Privacy Policy
1. General Provisions
  1. This privacy policy (hereinafter – the Policy) regulates the main principles and rules regarding the processing of personal data on the website (hereinafter – the Website) carried out by Andrius Žebrauskas, address for correspondence Naugarduko g. 12-10, Vilnius (hereinafter – us).
  2. We strive to ensure that the visitors of our Website and other individuals whose personal information we process would fully trust our services and to be transparent about how we process their data. In this Policy you will find information on how we collect and use (or wish to collect and use) your personal data.
  3. In carrying out our activities, we adhere to these principles of data processing:
1.3.1. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
1.3.2. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);
1.3.3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
1.3.4. Personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
1.3.5. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required to safeguard the rights and freedoms of the data subject (‘storage limitation’);
1.3.6. Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’);
1.3.7. We shall be responsible for, and be able to demonstrate compliance with, the abovementioned principles (‘accountability’).
  1. The Policy has been prepared in accordance to 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, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter – the GDPR), the Act on Legal Protection of Personal Data of the Republic of Lithuania (hereinafter – the ALPPD), other laws of the European Union and the Republic of Lithuania. The terms used in the Policy are understood as they are defined in the GDPR and ALPPD.
2. Personal data collection, processing and storage 
  1. It is very important that you carefully read the Policy, because when you visit the Website and use our services, this Policy will directly apply to the collection, processing, and, in the cases provided for in the Policy, transmission of your personal data to the recipients of the data.
  2. If you do not agree with this Policy and the processing of personal data described therein, please do not visit the Website and/or use our services.
  3. You are responsible for ensuring that the data you provide is precise, correct and detailed. Input of incorrect data is considered to be a violation of the Policy. If the data provided changes, you must immediately inform the Controller about it. The Controller shall under no circumstances be responsible for damages that may arise for the User and (or) third parties if the User provided incorrect and (or) undetailed personal data or did not request supplementation and (or) correction of data when it changes.
  4. The entities for which we can disclose your personal data are described in each of the data processing activities.
  5. In certain cases, we may disclose your information to other entities:
2.5.1. In order not to violate laws or by responding to a mandatory judicial process (for example, upon receipt of a court's order to provide data);
2.5.2. To confirm the legitimacy of our actions;
2.5.3. To protect our rights, property or safety;
2.5.4. In other cases, with your consent or upon your legitimate request.
3. Direct marketing
  1. With your consent, we would like to provide you with what can be described as "direct marketing" - send you newsletters and/or provide special offers by e-mail. The legal basis for such processing of your personal data would be the consent given freely to us by providing us with your data.
  2. You can subscribe to newsletters by entering your e-mail into the corresponding newsletter subscription box on the Website and clicking on the corresponding subscribe button.
  3. Data processed for direct marketing purposes shall not be provided to third parties but they can be made available to companies that provide IT and newsletter sending services, acting as data processors and thus processing personal data to a limited extent solely in accordance with our instructions.
  4. You have the right to rescind your consent to receive newsletters and/or special offers at any time with no effect on the lawfulness of prior data processing based on consent before its withdrawal.
4. Replying to queries
  1. We provide our Website’s visitors with an opportunity to submit queries. For the purpose of replying to said queries, we process these categories of personal data provided by the visitors:
4.1.1. Name;
4.1.2. Surname;
4.1.3. Telephone number;
4.1.4. E-mail address;
4.1.5. Information provided freely in the query.
  1. Data processed for the purpose of responding to queries shall not be provided to third parties but they can be made available to companies that provide IT services, acting as data processors and thus processing personal data to a limited extent solely in accordance with our instructions.
  2. Legal basis for processing personal data is Article 6 (1) (f) of the GDPR – our legitimate interest to provide responses and get in touch with people interested in our products and/or services.
5. Procedures and timeframes of personal data storage
  1. When processing and storing your personal data, we shall implement organizational and technical measures that would ensure protection of personal data from accidental or unlawful destruction, modification, disclosure and any other means of unlawful processing.
  2. We apply different timeframes for the storage of personal data, depending on the purpose of the processing of your particular personal data.
  3. We apply the following terms for personal data storage:
No. Purpose of personal data processing Retention period
Direct marketing 5 years after giving consent
Replying to queries 1 year after the last contact
  1. Exceptions to the above retention periods may be determined to the extent that such deviations do not violate the rights of the data subjects and comply with legal requirements.
  2. Data necessary for the establishment, exercise or defence of legal claims is kept as long as it is necessary for the fulfilment of these goals either in court proceedings or in an administrative or out-of-court procedure.
6. Your rights
  1. You as a data subject shall at any time have the right to access your personal data processed by us by making a request; to receive information on how your personal data is processed; to rectify incorrect, incomplete or inaccurate personal data; and to ask to suspend personal data processing actions when the data processing does not comply with laws and requirements of the Policy.
  2. Insofar personal data processing is based on consent, you shall have the right to rescind your consent at any time with no effect on the lawfulness of prior data processing based on consent before its withdrawal.
  3. You can exercise your rights as a data subject by submitting a written application by e-mail or mail to Naugarduko g. 12-10, LT- 03213 Vilnius, Lithuania.
7. Contact information and complaint submission
  1. If you have questions regarding personal data protection, please kindly contact us by e-mail or by telephone (8-640) 09669.
  2. If you are not satisfied by our answer or think that we process your personal data in a way that does not comply with legal requirements, you have the right to file a complaint with the State Data Protection Inspectorate of the Republic of Lithuania as a supervisory authority.
8. Information about the use of cookies
  1. When you visit the Website, we desire to provide such content and functionality as would best suit your needs. For that, cookies are used. Cookies are small-volume text files stored on your browser or device (personal computer, mobile phone, or tablet).
  2. With cookies we aim to provide a more enjoyable experience for persons browsing the Website and to improve the Website itself.
  3. Cookies used on the Website are the cookies that are essential for the Website's operation and are designed to enable the site to perform its core functions. These cookies allow you to browse the Website and use its preferred features.
  4. You can delete or block cookies by selecting the appropriate settings in your browser that allow you to cancel all or some cookies. It should be noted that by using browser settings that block cookies (including essential cookies), you may experience problems using all or part of the Website's features.
9. Processing of personal data carried out by third parties
  1. Your use of third-party services, such as visiting our Facebook social network, may be subject to third-party terms. For example, Facebook applies its Data Policy to all its users and visitors. Therefore, when using these third-party services, it is recommended to familiarize yourself with their terms and conditions.
10. Final provisions
  1. The legal relations related to this Policy are governed by the laws of the Republic of Lithuania.
  2. This Policy shall be reviewed and, if necessary, updated at least once every two years. Policy additions or changes take effect from the day they are published on the Website.
  3. If you continue to use the Website and our services after the Policy has been updated or changed, we will assume that you agree and are familiar with the changes made.

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