Personal data protection policy
DATA CONTROLLER AND ITS CONTACT DETAILS
1. The controller of personal data processing is UAB Deals On Wheels. Code: 305629352, office address Verkių st. 25C, Vilnius (hereinafter – UAB Deals On Wheels);
2. UAB Deals On Wheels contact details for issues related to personal data processing – data protection specialist Laurynas Boguševičius. By using these contact details or contacting UAB Deals On Wheels headquarters, you can ask questions about the processing of personal data. A request to exercise your rights can be made based on clause 23.
3. UAB Deals On Wheels contact details for informing about possible data protection violations: [email protected]
4. Personal data is any information about an identified or identifiable natural person.
5.1. natural persons – UAB Deals On Wheels customers, (including potential, past and present);
5.2. Visitors of UAB Deals On Wheels offices and other premises, including those that use a video surveillance system;
5.3. visitors to websites created by UAB Deals On Wheels;
5.4. persons whose personal data are processed in social networks and are related to marketing activities organized by UAB Deals On Wheels.
6. UAB Deals On Wheels takes care of Clients’ privacy and personal data protection, respects Clients’ rights to the legality of personal data processing in accordance with the applicable legal acts – the Law on the Protection of Natural Persons, 2016 of the European Parliament and the Council. April 27 Regulation 2016/679 on the protection of natural persons in the processing of personal data and on the free movement of such data (hereinafter – the Regulation) and other applicable legislation related to privacy and data processing.
PURPOSE OF PROCESSING PERSONAL DATA
8. UAB Deals On Wheels processes personal data for the following purposes:
8.1. Providing services and advising clients:
8.1.1. to identify the customer;
8.1.2. to prepare and conclude contracts;
8.1.3. to provide services;
8.1.4. to develop new services;
8.1.5. to promote and develop goods and services or for commercial purposes;
8.1.6. to serve customers;
8.1.7. to deal with statements of objection or claims;
8.1.8. to retain customers, to build loyalty, to conduct satisfaction surveys; 8.1.9. to administer settlements;
8.1.10. to recover and recover debts;
8.1.11. to maintain and improve the performance of websites and mobile applications;
8.2. For business planning and analysis;
8.3. For the safety of customers, to protect the company’s assets;
8.4. For other specific purposes for which the Client’s consent has been obtained, providing specific data to UAB Deals On Wheels.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
9. UAB Deals On Wheels processes the customer’s personal data based on the following legal basis –
9.1. conclusion and execution of a contract – in order to conclude a contract at the Customer’s request and ensure its execution (a verbal agreement on the purchase of goods or services is also considered a contract);
9.2. enforcement of legal acts – in order to fulfill UAB Deals On Wheels’ obligation provided for in binding external legal acts;
9.3. based on the consent of the Client, the data subject;
9.4. legal (legitimate) interests – in order to implement the existing relations or concluded contract between UAB Deals On Wheels and the Client, or the legitimate (legitimate) interests of UAB Deals On Wheels provided for by law.
10. The legal (legitimate) interests of UAB Deals On Wheels are:
10.1. engage in commercial activities;
10.2. verify the Customer’s identity before purchasing individual goods or services;
10.3. ensure the fulfillment of contractual obligations;
10.4. save Customer requests and applications related to the purchase of goods and the provision of services;
10.5. take steps to attract and/or retain Customers;
10.6. segment the customer database to ensure more efficient service provision;
10.7. create and improve goods and services;
10.8. promote your goods and services by sending commercial messages;
10.9. send other notifications about the progress of the contract execution and events significant to the execution of the contract, as well as conduct customer surveys about goods and services and their experience of using them;
10.10. prevent fraud against the company;
10.11. ensure company management, financial and business accounting and analysis;
10.12. ensure effective company management processes;
10.13. to ensure and improve the quality of services;
10.14. administer payments;
10.15. perform video surveillance for business protection purposes;
10.16. inform the company about the ongoing activities.
PROCESSING OF PERSONAL DATA
11. UAB Deals On Wheels manages customer data using the capabilities of modern technologies, taking into account the existing privacy risks and organizational, financial and technical resources available to UAB Deals On Wheels.
12. UAB Deals On Wheels can perform automated decision-making for the client. The customer is informed about such actions of UAB Deals On Wheels separately, based on legal acts.
13. Making automated decisions that have legal consequences for the Client (for example, approval or rejection of the Client’s request) can only be carried out during the conclusion or execution of the contract between UAB Deals On Wheels and the Client, or based on the Client’s express consent.
PROTECTION OF PERSONAL DATA
14. UAB Deals On Wheels protects Customer data using the capabilities of modern technologies, taking into account existing privacy risks and the organizational, financial and technical resources available to UAB Deals On Wheels, including the specified security measures:
14.2. intrusion protection and intrusion detection programs;
14.3. other protective measures, taking into account the possibilities related to the development of current technologies.
CATEGORIES OF PERSONAL DATA RECIPIENTS
15. UAB Deals On Wheels does not disclose to third parties the Customer’s personal data or any information received during the period of service provision and validity of the contract, including information about received goods and services, except for:
15.1. based on the clear and unambiguous consent of the Client;
15.2. to persons provided for in external legal acts upon their motivated request, in the manner and scope provided for in external legal acts;
15.3. in cases provided for by external legal acts, for the protection of UAB Deals On Wheels legitimate interests, for example, when applying to the court or other national institutions regarding a person who has violated the legitimate interests of UAB Deals On Wheels.
TRANSFER OF PERSONAL DATA
16. UAB Deals On Wheels does not transfer Personal Data to third parties, except to the extent necessary to implement reasonable business, ensuring that the relevant third parties maintain the confidentiality of Personal Data and ensure applicable protection.
17. UAB Deals On Wheels has the right to transfer personal data to UAB Deals On Wheels suppliers, subcontractors, strategic partners and others who help UAB Deals On Wheels and their customers in the performance of commercial activities in order to implement cooperation. However, in such cases, UAB Deals On Wheels requires data recipients to undertake to use the received information only for the purposes for which the data was transferred and in compliance with the requirements of legal acts.
ACCESS TO PERSONAL DATA BY THIRD PARTY ENTITIES
18. UAB Deals On Wheels does not transfer personal data to third countries (outside the European Union and the European Economic Area).
PERIOD OF STORAGE OF PERSONAL DATA
19. UAB Deals On Wheels stores and processes the Clients’ personal data as long as one of the following criteria is applied:
19.1. only as long as the contract concluded with the Customer or the service provided to the Customer is valid;
19.2. the data is necessary for the purpose for which it was collected;
19.3. until the Customer’s request is fully reviewed and/or fulfilled;
19.4. as long as UAB Deals On Wheels or the Client can realize their legitimate interests (for example, submit feedback or file a lawsuit in court);
19.5. While UAB Deals On Wheels has a legal obligation to store data;
19.6. as long as the Client’s consent to process the relevant personal data is valid, if there is no other legal basis for data processing.
20. After the circumstances mentioned in point 19 no longer apply, the Customer’s data is deleted. Audit records are kept for at least one year from the date of their completion.
ACCESS TO PERSONAL DATA AND OTHER CUSTOMER RIGHTS
21. The customer has the right to receive the information provided by the legislation related to the processing of his data.
22. In compliance with the law, the Customer has the right to demand from UAB Deals On Wheels to allow access to his personal data, as well as to demand from UAB Deals On Wheels to supplement, correct or delete them, or to limit processing in relation to the Customer, or the right to object to the data being processed ( including processing of personal data based on the legitimate interests of UAB Deals On Wheels), as well as the right to data portability. These rights are exercised to the extent that data processing is related to the obligations of UAB Deals On Wheels, which are established in accordance with valid legal acts, and which are carried out in the public interest.
23. In order to exercise his right, the customer can submit a request in the following ways:
23.1. In writing to UAB Deals On Wheels (address: Verkių st. 25C, Vilnius) or by sending it by post;
23.2. electronically, by signing with a secure electronic signature and sending an e-mail by mail [email protected]
24. Upon receipt of the Client’s request to exercise his right at the address Verkių g. 25C, Vilnius, the Client’s identity is verified, the request is examined and executed based on legal acts.
25. UAB Deals On Wheels sends the answer to the Customer by post, registered letter to the contact address specified by him or e-mail. by mail, signing with a secure electronic signature (if the request is submitted signed with a secure electronic signature), if possible, taking into account the form of receiving the answer specified by the Customer.
26. UAB Deals On Wheels ensures compliance with data processing and protection requirements based on legal acts, and takes useful steps to resolve the complaint after the Customer submits claims. However, if this fails, the Client has the right to apply to the supervisory authority – the State Data Inspectorate.
27. The customer has the right to receive free of charge one copy of his personal data submitted for processing by UAB Deals On Wheels.
28. The receipt and/or use of the information mentioned in point 27 of this document is restricted in order to prevent a negative impact on the rights and freedom of other persons (including UAB Deals On Wheels employees).
29. UAB Deals On Wheels undertakes to ensure the accuracy of Personal Data and trusts its customers, suppliers and other third parties who transmit Personal Data to ensure the completeness and correctness of the transferred Personal Data.
CUSTOMER CONSENT TO DATA PROCESSING AND RIGHT TO OPT OUT
30. The customer provides consent to the processing of personal data, the legal basis of which is consent (for example, to receive commercial messages, personal data analysis, to receive loyalty cards), in person in writing at the UAB Deals On Wheels office, on the UAB Deals On Wheels website and on mobile devices or elsewhere, where UAB Deals On Wheels organizes marketing activities.
31. The customer has the right to withdraw the consent given for data processing at any time in the same way as it was given and/or according to the procedure established in point 23. In this case, data processing based on the consent given above for a specific purpose will not be carried out.
32. Withdrawal of consent does not affect the data processing carried out during the period of validity of the Client’s consent. 33. Upon withdrawal of consent, data processing, which is carried out on the basis of other legal grounds, cannot be terminated.
34. UAB Deals On Wheels sends commercial messages related to UAB Deals On Wheels and/or third-party services and other messages unrelated to the provision of directly performed services (for example, customer surveys) in accordance with the procedure provided for in external legal acts or based on the Client’s consent.
35. UAB Deals On Wheels can communicate, as well as send commercial messages, using an automatic calling system or electronic means of communication.
36. The customer gives his consent to receive commercial messages from UAB Deals On Wheels and/or its partners by signing in person at the UAB Deals On Wheels office, on the UAB Deals On Wheels website and on mobile devices or elsewhere where UAB Deals On Wheels organizes marketing activities.
37. The consent given by the client to receive commercial messages is valid until it is revoked (also after the expiration of the service contract). The customer may at any time refuse to continue receiving commercial communications in one of the following ways:
37.1. sending email to the email address: [email protected]
37.2. by calling: +37067630636;
37.3. by submitting a written request at the UAB Deals On Wheels office;
37.4. after using the automated option provided for commercial communication to refuse to receive further messages by clicking on the opt-out link at the end of the relevant commercial message (e-mail).
38. UAB Deals On Wheels stops sending commercial messages as soon as the Customer’s request is processed. The processing of the request depends on technological capabilities, which may take up to three days.
39. By expressing his opinion in the surveys and leaving his contact details (e-mail address, phone number), the Client agrees that UAB Deals On Wheels can contact him using the provided contact information related to the evaluation provided by the Client.
VISITING WEBSITES AND MANAGING COOKIES
40.2. UAB Deals On Wheels websites may contain links to third-party websites that have their own usage and personal data protection rules, the completeness of which UAB Deals On Wheels is not responsible for.