MB “KOMERCINIS NT” (hereinafter – We, Us) privacy policy (hereinafter – Policy) outlines the processing of your data (including personal data): collection, use, sharing, storage, etc. Both before and after the General Data Protection Regulation (EU) 2016/679 (hereinafter – GDPR) came into effect, we handle your data fairly and lawfully. Providing an advanced sales management solution, we understand the importance of data security. By employing technical and organizational security measures and adhering to the GDPR, the Law on Legal Protection of Personal Data, and other legal regulations, we ensure the protection and privacy of your data.

Who are we?

MB “Komercinis NT,” legal entity code 306659569, registered address Ulyčios g. 2, Kriemalos k., LT-54182 Kauno r, Republic of Lithuania, email [email protected], phone +370 652 59077, website: www.perkuispanijoje.lt.

What personal data do we process about you?

Your personal data – any information about you (a natural person) whose identity we know or can directly or indirectly identify. Our Policy applies to all personal data we have received from you or other persons, based on a legitimate ground. Providing your personal data is voluntary but necessary for us to fulfill our commitments, respond to your inquiries, allow you to apply for our job openings, etc., as described in this Policy.

What specific personal data do we process?

All personal data we process is categorized based on the established data processing purposes and categories of data subjects (detailed below).

Employees personal data processed: name, surname, personal code, date of birth, address, phone number, email address, marital status, education, qualifications, skills, drivers license information, hobbies, photos, information about income received from MB “Komercinis NT” (salary, etc.). When a vehicle use agreement is concluded with an employee, we process data on the vehicle's registration numbers, make, and model.

Clients and partners employees personal data processed: name, surname, workplace data, personal and/or work email address, personal and/or work phone number, information about partners employees competence. Note: as a data processor, we may process personal data defined in the personal data processing agreement with the client.

Candidates personal data processed: name, surname, date of birth, age, address, phone number, email address, workplace data, work experience, previous workplaces and positions, education, qualifications, skills, driver’s license information, hobbies, additional information voluntarily provided in the candidates CV, data received during the candidate selection process (candidate evaluation).

Personal data processed for direct marketing information recipients: name, surname, phone number, email address, workplace data.

Personal data processed for individuals sending inquiries: name, email address, phone number, content of the message provided.

What personal data do we not process?

We do not process special categories of your personal data, i.e., data related to your racial or ethnic origin, political, religious, philosophical beliefs, union membership, health, sexual life, or information about criminal convictions.

For what purposes and on what grounds do we process your personal data?

We process your personal data to the extent necessary to achieve our established purposes.

Employees, clients, and partners employees personal data is processed for internal administration purposes, based on our legitimate interest. Clients, including potential clients, and partners employees personal data may also be processed for contract conclusion and performance purposes, to conclude and properly perform MB “Komercinis NT” contracts/commitments, and based on our legitimate interest.

Employees personal data is processed for employment contract conclusion, performance, and accounting purposes, proper execution of employer obligations stipulated by laws, maintaining proper communication with employees, and for other internal administration purposes, as well as vehicle use agreement conclusion and performance purposes with employees.

Candidates personal data is processed to select the most suitable candidates for employment and later, with your consent, for candidate database accumulation purposes.

Recommended candidates personal data is processed to offer potential candidates the opportunity to apply for our announced job vacancies. This data is processed based on personal consent. Please note that when a recommending person provides us with a potential candidate's personal data, they are obliged to inform the potential candidate about providing the data to us and obtain their consent for such data provision.

Personal data of individuals sending inquiries via our website(s) or general email is processed for inquiry administration and response purposes. The person submitting an inquiry agrees to their personal data processing in accordance with this Policy.

Personal data of information recipients related to our direct marketing activities is processed to carry out direct marketing, including but not limited to sending newsletters, offering our services by phone. Data is processed based on your consent or our legitimate interest. You always have the opportunity to withdraw your consent or object to the use of your data for direct marketing purposes as described further in this Policy.

To whom do we disclose your personal data?

We may disclose your personal data only based on legitimate grounds (e.g., as required by law, concluded contract, or with your separate consent). Such information is disclosed in accordance with applicable Lithuanian laws and regulations. We ensure that we do not transfer your personal data to any third parties, except where necessary to achieve the above-mentioned purposes. To fulfill these purposes, we responsibly select our service providers, providing server maintenance and administration services, granting and administering the programs and systems we use (e.g., financial accounting software), and providing other necessary services (data processors processing personal data according to our instructions). Please note that MB “Komercinis NT” may employ data processors who operate and may process your data in third countries (e.g., the USA, based on adequacy decision). In such cases, we will make every effort to ensure the security of your personal data in accordance with applicable laws.

How do we ensure the protection of your personal data?

We take appropriate technical and organizational measures to ensure the protection of your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

How long do we retain your personal data?

We retain your personal data no longer than required for the purposes of personal data processing.

Employees, clients (including potential clients), and partners employees personal data is retained for 10 (ten) years, in any case not shorter than until the end of the relevant contract with the client or partner.

Employees personal data is retained for 10 (ten) years from the end of the employment relationship with MB “Komercinis NT,” in any case not shorter than required by applicable laws.

Candidates personal data, who have given consent for their personal data processing for candidate database accumulation purposes, is retained for 5 (five) years. If a candidate does not consent to their personal data processing after selection for the applied position, their data is retained until the end of the selection for the applied position.

Personal data of individuals sending inquiries via our website(s) or general email is retained for 5 (five) years.

Personal data of information recipients related to our direct marketing activities is retained for 3 (three) years.

Your rights

You have the right to access the personal data held by MB “Komercinis NT” and receive information about what personal data has been collected, for what purpose it is processed, and to whom it is disclosed. You can submit a request via email to [email protected]. We commit to responding no later than 30 (thirty) calendar days from the date of receipt. If, after reviewing your personal data, you find that it is incorrect, incomplete, or inaccurate, and wish to correct it or wish us to cease processing your personal data, you can submit a request via email to [email protected]. We commit to responding no later than 15 (fifteen) calendar days from the date of receipt. If, after reviewing your personal data, you find that it is processed unlawfully, unfairly, or there are other grounds provided by law, you can submit a request via email to [email protected] to have your personal data deleted ("right to be forgotten") or to suspend (restrict) the processing of data (except for storage). We commit to responding no later than 30 (thirty) calendar days from the date of receipt. You also have the right to:

Withdraw the given consent to process personal data, without affecting the lawfulness of processing based on consent before its withdrawal.

Receive your personal data, which you have provided to us, in a structured, commonly used, and machine-readable format, and have the right to request the transfer of those data to another data controller, in accordance with the law.

Inform us of changes to the personal data processed by MB “Komercinis NT,” but you are not obliged to do so. In all the above cases, you can submit a request via email to [email protected]. We commit to responding no later than 30 (thirty) calendar days from the date of receipt. Note: We may not allow you to exercise your rights in cases provided by law, where it is necessary to ensure state security or defense, public order, prevention, investigation, detection, or prosecution of criminal offenses, important state economic or financial interests, prevention, investigation, and detection of breaches of professional or official ethics, or protection of your or others' rights and freedoms. Note: Please also note that the above rights are not absolute and their fulfillment may depend on the conditions stipulated by applicable data protection laws. If you believe that the processing of your personal data does not comply with applicable laws, you have the right to contact the State Data Protection Inspectorate (www.vdai.lrv.lt) to submit a complaint or claim. The provided information and rights are enforced without prejudice to your right to apply to a court of law.

Additional Information

This Privacy Policy comes into effect from June 20, 2024, but we reserve the right to update it at any time.

COOKIES

What are cookies ?

Cookies are small text files stored in your device's browser (e.g., computer, mobile phone, tablet) when you browse websites. Other technologies, including data stored in your internet browser or device, associated identifiers, and other software, are used for similar purposes. Cookies are widely used to ensure websites function properly or perform better and more efficiently. In this policy, all such technologies are referred to as "cookies."

Why do we use cookies ?

We use cookies to:

• Ensure the website functions as intended;

• Avoid making you re-enter your details each time you visit the site;

• Save your preferences during and between visits;

• Enhance the speed/security of the website;

• Allow you to share pages on social networks such as Facebook, Instagram, or LinkedIn;

• Enable you to customize the website according to your needs for quicker access to what you're looking for;

• Continuously improve the website to make it more appealing to you;

• Conduct more effective marketing campaigns.

What types of cookies do we use?

Strictly necessary cookies: These cookies are essential for navigating and using the website's features, such as remembering information entered in forms as you move from one page to another during a browsing session. Without strictly necessary cookies, certain website services may not be possible, and the website may not function as smoothly as intended. These cookies do not collect information for marketing purposes and do not remember where you've browsed on the internet.

Analytical cookies: Analytical cookies collect information about how the website is used and help improve its performance. For example, they can show which pages are visited most frequently, help identify issues on the website, and indicate if displayed advertisements are effective. Analytical cookies do not collect personal user information, and all information collected by these cookies is aggregated and anonymous.

Functional cookies: Functional cookies allow the website to remember your choices and provide enhanced and more tailored features according to your needs. Functional cookies also remember changes you've made, such as customizing a particular webpage, as well as in other instances, such as watching a video or leaving a comment on our website. Functional cookies do not track your actions on other websites.

Targeting or advertising cookies: Targeting or advertising cookies are used to display more interesting and relevant ads that align with your interests or to limit the number of times you see the same advertisement on the website. These cookies may also be used to measure the effectiveness of advertising campaigns. They may remember what you viewed on the website.

What cookies do we use?

The website uses strictly necessary, analytical, and targeting or advertising cookies.

How can you manage cookies?

Strictly necessary and analytical cookies are a condition of using our website. If you refuse these types of cookies, we cannot predict how our website will perform when you visit.

You can control the use of functional and targeting or advertising cookies by changing your browser settings.

Please note that deleting or disabling cookies in the future may affect certain parts or functions of our website. Changing cookie settings will also affect other websites you visit.

Information about the cookies used is available on the website www.perkuispanijoje.lt