Version of 31 May 2022
2. About the Company
The company shall mean the Private Limited Liability Company “Motusbona”, legal entity code 304126978, registered office at Kauno g. 55, Vievis, 21371 Elektrėnai Municipality, Republic of Lithuania, the data about the Company shall be collected and stored in the Register of Legal Entities of the Republic of Lithuania. Contact e-mail for data protection issues: email@example.com
3. What is personal data?
Personal data is any information collected by the Company about the Data Entity that can be used to identify the Data Entity and is stored electronically or otherwise.
4. Execution of the Company’s contracts with natural and legal counterparties
In the performance of contracts with legal counterparties, the Company inevitably processes the data of the employees of such legal entities or of other natural persons engaged to perform the contract. Information on the processing of personal data is provided in the table below:
|Purpose of data processing||Personal data processed||Basis for data processing||Time limit for data processing|
|Contracting with natural person customers||Name, surname, personal identification number, address, business address, bank account number, details of services or goods received/provided||Clause (b) Part 1 Article 6 of GDPR (contract)||10 years after the end of the contract|
|Authentication of the identity of natural person customers in distance contracts||Name, surname, details on the identity document provided, copy of identity document||Clause (f) Article 6 of GDPR (legitimate interest)||Written off identity documents – no copy of the identity document is retained for 10 years after the end of the contract (kept until identity verification and writing off)|
|Establishing and executing contracts with clients/suppliers legal entities||Name, surname, e-mail address, telephone number, content of correspondence, order progress, date||Clause (f) Part 1 Article 6 of GDPR (legitimate interest)||4 years of communication, 10 years after the end of the contract, information relating to performance of the contract or contained therein|
|Bookkeeping||Name, surname, details of services received/provided and goods sold, and other personal data in invoices and other accounting documents||Clause (c) Part 1 Article 6 of GDPR (legal obligation)||The data shall be kept within the time limits laid down by the legislation governing the keeping of accounting records, and in accordance with the Index of General Document Retention Periods|
5. Selection of candidates
We collect and process your personal data (name, surname, preferred office position, work experience (workplace, office position, person who can recommend you), education, any other data provided in your CV, questionnaire or cover letter and/or other information provided by you) for the purpose of participation in the selection process in order to conduct the job selection on the basis of the consent you give to the Company by sending your CV and/or cover letter. If you do not submit your CV and/or cover letter, we will not be able to assess your suitability for the position offered.
If you agree, we will contact your current employer, and we will contact your former employer on the basis of our legitimate interest (to select the right candidate). You may withdraw your consent or, as the case may be, object to us contacting your former employer at any time by notifying us at the e-mail address specified in Clause 2 of the Policy.
In the event that you do not express your individual consent to the processing of your personal data after the end of this selection procedure, we will delete and/or destroy your personal data within 3 days after signing the contract with the selected candidate or after making the decision to close the selection procedure, except in the case of an individual consent to the retention of the candidate’s personal data for the period of time specified in the consent.
On the basis of your consent, we will keep the data for the period specified in the consent.
On the basis of our legitimate interest, we will process data about the person (name, surname, e-mail, telephone number, information provided by the person) indicated by the candidate – a former or current employer or a person providing a reference, and the information provided by the person – for the purpose of selecting the candidate. In this case, our legitimate interest is to select the right candidate for the position we are seeking. We will destroy this data after the selection process has ended.
6. Protecting confidential information of the Company and business continuity
The Company may review its employees’ correspondence with contractors in order to protect the Company’s confidential information and the continuity of the Company’s business in its legitimate interest. For these purposes, the Company processes the following personal data of its employees and of persons who send or receive employee communications: e-mail address, name of the sender or recipient, date, content of information contained in electronic work tools. Such data shall be kept for 4 years.
7. Protection of property and persons
In order to protect the safety of customers, visitors, employees and other persons entering the surveillance area, the property of these persons and the Company, to collect evidence of violations, and to protect its rights, the Company carries out video surveillance. Video surveillance shall be carried out on the basis of the legitimate interest of these persons and the Company. In the course of video surveillance, the Company processes the following personal data: image, movement trajectory, objects in the possession of individuals. The data shall be kept for one week after recording.
8. Handling requests, complaints and disputes in and out of court
For the purpose of handling requests, complaints, and settling disputes in court and out of court (in the exercise of legitimate interest to protect its rights and legitimate interests), the Company processes the following personal data:
|Categories of Data Entities||Personal data processed||Basis for data processing||Time limit for data processing|
|1. Natural persons making requests, complaints or otherwise initiating disputes, as well as natural persons involved in disputes initiated by the data controller (in the case of a legal person, employees and other representatives);
2. Representatives, employees, etc. of state and local self-government authorities, pre-trial investigation bodies and other law enforcement agencies
|Name, surname, job title, employer, e-mail address, telephone number, the content of the claim, complaint or other disputed document, the personal data contained therein, and any other personal data obtained in the course of the claim, complaint or other submission.||Clause (f) Part 1 Article 6 of GDPR (legitimate interest)||1 year after the final judgment or out-of-court settlement of the dispute|
9. Internal administration of the company (exercise of shareholders’ rights)
The Company may, for internal administration purposes (upon a shareholder’s request for the exercise of the right to information), transfer to the shareholder any personal data (as recorded in the documents provided to the shareholder). The transfer is made in fulfilment of a legal obligation imposed on the Company (Clause (c) Part 1 Article 6 of GDPR), and the personal data shall be processed only until they are transferred to the shareholder.
10. Contact us
There are several ways in which you can contact the Company: by phone, by e-mail, via the Company’s social media accounts. We receive, review and respond to all communications ourselves. If you contact us, we may process the data you have provided to us, i.e. e-mail address, telephone number, name, surname (if provided), username (if the request is sent via social networking accounts), workplace (if provided in the signature of the e-mail), as well as the dates, times, content of the messages sent and received.
Such data will be processed in order to answer your questions and process your suggestions. If you do not provide your contact details, it will not be possible to contact you.
Any personal data you provide when you interact with us is only used for the purposes set out above and to view messages and administer and manage communication flows. We shall undertake not to use your personal data in any publications in a way that could identify you without your explicit consent.
Please note that we may need to contact you by post, e-mail or telephone. Please notify us of any changes to your personal data.
Most browsers allow you to reject all cookies, and some browsers only allow you to reject third party cookies. You can therefore take advantage of these options. However, please note that blocking all cookies will have a negative impact on the use of the Website and without cookies you will not be able to use all the services provided on the Website. Further information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.
We may use the types of cookies described below, but you can find a detailed and up-to-date list of the cookies we use HERE
Absolutely essential cookies.
These cookies are essential for our Website to work. The basis for the data processed by these cookies is the proper performance of the contract when you visit the Website and for us to ensure the quality and security of your visit. These may be cookies that, for example, allow you to log in and access secure areas of our Website, use the shopping cart function or e-billing services.
Analytical and/or performance cookies.
These cookies allow us to recognise and count visitors to our Website and to track how visitors move around our Website as they use it. This helps us to improve the performance of the Website, for example to ensure that users can easily find what they are looking for. The processing of data collected by these cookies is based on your consent.
These cookies are used to recognise you when you return to our Website so that we can tailor the content to your needs and remember information that is relevant to you. The processing of data collected by these cookies is based on your consent.
We use our own and third-party cookies to serve personalised advertising on our own and other websites. This is called “remarketing”, which is based on browsing actions, such as the products you have searched for and viewed.
Facebook, LinkedIn and YouTube icon plugins
This website uses the Facebook, LinkedIn and YouTube icon plug-ins and by browsing this website you agree that we can use your data on Facebook, LinkedIn and YouTube.
12. Social media
The information you provide to us via social media (including messages, the use of the “Like” and “Follow” fields, and other communications) is controlled by the operator of the social network.
Our Website provides links to our social media accounts (hereinafter – the Social Accounts). We currently administer the following social media accounts:
- Finėjas Group on Facebook;
- Finėjas Group on LinkedIn;
- Finėjas Group on YouTube.
We process the information provided in our accounts for the purpose of administering the accounts on the basis of your consent.
When you visit the Social Accounts, social network administrators place cookies on your device that collect personal data. Cookies are stored both if you are a registered user of a social network and if you do not have an account with the relevant social network. We do not have access to the personal data collected about you and can only obtain statistical information from the administrators of the social networks about the traffic of the Social Accounts.
For further information on the processing of your personal data for the purpose of managing the Social Accounts, please refer to the privacy/cookie policies of Facebook, LinkedIn and Google (for personal data processed on your YouTube account).
13. Receipt and disclosure of data
We receive your data from you, your devices, our employees and our contractors.
In addition, we may disclose information about you:
- if that is what we have to do by law;
- to defend our rights or interests (including the provision of your data to third parties for the purpose of collecting debts owed to us);
- when intending to sell the Company’s business or part of its assets by disclosing your personal data to a potential buyer of the business or part thereof;
- after selling the Company’s business or a substantial part of its assets to a third party.
14. Security of your personal data
Your personal data will be processed in accordance with the General Data Protection Regulation, the Law of the Republic of Lithuania on Legal Protection of Personal Data and other legal requirements. When processing your personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.
15. Your rights
The company will provide you with information on the action taken following your request for the exercise of your rights without undue delay, but at the latest within one (1) month of receipt of the request. Depending on the complexity of the request and the number of requests received, the aforementioned time limit may be extended for a further 2 (two) months. In this case, we will inform you within 1 (one) month of receipt of the request of such extension and the reasons for it. The company will only refuse to exercise your rights in cases provided for by law.
15.1. The right of access to your personal data
15.2. The right to withdraw consent
If you have given us your explicit consent to the processing of your data, you can withdraw it at any time.
15.3. Additional rights
Below you will find information about additional rights that you may have, which you can exercise by following the procedures described below.
(a) You have the right to ask us to correct any inaccuracies in the data we hold. In this case, we may ask you to confirm the corrected information.
(b) You have the right to ask us to delete your personal data. This right shall be exercised in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679.
(c) You have the right to ask us to restrict or not to process your personal data:
- within the period of time necessary to verify the accuracy of your personal data when you make a complaint about the accuracy of the data;
- when our collection, storage or use of your personal data is unlawful, but you choose not to request erasure;
- when we no longer need your personal data, but you need it to establish, exercise or defend a legal claim;
- the period necessary to determine whether we have an overriding legal basis to continue processing your personal data if you have exercised your right to object to the processing of personal data.
(d) You have the right to the transfer of data processed by automated means and which we have received from you with your consent or for the purpose of concluding a contract. If you exercise this right, we will transfer a copy of the data you have provided to us upon your request.
(e) You have the right to object to our use of your personal data in accordance with Article 21 of the GDPR. You have the right to object when your personal data is processed on the basis of legitimate interest (for each of the above purposes of processing, it is indicated on which basis the data is processed) or for direct marketing purposes.
15.4. The right to request more information
If you are not satisfied with the results of the investigation, you can lodge a complaint with the supervisory authority, the State Data Protection Inspectorate (www. vdai.lrv.lt).
You are responsible for maintaining the confidentiality of the data you provide to us and for ensuring that the data you provide to us is accurate, correct and complete. If there is any change in the data you have provided, you must inform us immediately by e-mail. In no event shall we be liable for any damage caused to you as a result of your providing incorrect or incomplete personal data or your failure to inform us of any change in the data.
|Cookie name||Purpose/designation of data processing||Moment of creation||Validity period|
|CMSSESSIDX||A standard cookie used to maintain a user’s session||On entering the page||Until the website window closes|
|cookiesLevelX||A cookie that distinguishes which cookies you allow to be used on our website||With consent||Until deletion|
|_ga||This cookie is used by Google Analytics to measure the user’s visit goals, to generate reports on website activity for website operators to improve the customer’s experience when visiting the website||With consent||2 years|
|_gat||This cookie is used by Google Analytics to collect statistical information about website traffic||When you first visit the page||Until the end of the session|
|_gid||This cookie is used by Google Analytics to identify a person||On first access to the page||2 days|
|Session cookies allow you to be recognised during a single visit to our website so that any changes or options you make to a page are remembered as you move from one page to another. These cookies allow you to quickly and easily navigate through many pages on the site, so that you don’t have to re-process information each time you visit a new location. Session cookies are temporary and are deleted as soon as you close your browser or log out of the website.|
|Long-term cookies are cookies that remain on your computer for a set period of time after the end of your browsing session and may therefore record certain user preferences or actions when the website is revisited.|
|First party cookies|
|These are cookies that are necessary for the proper functioning of UAB FINĖJAS website.|
|Third party cookies|
|These are cookies used by other organisations through our website. Our UAB FINĖJAS website uses Google Analytics cookies to analyse website traffic. Google Analytics collects information anonymously about the number of visitors, the location from which our website was used and which parts of the website were browsed by visitors. These cookies are created for Google Analytics. For more information about Google Analytics, please visit http://www.google.com/analytics.|