Privacy Policy

PRIVACY POLICY

v.1, effective as of 2019.10.01

 

The rules set out in this Privacy Policy (the “Privacy Policy”) regulate the processing and use of Your personal data on this website (the “Website”) and/or the mobile application (“the App”).

 

 

By logging in, creating an account or using the Website, the App or its services in any way, and by registering on the Website, the App, by ticking the “I have read and agree to the Privacy Policy” box You (hereinafter referred to as “data subject”, “You”, “Your”, etc.) acknowledge familiarity and agree to be bound by this Privacy Policy for the entire duration of Your use of the Services (Site or App) and also after termination of Your use of the Services (termination of the Service Agreement, etc.), as appropriate.

 

 

 

 

 

 

In the event that You do not agree to the terms of this Privacy Policy, please disconnect from the Website, do not install or delete the App and do not use them.

 

GENERAL PROVISIONS

The Company specified on the Website and / or the App, as the context may require referred to as “Company”, “We”, “Our”, “Us”, etc. has developed and maintains this Website and / or the App in order to provide electronic services and operations complementing the services of the ELCA group companies (e.g. set up an account, conclude electronic transactions, settle accounts, open a payment account for paying for the services, top up an account, view transactions and receive other electronic services related to customer service and non-electronic services to the users in connection with the services provided by the ELCA group companies (“Services”). The Company is a member of the ELCA group of companies, which at this time includes but is not limited to: UAB „ELCA Holding“, code 302837280, address Parodų g. 2, LT-04133 Vilnius; Gelgotos transportas, UAB, code 300016057, address Gėlyno g. 10, LT-68100 Marijampolė; Delca logistic, UAB, code 303252550, address Gėlyno g. 10, LT-68100 Marijampolė; Delca invest, UAB, code 303251135, address Parodų g. 2, LT-04133 Vilnius; Manta CWS, UAB, code 304492648, address Gėlyno g. 10, LT-68100 Marijampolė.

 

 

 

When providing the Services on the Website and / or the App, We collect and process personal data relating to the use of the Website and / or the App and the personal data related to the use of the Website and / or App. We do so in accordance with applicable law and this Privacy Policy. We understand that the protection of privacy and personal data when using the Website and / or the App are important issues, so Our Privacy Policy sets out in detail what personal data We process and how We process it, what rights You have, and what responsibilities apply to the personal data We process.

You may use the Services (the Website and / or the App) only if You have read and accept this Privacy Policy.

The Privacy Policy applies to the processing of all Your personal data when We provide the Services at the Website and / or the App. For the processing of certain categories of personal data, in particular where personal data are processed for other purposes and by other means than those set out in this Privacy Policy (e.g., when data is processed outside the Website and / or App), the Company may establish and make public separate rules. For Video Surveillance Data Processing the Company has adopted and published separate Video Surveillance Data Processing Rules.

You will always find the current version of the Privacy Policy in the “Information” section of the Website and / or the App.

 

PERSONAL DATA CONTROLLER

The controller of Your personal data processed in connection with the provision of the Services on the Website and / or the App is the ELCA group company that manages a specific Website and / or App and is listed in the “Information” section of the Website and / or App.

You can also contact UAB ELCA Holding, legal entity code 302837280, located at Parodų g. 2, LT-04133 Vilnius, Republic of Lithuania, which is a company which controls the processing of personal data of the ELCA group of companies.

The Company processes the personal data itself or through a data processor(s), e.g. technology platforms used as suppliers for the Website and / or App. If the Company employs data processors, You may obtain information about them and their contact details by contacting the Company or UAB ELCA Holding.

 

 

 

PURPOSES OF PROCESSING PERSONAL DATA

We process Your personal data for the following purposes:

  • Identifying the customer, getting to know the customer and concluding the contract. We are required by law to identify You prior to the provision of the Services. For the purpose of verifying Your identity, We process copies of Your personal documents (Your passport or ID card, residence permit, etc.), or require You to use third-party payment or identification services, or We may obtain Your identity from Your mobile operator (which issued Your SIM card), or We can compare data from all of these sources and use third-party identification services. Copies of documents may be retained in accordance with legal requirements.

 

 

  • Provision of services (performance of contract). We use Your personal data to provide You with the Services, such as enabling You to make transactions, enabling You to acquire property offered for sale on the Website and / or App, pay for property acquired, see Your action and transaction history, manage Your Website and / or App account and so on. We may also use Your personal data to contact You regarding the Services We provide to You (to inform You of changes to the Services, malfunctions, respond to Your inquiries or address any complaints You may have to us).

 

 

  • Prevention of money laundering and terrorist financing (fullfilment of legal obligations). Your personal data is processed, for example, in accordance with the requirements of money laundering and terrorist financing prevention and other regulatory obligations imposed on us.
  • Safeguarding and protecting Our rights and legitimate interests. We process Your personal data in the exercise and protection of Our rights under the agreement with You regarding the provision of the Services.
  • Service design, development and quality improvement. To the minimum extent necessary for business needs, and where possible by depersonalizing, Your personal data may be processed, for example, by depersonalizing it and using it for analysis of the Website and / or App usage patterns and trends, in order to know the customer, their expectations, develop the Services and Website and / or App. We may use Your personal data to correct errors and improve performance of the Website and / or the App.
  • Offering services (direct marketing). Your personal data is processed in order to provide You with relevant information about Our goods or services (including those provided with Our partners, such as financial service providers) and to seek Your opinion on them.
  • Customer service via electronic communications, evidence collection for the protection of Our rights and legal interests. After contacting Us by telephone, conversations may be recorded for the specified purpose, with separate notice.

We may also process Your personal data for purposes other than those stated above, as required by law, and, where appropriate, with proper notice or other legitimate processing grounds.

 

GROUNDS FOR THE PROCESSING OF PERSONAL DATA

We process Your personal data only on legitimate grounds:

  • In order to enter into and / or execute a contract with You for the provision of the Services (e.g. processing of Your personal data necessary to order and provide the Services, etc.).
  • With Your consent (e.g. sending offers, accessing contact data, using Your location data).

 

  • Pursuing Our legitimate interests (e.g., collecting evidence of proper provision of Services to you, ensuring the security of Our assets, preventing crime and protecting law and order, pursuing and developing Our activities, defending Our rights, managing indebtedness, and providing a safe and secure Website and/or App experience and security etc.); or
  • By complying with the legal requirements applicable to Us (e.g. by effectively monitoring and investigating suspicious transactions and money transactions in accordance with the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania).

If necessary, We may also process Your personal data on other legal grounds, as required by law, after duly informing you.

 

 

PERSONAL DATA PROCESSED

We or Our service providers (data processors) process Your personal data relating to Your use of the Services (in particular with transactions that you have made) and may automatically collect technical data generated by the Website and / or the App when You use the Services or the Website and / or App functionality (e.g. records of technical operations on the Website and / or the App are recorded in the system log). We do not generally associate the Website and / or App data recorded in the technical logs and the System Log with You, as a user of the Website and / or the App, but in certain cases (to ensure proper interaction between the Website and / or App and Our systems and especially in order to ensure systems security and resolution of technical malfunctions (as well as, for example, when recording transactions and timing of other actions; when recording Your consents granted when using the Website and / or the App; when keeping track of client transactions for money laundering and terrorist financing prevention purposes; when using the Website and / or the App for the first time We need to capture Your identity) You will be identified or distinguished by the technical records recorded in the system log. In the technical logs of the Website and / or App transactions recorded in the System Log, We record Your actions on the Website and / or the App that require information not stored on the Website and / or App itself (e.g. password (in)correct, fact of execution, level of identification of the client performing actions on the Website and / or the App, data provided by the client, list of operations performed on the Website and / or the App). In such cases, the technical logs of the Website and / or the App will be treated in the manner prescribed by law as Your personal data and processed in accordance with the personal data processing rules.

 

 

 

 

 

We may process the following personal data for customer identification, customer knowledge and contract conclusion:

  • Customer identification, customer KYC data, and customer agreement conclusion (at Our request, You will provide this personal information as required by law or such data as is necessary to conclude or to enforce a Service agreement with You regarding provision of Services; without providing this data You will not be able to use the Website and/or the App):
  • personal code;
  • name;
  • surname;
  • number;
  • date of birth (for foreign nationals) (if applicable, personal identification number or other unique character sequence assigned to that person);
  • copy (copy) of the personal identification document You provided for establishing Your identity;
  • Your signature (except situation when not required in the identity documents);
  • Your nationality (if You are a stateless person, the country that issued Your identity document);
  • mobile (qualified electronic) signature data;
  • residential address;
  • Your area of individual business activity or business;
  • transaction data (objects, amounts, time and other data);
  • workplace;
  • positions held;
  • the nature of the activity;
  • source of income;
  • Your image and the image of Your identity document or equivalent document, verifying the identity of Your face image with the identity document You provided (when used for verification);

 

 

 

  • biometrical data (technically processed face image and facial image in Your identity document (when used to verify identity));

 

  • email address;
  • Internet Protocol (IP) address;
  • telecommunications terminal information;
  • other data obtained during customer identification and / or transaction.

 

 

We may process the following personal data for the purposes of Our Services:

  • personal code;
  • name;
  • surname;
  • IBAN account number;
  • telephone number;
  • date of birth (if foreign national) (if applicable, personal identification number or other unique character sequence assigned to that person);
  • a copy of the personal identification document You provided for establishing Your identity;
  • Your signature (except situations when it is not required in the identity document);
  • Your nationality (if You are a stateless person, the country that issued Your identity document);
  • email address;
  • residential address;
  • Website and / or App User ID;

 

  • Your location data (if applicable);
  • details of transactions and Your actions (objects, amounts, time, etc.);

 

  • system logs and technical records of Your activities on the Website and / or App (technical records) used to troubleshoot and ensure system security;

 

  • the balance (amount) of funds transferred for the payment for the Services;
  • details of financial transactions (funds added / deposited / transferred to account (amount), number, type (received, sent) of payment transactions, status, date and time, amounts, periodicity, purpose of payment, amount of transaction fee used from deferred payment) the amount of the bill);
  • data related to auto-recharge (whether this service is enabled, its settings, etc.);
  • fixed limits for operations;
  • bank card details (name, surname, number (part of it), year and month of validity, CVV code) if the card is linked to Your account;
  • data on Your visits to and use of the Website and / or the App;

 

  • Website and / or App Security Code;

 

  • Internet Protocol (IP) address;
  • the versions of the Service Agreements You have entered into, the consents You have given, the communications You have received, the Privacy Policy and any other related documents You have agreed to abide by;
  • details of Your requests and communications to Us;
  • for the purposes of promotions your personal details (name, phone number, data, whether specific tasks specified in the rules of the promotion were fulfilled, etc.). For promotion purposes We make automated decisions for You based on specific rules of the promotion.

 

 

We may process the following data for the purposes of Our regulatory compliance (e.g. Money Laundering and Terrorist Financing Prevention Law, Payments Law, Tax Administration Law, etc.):

  • Your identity data;
  • Your transaction and operation data;
  • Other data required by law.

 

For the purposes of safeguarding and protecting Our rights and interests, We may process data about You (such as the content of Your transactions and obligations to us, communications with you,) and other data required by Us to safeguard Our interests.

 

 

For the purposes of creating, developing and improving the Services, We may process the data You provide (such as error reporting) and the data We generate (such as the scope of the Services) as well as any other information You provide, including personal data, when You notify Us of and / or App glitches and errors.

 

For the purpose of offering services (direct marketing) We may process the following data about you: name, surname, email address, phone number, selected message delivery method (via SMS, email, Website and / or App).

 

For customer service via electronic means (e.g. service and advice on services, Website and / or App usage and troubleshooting), evidence collection for the purposes of protecting Our rights and legitimate interests, We may process Your personal data: name, surname, telephone number, personal identification number (or the last 4 digits of the personal identification number), answers to questions, transactions completed and any type of operation performed, workplace, position, nature of activity, source of income, e-mail address, information relating to the matter being sought or defended. To this end, We will also maintain records of electronic communications, and their dates, times and duration.

 

When organizing games or promotions We, as data controller, may process the following personal data of You and / or other persons to the extent that is specific to the nature and rules of the game or promotion: transaction or operation number, name, surname, amount, time, date, information necessary for tax payment or tax declaration when your win or benefit gain requires tax payment.

 

We generate some of the above data ourselves. In the event of any change in Your personal data You have provided to Us for any purpose of processing as stated in this Privacy Policy, You will promptly notify Us of any changes to Your personal data so that Your personal data We process is accurate and correct.

We will process Your personal identification number in accordance with the legal grounds allowed under the applicable law, which is usually a contract for the provision of Services to you.

 

SOURCES OF PERSONAL DATA

Subject to legal grounds, We receive Your personal data:

  • directly from You (when You submit data to Us upon request or voluntary use of the Services, when establishing your identity, reporting the errors on the Website and / or the App);

 

  • by generating it ourselves (e.g., technical details of the Website and / or App that identify you; Your authentication data generated by capturing a face image during a live video transmission and matching the face image of the identity document displayed);

 

 

  • from a financial service provider of Your choice (e.g. a commercial bank);
  • from other persons established in the European Union providing Us with information technology, identity verification / identification and / or other services;
  • from public sources (for example, from the register of residents of the Republic of Lithuania maintained by the State Enterprise Center of Registers);
  • persons managing joint debtors’ files (e.g. UAB Creditinfo Lietuva);

 

  • by collecting public negative information (such as information about violations of law) about You online through targeted search;
  • from organizations that maintain public registers and international databases (e.g. lists of validity of international identity documents, international financial sanctions);
  • from service providers and third parties (e.g. Internet service providers, authentication service providers);

 

  • from other persons (subject to notice to You).

 

CATEGORIES OF PERSONAL DATA RECIPIENTS

Your personal data will be processed on Our behalf by Our trained employees, who ensure security and confidentiality of Your personal data, or by trusted, properly instructed and controlled providers of information technology and other services necessary for the provision of the Services (processors of Your data), and only to the extent necessary for the proper provision of the Services.

We can use service providers both in Lithuania and in other European Union or European Economic Area countries as well as in any other country in the world (“third country”). In this case, if Our service provider is established in a third country that does not ensure adequate protection of Your personal data, We will take appropriate technical and organizational measures to protect personal data (for example, We will include personal data protection clauses in contracts with these service providers and / or measures to ensure the lawfulness and security of the data transfer) to protect Your personal data from unauthorized processing in such states.

 

 

In all cases, when We provide Your personal data to others, We apply technical and organizational security measures to ensure that the recipients of Your personal data process the data only for the purposes stated in Our Privacy Policy and in accordance with applicable data disclosure requirements.

 

We will not share Your personal data outside the ELCA group of companies with other independent controllers (recipients), except when necessary for the purposes stated in this Privacy Policy, such as:

  • to the extent necessary to verify Your identity, when You access the Website and / or the App, We may transfer Your personal data to Our identification service provider;

 

  • to the extent necessary for the provision of the Services (such as entering into and executing transactions on the Website and / or App, performing account operations), We will provide Your personal data to providers of services you ordered, who are established in any country of the world and are designated by You and who will participate in the transaction and provision of the Services ordered by you (e.g. payment institutions, transport service providers);
  • to the extent necessary to ensure telephone support for You and to collect evidence for the protection of Our rights and legitimate interests, We will provide access to certain Your personal data to persons providing security and legal services to us;
  • to the extent necessary to the development and quality improvement of the Services, capturing, analysing and removing of the errors and malfunctions of the Website and / or the App We will provide Your personal data to providers of technical maintenance of the Website and / or the App;
  • subject to legal grounds, We may provide Your personal data to the administrator of the joint debtors file (e.g. UAB Creditinfo Lietuva).

 

We may share Your personal data outside ELCA group of companies with other independent controllers (recipients) and as required by law.

We will notify You of the transfer of Your personal data, if it is required by law and if such disclosure is not contrary to law or does not harm the protection of interests protected by law.

To third parties established inside or outside the European Union in order to pursue Our reasonable and legitimate interests (e.g. to investors and potential investors in the event of a transfer of business (or part of business); to the financial institutions of the EU or a third country while ensuring appropriate safeguards for the protection of personal data provided when conducting investigations into suspicious financial operations or transactions made by or for You for the purpose of  prevention of money laundering and terrorist financing), when these persons ensure the confidentiality and protection of Your personal data and other conditions for the proper transfer of Your personal data.

 

We may share Your personal data outside ELCA Group of Companies with other independent controllers (recipients) and as required by law.

 

PERIOD OF PROCESSING OF PERSONAL DATA

 

We will process Your personal data for the minimum period required by law or for the purposes set out in Our Privacy Policy, and thereafter, unless We have a legitimate basis for further processing of such personal data, it will be securely and irreversibly destroyed. We choose the specific retention period for personal data based on the nature of the personal data and the purposes for which they are processed.

As a general rule, We will process Your personal data for the entire duration of Your use of the Services and after the termination of Your use of the Services (e.g. termination of the Service Agreement) we will retain Your personal data without any active processing for 10 years.

We will retain records of the correspondence with You regarding the provision of the Services or the use of the Website and / or the App for the duration of Your use of the Website and / or the App and for 5 years after termination of Your use of the Services (e.g., termination of Service Agreement).

The prescribed periods of retention may be extended for up to 2 years upon receipt of an order from the competent public authorities or in other cases provided for by law.

 

For the purposes of protecting Our rights and interests, We process Your personal data in the exercise and protection of Our rights under Our contracts with You and for such period as is necessary to exercise Our rights or protect any affected rights or interests, or for such period as is required by statutory deadlines established by law.

We will protect Your personal data for the purpose of creating, developing and improving the Services for 1 year after the submission of the relevant data.

When We process Your personal data on the basis of Your consent (e.g. direct marketing), We will process Your personal data for the period specified in the relevant consent (in the relevant section of the Privacy Policy). Unless otherwise provided by law, We will process Your personal data processing records (evidence of consent You have consented to, data processing notices with which You have access) for the duration of Your use of the Services, and for 3 years after Your use of the Services (e.g. termination of the Service Agreement) without any active processing.

 

 

Your actions on the Website and / or the App are recorded in the technical logs (and/or the system log) at the moment of downloading, installing, and using the Website and / or App on Your terminal device (or mobile device) or at other moments when the Website and / or App performs the relevant actions, which are recorded. These records of Your actions on the Website and / or the App are processed and maintained as they are necessary to preserve evidence of actions that have legal consequences (such as confirmations of Your operations, records of Your transactions, etc.). The procedure for determining the retention period for records that are the proof of actions having legal consequences is the same as for the personal data (Your actions) for the proving of which they are retained.

 

We will securely destroy Your personal data if we do not have legal grounds for further processing.

 

DIRECT MARKETING

We will provide service offerings (notices) subject to Your consent (subject to ticking the appropriate box) during the use of the Website and / or the App or at any time thereafter in the Website and / or App Settings and, where permitted by law will notify You of Our Services and Our other services similar to the Services used by You.

By selecting the box for receiving direct marketing (offers) during the use of the Website and / or the App, or at any time thereafter, You choose to receive Our offers and agree that We, as data controller, may contact You by e-mail, text message and instant message on the Website and / or App in order to offer Our services or request Your opinion on the Services We provide (for direct marketing purposes) and to process Your personal data (phone number, name, email address, the manner in which You would like to receive notifications (by short text message, e-mail, on the Website and / or App)) on the basis and terms of such consent.

 

 

 

You have the right to opt out of receiving notifications. You can revoke Your consent to receive notifications at any time without adverse consequences. You can do this in the Website and / or App Settings by unchecking the selected option (for example, unchecking the box) to receive offers.

If You do not agree to receive offers, We will not be able to provide You with relevant information.

Upon receipt of a request to revoke Your consent to receive direct marketing communications, We will immediately terminate the processing of Your personal data on the basis of consent, but the revocation of consent will not affect the lawfulness of processing of consent-based personal data prior to revocation (communication sent prior to revocation).

For the purpose of receiving notices about Our services, We will collect and process Your personal data in digital form in a secure manner. We will receive Your personal data for the purpose of sending notifications from You and will not disclose this data to anyone for this purpose.

On the basis of Your consent to receive notices of Our services, We will send You communication for the duration of Your use of the Website and / or the App (until You terminate the Service Agreement) or until You revoke this consent.

 

YOUR RIGHTS

You have the following rights as a data subject in relation to Your personal data:

  • know about the processing of Your personal data;
  • request access to Your personal data processed by Us and provide a copy thereof;
  • request rectification of Your personal data;
  • request the deletion of Your personal data;
  • request the transfer of Your certain personal data;
  • in certain cases, prescribed by law, to request restriction of the processing of Your personal data;
  • notify Us in certain cases provided by law that You do not consent to the processing of Your personal data;

 

  • withdraw Your consent to the processing of personal data, if such consent has been given previously;
  • if We make automated decisions with respect to You (for example, based solely on Your personal data and solely by automated means making a decision not to provide the Services) or profile You (for example by assigning You to a category created by Us according to the use of the Services or other features), You are entitled to object to a decision made by Us by automated means, including on a profiling basis, and require human participation to make such a decision;

 

 

  • if You believe that We are violating Your rights as a data subject, You have the right to lodge a complaint with the State Data Protection Inspectorate and / or seek redress before the courts.

 

 

 

 

How to enforce Your rights:

  • Correction (correction, updating), deletion, restriction of personal data is carried out upon Your request or on Our own initiative for the fulfilment of legitimate (e.g. internal administration) purposes. Your other rights as data subjects are exercised only upon Your request.
  • Your requests for enforcement of data subject’s rights must comply with the requirements of the Privacy Policy and the law. Requests that do not meet these requirements may be considered as unfounded and may not be honoured. We will only honour reasonable, non-abusive requests and only after establishing the identity of the person (and the representative) making the request and the right to submit the request.
  • We will only process requests for the exercise of Your rights upon receipt of a free-form written request for the exercise of a specific right (or several rights). The request shall be in legible form, shall not contain explicit language, profanity, insulting or disrespectful wording, and shall clearly and specifically state which right(s) are to be exercised. You must submit Your request for the exercise of Your data subject’s rights to Us in writing by email to personaldata@elcaholding.com, or in person at Our office (Parodų g. 2, LT-04133 Vilnius), or by postal mail to Our office address.

 

  • The application must be signed by You with a physical signature or a qualified electronic signature. The request and any accompanying documents, if required for Your or Your representative’s identification procedure described below, or the request not signed by a qualified electronic signature, must be in a sufficiently readable on a standard computer, have high contrast and be otherwise legible (e.g. scanned pdf document).
  • We may request additional information from You in order to identify You or to clarify Your request.
  • We will identify the data subject who submitted the request (and his / her representative) by a notarized copy (s) of the identity document (s) attached to the request or by a qualified electronic signature on Your request. When a request for the exercise of the rights of the data subject is provided by Your representative by law or by power of attorney, the request must be accompanied by a notarized copy of the document certifying the right of representation (e.g. civil status document) or notarized power of attorney. Failure to sign the request (including an option of a qualified electronic signature) and / or attach a copy of the requested document (s) will result in Your request being considered unfounded and will not be honoured. We will retain the request and the documents submitted with the request during the execution of the request and for 3 years after the execution of the request, after which We will safely destroy it;

 

  • Requests are executed or denied (by indicating reasons) within 30 calendar days of the date of submission of the request in accordance with the Privacy Policy and the law. This time limit may be extended by prior notification to the Data subject in accordance and in cases prescribed by the law (e.g. where the request concerns a large amount of personal data). We will reply You in the same way by which You sent the request;
  • Your request will be processed free of charge once per calendar year. If You abuse or re-submit substantially analogous requests within 1 calendar year of the date of fulfilment of the last substantially analogous request (or reasoned refusal to honour such request), in particular if We have not made substantial changes to Your personal data processing during that period, We may request You to compensate Us for the costs of executing Your request or We may consider such a request to be unjustified and refuse to honour it. We may also consider the request to be unjustified and refuse to honour it, when: it does not specify the specific rights to be enforced; it does not contain information required for Your request under the Privacy Policy or the law; such request is not allowed by the law or the Privacy Policy; the request is otherwise manifestly unfounded; the request was made in abuse of rights; We do not process Your personal data; together with the request documents needed to establish Your (or Your representative’s) identity were not submitted (or are inadequate); the applicant is not duly authorized or entitled to make the request; the law does not provide for the possibility to honour such request. In the course of fulfilling Your requests, We will not disclose information that comprises Our trade secrets and other data, which is not required to be disclosed to the data subject according to the law.

 

We implement Your right to know about the processing of personal data by providing information in the Privacy Policy, in communications in the Website and / or the App and through other channels.

By exercising Your right to access to Your personal data, You may obtain confirmation that We are processing Your personal data; information on the categories of personal data We process, the sources from which We collect them, the purposes for which We process them, the categories of recipients of Your data, and the retention period for such data; information on automatic decision making or Your profiling (if applicable); information on transfers of personal data outside the European Economic Area (if applicable). Upon request, We will provide a copy of Your personal data in the format and medium of Our choice.

Once You have identified that We are processing incorrect, incomplete or inaccurate personal data about You, You may request that this personal data be corrected or deleted. Upon receipt of a request for rectification of personal data, We will suspend the active processing of such data other than storage, verify the accuracy of the personal data and, where applicable, renew the processing of the rectified personal data by correcting incorrect, incomplete, inaccurate data.

In the cases provided by law, You may request a restriction on the processing of Your personal data. In this case, You must indicate in the request the reason for the restriction, the scope of the personal data to be restricted and the period of time for which the restriction is requested. If there is a reason to restrict the processing of personal data, We will separate the processing of the restricted data from processing of other personal data and suspend the processing of the restricted data other than storage, and, if applicable, will notify you. We will only be able to process personal data subject to restricted processing to the extent and in the cases provided for by the law. After restricting the processing of Your certain personal data, the full or proper functionality of the Website and / or the App or the provision of the Services may not be possible.

In the cases and to the extent provided by law, We will exercise Your right to erase all or part of Your personal data (other than required by law for further processing) processed by Us (the right to be forgotten). Upon receipt of such a request, to the extent that it complies with Our obligations under the law, the data requested to be deleted will be securely and irreversibly destroyed and, to the extent possible, We will notify the recipients of such personal data known to Us about Your request. In case we do not have reasonable technical ability to delete all copies of Your personal data from all information systems or backups at once, We will notify You when the data can be completely removed from Our systems.

 

When exercising Your right to portability of personal data (to receive it in a standard, computer readable and interoperable format or to request transfer to another controller), You should further specify in the request whether You request personal data yourself or request Your personal data processed by Us to be transferred directly to other data controller (in this case You shall precisely specify the recipient of the data, the recipient’s information system to which You are requesting the transfer, the preferred format to be used for the transfer), as well as Your personal data that shall be transferred and the purpose(s) of the transfer of Your personal data. A request for transfer of personal data can only be made with respect to limited personal data: i.e. only with respect to personal data processed by automated means, processed on the basis of consent or performance of a contract, and provided to Us directly by You or directly recorded by Us (without the use of special algorithms) through the use of the Services by You.

 

When Your personal data is processed for a legitimate interest (e.g. processing of Your personal data for direct marketing purposes, analysis of the Services, market trends; providing or obtaining personal data to or from a credit institution established in the European Union or a third country for the purpose of suspicious financial transactions, for the purposes of preventing money laundering and terrorist financing) or in the public interest, profiling based on Your personal data or automatic decision making (if any) is performed, You have the right to object to such processing of Your personal data. If You do not agree, You must notify Us in the way and subject to terms provided in the Privacy Policy. In such case, We will terminate the processing of the personal data concerned unless there are legitimate and justified reasons for the further processing of Your personal data.

When processing Your personal data on the basis of consent, You have the right to revoke Your consent at any time (for example, by unchecking the check boxes in the Website and / or App Settings or by submitting a request discussed above). Upon receipt of information about the withdrawal of consent, We will immediately terminate the processing of personal data on the basis of consent, but the withdrawal of consent will not affect the lawfulness of the processing of consent covered personal data prior to the withdrawal of consent.

 

PROCESSING OF STATISTICAL INFORMATION AND USE OF COOKIES

In order to ensure Your proper use of the Website, the App and the Services, We use the technologies necessary to provide the Services – for processing of the technical parameters of the user devices, the location, technical actions taken on the Website and / or the App, etc. No data that could directly identify You or identify You from the group of users will be collected and processed using this technology and it will not be possible to identify You on the basis of the technical data recorded. Technologies are required for the proper provision of the Services and will continue to apply as long as You use the Website and / or the App. Technology solutions for this purpose are provided by Our trusted vendors (such as Google Inc.).

Cookies are data files and carriers that store information on Your device. Using the Website may store session cookies on Your device that identify the session and user technical parameters.

More information about cookies can be found at: www.AllAboutCookies.org. Cookies are under Your control, and You may refuse them at any time or terminate them (delete, uninstall) by adjusting the permissions for the Website on Your terminal device, clearing the cache, or reinstalling the terminal device.

Using the App saves App files to Your device and files needed for its operation.

 

 

DATA SECURITY

We apply appropriate security measures (including but not limited to data encryption, transmission and network security, access control) to protect the processing of Your personal data by Us from unauthorized access, alteration, disclosure, destruction or other unlawful processing. If, despite the security measures in place, there is a personal data breach that could have serious negative consequences for Your rights, We will notify You immediately. We will also observe all statutory duties for data breach notification.

 

 

 

 

CONTACT US

If You have any questions regarding the Privacy Policy, the processing of Your personal data or Your rights, please contact Us or ELCA Holding UAB by email: personaldata@elcaholding.com.

 

FINAL PROVISIONS

We may change the Privacy Policy in whole or in part at any time. Such changes take effect upon posting the updated Privacy Policy on the Website and / or the App.

 

We kindly ask You to review and read the Privacy Policy on a regular basis. We will notify You in advance of any material changes to Our Privacy Policy by notice posted on the Website and / or the App or otherwise.

 

 

You shall not use the Website, the App and / or the Services without agreeing to the amendments of the Privacy Policy.

 

The Privacy Policy is available in Lithuanian and English. In case of discrepancies, the Lithuanian text shall prevail.

 

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