Privacy policy

• Personal data – any information associated with natural person (data subject, whose identity is known or may be directly or indirectly determined by using respective data.
  
• Data subject – any natural person: client, employee, partner or visitor of the company.
• Client – any person, who orders, purchases or uses our Company’s services. The client, with whom the Company has concluded an agreement, must ensure that all of the final users (e.g., family members), who uses the Company’s services ordered by the client, would be familiar with the Privacy Notice and would conform to its provisions.
  Impersonal data – information, which is not associated with the natural person, because all of the elements allowing to determine the identity of the person were removed from the personal data kit.
  
• Impersonal data – information, which is not associated with the natural person, because all of the elements allowing to determine the identity of the person were removed from the personal data kit.
  
• Services – any products and/or services, which the Company offers electronically and physically.
  
• Flow data – data, which is being processed in order to transfer information via electronic communication network and/or for the purposes of accounting such transfer. When using the electronic communication services, data is created. This data may, for example, show information about subscribers and their used back-end devices, start and end time of communication, duration and route, data transfer protocol, quantity of transferred data, geographical place of devices of the factual user of electronic communication services, format of data being transferred via communication network and other data located inside electronic communication networks or data being processed when providing electronic communication services. If the flow data allow to directly or indirectly identify the person, they will also be considered to be personal data.
  
• Place determining data – data located inside electronic communication networks or data being processed when providing electronic communication services, which show the geographical place of devices of the factual user of electronic communication services.
  

How Do We Collect Your Personal Data?

The Company offers wide selection of devices and services. Information, which we collect about you, depends on the services, which you order or use, and on what kind of information you submit to us when ordering equipment and/or services, or registering on our websites. We collect data:

•    which you submit, e.g., when you communicate or have legal relations with our Company, for example, when purchasing or registering for services, subscribing to newsletters or addressing us with the request to provide information;

•    which are generated when you use our services in so far as this is envisaged in the valid statutes of law, for example, when you are using our network and services (e.g., telephoning, forwarding an e-letter or visiting our websites);

•    which we receive from other sources, for example, other service providers or publicly accessible registers. You do not have to submit any personal data to the Company. If you decide not to submit them, it may very well be that we will not be able to provide you with equipment and/or services.

 

What personal data do we collect?

We collect data belonging to these categories:

•    main information, for example, name, surname, personal identification number, date of birth, address, data of the document confirming the person’s identity, contact data;

•    data associated with the provision of equipment and/or services, for example, details of service and its order, issuance of invoices, details of payments, information regarding consent or no consent to the processing of personal data for the purposes of direct marketing and their submission to third persons, contact data and associated records;

•    data, which are generated by using communication means and our services, e.g., flow data – date of connection start, time, duration, subscription number of the caller, subscription number of the receiver, IP address used during the user’s internet connection etc.;

•    other data about the use of services, for example, data collected by using cookies and similar technologies associated with browsing the internet etc.;

•    video data recorded by our video surveillance equipment when you visit our salons in order to ensure the safety of staff, clients and premises;

•    phone call conversations when you call the client services center of the Company or answer the calls from the Company’s employees;

•    other data, which are collected in accordance to your consent, and which are thoroughly defines when asking for your consent.

 

How Do We Use Your Personal Data?

The Company shall collect and further process your personal data only by following the legal basis defined in the statutes of law regulating the protection of personal data – in order to conclude and/or perform the agreement concluded with you, with your consent, when respective statutes of law obligate the Company to process personal data and when personal data needs processing due to the lawful interest of the Company (if the interest of the data subject do not prevail). The Company processes personal data for these purposes:

•    Conclusion and performance of electronic communication and other service provision agreements; accounting of clients and contractual settlements; submission of allowed to be published information regarding subscribers in the public printed or e-subscribers lists; protection of creditor’s interests and prevention of material losses; collection of clients debts. We are processing personal data, which is mandatory in order to ensure the proper provision of services to our clients – in order to properly determine the identity of the person, accept and execute orders, commence clients servicing, determine and remove various malfunctions and incidents, issue invoices for equipment and/or services, perform credit control, debt collection, hear complaints etc.

•    Direct marketing. We are processing impersonal data and personal data for the purposes of direct marketing. This data is being stored until you will withdraw you consent, however, in any case, no longer than for 3 years from the day of giving your consent.

•    Ensuring of the protection of staff, clients and other persons in the vicinity of the video surveillance cameras, as well as, property (video surveillance). We are processing video data of our staff, clients and other persons in the vicinity of the video surveillance cameras in order to ensure their and property safety.

•    Conclusion and performance of agreements; ensuring of provision of services; assessment of clients’ solvency and debt control; assessment of clients’ servicing quality; protection and defense of the rights and lawful interests of the Company; evidence collection (phone call recording). We are processing the records of your phone calls when you call the clients’ servicing center of the Company or answer the calls of the Company’s employees and data submitting during conversations in order to properly assess your solvency, control debts, conclude agreements with you and ensure the quality of the services being provided.

•    When the purposes, based on which the Company has to process your personal data when you give your consent, when the data needs to be processed due to the lawful interest of the Company or when respective statutes of law obligate the Company to process the data. We can process personal data for other purpose, if we have the consent of the data subject or we have the right to process data in accordance to a lawful interest. We also process personal data in order to properly perform the obligations determined for us by the statutes of law, which are associated with, e.g., accounting, submission of data to competent institutions, when the statutes of law demand this. In all other cases mentioned above, the Company processes personal and/or flow data in so far as this is necessary in order to achieve respective clearly defined and lawful interests, having regard to the protection of privacy of the data subject. The Company ensures that the personal data would be processed precisely, honestly and legally, that the personal data be processed only for the purposes, which are determined prior to collecting personal data, that the personal data be processed only by strictly adhering to the clear and transparent personal data processing requirements determined in the statutes of law.

 

How Do We Protect Your Personal Data?

In order to process your personal data the Company implemented respective organizational and technical means ensuring safety, which help protecting personal data against accidental or unlawful destruction, change, disclosure, as well as, from any other unlawful processing. The safety ensuring activity being performed in the Company includes the protection of staff, information, IT infrastructure, internal and public networks, as well as, office buildings and technical equipment.

To Whom We Provide Your Data?

We can provide your data:

•    To data processors (subcontractors) that provide services to us (perform works) and process your data on behalf of the Company, as a data provider. Data processors have the right to process personal data only in accordance to our instructions and only in such a scope as it is necessary in order to properly perform the contractual obligations. Through the subcontractors we take-up all of the necessary means in order to ensure that our data processors would implement proper organization and technical means ensuring safety and would maintain the secrecy of personal data. Data processors may be established outside the territory of the Republic of Lithuania, European Union or European Economic Area. If we will transfer your personal data to such processors, we will take up all of the necessary means indicated in the statutes of law in order to ensure that your right to privacy would be further properly protected.

•    To companies/institutions issuing and/or handling the public lists of electronic communication providers’ subscribers. With your consent, in cases envisaged in the statutes of law, the Company submits your personal data (e.g., name, surname, phone number and address (a part of it)) in order for them to be published in public subscribers lists (e.g., internet catalogs on subscriber information or phone books). You have the right to inspect, correct or delete such data.

•    To companies processing joint debtors’ data files. The Company has the right to provide to the data controllers that handle joint debtors’ data files the data on those data subjects (debtors) that did not timely and properly performed their financial and/or monetary obligations in order to control their debt. The debtors’ data is provided only by adhering to the conditions indicated in the statutes of law, after receiving a prior written reminder from the data subject about the default on obligations and having properly implemented the data protection requirements envisaged in the statutes of law.

•    To companies acquiring the right of demand. In accordance to the Civil Code of the Republic of Lithuania, the company (creditor) has the right via sale agreement of the rights to the debt portfolio to transfer the right of demand to another person without the consent of the debtor. The old and new creditor can inform about the transfer of the debt.

•    To other third persons, with your consent, which may be received in regards to a specific case. We can also provide your data:

•    By answering the requests of judicial or state institutions in so far as this is necessary for proper performance of the statutes of law or court decision/certificate.

 

For How Long We Protect Your Data?

We protect your personal data no longer than it is required by the purposes of data processing or statutes of law, if they determine a longer data protection period. Data collected for direct marketing purposes are protected until you will withdraw your consent, however, in any case, no longer than 3 years from the day of your consent. We intend not to protect old or unnecessary information and ensure that personal data and other information about the clients would be continuously updated and true.

 

How Do We Use Cookies?

In order to better your experience when visiting the Company’s website, we use cookies – small details of textual information, which are automatically created when browsing the website and are stored on your computer or on other back-end device. Information gathered by cookies allows us to ensure your possibility to browse the website more comfortably, to provide you with attractive offers and learn more about the behavior of our website users, analyze tendencies and develop the website, servicing and services provided by the Company. You may choose whether you want to accept the cookies. If you do not accept that the cookies would be written in to your computer or other back-end device, you may change your web browser’s settings and turn-off all of the cookies or turn-on/turn-off them one by one. However, we alert your attention that in some cases this may slow down the browsing speed, limit the functionality of certain websites’ functions or block access to the website. More thorough information is submitted at the address: AllAboutCookies.org or www.google.com/privacy_ads.html. We usually use information collected through cookies for these purposes:

•    For the use of functional cookies and provision of services. Cookies are very important for the functioning of our website and electronic services, they ensure smooth experience for the user when using them. For example, if the user so wishes, they do not need to input their name, surname, password or other data with each login.

•    For the development of services. When monitoring the use of cookies, we may better the functioning of our website and electronic services. For example, we receive information about which parts of our website are the most popular, to which parts the website users access from our site, from which websites they access our site and how much time they spend on our website.

•    For the usage analysis. We use the cookies to assess the statistical data about the number of users that visited our websites and to assess the accumulation of electronic services use and the effectiveness of advertisements. For example, we may collect information from e-letters and newsletters being sent for marketing purposes in order to uncover whether they were opened and whether they incited the users to perform any actions, e.g., did the user click on the link inside the e-letter and entered our website.

•    For the target orienting of the marketing.. By using the cookies, we may also collect information in order to provide advertisement or content for respective web browser, by creating separate target groups. All information about the cookies used on the website, their purpose, validity and data used is laid down in the table below.

 

Data about the cookies used 

Name of the cookie	Purpose of data processing	Moment of creation	Validity period	Data used	Additional information
Pll_language	through which language information is submitted	after accessing the system	1 year
PHPSESID	used for session	created after logging in to the website	until the website is closed

Without infringing the statutes of law we can connect the information received through cookies with the information about the person received through other means, e.g., information about the use of services. The Company’s website may contain links to third parties’ websites, products and services, as well as, social networks’ extensions (e.g., social network “Facebook” add-ons). For the third parties’ services or apps located on the Company’s website a respective Privacy Notice of the third party is applied. We urge you to familiarize with the privacy protection practice applied by such third parties. If you submitted data about yourself via “Facebook”, we understand that you agree to receive Company’s service offers via contact phone and E-Mail. You may change your mind (object) by calling the Company’s clients servicing center: (8 5) 2161616 or by writing to the E-Mail: [email protected].

 

What Rights Do You Have?

You have the right to:

•    Address the Company with the request to provide information about the personal data being processed by the Company;

•    Address the Company with the request to correct your personal data and/or stop the data processing, save for protection, in the event, when after familiarizing with personal data, you determine that they are incorrect, not thorough or imprecise;

•    Address the Company with the request to destroy your personal data and/or stop the data processing, save for protection, in the event, when after familiarizing with personal data, you determine that they are being processed unlawfully or dishonestly;

•    Address the Company with the request to transfer your personal data to another controller or processor;

• Object to the processing of your personal data, when they are being processed or intended to be processed for the purposes of direct marketing or for lawful interest, which the Company or third person seeks, to whom the personal data is provided.
  
• If you are worried about actions/inactions of the Company, by which this Privacy Notice or other requirements of the statutes of law are allegedly not adhered to, you may address the company by using any method comfortable to you: E-Mail: [email protected], phone: (8 5) 2040300, in writing: address: 10 Sausio 13-osios Str., Vilnius LT-04347.
  

Regarding consultation and questions associated with this Privacy Policy or processing of personal data, please address the Company’s data protection officer via E-Mail: [email protected] or phone: 8-61677744. If the issue cannot be solved with the Company, you have the right to address the State Data Protection Inspectorate (www.ada.lt), which is responsible for the supervision and control of statutes of law regulating the protection of personal data. How to Find Out About the Changes to This Notice? With the development of activities and services, we may need to update this Privacy Notice. For this reason, we recommend that you periodically would visit our website, wherein you will always find the newest version of this Privacy Notice. If we will make essential changes to this Notice, we will inform about this upfront on our website. 08-10-2021