I. GENERAL PROVISIONS

1. This Privacy Policy (hereinafter referred to as the Policy) governs the principles and procedures for the processing of personal data carried out by UAB “1Partner LT”, registered at Lvivo St. 37-101, Vilnius, email address info@1partner.lt, legal entity code 305208257 (hereinafter referred to as the Data Controller or the Company), as well as the terms of operation of the website https://1partner.lt managed by the Data Controller (hereinafter referred to as the Website).

2. This Policy is intended for persons who visit the Website owned by the Company (https://1partner.lt), use the information available on the Website and the services provided through it.

3. For the purposes of this Policy, a Data Subject means any natural person whose personal data is processed by UAB “1Partner LT”.

4. By using the services and continuing to browse the Website, the Visitor (Website user) confirms that they have read this Policy, understand its provisions and agree to comply with them.

5. The Data Controller ensures that, in adopting and implementing this Policy, it seeks to comply with the following fundamental principles relating to the processing of personal data:

·         Personal data shall be processed lawfully, fairly and transparently in relation to the Data Subject (the principle of lawfulness, fairness and transparency);

·         Personal data shall be collected for specified, explicit and legitimate purposes and shall not be further processed in a manner incompatible with those purposes;

·         Further processing of personal data for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered incompatible with the original purposes (the principle of purpose limitation);

·         Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (the principle of data minimisation);

·         Reasonable efforts shall be made to ensure that personal data is accurate and, where necessary, updated within a reasonable period after any change;

·         All reasonable measures shall be taken to ensure that personal data which is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay or within a reasonable period (the principle of accuracy);

·         Personal data shall be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data is processed;

·         Personal data may be stored for longer periods where it is processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures required to safeguard the rights and freedoms of the Data Subject (the principle of storage limitation);

·         Taking into account the general nature of the personal data processed by the Data Controller, personal data shall be processed in a manner that ensures appropriate security of the personal data through the use of appropriate technical or organisational measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage (the principle of integrity and confidentiality);

·         The Data Controller shall be responsible for compliance with the principles set out above and must be able to demonstrate such compliance (the principle of accountability).

6. This Policy has been prepared 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 and other applicable legislation of the European Union and the Republic of Lithuania. Terms used in this Policy shall have the meanings assigned to them in the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania.

7. We recommend that you take the time to read this Privacy Policy carefully.

8. If you do not agree with the processing of your personal data as described in this Privacy Policy, you have the right not to provide your personal data to the Company. Where we process certain personal data on the basis of your consent, you may withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

9. This Privacy Policy explains how the Company collects and uses your personal data when you:

·         visit the Website operated by the Company and use the features available on it;

·         intend to enter into or enter into an agreement with the Company;

·         purchase services provided by the Company;

·         provide goods or services to the Company;

·         participate in recruitment processes organised by the Company;

·         otherwise communicate or cooperate with the Company as a client, supplier or other person having a business or consumer relationship with the Company.

10. Contact details of the person responsible for personal data protection within the Company:

Email: augustas.jagusinskis@1partner.lt

II. PURPOSES OF PERSONAL DATA PROCESSING AND CATEGORIES OF PERSONAL DATA COLLECTED

1. Depending on who you are (a client, supplier, Website visitor, etc.) and how you interact with the Company (in person, online, by telephone, etc.), the Company may process different categories of your personal data.

2. Below are the categories of personal data that we may collect:

III. TO WHOM YOUR PERSONAL DATA MAY BE DISCLOSED

1. The Company does not disclose your personal data to any third parties without your prior consent, except in the cases described below.

2. We may provide your personal data for processing to third parties that assist us in carrying out our activities and administering the provision of services. Such parties may include companies providing data centre, hosting and related services; companies developing, supplying, maintaining and improving software; providers of information technology infrastructure services; communications service providers; companies providing internet browsing or online activity analysis services; security service providers; and similar service providers.

3. In each case, we provide a data processor only with the amount of data necessary to perform a specific assignment or provide a specific service.

4. Data processors engaged by us may process your personal data only in accordance with our instructions. They must also ensure the security of your data in accordance with applicable legislation and written agreements entered into with us.

5. Data may also be disclosed to competent public authorities or law enforcement authorities, such as the police or supervisory authorities, but only upon their request and only where required by applicable law or in cases and according to procedures prescribed by law, including for the purpose of protecting our rights, safeguarding our customers, employees and resources, and establishing, exercising or defending legal claims.

IV. HOW WE ENSURE THE SECURITY OF YOUR DATA

1. In order to protect your data, the Company implements appropriate measures in accordance with data protection and data security laws and regulations, including requiring the Company’s service providers and engaged data processors to implement appropriate measures to protect your personal data and its confidentiality.

2. Taking into account the state of the art, the cost of implementing the measures and the nature of the data to be protected, the Company has implemented technical and organisational measures designed to protect your data against risks such as destruction, loss, alteration, unauthorised disclosure or unauthorised access.

V. YOUR OBLIGATIONS

1. We would like to remind you that, to the extent that it is within your control, you are responsible for ensuring that the data you provide to us is accurate, complete and up to date. In addition, if you provide us with personal data relating to other persons, you are responsible for obtaining and providing such information to us in compliance with applicable legal requirements. For example, you must inform other persons whose data you provide to the Company about the contents of this Privacy Policy and obtain their consent to the provision of such personal data, where such consent is required.

VI. YOUR RIGHTS

1. Data protection legislation grants you a number of rights relating to the processing of your personal data.

2. Right of access to your personal data You have the right to ask us to confirm whether we process your personal data and, where we do so, to request access to the personal data we process about you. To exercise this right, please submit a written request to us by email at augustas.jagusinskis@1partner.lt.

3. Right to rectification of inaccurate personal data If you believe that information relating to you is inaccurate or incomplete, you have the right to request that it be corrected. To exercise this right, please submit a written request to us by email at augustas.jagusinskis@1partner.lt.

4. Right to object to the processing of your personal data You have the right to object to the processing of personal data where such processing is based on our legitimate interests. However, despite your objection, we may continue processing your data where there are compelling legitimate grounds for such processing. To exercise this right, please submit a written request to us by email at augustas.jagusinskis@1partner.lt.

5. Right to erasure of your personal data (“right to be forgotten”) Under certain circumstances, you have the right to request that we erase your personal data. However, this shall not apply where we are required by law to retain such data. To exercise this right, please submit a written request to us by email at augustas.jagusinskis@1partner.lt.

6. Right to restriction of processing Under certain circumstances, you also have the right to request restriction of the processing of your personal data. To exercise this right, please submit a written request to us by email at augustas.jagusinskis@1partner.lt.

7. Right to lodge a complaint You have the right to lodge a complaint regarding improper processing of your personal data directly with the State Data Protection Inspectorate of the Republic of Lithuania or by email at ada@ada.lt.

VII. INFORMATION ABOUT THE COOKIES USED

1. The Data Controller uses cookies on the Website in order to distinguish one Website user from another. By using cookies, the Data Controller seeks to provide a more convenient browsing experience for Website visitors and to improve the Website itself.

2. Cookies are small text files stored in a person’s browser or device, such as a personal computer, mobile phone or tablet.

3. The Company may use the following categories of cookies:

·         Strictly necessary cookies: cookies required to ensure the operation of the system. For example, certain cookies allow us to identify registered users and ensure that they can access the full functionality of the system. If a user refuses these cookies, they may no longer be able to access all of the system’s content;

·         Performance cookies: cookies that enable us to analyse how users interact with the system and monitor its performance. This allows the Company to select appropriate solutions and quickly identify and resolve problems, thereby ensuring a high-quality browsing experience. For example, performance cookies allow us to determine which pages are the most popular and identify why error messages appear on certain pages;

·         Functional cookies: cookies that enable us to remember users’ preferences and apply them to the Website/mobile application so that the Company can provide enhanced functionality;

·         Targeting cookies: the Company may use cookies to display advertisements promoting the Company’s services that may be of interest to individual users.

4. The following cookies are used on the Website https://1partner.lt: INFORMATION IS BEING UPDATED

5. The cookies used on the Website do not enable the identification of the Website user. Visits to the Website are recorded anonymously by recognising the personal computer, mobile phone or tablet and the IP address. The information collected in this manner is not disclosed to third parties, except in cases provided for by law.

6. By opening the Website and clicking the “I agree” button in the pop-up window, the person browsing the Website agrees to cookies being stored on their computer, mobile phone or tablet.

7. To withdraw consent, the person browsing the Website may delete or block cookies by selecting the appropriate settings in their browser, allowing them to reject all or some cookies. Please note that if browser settings are used to block cookies, including necessary cookies, the user may experience difficulties when using all or some of the Website’s functions.

8. Personal data collected through cookies is processed in accordance with the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, 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, Directive 2002/58/EC of the European Parliament and of the Council, and other applicable legislation governing the protection of personal data.

9. In accordance with applicable legal requirements, security measures are implemented on the Website to prevent the unlawful disclosure or unlawful use of personal data.

VIII. FINAL PROVISIONS

1. Legal relations arising in connection with this Policy shall be governed by the laws of the Republic of Lithuania.

2. The Data Controller shall not be liable for damage, including damage caused by interruptions in the operation of the Website, or for loss or corruption of data resulting from the actions or omissions of the person concerned or third parties acting with that person’s knowledge, errors, intentional harmful conduct or other improper use of the Website.

3. The Data Controller shall also not be liable for interruptions in access to and/or use of the Website or for any resulting damage caused by the actions or omissions of third parties unrelated to the Data Controller or the person concerned, including interruptions in electricity supply, internet access or other similar services.

4. The Data Controller reserves the right to amend this Policy in whole or in part.

5. Any additions or amendments to the Policy shall take effect from the date on which they are published on the Website.

6. If a person continues to use the Website and/or the services provided by the Data Controller after the Policy has been supplemented or amended, the person shall be deemed not to object to such additions and/or amendments.

7. For all matters relating to the processing of personal data, you may contact us by email at augustas.jagusinskis@1partner.lt.

8. This Privacy Policy is effective from 24 September 2024.