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Privacy policy

What does this Privacy Policy mean?

In this Privacy Policy for you, our website http://businessgarden.lt (“Website“) visitor, we will provide information on how Vastint Lithuania, UAB (corporate ID number 111622773, address: Jogailos str. 4, Vilnius, LT-01116 Lithuania) (“Company”) processes your personal data submitted to us either at the Company’s office address or on the Website or via e-mail or phone.

What kind of personal data do we collect?

Whenever you visit the Company’s Website or our Facebook page or contact us by e-mail or phone, we may collect the following information:

  • For concluding and performing contracts – your first name, last name, personal ID number, address, phone number, e-mail address and other information relevant to concluding and performing the contract. These data will be stored for 10 (ten) years from the real property sale and purchase contract date;
  • For administering debts – your first name, last name, personal ID number, address, e-mail address, phone number, your debt amount and other particulars of your indebtedness. These data will be collected to ensure performance of a contract and will be stored for 10 (ten) years from the debt payment date or the date of settlement of the dispute regarding your indebtedness;
  • For sending you a commercial offer – your first name, last name, e-mail address, phone number, requested type of saleable or leasable real property and other conditions. These data will be collected in order to make it possible for us to take action at your request prior to concluding a contract and will be stored for 10 (ten) years from the real property sale and purchase contract date. Should no real property sale and purchase contract or commercial lease be drawn up according to our commercial offer, the data will be stored for 3 (three) years from the offer submission date;
  • For sending direct marketing communications – your first name and e-mail address. These data will be collected on the basis of your consent and will be stored for 2 (two) years from the date of your consent to receive direct marketing communications. You will be free to opt out of such direct marketing information at any time in any of the following ways:
    • By sending an e-mail to lithuania@vastint.eu; or
    • By sending a letter at the address of Jogailos str. 4, Vilnius, LT-01116 Lithuania; or
    • By visiting Vastint Lithuania, UAB at Jogailos str. 4, Vilnius, LT-01116 Lithuania.

 

  • For collecting information about how the Website is used – data collected through cookies and similar technologies related to browsing the Internet, etc. (for more details visit our Cookies Policy). These data will be collected on the basis of your consent and on the grounds provided for in the Law of the Republic of Lithuania on Electronic Communications stipulating that no consent is required for using “session cookies” where the sole purpose of the cookie is to transfer information via the electronic communications network or, if necessary, to provide information society services ordered by the Website user.
  • For collecting data related to employment – your first name, last name, date of birth, address, e-mail address, phone number, educational background, professional experience, skills and other relevant information. This information will be collected in order for us/an employment agency to select a proper candidate for the position with a view to making an employment contract with him/her. In the event that you do not give your separate consent to processing your personal data upon completion of the employee selection process, we undertake to delete and/or destroy your personal data within 5 (five) business days after signing an employment contract with the selected candidate. Should keeping CVs of the rejected candidates be necessary, each such candidate will be notified to that effect and will be asked to consent to the extension of the personal data processing period;
  • For performing contracts between the Company and its contracting partners – in furtherance of its legitimate interest to ensure fulfilment of contracts concluded with its contracting partners who are legal entities, the data controller will process personal data of their employees, i.e. their first names, last names, e-mail addresses, phone numbers and the contents of their communication. These data will be stored for 10 (ten) years.
  • Any other personal data you may provide to us at any time by contacting us in any of the following ways: by sending us an e-mail or a letter, by giving us a phone call, by filling out a form on the Website or by coming to the Company’s office. These data will be processed on the grounds of our legitimate interest to keep communication with clients and other persons and will be stored for 2 (two) years from their submission date.

Social media sites

Information communicated to us when visiting our social media sites (including notifications, use of “Like” and “Follow” buttons and other communication) will be controlled by us jointly with social media managers as joint controllers.

We currently have accounts named “Vastint” and „Business Garden Vilnius“ on Facebook.

If you have any questions about how your personal data are processed on that social media site, please read their privacy policy at https://www.facebook.com/privacy/explanation and contact the service provider directly.

 

How is your personal data processed?

Your personal data will be processed in accordance with the General Data Protection Regulation (“GDPR”), the Law of the Republic of Lithuania on Legal Protection of Personal Data and other legal acts. We will manage your personal data responsibly and securely. When identifying the means of personal data processing and in the course of such processing, the Company undertakes to implement appropriate technical and organizational measures for protecting your personal data from accidental or unlawful destruction, damage, modification, loss, disclosure or any other kind of illegal handling and to adopt proper measures taking into account the risks around your personal data processing.

Who can we disclose your personal data to?

We receive your personal data from you, your devices, social networks (Facebook), etc.

We may disclose your information to our employees, agents or such service providers as debt administration/collection companies or companies providing archiving services, also to providers of marketing/IT services or subcontractors if it is reasonably required for the purposes stated in this Privacy Policy.

We do not transfer your personal data to any third parties except as specified in this Privacy Policy. Depending on such third party, transfer of personal data may be made on the basis of an adequacy decision (Article 45.3 of the GDPR) or on the basis of your consent (Article 49.1(a) of the GDPR) or for the performance of a contract (Article 49.1(b) or (c) of the GDPR). We may disclose your personal data to data processors who provide services/carry out works to us (i.e. IT service providers, auditors, lawyers, consultants) and process your data on behalf of the Company, as the data controller.

We may also disclose your personal data to other companies of our group, namely to Vastint Holding B.V., Interogo Holding AG, including their subsidiaries.

Data processors will be allowed to process your personal data solely based on our instructions and only to the extent necessary. We will take all necessary steps to ensure that our data processors implement the appropriate organizational and technical measures to ensure safety and confidentiality of your personal data.

Your data may also be transferred to public bodies or institutions or other persons who are statutorily entrusted with certain functions.

In addition, we may disclose your information in the following cases:

  • If required to do so by law;
  • In order to protect our rights or interests (including the case when your personal data are disclosed to others for debt recovery purposes);
  • When intending to sell any of the Company’s business or assets, we are asked to disclose your personal data to potential buyers of such business or assets;
  • If the Company’s business or assets have been sold to others.

We may conclude agreements with third parties in order to provide you with services on our behalf. This may include processing of payments, installing of search engines and marketing activities. In some cases, third parties may require access to some or all of your personal data. Such third parties having access to your personal information are service providers whom we recruit on demand.

The list of recipients and their categories contained in this Privacy Policy are subject to change. Therefore, if you wish to be informed of any such change, please let us know by sending us an e-mail at the address given in this Privacy Policy saying that “I wish to be informed of any change of my personal data recipients” and giving your full name.

What are your rights?

This section gives information about your rights associated with the processing of your personal data by the Company and about how such rights may be exercised. If you want more information about your rights or want to exercise them, please contact us at the e-mail address given in this Privacy Policy.

Information on how your request is being processed will be given by the Company without undue delay, yet no later than within 1 (one) month after such request for the exercise of your rights was received by the Company. The above period may be extended for another 2 (two) months depending on how complicated the request is and how many requests have been received. In such a case, we will let you know if the period has been extended and for what reasons within 1 (one) month after receiving your request. The data controller may refuse to implement your rights solely in the cases specified by law.

Right of access to your personal data

In order for you to understand how we use your personal data and to suffer no inconvenience on that account you may contact us at any time to ask whether any of your personal data are processed by us. If your personal data are stored or used by us in any way, you have the right of access to them. In order for you to exercise such right, please send us your written request at the e-mail address given in this Privacy Policy. We may ask you to confirm your identity in order to grant your request, which should be submitted by you acting reasonably and in good faith.

Right to withdraw consent

You have given us your explicit consent to process your personal data which may be withdrawn by you at any time by sending us an e-mail at the address given in this Privacy Policy.

Additional rights

Below, please find information about your additional rights that may be exercised by you in the following manner:

  • You have the right to request us to correct any inaccuracy of your personal data. In that case we may ask you to confirm the corrected information.
  • You have the right to request us to erase your personal data. This right may be implemented in the cases described in Article 17 of the GDPR.
  • You have the right to request us to restrict/refrain from processing your personal data in the following cases:
    • During the period needed for us to ascertain whether your personal data are accurate when you file a complaint regarding their accuracy;
    • When your personal data collection, storage or usage by us is illegal but you decide not to request their erasure;
    • When we no longer need your personal data but such data are needed by you in order to impose, enforce or protect legal demands;
    • During the period needed for us to determine whether we have another valid legal basis for further processing of your personal data if you have opted to exercise your right to object to such personal data processing.
  • You have the right to data portability if processing of such data is carried out by automated means and we have obtained such data from you based on your consent or for the purpose of concluding a contract. If you opt to exercise this right, we will transmit at your request a copy of the data submitted by you.
  • You have the right to object to processing of your personal data pursuant to Article 21 of the GDPR.

Right to request more information

We hope you understand that it is very difficult to discuss all possible ways how personal data may be collected and used. Therefore, we endeavor to provide as clear and complete information as possible and undertake to update this Privacy Policy if changes are made to the use of personal data. Nevertheless, if you have any questions regarding your personal data use, we will be happy to answer them or to provide you with further information that we are allowed to disclose. Please contact us if you have any specific questions or have not understood the information presented in this Privacy Policy.

Complaints

Please immediately contact us at the e-mail address given in this Privacy Policy if you believe that your rights as a data subject are and/or may be violated. We ensure that having received your complaint, we will inform you within a reasonable time about the progress of the complaint investigation and later about its outcome.

If you are not satisfied with the investigation outcome, you may file a complaint with the supervisory authority (the State Data Protection Inspectorate www.vdai.lrv.lt).

Responsibility

You are responsible for the confidentiality of data submitted by you and for ensuring that such data are accurate, correct and complete. You should inform us immediately by e-mail if changes are made to the submitted data. Therefore, we will not be held liable for damage resulting from your failure to provide correct or complete personal data or to give us notice of changes made to such data.

How can you exercise your rights?

To enforce your rights, you may submit requests, complaints or claims to us in writing in any of the following ways:

  • By sending an e-mail to lithuania@vastint.eu; or
  • By sending a letter to Jogailos str. 4, Vilnius, LT-01116 Lithuania; or
  • By visiting Vastint Lithuania UAB at Jogailos str. 4, Vilnius, LT-01116 Lithuania.

 

We will respond to your request, complaint or claim in writing in accordance with the applicable laws and will do our best to provide you with information within the shortest time possible but in no event later than within 30 days after receiving your request.

We ourselves receive, review and answer all messages. Whenever you contact us, we may process the following data you have submitted to us, namely your first name, last name, e-mail address, phone number and the text of communication.

Such data will be processed in order to give answers to your questions. If you do not provide your contact details, we will not be able to contact you.

Communication messages will be retained for 1 (one) year after receipt except for the information which is subject to another retention period pursuant to this Privacy Policy or the laws.

All personal data submitted in the course of our communication will be used solely as described above for reviewing messages and for managing and administering communication flows.

Please note that we may need to contact you by regular post or e-mail or phone. If your personal data change, please let us know about such change.

If having received your request, complaint or claim we have doubts about your identity, we may ask for your identity document.

If we fail to provide you with the necessary information and/or should you have complaints about how your personal data are processed, you may approach the State Data Protection Inspectorate (www.vdai.lrv.lt) by filing a complaint.

How will we inform about changes in our Privacy Policy?

We may update or amend this Privacy Policy at any time. Such updated or amended Privacy Policy will take effect from the date of being published on the Website. You should check our Website occasionally to make sure that you see the latest version of our Privacy Policy.

Each time our Privacy Policy is updated, we will inform you of all changes that we deem significant by posting them on the Website. You may look at the “Update Date” listed at the bottom to find out when the Privacy Policy was last updated.

How to contact us?

If you have any questions regarding the terms and conditions of this Privacy Policy, please feel free to contact us by phone or e-mail or registered post using the following contact details:

Vastint Lithuania UAB

Corporate ID number 111622773

Address: Jogailos str. 4, Vilnius, LT-01116 Lithuania

Phone: +370 5 2690090

E-mail: info.lithuania@vastint.eu

 

This Privacy Policy was last updated on 3 April 2020