PRIVACY POLICY
The purpose of the privacy policy is to inform how personal data of subjects are collected and processed, to explain how long they are stored, to whom they are provided, what rights data subjects have and where to apply for their implementation or other issues related to personal data processing.
Personal data is processed in accordance with the General Data Protection Regulation (EU) 2016/679 of the European Union (hereinafter – the Regulation), the Law of Republic of Lithuania on Legal Protection of Personal Data and other legal acts regulating the protection of personal data.
UAB “Metralis” is guided by the following basic data processing principles:
- personal data is collected only for clearly defined and legitimate purposes;
- personal data is processed only legally and fairly;
- personal data are constantly updated;
- personal data is stored securely and for no longer than the established purposes of data processing or legal acts require;
- personal data is processed only by employees of the Company who have been granted such a right according to their work functions or by duly authorized data processors
CONCEPTS
- Data controller – UAB “Metralis” (hereinafter – the Company), legal entity code 304184732, registration address: Liubčios st. 8, Vilnius.
- Data subject – any person of which data processed by the Company. The data controller collects only data of the subject that is necessary for the Company’s activities and/or when visiting, using, browsing the Company’s websites, social network accounts, etc. (hereinafter referred to as the Website). The company ensures that the collected and processed personal data will be secure and will used only for a specific purpose.
- Personal data – any information directly or indirectly related to a data subject of which identity known or can be directly or indirectly determined using the relevant data. Processing of personal data is any operation performed with personal data (including collection, recording, storage, editing, modification, granting of access, submission of requests, transfer, archiving, etc.).
- Consent – any voluntary and knowingly given confirmation by which the data subject agrees to the processing of his personal data for a specific purpose.
SOURCES OF PERSONAL DATA
- Personal data is provided by the data subject himself. The data subject addresses the Company, leaves comments, asks questions, requests the Company to provide information, etc.
- Personal data is obtained when the data subject visits the Company’s website. The data subject fills in the forms therein or leaves his contact details etc. for any reason.
- Personal data is obtained from other sources. Data is obtained from other institutions or companies, publicly available registers, etc.
PROCESSING OF PERSONAL DATA
By submitting personal data to the Company, the data subject agrees that the Company will use the collected data to fulfill its obligations to the data subject, providing services that the data subject expects.
The Company processes personal data for the following purposes:
Ensuring and continuity of the company’s activities. The following data is processed for this purpose:
- Personal data of suppliers (natural persons) may be processed for the purpose of concluding and executing contracts: first name(s), last name(s), personal identification number or date of birth, place of residence (address), telephone number, e-mail address, workplace, position, signature, data in the business certificate (type of activity, group, code, name, periods of activity, date of issue, amount), individual activity certificate number, data or data subject is a VAT payer, bank current account and bank, services/goods amount, currency and other data provided by the person himself, which the Company receives in accordance with legislation in the course of the Company’s activities and/or which the Company is required to process by laws and/or other legal acts;
- For the purpose of concluding and executing contracts, data of supplier representatives may be processed: first name(s), last name(s), telephone number, e-mail address, company name, address, duties, authority data (number, date, date of birth of authorized person , signature);
- Contracts, VAT invoices – invoices and other related documents are stored in accordance with the terms specified in the General Document Storage Index, approved by order of the Chief Archivist of Lithuania.
- The legal basis for data processing is the need to fulfill a contract to which the client is a party as a data subject, or in order to take action at the client’s request before concluding a contract with him (GDPR Article 6 d. 1 point b), when certain personal data are required to be processed by legal acts (GDPR Article 6 d. 1 point c).
Administration of inquiries, comments and complaints. The following data is processed for this purpose:
- Name(s), surname(s) and/or username, e-mail address, telephone number, address, subject of the message, comment, feedback or complaint, text of the message, comment, feedback or complaint.
- The data of requests, comments and complaints are stored for 1 calendar year after their submission.
- Legal basis for data processing – processing data is necessary to achieve the legitimate interests of the data controller or a third party, except in cases where such data and the subject’s interests or fundamental rights and freedoms, which make it necessary to ensure the protection of personal data, take precedence over them, especially when the data subject is a child (GDPR Article 6(1)(f)) and the data subject’s consent (GDPR Article 6(1d) . point a).
For the purpose of ensuring the security of the company’s employees, other data subjects and property (video surveillance). For this purpose, the following data is processed:
- Image representation. Video surveillance systems do not use facial recognition and/or analysis technologies, the video data captured by them are not grouped or profiled according to a specific data subject (person). The data subject is informed about the ongoing video surveillance by means of information signs with a video camera symbol and Company details, which are presented before entering the monitored territory and/or room. The premises where the data subject expects absolute protection of personal data are not included in the surveillance field of video cameras.
- Personal data (video data) obtained by video surveillance cameras are stored for up to 19 (nineteen) calendar days from the moment of their capture, after which they are automatically destroyed, except in cases where there is reason to believe that a misdemeanor, a criminal act or other illegal actions have been recorded. (until the end of the relevant investigation and/or trial).
- Legal basis for data processing – processing data is necessary for the pursuit of the legitimate interests of the data controller or a third party, except in cases where such interests of the data subject or the fundamental rights and freedoms necessary to ensure the protection of personal data override them, especially when the data subject is child (GDPR Article 6 d. 1 point f).
For other purposes for which the Company has the right to process the data subject’s personal data, when the data subject has expressed his consent, when the data needs to be processed due to the legitimate interest of the Company or when the Company is required to process the data by relevant legal acts.
USE OF SOCIAL NETWORKS
- All information you submit via social media (including messages, use of the Like and Follow boxes, and other communications) is controlled by the operator of the relevant social network.
- Currently, our Company has an account on the social network LinkedIn, whose privacy policy is available at https://www.linkedin.com/legal/privacy-policy.
- We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions about how they use your personal data.
PROVISION OF PERSONAL DATA
- The company undertakes to observe the duty of confidentiality towards the data subjects. Personal data may be disclosed to third parties only if it is necessary to conclude and execute a contract for the benefit of the data subject, or for other legitimate reasons.
- The Company may provide personal data to its data processors who provide services to the Company and process personal data on behalf of the Company. Data processors have the right to process personal data only in accordance with the Company’s instructions and only to the extent that it is necessary in order to properly fulfill the obligations stipulated in the contract. The company uses only those data processors who sufficiently ensure that appropriate technical and organizational measures will be implemented in such a way that the data processing meets the requirements of the Regulation and ensures the protection of the data subject’s rights.
- The company may also provide personal data in response to court or state authority requests to the extent necessary to properly comply with applicable legislation and state authority orders.
- The company guarantees that personal data will not be sold or rented to third parties.
PROCESSING OF PERSONAL DATA OF MINORS
- Persons under the age of 14 may not provide any personal data through the Company’s website. If a person is younger than 14 years old, in order to use the Company’s services, before submitting personal information, it is mandatory to submit the written consent of one of the representatives (father, mother, guardian) regarding the processing of personal data.
PERSONAL DATA STORAGE TERM
- Personal data collected by the Company are stored in printed documents and/or in the Company’s information systems. Personal data is processed no longer than is necessary to achieve the purposes of data processing or no longer than is required by the data subjects and/or provided for by legal acts.
- Although the data subject may terminate the contract and refuse the Company’s services, the Company must continue to store the data subject’s data due to possible future demands or legal claims until the data storage terms expire.
RIGHTS OF THE DATA SUBJECT
- The right to receive information about data processing.
- The right to access the processed data.
- The right to demand rectification of data.
- The right to request deletion of data (“Right to be forgotten”). This right does not apply if the personal data that is requested to be deleted is also processed on another legal basis, such as the processing is necessary for the performance of a contract or is the fulfillment of an obligation according to applicable legislation.
- The right to object to data processing.
- Right to data portability. The right to data portability cannot adversely affect the rights and freedoms of others. The data subject does not have the right to data portability in relation to personal data that is processed in manually structured files, such as paper files.
- The right to request that a decision based solely on automated data processing, including profiling, not be applied.
- The right to submit a complaint regarding the processing of personal data to the State Data Protection Inspectorate.
The company must provide conditions for the data subject to implement the above-mentioned rights of the data subject, with the exception of cases established by law when it is necessary to ensure state security or defense, public order, prevention, investigation, detection or prosecution of criminal activities, important economic or financial interests of the state, official or professional prevention, investigation and detection of ethical violations, protection of the rights and freedoms of the data subject or other persons.
PROCEDURE FOR IMPLEMENTATION OF THE RIGHTS OF THE DATA SUBJECT
The data subject, in order to exercise his rights, can contact the Company:
- by submitting a written request in person, by post, through a representative or by means of electronic communication – e-mail by mail: info@metralis.eu;
- by phone: +370 696 39399;
- in writing – to the address: Liubčios st. 8, Vilnius.
- In order to protect data from illegal disclosure, the Company, upon receiving a data subject’s request to submit data or exercise other rights, must verify the identity of the data subject.
- The company’s response to the data subject is given no later than one month from the date of receipt of the data subject’s request, taking into account the specific circumstances of personal data processing. This period may be extended by another two months if necessary, depending on the complexity and number of requests.
RESPONSIBILITY OF THE DATA SUBJECT
The data subject has:
- inform the Company about changes in the provided information and data. It is important for the company to have correct and valid data subject information;
- to provide the necessary information so that, at the request of the data subject, the Company can identify the data subject and make sure that it is really communicating or cooperating with a specific data subject (provide a document confirming the identity of the person or in accordance with the procedure established by legal acts or electronic means of communication that would allow the proper identification of the data subject). This is necessary for data protection of the data subject and other persons, so that the disclosed information about the data subject is provided only to the data subject, without violating the rights of other persons.
FINAL PROVISIONS
- By transferring personal data to the Company, the data subject accepts this Privacy Policy, understands its provisions and agrees to comply with it.
- During the development and improvement of the Company’s activities, the Company has the right to unilaterally change this Privacy Policy at any time. The company has the right to unilaterally, partially or completely change the Privacy Policy by announcing it on the website www.metralis.eu.
- Additions or changes to the privacy policy take effect from the date of their publication, i.e. i.e. from the day they are placed on the website www.metralis.eu.