1.  What Is This Privacy Policy About?

In this Privacy Policy (the "Privacy Policy") we provide you with information about the way UAB "Vičiūnų grupė" (hereinafter, "The Company") processes your personal data generated and/or used in the following processes: (i) the execution of contracts; (ii) your activities in the Company's social media accounts; (iii) your participation in the employee recruitment for the vacancies in the Company; (iv) to ensure the protection of confidential information and business continuity; (v) the Shareholders, (natural persons) and members of the management bodies, participation in the Company administration; (vi) the execution of contracts concluded between the Company and third parties (legal persons) as the contracting parties; (vii) video surveillance; (viii) contacting in cases of emergency situations that might involve the Company employees.  Hereinafter, the persons whose data are processed by the Company, are jointly referred to as the Data Subjects. This Privacy Policy also sets certain obligations of the Data Subjects that have be complied with when browsing the website http://viciunaigroup.eu/ (hereinafter, the "Website"). 

2.  About the Company

UAB "Vičiūnų grupė", legal entity code 303211678, registered domicile address: Karaliaus Mindaugo pr. 38, LT-44307 Kaunas, Lithuania, has its official company data collected and stored in Kaunas Branch of the Legal Entities Registry of the Republic of Lithuania. Data Protection Officer of the Company is to be contacted via email address: duomenuapsauga@vici.eu.

3.  What is Personal Data?

Personal data is any information collected by the Company about a Data Subject which may be used to identify the Data Subject and which is stored in electronic or any other form.
Personal data is any information about Data Subjects, including the name and address of the Data Subject, that the Company collects for the purposes set out in this Privacy Policy or a consent given by a Data Subject, or in a bilateral agreement with the Data Subject.

4.  What Do We Process Your Personal Data For?

4.1.  Execution of contracts

For the purpose of the contract conclusion and the services sales and provision, the Company processes your Personal Data: first name, surname, telephone number, email address, place of residence (address) , date of birth, information related to your purchasing (date of purchase, description of service, price, discount rate if granted). The above listed data is mandatory for the appropriate execution of a contract.
The data are processed on the grounds of the performance of the contract and retained for 10 (ten) years.

4.2.  Participation in the Employee Recruitment for Job Vacancies

On the basis of your consent that you give as a participant in the recruitment of candidates to get employed at our Company, we collect and process your CV and/or your motivation letter and/or other information that you provide to us (first name, surname, telephone number, email address, date of birth, education, workplace), information about the candidate from social networks.
If you do not provide your CV and/or your motivation letter, we will not be able to assess your suitability to fill the vacancy that we have.
Without your expressed consent for the processing of your personal data beyond the recruitment to a position that you were applying, we commit to erasing your personal data and/or deleting it within 5 (five) working days after the contract has been signed with the selected candidate.

4.3.  Conclusion and Administration of Employment Contracts

For the purposes of the employment contract conclusion and administration the Company processes the Personal Data of its employees, such as first name, surname, telephone number, email address, place of residence (address), personal code, date of birth, a copy of personal identification document, social security No., bank account No., the date of birth of children,  data on health status and capability to perform certain type of work). The above listed data are mandatory for the conclusion of the employment contracts and fulfillment of the employer’s obligations under the law.
The data are processed for the purposes of contract execution and per the legal obligations imposed on data controllers and are subject to retention from 1 (one) to 50 (fifty) years as per provisions of legislation of the Republic of Lithuania.

4.4.  Protection of Company’s Confidential Information and Ensuring Business Continuity

In order to ensure its legitimate interest of ensuring the protection of the Company's confidential information and its business continuity, the Company may review the correspondence of its staff with the contractors. For these purposes, the Company processes the following data: IP address, browsing history, dates and durations of websites visited, the quantity of data downloaded, the name of the device used for browsing, first name, surname, the content of the electronic mail, the summary of the employee's actions online, the content of the information contained in the electronic devises granted as work equipment. Such data will be stored for 4 (four) years.

4.5.  Protection of Assets and Persons’ Safety

In order to ensure the security of Data Subjects (visitors and employees) and to protect the Company assets and those of Data Subjects (visitors and employees), the Company performs video surveillance. For these purposes we process: a view that is covered by surveillance cameras, a location and information on the objects’ movement through the camera surveillance areas, the assets within the surveillance area, behavior and other relevant information (date, time) captured in the surveillance area. On the grounds of the legitimate interests pursued by the controller, this data is stored for 14 (fourteen) days from the date of their collection by the Company.

4.6.  Execution of the Company's Contracts with Legal Persons

In pursuit of its legitimate interest in the execution of the contracts concluded by the Company with legal persons, the Company processes the following personal data of the employees of those contractors: first name, surname, email address, telephone number, the content of communication. This data shall be retained for a 4 (four) years.

4.7.  Processing Personal Data of Shareholders (Natural Persons) and of Members of the Management Bodies

On the grounds of legal obligation imposed by the law, the Company processes first names, surnames, personal codes, residential addresses, dates of appointment of the shareholders (natural persons) and of members of the management bodies. The Company will retain these data for 10 (ten) years.

4.8.  Personal Data of Contact Persons for Emergencies Involving Company Employees

For the purposes of the employment contract execution and fulfillment of legal obligation under the law, the Company processes the following personal date of persons indicated by the employee as their contact persons in cases of emergency: first name, surname, telephone number and relationship with the employee. The data are stored for the duration of the employment contract.

5.  Contact Us

There are several ways to contact the Company: by phone, or by email. We receive, review and answer all your messages ourselves. If you contact us, we will process your personal data that you will forward for us, i.e. first name, surname, email address, telephone number, date and communication contents.
These data will be processed in order to prepare for the contractual relations or to respond to your concerns. If you do not submit your contact details, we will not be able to contact you.
The correspondence will be stored for 1 (one) year from the receipt of the message, except for the information that is subject to different retention periods in accordance with this Privacy Policy or applicable legislation.
All personal data that you have provided to us in communication with you are used only for the purposes stated above, as well as for the messages review and for the administration and management of communication flows. We commit to abstain from using your personal data or information where you could be identified as a person in any publications without your explicit consent.
Please note that we may need to contact you by post, email or telephone. Please kindly let us know about any changes in your contact details.  

6.  Disclosure of Data

We may disclose the information about you to our employees, managers, agents, service providers such as debt management or recovery companies, providers of marketing and/or IT services, if it justifiable for the purposes defined in this Privacy Policy.
In addition, we may disclose the information about you:

• If we are obligated to do so by the law;

• To defend ours rights or legitimate interests (including the disclosure of your data to third parties in order to recover your debts to us);

• When planning to sell a part of the Company's operations or assets, disclosing your personal data to the potential buyer of the operation or assets;

• When we sell Company's business or the substantial part of its assets to third parties.

Your personal data will not be transferred to a third country and/or to an international organisation.
Except for the cases set forth in this Privacy Policy, we do not share your personal data with any third parties.
The list of data recipients or recipient categories listed in this Privacy Policy might change over time, therefore if you wish to be informed about the changes related to recipients of your personal data, please inform us by email indicated in this Privacy Policy, and indicate in the message body "I wish to be informed about the changes of the recipients of my personal data. First Name, Surname”.

7.  Security of Your Personal Data

Your personal data will be processed in accordance with the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other statutory requirements. When processing your personal data, we implement organizational and technical measures that ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as any other illegal processing.

8.  Your Rights

This section contains information about your rights in regard of processing of your personal data conducted by us and how you may exercise those rights. If you wish to obtain more information about your rights or how to enforce them, please contact us at the email address indicated in this Privacy Policy.
The Company will provide you with information about the actions it has taken in response to your request for the implementation of your rights without any undue delay, but no later than within 1 (one) month of receipt of the request. Given the complexity of the request and the number of requests received, that deadline may be extended by a further 2 (two) months. In this case, within 1 (one) month of receipt of the request we will inform you about such extension and provide its reasons. The company may refuse to implement your rights only in the cases stipulated for by the law.

8.1.  Right to Withdraw a Consent

If you have provided us with an explicit consent to the processing of your data, you can withdraw it at any time.

8.2.  Right of Access to Your Personal Data

We strive that you fully understand how we use your personal data and would not experience any inconvenience. You may contact us at any point to inquire if we process any of your personal data. If we do store or use your personal data in any other way, you have the right to access them. To do so, please provide us with a written request to the address specified in this Privacy Policy, get identified and observe the principles of fairness and rationality while making such a request.

8.3.  Right to Request Further Information

We hope that you will understand that it is very difficult to discuss all possible ways to collect and use personal data. We strive to provide as clear and comprehensive information as possible and we commit to updating this Privacy Policy once there are changes in the ways we process personal data. However, if you have any questions about the use of your personal data, we will be happy to respond to them or provide any additional information we are allowed to disclose by the law. If you have any specific questions or have not understood the information we have provided, please contact us.

8.4.  Additional Rights

Below we provide information about additional rights that you have and that can be implemented in accordance with the procedure below.

1.  You have the right to ask us to rectify any inaccuracies in the available data. In this case, we may ask you to confirm the corrected information.

2.  You have the right to ask us to delete your personal data. This right shall be implemented in the cases provided for in Article 17 of the General Data Protection Regulation 2016/679.

3.  You have the right to ask us to limit the processing of your personal data or to stop processing them:

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• For the period required to make sure that your personal data is accurate when you submit claims regarding the accuracy of your data;

• When collection, storage or use of your personal data by us is unlawful but you decide not to request the erasure of the data;

• When we no longer need your personal data but you need it to identify, enforce or defend a legal claim;

• For the period necessary to determine if our legitimate interests to continue with your data processing overrides your rights as a Data Subject, if you have exercised your right to object to the processing of your personal data.

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4.  You have the right to transfer the data we have received from you with your consent or for the purpose of concluding the contract. Once you have exercised this right, as per instruction in your request we will transfer a copy of your data.

5.  You have the right to object to our processing of your personal data:

• When we process your data on the grounds of our legitimate interest but it is not sufficient to form a lawful basis for us to continue using your personal data.

9.  Complaints

If you believe that your rights as a Data Subject are and/or may be violated, please contact us immediately by email indicated in this Privacy Policy. We ensure that once we receive your complaint, we will contact you within a reasonable timeframe and inform you of the progress of the complaint investigation and then about its findings.
If you find results of our investigation not satisfactory, you will be able to lodge a complaint with the supervisory authority-- State Data Protection Inspectorate https://vdai.lrv.lt/.

10.  Responsibility

You are responsible for the confidentiality of your data, as well as the accuracy, correctness and comprehensiveness of the data you provide to us. If the data you provide changes, you must immediately notify us by email. We will not be liable, in any event, for any damages caused to you by the fact that you have indicated the incorrect or incomplete personal data or have not informed us of any changes.

11.  Changes to Our Privacy Policy

We may update or amend this Privacy Policy at any date. The updated or altered privacy policy will take effect from its publication on our website. You should occasionally check it to make sure that you are familiar with the valid version of our Privacy Policy.
Once our Privacy Policy gets updated, we will inform you of any substantive changes by announcing them on this Website. The update date below indicates when the Privacy Policy was last updated.

The last update of this Privacy Policy was made on March 19, 2021.

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