).

If, after considering your application, we select another applicant who meets our requirements better, we may ask you for a separate consent to store your personal data received during the recruitment process for future recruitment procedures, including contacting you for that purpose. If you consent, we will store your personal data indicated above for no more than two years after the date of your consent. You have the right to withdraw the consent at any time, without affecting lawfulness of processing based on the consent before its withdrawal. If you exercise this right, we will immediately take actions to destroy your personal data.

If you come across a job ad suitable to you on Company’s website or any of the job search portals, we invite you to apply directly at the e-mail address indicated in the ad.

Personal data processing on the website

When visiting our website, the Company may process the Visitor’s IP address, network and location data when the Visitor provides access to them. Data is collected by use of cookies and other similar technologies based on the Visitors’ consent.

Cookies

When you visit our website, we want to provide you with such content and functions, that would be tailored to your needs. We need cookies for this – small pieces of information that are automatically generated when you browse a website and are stored on your computer or other terminal device. They help the data controller to identify you as a previous Visitor of a particular website, save your visit history and tailor the content accordingly. Cookies also help to ensure the smooth running of websites, monitor the duration and frequency of visits to websites and collect statistics about the number of website Visitors.

We use the information we collect through cookies to:

  • gather information about Visitor actions on the website;
  • analyse data for the purpose of improving the usability of the website.

Types of cookies

Cookies of the following types can be used in our website:

  • necessary technical cookies – these are cookies that are necessary for the operation of our website;
  • functional cookies – these are cookies that, while not essential to the operation of our website, significantly improve its operation, quality and user experience;
  • statistical cookies – these are cookies that are used to provide a statistical analysis of our site Visitors’ navigation methods; the data collected by these cookies are used anonymously;
  • targeted or promotional cookies – these are cookies that are used to show ads or other information that may interest you. .

Description of cookies used on our website:

Cookie name Type of cookie Moment of creation Time of validity Data used
_gat statistical cookies at the first visit by the end of the session unique identifier
_ga statistical cookies at the first visit 2 years unique identifier
_gid statistical cookies at the first visit 2 days unique identifier
pll_language system cookies at the first visit 1 year, unless the value is changed code of the selected language
wfvt_1544552642 statistical cookies at the first visit 2 years unique identifier
wordfence_verifiedHuman system cookies at the first visit 24 hours unique identifier
cookie_notice_accepted system cookies at the first visit 1 hour unique identifier

Management and deletion of cookies

When you use a browser to access our content, you can configure your browser to accept all cookies, to reject all cookies, or to notify you when a cookie is downloaded. Each browser is different, so if you are not sure how to change your cookie preferences, check out your browser’s Help menu. Your device’s operating system may have additional cookie controls.

If you do not want your information to be collected by cookies, use the simple procedure available in most browsers that allows you to opt out of cookies: Chrome; Firefox; Internet Explorer; Edge; Safari; Opera. To learn more about managing cookies, visit: http://www.allaboutcookies.org/manage-cookies/ bei http://www.youronlinechoices.com/ However, please note that in some cases deletion of cookies may slow down the Internet browsing, limit certain website functionalities or block access to the website altogether.

Data processors and other data recipients

The Company involves certain service providers (data processors) to process your personal data.

Such data processors include: data analysis service providers, data centre service providers, web browsing or web activity analysis and related services providers, software creation, provision, support and development companies, accounting service providers, IT infrastructure service providers, providers of communications, security, recruitment, call services and other service providers to whom your personal data is disclosed only to the extent necessary for the provision of their services.

If there is a sufficient legal basis (for example, when necessary for the conclusion or execution of a contract with you and you have been properly informed of such transfer), the data may be transferred to our business partners, counterparties.

We may be required to transfer your personal data to state supervisory authorities in the cases and on the grounds provided for by applicable legal acts.

The Company informs you that certain data of your visit in our website (IP address, cookies, technical information of the browser you use, other information related to operation of the browser and browsing on the website) for the purposes of the website browsing statistics, analysis and related purposes may be transferred or made accessible to entities both in the European Economic Area and outside it (for example, when we use the Google Analytics service, such an entity is a United States company). The Company reminds that personal data outside the European Economic Area can be subject to lower protection than in the states of the European Economic Area, but the Company will carefully evaluate the conditions under which such personal data will be processed and stored after their transfer to the above-indicated entities.

Your personal data may be provided to other data recipients only on the grounds provided for in legal acts.

Term of data storage

Your personal data may be stored for a period longer than indicated above when:

  • That is necessary for the Company to defend itself from demands, claims or legal actions and exercise its rights;
  • There are reasonable suspicions of illegal activities, which are subject to investigation;
  • Your data is necessary for proper settlement of a dispute, complaint;
  • For making backup copies and other purposes in connection with operation and support of information systems and for similar purposes;
  • On other grounds provided for in legal acts.

Your rights

To the extent and under the conditions provided by the applicable law, you have the following rights:

  • To access your personal data and to be informed how they are processed;
  • To request rectification of incorrect, inaccurate or incomplete data;
  • To request erasure of your personal data or restrict the processing of your personal data when personal data is processed without complying with legal requirements or when there is another legal basis for such request;
  • To request transfer of your personal data to another data controller or to you directly in a convenient form (applicable to the personal data that you submitted and that is processed by automated means on the basis of a contract or consent);
  • To object to processing of your personal data if they are processed on the basis of a legitimate interests, except cases where other lawful reasons for such processing exist or such data are processed for the purpose of making, pursuing or defending legal claims;
  • To withdraw a given consent at any time where your personal data is processed on the basis of a consent.

If you believe that your personal data is processed unlawfully or your rights regarding personal data are violated, you have the right to contact the State Data Protection Inspectorate (for more information visit www.vdai.lrv.lt) and file a complaint. Before filing an official complaint, the Company recommends contacting the Company by e-mail info@vp.lt to find a proper solution for your problem.

How to contact us?

If you have any questions regarding the Policy or have any requests regarding the processing of your personal data, you can contact us at: By post: Ozo 25, LT-07150, Vilnius, Lithuania
By phone: 8-5 204 21 03
By e-mail: info@vp.lt

Final provisions

The Company may update the Policy at any time. The Company will inform the Visitors of the updates by submitting a new version of the Policy along with the date of the last changes on the website. Visitors understand that by continuing to use this website after the Policy updates are made, they agree to the changes.
If any provision of the Policy is declared invalid or inapplicable, this provision shall not affect the legality and validity of the remaining provisions of the Policy.
The Policy shall apply from the date of its publication on the Company’s website.
Updated on [day] September 2019.