EUROCASH1, UAB PRIVACY POLICY
1. GENERAL CONDITIONS
We, EUROCASH1, UAB, legal entity code 225329030, registered office at Ukmergės g. 219-1, Vilnius, Lithuania (hereinafter referred to as “EUROCASH1”), respect and protect the privacy of every visitor and customer of www.eurocash1.lt website and we are committed to the fair and lawful processing and protection of your data.
This Privacy Policy has been drawn up in accordance with 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 (hereinafter referred to as the “GDPR”), the “Law on Legal Protection of Personal Data of the Republic of Lithuania” (hereinafter referred to as the “LPPD”), and other legal acts of the European Union and the Republic of Lithuania.
This Privacy Policy explains EUROCASH1’s policy regarding the information (including personal data) we collect about you and why we collect, process, and use this information.
This Privacy Policy describes the principles of collection, use, and storage of personal data of www.eurocash1.lt website visitors and customers, the purposes and means of personal data processing, and informs who can access personal data and for what purposes. The terms used in the EUROCASH1 Privacy Policy shall be understood as they are defined in the GDPR and the GDPR.
We may change the Privacy Policy from time to time. If we change our Privacy Policy, we will notify you of these changes by posting the revised Privacy Policy on the www.eurocash1.lt website (the “Website”), and we encourage you to check our website www.eurocash1.lt periodically.
Each time you visit the www.eurocash1.lt website, you agree to the terms and conditions described in this Privacy Policy. If you do not agree to these terms and conditions, you have the right to refrain from visiting the www.eurocash1.lt website, from using its content, and/or from using EUROCASH1 services.
The visitor and/or customer of the www.eurocash1.lt website (hereinafter referred to as the “Data Subject”), by submitting his/her personal data (including the data that he/she directly or indirectly submits by visiting the www.eurocash1.lt website and using its services), agrees and does not object to EUROCASH1 (hereinafter referred to as the “Controller”) to manage and process them for the purposes and in accordance with the procedure set out in the present Privacy Policy, in the consent of the data subject, and in the legislation of EUROCASH1.
Persons under 16 may not submit personal data through the www.eurocash1.lt website. If you are a person under 16, you must obtain the consent of your parents or other legal guardians before submitting personal information.
We are concerned about the protection and privacy of your personal data and aim to keep you fully informed about its processing, whether you communicate with us orally, in writing, or in any other way you choose.
2. WHAT ARE THE PRINCIPLES OF PERSONAL DATA PROTECTION THAT WE FOLLOW?
We comply with the following principles when collecting and using the personal data you have entrusted to us, as well as personal data received from other sources:
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- Your personal data is processed in a lawful, fair, and transparent manner (the principle of lawfulness, fairness, and transparency);
- Your personal data are collected for specified, explicit, and legitimate purposes and are not further processed in a manner incompatible with those purposes (purpose limitation principle);
- Your personal data is adequate, relevant, and only necessary for the purposes for which it is processed (data minimization principle);
- The personal data processed are accurate and updated where necessary (accuracy principle);
- Your personal data are kept in a form that permits identification of the individual for no longer than is necessary for the purposes for which your personal data are processed (principle of limitation of storage period);
- Your personal data are processed to ensure adequate security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage (principle of integrity and confidentiality), through appropriate technical or organizational measures.
3. WHAT DATA DO WE COLLECT, PROCESS, AND USE, AND FOR WHAT PURPOSES?
We receive and use your personal data if you intend to enter into or have entered into a contract with EUROCASH1 for the provision of services and have given your consent to this or if the processing of your personal data is possible on the basis of law for our legitimate interests.
We collect, process, and use your personal data, whether provided by you or obtained from other sources, in accordance with the GDPR, the DPA, and EUROCASH1 legislation.
We collect, process, and use your personal data for the following main purposes:
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- If you visit the www.eurocash1.lt website, we collect information about visitors to the www.eurocash1.lt website and other browsing information, including when and from where our website or other electronic platforms were accessed. When you register on the www.eurocash1.lt website, you will be asked to provide personal data and consent to the collection and processing of the personal data you have provided in order for EUROCASH1 to provide you with the newsletters, publications, and information about services or events that you have signed up for. You can withdraw your consent to EUROCASH1 processing the personal data you have provided at any time by sending an email to: info@eurocash1.lt. You are responsible for ensuring that the personal data and other information you provide to us is true and accurate.
- In order to advise you on EUROCASH1 recruitment and to assess your candidature, we collect and process your name, surname, date of birth, a copy of your identity document, address, telephone number, and other contact details, as well as information about your marital status, education, income, financial obligations and other information that you provide to us during meetings or remote consultations. We process and store this information for no longer than is necessary to respond to the request.
- In order to advise you on the services provided by EUROCASH1 or to provide you with services and contact you, we collect and process the following data: your name, surname, date of birth, address, telephone number, and other contact details. We keep this information no longer than necessary to fulfil your request.
- In order to provide you with the EUROCASH1 services and to properly perform our contractual obligations, as well as to comply with our obligations under the law, we collect and process the following data from you or your representative: name, surname, date of birth, personal identification number, copy of identity document, address, telephone number, and other contact details. For this purpose, we also use your bank account number, details of your transactions with EUROCASH1, and other data and information necessary for the performance of the contract that we receive when you use EUROCASH1 services. We automatically analyze your use of the EUROCASH1 services in order to properly inform you of any disruptions in the EUROCASH1 service and to introduce service improvements or similar services. We keep the data collected in the course of providing our services for as long as you use our services and for 10 years after you stop using our services.
- In order to communicate with you, to properly fulfill our contractual obligations, to respond to your questions and requests regarding the provision of EUROCASH1 services, to receive your feedback, to send you important notices regarding the provision of the EUROCASH1 services, changes to the rules, this Policy or other documents, and to send you security alerts, we will process your contact details and the content of the notices received and sent to you. We process the data collected in the course of providing our services for as long as you use our services.
- In order to send and deliver direct marketing offers that are tailored to your needs, we collect and use your name, telephone number, and email address, as well as information about your use of our services, payment transaction history, and other information you provide to us during meetings or through electronic channels. For this purpose, we automatically analyze your personal data, including information about the services you have ordered and your purchase history, i.e., which goods and services you have purchased through our services. We process the data collected in the course of providing our services for as long as you use our services. If you do not consent to the use of your personal data for direct marketing purposes, please inform us immediately.
- To ensure that EUROCASH1 can provide services to you remotely, we record telephone conversations or other communications between you and us. For this purpose, we also store the telephone number, IP address, and other data that identifies you, as well as the content, duration, time, and other technical data of the conversation. We keep the data collected in the course of providing our services for as long as you use our services.
- To ensure the security of you and our property, we carry out video surveillance and process your video data when you visit EUROCASH1. We keep the video data for 30 days.
- For the purposes of EUROCASH1’s customer debt management, the management of the joint debtors’ data file, the assessment of personal solvency, and in order to manage your debts to us, we collect and process the following data from you: name, surname, personal identification number, date of birth, copy of identity document, address, telephone number, details of your income, place of work, position held, assets owned, financial liabilities, credit and payment history, family assets, date and fact of death (if deceased), amount of debt. We process the data for no longer than is necessary to achieve the purpose of the data collection. The period of retention of personal data for archiving purposes is defined according to EUROCASH1’s legitimate interest in accordance with the time limits set by law.
- In order to comply with anti-money laundering requirements and to determine whether you are eligible to become a client, we collect data about your place of work, job title, and nationality. We keep this information for no longer than is necessary to respond to your request or to conclude a contract.
- In order to manage and protect EUROCASH1’s legitimate interests and to comply with the GDPR, the GDPR and the EUROCASH1 Rules and other legal provisions, and to comply with the requirements of the courts, law enforcement authorities, and to satisfy their requests, we may process data and information about the judicial or administrative proceedings in which you are involved, and other information communicated to us for the purposes mentioned above. We process and store the data for no longer than is necessary to achieve the purpose of the data collection.
- We may also obtain your personal data from other sources in order to comply with our contractual obligations or statutory duties:
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- State Social Insurance Fund Board;
- State Enterprise “Registrų centras”, State Enterprise “Regitra”, law enforcement authorities, other registers, and state institutions;
- UAB “Creditinfo Lietuva”;
- Insurance companies, if you use insurance services;
- Ministry of Finance and other financial institutions;
If you are related to EUROCASH1 clients (legal entities) and you are an agent, employee, contractor, promoter, founder, shareholder, participant, owner, etc., of these legal entities.
The use of your personal information helps us to manage, improve, and develop our services, to minimize disruptions to the services we offer, and to update, facilitate, and personalize our communications.
In collecting and using the personal data you have entrusted to us, as well as personal data obtained from other sources, we undertake to:
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- Process them only for clearly defined and legitimate purposes;
- Not to process your personal data for purposes other than those set out in this Policy, except as required by law;
- Process and store your personal data lawfully, accurately, transparently, fairly, and in such a way as to ensure the accuracy, identity, and security of the personal data processed;
- Ensure that no redundant personal data is processed;
- Process and store your personal data for no longer than is necessary for the purposes for which the personal data are processed;
- Be responsible for and be able to demonstrate compliance with the principles set out in the Policy;
- Comply with any other obligations under the law.
We do not collect special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, or sexual orientation.
4. WHAT DO WE DO TO PROTECT YOUR PERSONAL DATA AND INFORMATION?
We use various security technologies and procedures to protect your personal information—which we collect to provide our services—from unauthorized access, use, or disclosure. We also require our suppliers to use appropriate measures to protect your confidentiality and ensure the security of your personal information.
We remind you that while we take reasonable steps to protect your information, no website, online transaction, computer system, or wireless connection is completely secure. The security of transmission of information over the Internet or by e-mail sometimes cannot be guaranteed for reasons beyond EUROCASH1’s control, so you should take care when submitting confidential information to us by means of your choice other than through the electronic systems used by EUROCASH1.
We keep your personal data in EUROCASH1 printed documents and information systems for no longer than is necessary for the purposes for which it was collected or for the period of time required by law and for the purposes of archiving the data in accordance with the requirements and time limits set by law.
EUROCASH1 applies different retention periods for personal data in accordance with the requirements of the law and the purposes for which the personal data are processed.
Exceptions to the retention periods may be made provided that they do not prejudice the rights of data subjects and comply with legal requirements. Longer retention of your personal data may be carried out when:
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- We need to defend ourselves against claims, demands, or lawsuits and enforce our rights;
- There are reasonable grounds to suspect an illegal act that is the subject of an investigation;
- Your data is necessary for the proper resolution of a dispute or complaint;
- Other grounds provided for by law.
At the end of the time limits, if they have not been extended, the data will be destroyed without any possibility of reproduction.
5. YOUR RIGHTS
We will do our best to enforce your rights and answer any questions you may have about the information contained in this Policy.
You have the right at any time, by submitting a written request to EUROCASH1, UAB, at Savanorių pr. 19, Vilnius, Lithuania, or by sending an e-mail to info@eurocash1.lt, to have access to your personal data and to be informed about how it is processed. You have the following rights:
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- The right to access your personal data;
- The right to have incorrect, inaccurate, or incomplete data rectified;
- The right to restrict the processing of your personal data until the lawfulness of the processing has been verified at your request;
- The right to request the erasure of personal data;
- The right to object to the processing of personal data for direct marketing purposes, including profiling, and where the processing is carried out for our legitimate interests;
- The right to request the transfer of your personal data to another controller or to have them provided directly to you in a form that is convenient for you (applies to personal data provided by you and processed by automated means on the basis of consent or on the basis of a request or for the conclusion and performance of a contract);
- The right to withdraw the consent you have given, without prejudice to the use of your personal data prior to the withdrawal of your consent;
- The right to lodge a complaint with the supervisory authority, the State Data Protection Inspectorate.
We will respond to your request no later than 30 (thirty) calendar days from the date of receipt. In exceptional cases requiring additional time, we shall have the right, upon notice to you, to extend the time limit for the provision of the requested data or for the processing of any other requirements set out in your request by up to 60 (sixty) calendar days from the date of your request.
We will refuse to comply with your request with a reasoned response where the circumstances set out in the GDPR and other legislation are established, and we will inform you in writing of this.
6. TO WHOM CAN WE TRANSFER YOUR PERSONAL DATA?
EUROCASH1 ensures the protection of personal data in accordance with the directly applicable legislation of the European Union, as well as the legislation of the Republic of Lithuania and EUROCASH1, therefore, we may transfer your personal data to third parties in accordance with the requirements of the legislation, and only in accordance with the one-time lawful requests of these persons or in accordance with the concluded data provision agreements, except for the data processors used by EUROCASH1.
We may use data processors to process the personal data referred to in this Policy:
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- Companies providing data centers, website administration, and related services;
- Companies providing document archiving and destruction services;
- Companies that develop, provide, support, and evolve software;
- Companies providing information technology infrastructure services;
- Companies providing communication services;
- Companies that analyze and provide services for the analysis of Internet browsing or online activity.
Processors are entitled to process your personal data only on EUROCASH1’s instructions and only to the extent necessary for the proper performance of the obligations set out in the data processing agreement. We take all necessary measures to ensure that our data processors have implemented appropriate organizational and technical security measures.
In all cases, EUROCASH1 requires a legal basis from the data recipient. In the absence of a legal basis, EUROCASH1 refuses to provide your personal data to third parties.
Subject to legal requirements, your personal data may be transferred:
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- Courts and other law enforcement and/or dispute resolution authorities in the exercise of their lawful powers upon written request;
- Companies providing debt collection, event organization, and video surveillance services;
- The Department of Statistics, the State Social Insurance Fund Board, the State Enterprise “Centre of Registers”, the State Enterprise “Regitra”, notaries, bailiffs, law enforcement, and state authorities;
- Representatives of audit institutions;
- Other third parties in connection with the transfer, sale, purchase, reorganization of our services, or similar changes in the company.
Thank you for choosing EUROCASH1 as your partner. We strive to ensure that our services meet your expectations. It is important to us that you provide us with information about changes in circumstances and personal data so that we can inform you about changes to our services, fees and other important terms.