Privacy policy
General Information
UAB Impeka, company code 167325952, address of
the headquarters Gamyklos g. 34, Mažeikiai, (hereinafter referred to as the Data
Controller) through this privacy policy (hereinafter referred to as the Privacy
Policy) hereby establishes the terms how personal data processing is
carried out in the company controlled by the Data Controller and while using
the website http://www.impekahome.lt (hereinafter
referred to as the Website). The conditions set out in the Privacy
Policy apply every time you visit the website, regardless of the device you use
(computer, mobile phone, tablet, TV, etc.).
It is very important that you read the Privacy
Policy carefully, as you accept the terms and conditions described in this
Privacy Policy each time you visit the Data Controller’s website.
The Data Subject shall accept and not object
to the controller’s management and processing of his or her personal data,
including those provided directly or indirectly by visiting the website and
using its services, for the purposes and in accordance with the procedures
established in this Privacy Policy, Data subject's consent and legislation.
Persons under the age of 16 may not submit any
personal data through the Data Controller’s Website. If you are under the age
of 16, you must obtain the consent of your parents or other legal guardians
before submitting your personal information.
Personal data shall mean
any information relating to an identified or identifiable natural person
("Data Subject"); an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data and an online
identifier or to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural person.
‘Representative’ means a
person representing Clients, Data Controller Partners, Service Providers,
Suppliers, both natural and legal persons.
‘Applicant’ means a
natural person or a Representative interested in goods and/or services sold by
a Data Controller or interested in contacting the Data Controller on other
matters.
The Data Subject for the purposes of
this Privacy Policy shall include ‘Representative’, ‘Applicant’, ‘Client’,
‘Candidate’, ‘Partner’, ‘Service Provider’, ‘Supplier’, ‘Persons calling by
phone’ or any other natural person whose personal data are processed by a Data
Controller.
‘Data subject's consent’ means any
freely given, specific and informed and unambiguous indication of his or her
intentions by which the Data Subject, either by a statement or by a clear
affirmative action, agrees to the processing of personal data relating to him
or her.
‘Candidate’ means a
person who is or intends to be involved in a selection of staff by the Data
Controller.
‘Client’ means a
natural person or Representative who buys goods or services from a Data
Controller or has entered into a contract with a Data Controller for the sale
of goods or the provision of services.
‘Partner’ means a
natural or legal person that cooperates with the Data Controller or has entered
into a cooperation agreement with the Data Controller (e.g. for the purpose of
sale of goods).
'Service provider' means any
natural or legal person who is able to offer or offers goods, services or works
to, and cooperates with, the Data Controller or has entered into a contract
with the Controller for the purpose of
sale of goods, services or works.
‘Persons calling by phone’
means a person making a call to the publicly published telephone number
regarding sale of Data Controller's goods, provision of services and/or other
matters.
‘Supplier’ means a
natural or legal person supplying goods for data controller.
‘Direct marketing’ means any
activity designed to offer goods or services to persons by post, telephone or
any other direct means and/or to seek their opinion on the goods or services
offered.
‘Processing of personal data’
means any operation or set of operations which is performed on personal data or
on sets of personal data, whether or not by automatic means, such as
collection, recording, organisation, structuring, storage, editing or
alteration, retrieval, consultation, use, disclosure by transmission, dissemination
or otherwise making available, alignment or combination, restriction, erasure
or destruction.
The Data Controller shall collect personal
data in accordance with the requirements of the European Union and Lithuanian
legislation in force and with the instructions of the controlling authorities.
All reasonable technical and administrative measures shall be taken to protect
data collected on Data Subjects against loss, unauthorised use and alteration.
This Privacy Policy has been drawn up in accordance
with the Regulation (EU) 2016/679 of the
European Parliament and of the Council 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), the Law on the legal protection of
personal data of the Republic of Lithuania and other legal acts of the European
Union and the Republic of Lithuania. The terms used in the Privacy Policy shall
be understood as defined in the General Data Protection Regulation and the Law
of the Republic of Lithuania on the legal protection of personal data.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
Information you provide directly.
Information on how you use our website.
If you visit our website, we also collect
information that reveals the specificities of the use of our services or
automatically generates visit statistics. For more information, read the
section “Cookies”.
Information from sources of third parties
We can obtain information about you from
public and commercial sources (to the extent permitted by applicable legal
acts) and link it with other information which we receive from or about you. In
addition, we can obtain information about you from third parties’ social
network services when you connect to them, e.g. thorough Facebook network
accounts.
Other information collected by us
We can also collect other information about
you, your device or your use of the content of our website with your consent.
You may choose not to provide us with certain
information, however, in this case you may not be allowed to use the service we
offer.
PROCESSING OF PERSONAL DATA FOR THE PURPOSES
OF PROVIDING RESPONSES, CONSULTATION, AND FULFILMENT OF A QUERY
Processing of personal data of Applicants,
including Persons calling the Data Controller phone, for the purpose of a
consultation, submission of a query and/or for other purposes. The Data Controller shall process the
following personal data of Applicants, including Persons calling by phone:
·
Name;
·
Surname;
·
Phone number;
·
E-mail address;
·
Position;
·
Workplace.
Personal data of Applicants shall not be communicated to third
parties.
Personal data for the purposes of a
consultation, submission of a query shall be processed on the basis of consent
expressed when submitting personal data (Article 6(1)(a) of the General Data
Protection Regulation).
PROCESSING OF PERSONAL DATA FOR THE PURPOSE OF THE SALE OF GOODS
OR THE PROVISION OF SERVICES
Processing of personal data of Clients. The
Data Controller shall process the following personal data of Clients
(Representatives):
·
Name;
·
Surname;
·
Personal identification number;
·
Date of birth;
·
Power of Attorney;
·
Authorisation term;
·
Represented person (connection
with the represented person);
·
Position;
·
Workplace;
·
Phone number;
·
E-mail address;
·
Address;
·
Taxpayer identification number;
·
The amount of the payment (in the
case of electronic commerce - details of the payment order, accounts);
·
Data on behavioural habits,
priorities and satisfaction with services;
·
Other information relating to the
goods or services being purchased.
Data are obtained directly from Clients or
Representatives when performing the agreement concluded with the Client and/or
from other third parties connected with the Data Subject.
We undertake not to transfer your personal
data to any unrelated parties, except for the following cases:
Having obtained the Client’s consent for
personal data disclosure;
In implementing our, as the Seller’s of goods
or Service Provider’s, obligations (e.g., the data may be transferred to
companies providing delivery (courier), logistics, archiving, audit, legal,
financial service providers, Partners, Service providers, stakeholders and/or
parties related with national, European and international payment systems,
e.g., SWIFT);
In implementing the legitimate interests of
the Data Controller (e.g., in the case of debt collection);
Disclosure of the data to authorised bodies
according to the procedure established by legal regulations of the Republic of
Lithuania.
The Data Controller may transfer personal data
of Clients and other Data Subjects to Data Processors not specified in this
Policy who provide services (carry out works) to the Data Controller and
process personal data of Clients and Data Subjects on behalf of the Data
Controller. Data Processors may process personal data only according to the
Data Controller’s instructions and only to the extent necessary for the proper
fulfilment of contractual obligations.
If the Data Controller involves data processors, the Data Controller
shall take all necessary measures to ensure that the data processors have in
place appropriate organisational and technical security measures and maintain
secrecy of personal data.
Personal data processed on the basis of the
Data Subject’s consent expressed when submitting personal data, and/or
performance of the agreement concluded with the Data Subject (Article 6(1)(a)
and (b) of the General Data Protection Regulation).
PERSONAL DATA PROCESSING FOR THE PURPOSE OF
PERFORMING AGREEMENTS WITH PARTNERS, SERVICE PROVIDERS
When cooperating with Partners and Service
Providers the Data Controller shall process the following personal data of
natural persons or Representatives:
·
Name;
·
Surname;
·
Personal identification number;
·
Address;
·
Individual activity certificate
number and date of issue;
·
In the case of e-commerce – data
of a payment order;
·
Power of Attorney;
·
Authorisation term;
·
Represented person;
·
Position;
·
Workplace;
·
Phone number;
·
E-mail address;
·
Other information provided during
cooperation or performance of the contract.
Data obtained directly from natural persons,
Representatives and/or represented persons.
We undertake not to transfer your personal
data to any unrelated third parties, except in the following cases:
·
Having obtained the Client’s
consent for personal data disclosure
·
In implementing our, as the Data
Controller’s, obligations (e.g., the data may be transferred to (courier),
logistics companies providing services of delivery of goods, companies
providing postal, archiving, audit, legal, financial services, service
providers and/or parties related with national, European and international
payment systems, e.g., SWIFT);
·
In implementing the legitimate
interests of the Data Controller (e.g., in the case of debt collection);
·
Disclosure of the data to authorised
bodies according to the procedure established by legal regulations of the
Republic of Lithuania.
The Data Controller may transfer personal data
of natural persons, Representatives to Data Processors not specified in this
Policy who provide services (carry out works) to the Data Controller and
process personal data of natural persons, Representatives on behalf of the Data
Controller.
Processing of personal data in performing
agreements with Service Providers and Suppliers shall be carried out on the
basis of performance of the agreement and/or of the legitimate interest of the
Data Controller (Article 6(1)(b) and (f) of the General Data Protection
Regulation).
PERSONAL DATA PROCESSING FOR THE PURPOSE
OF DIRECT MARKETING
The Data
Controller seeks to share with recipients of newsletters only relevant news and
other useful information. This is performed in accordance with this Privacy
Policy.
The following personal data of Clients and
other Data Subjects may be processed for the purpose of direct marketing:
·
Name;
·
Surname;
·
E-mail address.
Having sent a newsletter, the Data Controller
may collect statistics on the Data Subject’s behaviour related to the use and
content of the newsletter (e.g., whether the newsletter was read, what links
were opened by the Data Subject).
The Data Subject’s e-mail address may be used
for providing advertising on Facebook, Google and other advertising platforms,
adapting the advertising to the targeted audience.
For the purposes of direct marketing,
profiling of your personal data may take place according to the personal data
you have provided in order to offer you individually adapted solutions and
suggestions. You may at any time withdraw your consent or object to the
automated processing of your personal data, including profiling (if
applicable).
Personal data obtained directly from Data
Subjects. The Data Controller may transfer Personal data only to third parties
who provide specialised services in order to send e-messages, adapt the type of
advertising ordered through advertising platforms.
Personal data of Clients and other Data
Subjects processed on the basis of consent expressed when submitting personal
data and agreeing with their processing for the purpose of direct marketing, or
on the basis of the Data Controller’s legitimate interest (Article 6(1)(b) and
(f) of the General Data Protection Regulation and Article 69(2) of the Law of
the Republic of Lithuania on Electronic Communications when personal data are
processed on the basis of the Data Controller’s legitimate interest).
Please be informed that the Data Subject shall
have the right to disagree or to withdraw the consent to process his (her)
personal data for direct marketing purposes at any time without specifying the
motives of the disagreement:
·
By clicking the button
“unsubscribe” at the bottom of the newsletter, or by
·
notifying by e-mail info@impeka.lt or calling at the phone
number +370 443 66 395.
The withdrawal of consent shall not affect the
lawfulness of processing based on consent before its withdrawal.
PROCESSING OF PERSONAL DATA FOR THE PURPOSES
OF ENSURING THE SECURITY OF STAFF, CLIENTS AND THE PROTECTION OF ASSETS (VIDEO
SURVEILLANCE)
For the purposes of the security of personnel,
clients and other persons accessing the video-surveillance field, as well as
the protection of property (video-surveillance), the Data Controller shall
process image data of its personnel and of clients and other persons accessing
the video-surveillance field in order to ensure their security and that of
property.
Please be informed that your video data is
being recorded by the Data Controller’s video-surveillance equipment when you
visit the Data Controller’s territory around the building, and at the premises
located at Gamyklos g. 34, Mažeikiai. Video data may be handed over only to law
enforcement authorities in accordance with the procedures laid down by the
legislation of the Republic of Lithuania and to insurance companies in the
event of an incident which may be recognised as an insured event. Video data
shall be transmitted only to the extent relevant to the incident under
investigation.
The Data Controller may provide video data of
personnel and of clients and other persons accessing the video-surveillance
field to Data Processors not covered by this Policy, who provide services/work
to the Data Controller and process the image data of personnel and clients and
other persons accessing the video-surveillance field on behalf of the Data
Controller.
Processing of personal data for the purposes
of video surveillance shall be carried out on the basis of the legitimate
interest of the Data Controller (Article 6(1) (f) of the General Data
Protection Regulation).
PERSONAL DATA PROCESSING FOR THE PURPOSES OF
SELECTION OF CANDIDATES TO JOB VACANCIES
For the staff selection purposes the Data
Controller shall process personal data voluntarily provided by the Candidate to
the extent to which such personal data were provided. The Data Controller may process the below
specified data of Candidates:
·
Name;
·
Surname;
·
Date of birth;
·
Phone number;
·
E-mail address;
·
Residence address;
·
Educational attainment;
·
Workplace;
·
Completed courses;
·
Language skills;
·
Computer skills;
·
Person’s photo (only if it is
submitted by the Candidate with his (her) CV; the Data Controller shall not
require the submission of the photo);
·
Recommendations;
·
Other data voluntarily submitted
by the Candidate specified in his (her) CV or other presented documents.
Data obtained directly from Candidates and/or
third parties providing job search, selection and/or intermediation services
(e.g., employment agencies, job search online portals, career social networks
(e.g., Linkedin), etc.). These data
shall not be transferred to third parties.
Data of Candidates shall be processed on the
basis of consent declared when submitting personal data and/or on the basis of
the Candidate’s request prior to conclusion of the contract (Article 6(1)(b)
and (b) of the General Data Protection Regulation).
WHAT WE DO TO PROTECT YOUR INFORMATION
Personal data shall be protected against loss,
unauthorised use and changes. We have
implemented organisational and technical measures to protect all information
collected by us for the purposes of provision of services. Please be reminded that despite appropriate
actions taken by us to protect your information, no website, online
transaction, computer system or wireless communication is completely secure.
The Data Controller shall apply different
periods of storage of Personal data in observance of requirements of legal acts
and according to personal data processing purposes.
Personal data storage period:
Personal data processing purpose |
Period of storage |
Processing of Data Subjects’ personal data for the
purposes of consultation, fulfilment of a query |
1 (one) year from the day of the consultation, fulfilment of the
query, except where the Data Subject
applies for provision of the Data Controller’s services. In such case, the general time limit of 10
(ten) years shall apply. |
Processing of personal data of Clients for the
purpose of sale of goods and provision of services |
10 years after tge last contact, or 10 (ten) years after its
expiration. |
Processing of personal data of natural persons,
Representatives for the purpose of performance of agreements with Partners,
Service Providers, Suppliers |
The term of validity of the agreement and 10 (ten) years after
its expiration. |
Processing of personal data of Data Subjects for
direct marketing purpose |
5 (five) years from the day on which the consent is given,
unless the Data Subject requests the extension of this time limit. When the Data Subject’s personal data are processed for the
direct marketing purpose on the basis of consent or legitimate interest of
the Data Controller, the Data Controller shall stop processing the Data
Subject’s personal data for the direct marketing purpose (shall immediately
destroy them) as soon as the Data Subject objects the processing of personal
data for such purpose. |
Processing of personal data for the purposes of
ensuring the security of staff, clients and the protection of assets (video
surveillance) |
30 calendar days Where video data are used as evidence in civil,
administrative or criminal proceedings or in other cases provided for by law,
the video data may be stored to the extent necessary for these purposes of
the processing and destroyed as soon as it is no longer necessary. |
Processing of personal data of Candidates for staff
selection purposes |
6 (six) moths after the end of staff selection. For a longer
retention of Candidates’ CVs and other data the Candidate’s consent shall be
required |
Exemptions from the periods of storage may be
applied to the extent they do not infringe the rights of Data Subjects and are
in compliance with legal requirements.
On expiration of the established time limits,
unless they have been extended, the data shall be destroyed in a manner which
prevents them from being recovered.
YOUR RIGHTS
The Data Subject whose data are processed
while implementing the Data Controller’s activities shall have the following
rights:
·
The right to know (be informed)
about the processing of his (her) data;
·
Right to access own data and know
how they are processed;
·
Right to rectification of personal
data or to supplement incomplete personal data having regard to the purposes of
their processing;
·
Right to erasure (‘right to be
forgotten’), i.e. to stop actions of processing of own data (except for
storage);
·
Right to restriction of processing
of personal data under a valid reason;
·
Right to data portability, where
the Data Subject has provided his (her) personal data to the Data Controller in
a structured, commonly used and machine-readable format;
·
Right to object to processing of
personal data when they are processed or intended to be processed for direct
marketing purposes including profiling to the extent related to such direct
marketing;
·
Right to lodge a complaint with
the State Data Protection Inspectorate of the Republic of Lithuania.
he Data Subject shall have the right to submit
to the Data Controller in writing any request or order concerning processing of
personal data in one of the following ways: deliver directly to the address:
UAB "Impeka", Gamyklos g. 34, Mažeikiai; by post: UAB
"Impeka", Gamyklos g. 34, Mažeikiai; by e-mail: info@impeka.lt.
Having received such a request or order the
Data Controller shall, not later than within one month from the date of
request, submit the answer and carry out or refuse to carry the actions
specified in the request. Where
appropriate, the specified time limit may be extended for two more months,
considering the complexity and number of requests. In such case, the Data
Controller shall notify the Data Subject about such extension within one month
from the date of request, also specifying the reasons for the refusal.
The Data Controller may refuse enabling data
subjects to implement the above specified rights, except for disagreement with
personal data processing for direct marketing purpose when in the cases
established by laws it is necessary to ensure the prevention, investigation and
identification of crimes, infringements of business or professional ethics, and
the protection of rights and freedoms of the Data Subject or other persons.
THIRD PARTY WEBSITES, SERVICES AND PRODUCTS ON
OUR WEBSITE
The Data Controller’s Website may contain
advertising banners of third parties, links to their websites and services
which are not controlled by the Data Controller, e.g., a link to the Data
Controller’s Facebook profile. The Data
Controller shall not be responsible for the safety and privacy of the
information collected by third parties. You must read the privacy provisions
applicable to third party websites and services which you use.
If you provide your personal data using
Facebook, we understand that you give your consent to us to get in touch with
you by the specified contact phone number or e-mail and to submit the offers of
services.
COOKIES
When you visit the Data Controller’s website,
we want to provide content and functionalities that are tailored to your
specific needs. This requires the use of cookies. A cookie is a small text file
that a website stores on your computer or mobile device when you visit the
site. They help the Data Controller to recognise you as returning visitor of a
certain website, to remember the history of your visiting the website and to
adapt the content accordingly. Cookies also help to ensure proper operation of
websites, monitor the duration and frequency of visits to websites and collect
statistical information on the number of visitors to websites.
Descriptions of cookies used on our website
Cookie |
Description/Purpose |
Time of creation |
Storage duration |
Data used |
__utmc |
Google Analytics cookies that identify unique
visitors and monitor user sessions |
During the first visiting of the page |
Until closing the browser |
IP addresses and unique ID numbers used for
compiling reports. The report provides statistical results. Monitoring
performed via Google Analytics. |
__utmb |
Google Analytics cookies that identify unique
visitors and monitor user sessions |
During the first visiting of the page |
Until closing the browser |
IP addresses and unique ID numbers used for
compiling reports. The report provides statistical results. Monitoring
performed via Google Analytics. |
__utmt |
Google Analytics cookies that identify unique
visitors and monitor user sessions |
During the first visiting of the page |
Until closing the browser |
IP addresses and unique ID numbers used for
compiling reports. The report provides statistical results. Monitoring performed
via Google Analytics. |
__utmz |
Google Analytics cookie identifying the
source of traffic to the site, what search engine was used, what link was
followed, what keyword was used, and the location of the user during the
visiting of the page. |
Upon opening the page |
6 months |
IP addresses and unique ID numbers used for
compiling reports. The report provides statistical results. Monitoring
performed via Google Analytics. |
__utma |
Google Analytics cookies that identify
unique visitors and monitor user sessions |
During the first visiting of the page |
2 years |
IP addresses and unique ID numbers used for
compiling reports. The report provides statistical results. Monitoring
performed via Google Analytics. |
6f23c04236f0d208270c00b207d8c639 |
Used to save the user’s language settings |
During the first visiting of the page |
1 year |
Language code |
How to manage and delete cookies
When you use a browser to access our content,
you can configure your browser to accept all cookies, reject all cookies or get
notification when the cookie is downloaded. Each browser is different, so if
you don't know how to change cookie settings, go to the help menu. Your
device’s operating system may include additional cookie controllers. If you do
not want the information to be collected through cookies, use a simple
procedure included in many browsers that allows you to opt out of cookies. To
find out more about how to manage cookies, please visit: http://www.allaboutcookies.org/manage-cookies/.
Please note, however, that in some cases the
deletion of cookies may slow down web browsing, limit the functioning of
certain functions of the website or block access to the website.
FINAL PROVISIONS
Supplements or amendments to the Privacy
Policy shall enter into force from the day of their publication on the Website.
When the Data Subject uses the Website and of
services provided by the Data Controller after supplementing or amending the
Privacy Policy, it shall be considered that the Data Subject does not object to
such supplements and/or amendments.
CONTACT US
If you have any questions concerning the
information provided in this Privacy Policy, you are kindly invited to get in
touch with us in any manner convenient for you:
Phone: +370 443 66 395
E-mail: info@impeka.lt
By post: UAB Impeka, Gamyklos g. 34,
Mažeikiai;
Updated on 14.05.2019