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Privacy policy

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We, UAB Ekskomisarų Biuras, legal entity code 122755433, address Laisvės pr. 10, Vilnius (“Ekskomisarų Biuras”), respect and protect the privacy of every website visitor and customer and are committed to the fair and lawful processing and maintenance of personal data.

We are committed to storing the personal data collected about website visitors and customers as set out in this Ekskomisarų Biuras Privacy and Personal Data Processing Policy (“Privacy Policy”). This Privacy Policy explains our policy regarding the information (including personal data) we collect as well as why we collect this information and how we use it.

We may change the Privacy Policy periodically. In any case, if we change the Privacy Policy, we will notify you of the changes by posting the amended Privacy Policy on the Ekskomisarų Biuras website (“Website”). We therefore advise you to visit our Website periodically to review the Privacy Policy.

1. CATEGORIES OF PERSONAL DATA

Personal data may be obtained directly from the customer, from the customer’s activities when using the services, or from external sources, such as state and private registers and other third parties.

The main categories of personal data collected by Ekskomisarų Biuras include, but are not limited to:

  • Personal identification data such as name, surname, national identification number, date of birth or identity document (passport, identity card) data.
  • Contact details such as address, telephone number or e-mail address.
  • Data on relations with legal entities such as contact details of the person representing the customer (legal entity).
  • Financial data such as data on accounts or outstanding debts.
  • Data obtained and/or created in complying with legislative requirements such as data obtained through enquiries from law enforcement authorities, notaries, tax administrators, courts or judicial officers.
  • Video surveillance data such as data collected by means of video recording.
  • Data related to the provision of services such as data on the performance or non-performance of agreements, current or expired agreements, or requests or complaints that are submitted. Data on behaviours, priorities and satisfaction with services, such as data on the level of activity in using the services, the services provided to the customer, customer feedback on the services, or data on whether the customer was happy with the services, including audio recording.

2. PURPOSES AND BASIS FOR PERSONAL DATA PROCESSING

The main objectives pursued by Ekskomisarų Biuras when processing personal data are:

  • Assessment of personal solvency: For the legitimate interest of Ekskomisarų Biuras and the conclusion of an agreement, we assess the customer’s solvency.
  • Processing of joint debtor data files: For the legitimate interest of Ekskomisarų Biuras, we process joint debtor data files.
  • Internal administration (structural management, record-keeping, financial and accounting management): For the legitimate interest of Ekskomisarų Biuras and in complying with the requirements of legislation and pursuing the goals of internal administration (proper management of company structure, records, finance and accounting), we process personal data.
  • Debt management: We process related personal data in order to manage customer debts when this is necessary for the performance of an agreement or for the legitimate interest of Ekskomisarų Biuras to ensure debt management.
  • Filing, execution and defence of legal claims: We process personal data for the purposes of filing, executing, transferring and defending legal claims when this is necessary for the performance of an agreement or legal obligation, or for a legitimate interest of Ekskomisarų Biuras related to the execution of legal claims.
  • Direct marketing, customer opinion enquiries, market research: Upon obtaining the customer’s consent, Ekskomisarų Biuras processes personal data for the purpose of direct marketing.
  • Enquiry management: In order to respond to your enquiries, we process your personal data in the legitimate interest of Ekskomisarų Biuras.
  • Conclusion and performance of agreements: We process personal data to the extent necessary to conclude and perform agreements.
  • Video surveillance (protection of persons and property): Ekskomisarų Biuras uses video surveillance in the company’s premises and at the entrances thereto. Video surveillance is used at the company because due to the specifics of the work, it is necessary to ensure the safety of persons and property, and other methods or measures are insufficient and/or inappropriate for achieving this goal (the legal basis for data processing is the legitimate interest of Ekskomisarų Biuras to protect its own property and safety and that of its customers). Ekskomisarų Biuras also acts as the processor of video data in the event that other data controllers entrust Ekskomisarų Biuras with installing video surveillance equipment and conducting video surveillance in the data controller’s premises. In such cases, Ekskomisarų Biuras processes the video data in accordance with the conditions and instructions given by the other data controllers.

3. STORAGE PERIOD

We process data for no longer than is necessary to achieve the purpose of data collection. The period for which the personal data will be stored is defined taking into account the legitimate interest of Ekskomisarų Biuras or the legislative requirements (e.g. regarding accounting, archiving, the statute of limitations, etc.).

4. CATEGORIES OF DATA RECIPIENTS

Personal data collected for the above purposes may be transferred to recipients, such as state institutions and authorities, law-enforcement authorities, courts and other institutions handling disputes, and other persons performing the functions assigned to them by law (for example, judicial officers, notaries, debt collection companies, bankruptcy administrators). Your data may also be transferred to legal and other consultants.

For the processing of personal data, Ekskomisarų Biuras may use data processors (for example, other security companies, direct marketing service providers, market research or business analytics service providers, database software providers, database administration service providers, data centre, hosting and cloud service providers). In such cases, Ekskomisarų Biuras shall take the necessary measures to ensure that the said data processors process the personal data in compliance with the instructions given by Ekskomisarų Biuras and valid legislation, and shall require the implementation of appropriate personal data security measures.

5. INFORMATION TRANSFER OUTSIDE THE EUROPEAN UNION

Generally, Personal Data are processed within the territory of the European Union/European Economic Area (EU/EEA), but in certain cases they may be transferred and processed outside the EU/EEA.

Personal data may be transferred and processed outside the EU/EEA when the transfer is necessary for the conclusion and performance of an agreement or when you have given your consent, provided that appropriate safeguards are in place. Appropriate safeguards are:

  • an agreement is concluded that includes standard conditions adopted by the European Commission or other approved clauses, codes of conduct, certificates, etc., approved in accordance with the General Data Protection Regulation;
  • by decision of the European Commission, the non-EU/EEA country where the data recipient is located ensures an adequate level of data protection;
  • the recipient is certified according to the requirements of the EU-US data protection “Umbrella agreement” (applicable to recipients located in the US).

6. YOUR RIGHTS

You have the right at any time to submit a request to Ekskomisarų Biuras to obtain access to your personal data and how they are processed, to demand the deletion, transfer or restriction of processing of your personal data, to demand the rectification of incorrect, incomplete or inaccurate personal data, and to demand the suspension of the processing of your personal data (except for storage) when the data are being processed in violation of the law and the terms and conditions of this Privacy Policy. You can exercise your rights by contacting us in one of the following ways: 1) by e-mailing us at info@ekskomisarai.lt and/or 2) by submitting a written request to UAB Ekskomisarų Biuras at Laisvės pr. 10, Vilnius, Lithuania. Ekskomisarų Biuras undertakes to respond to your request within one month.

You can withdraw your consent to receive newsletters and for Ekskomisarų Biuras to collect and process the personal data you have provided for direct marketing purposes at any time by e-mailing a letter to info@ekskomisarai.lt.

You have the right to lodge a complaint with the State Data Protection Inspectorate if you believe that Ekskomisarų Biuras is not processing your personal data properly.

7. COOKIES

Cookies are small files that the browser of the device you are using receives from the Website you are visiting and saves on your device. Cookies allow the Website to remember information about your browsing habits, actions, searches and settings, so that you can use the full functionality of the Website, and so that other visits to our Website are simpler and more useful. Cookies are valid for one year.

Cookies used on our Website:

  • Performance (session) cookies. These are designed to improve the functioning of the website and collect general (anonymous) information about the use of the website.
  • Persistent Cookies (tracking cookies from Google Analytics). These cookies are used to analyse the behaviour of website visitors and collect general (anonymous) information about the number of website visitors, the pages visited and the duration of time spent on our website.
  • Targeted (advertising) cookies. These are used to display advertising information that matches your interests.

Disabling cookies Most browsers are set to accept cookies automatically. With information on how and what they are used for, you can decide whether to keep the cookies or disable them in your browser. We would like to warn you that by disabling the cookies, you may lose access to some features of the Website. If you do not want to receive cookies, you can set your browser to reject all cookies or to send a warning when a cookie is created.

These provisions are subject to change without separate notice, because we comply with the legislation governing the use of cookies and take into account generally accepted practices related to the use of cookies.

8. LINKS TO OTHER WEBSITES

On the Website, you may find links to different websites (“links”) that we do not manage (“different websites”) and that have different privacy policies. We aim to only provide links to websites we trust, but we are not responsible for the privacy policies or information security and protection systems in place on the different websites, and we are not responsible for the information collected by the different websites and/or third parties not covered by this Privacy Policy. We also assume no responsibility for the policies (including the privacy policy), practices, acts or omissions of the different websites and/or such third parties. We advise you to check the terms of use and privacy policies of these websites.

9. DATA SECURITY

Protecting your personal data is important to us. We understand the importance of security and the methods required to protect information. We take the necessary measures to protect against the loss, abuse or alteration of the information we have collected from you.

You should be aware that there are many risks involved in surfing the net, such as credential theft (data theft), disclosure of unencrypted information, virus infection and eavesdropping.

Using a computer without an anti-virus programme and without updating the system may expose you to the risk of viruses and spyware that can record your actions on the computer or disrupt your activities. It is your responsibility to keep your system and virus protection up to date.

Beware of fake e-mails. Fake e-mails are messages that look like they were sent by us. These messages usually contain a link to a page where you are asked to enter your details for various reasons. This is an attempt to illegally obtain the recipient’s personal data in order to access their accounts.

Please note that we never send e-mails to our customers asking them to update their personal data or log in, so never respond to a request to update your information via a link sent to you by e-mail.

10. LIMITATION OF OUR LIABILITY

We are not responsible for events that we cannot directly control. We cannot guarantee that no operational errors will occur in protecting your personal data. In addition, we are also not responsible for any direct or indirect events or damages arising from the use and/or provision of your personal data, including, among other things, risks to personal data due to errors, unauthorised access by third parties, or any other factors beyond our direct control.

11. CONTACT INFORMATION

For all questions regarding the Privacy Policy, you can contact:

UAB Ekskomisarų Biuras
Laisvės pr. 10, Vilnius, Lithuania
E-mail: info@ekskomisarai.lt
Telephone: 8 (5) 212 41 61

You can contact the Ekskomisarų Biuras data protection officer by e-mail at info@ekskomisarai.lt or by phone at 8 (5) 212 41 61.

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