____________________________________________________

UAB VILNIAUS DEGTINĖ

PRIVACY POLICY

__________________________________________________________________________

1.Who is this Privacy Policy for?

This Privacy Policy (hereinafter – the Privacy Policy) is intended to inform data subjects about the processing of personal data carried out by UAB VILNIAUS DEGTINĖ. In the Privacy Policy, we provide our clients, suppliers, and other partners, as well as related individuals, candidates, correspondence counterparts, and other data subjects specified in the Privacy Policy with information on how we process your personal data. Hereinafter, any individual whose personal data we process is referred to as the Data Subject in this Privacy Policy.

2. About the Company

The Company means UAB VILNIAUS DEGTINĖ, legal entity code 120057287, registered office at Panerių g. 47, LT-03160 Vilnius, Republic of Lithuania. Our contact email address for personal data protection issues is dpo@mbws.com.

3. What is personal data?

Personal data shall mean any information collected by the Company about the Data Subject that can be used to identify the Data Subject and which is stored electronically or otherwise.

Personal Data shall include any information, including the name and address of the Data Subject, collected by the Company about the Data Subjects for the purposes specified in this Privacy Policy or in the separate consent of the Data Subject or agreement with the Company.

This data also includes personal information in the public domain that the Company can access when you contact the Company via social media or through active actions on the Company’s social media accounts.

In processing personal data, the Company is guided by Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 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 (the ‘General Data Protection Regulation’ (the ‘GDPR’)), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, as well as by the other legal acts regulating personal data protection.

Below you can learn how we process your personal data: what personal data we process, the purpose of the processing, how long we retain it, and what are your rights.

4. Processing of Personal Data Arising from the Performance of Contracts with Clients and Suppliers

5. Selection of candidates

We collect and process the following personal data: your workplace, email address, date of birth, address, education, last name, telephone number, first name, preferred job, date of receipt of your CV, information about your personal qualities, your work experience (last workplace, length of employment with the workplace, your last job title, other work experience), information on your knowledge of foreign languages (language, reading, writing, speaking levels), your ability to work with computer programmes, and any other information contained in your CV, letter of recommendation and/or cover letter, your preferred salary, for the purpose of the selection process, on the basis of your consent, which you express to the Company by sending your CV and/or cover letter. If you do not produce your CV and/or letter of motivation, we will not be able to assess your suitability for the position offered.

With your consent, we will contact your current employer, and your former employer on the basis of our legitimate interest (to select a suitable candidate) and on the basis of Article 5(2) of the Law on the Legal Protection of Personal Data of the Republic of Lithuania, for the purpose of verifying information about your qualifications, professional abilities and business qualities (such as your performance at work, your relations with your clients and/or colleagues, the evaluation of your work, etc.). You may withdraw your consent or, if applicable, object to us contacting your former employer at any time by notifying us at the email address set out in Section 2 of the Policy.

In the event that you do not express your explicit consent to the processing of your personal data for a longer period of time at the end of a specific job selection, we undertake to delete and/or destroy your personal data within 3 working days after the signing of the contract with the successful candidate or the adoption of the decision to terminate the selection process. If you are not selected but have given your consent to the processing of your personal data for the purpose of offering you a job in the future, we will keep the data for 1 year from the end of the selection process on the basis of your consent.

On the basis of our legitimate interest, we will process data about the person (name, email, telephone number, information provided by the person) indicated by the candidate – a former or current employer or a person providing a recommendation, and the information provided by him/her – for the purpose of selecting a candidate. In this case, it is in our legitimate interest to select the right candidate for our position. We will delete this data within 3 days after the signature of the contract with the successful candidate or the decision to end the selection.

6. Video surveillance

In order to protect the safety of clients, visitors, employees, and other individuals within the surveillance area, as well as to safeguard their and the Company’s property, collect evidence of violations, and defend its rights, the Company conducts video surveillance. Video surveillance is conducted on the basis of the legitimate interest of these individuals and the Company. In conducting video surveillance, the Company processes the following personal data: image, movement trajectory, and belongings of individuals. Recorded video data is stored for 3 to 6 months, depending on the specific area of the Company you visited (all monitored areas of the Company are marked with informational signs). More detailed information will be provided upon contacting the email address specified in Section 2 of the Privacy Policy.

7. Protecting confidential information of the Company and business continuity

In order to protect its legitimate interest in ensuring the security of the Company’s confidential information and the continuity of its operations, the Company may review its employees’ correspondence with counterparties. For these purposes, the Company processes the following personal data of its employees and of persons who send or receive emails from its employees: the email address, the name of the sender or recipient, the date, and the content of the information contained on the electronic devices. Such data is stored for 4 years.

8. Protection of legitimate interests

The Company, on the basis of its legitimate interest in defending its rights, including in the event of civil disputes, shall process the names, surnames, personal identification numbers, circumstances of the case, other information related to the case and publicly available information. The data may be transferred to law enforcement authorities, lawyers or bailiffs carrying out the recovery. The data shall be destroyed 1 year after the final settlement of the case and full satisfaction of the Company’s claims (if the claims are satisfied).

9. Archiving

Contracts for goods, works, and services, as well as acceptance certificates for goods, works, and services, are stored for archiving purposes (10 years from the contract’s expiration) after they are no longer needed for their original purpose (generally, contract conclusion and performance). We process personal data for this purpose in compliance with a legal obligation (Article 6(1)(c) of the GDPR), as established in point 10.37 of the General Document Retention Period Index, approved by the Chief Archivist of the Republic of Lithuania by Order No. V-100 on March 9, 2011. The retention periods for other personal data for archiving purposes are specified under the respective personal data processing purpose.

10. Contact us

There are several ways you can contact the Company: by phone, email, social media accounts, the contact form on the website or by sending a letter to the Company’s registered office address. We receive, review and respond to all reports ourselves. If you contact us, we may process the data you provide to us, i.e. email address, name (if provided), username (if the request is sent via a social networking account), workplace (if provided), the date and time of sent and received messages, the recipient, the sender (in the case a message is addressed to you), and the content.

Such data shall be processed in order to answer your questions and examine your suggestions. Unless you provide your contact details, we shall be unable to contact you.

Correspondence is retained for 1 years from the date of receipt of the message, except for information for which there are other terms set out in the Privacy Policy or legislation.

All personal data you provide in the course of cooperation, are used for the purposes above, in order to review messages, and to administer and manage communication flows. We agree we shall never use your personal data in any publications that would allow for your identification, except where you expressly grant your consent.

Please note that we may need to contact you by mail, e-mail or telephone. Please notify us of any changes to your personal data.

11. Cookies and other tracking technologies

Our website uses cookies and other tracking technologies. A cookie is a small file made up of letters and numbers that we place on your browser or on the hard drive of your computer with your consent. We use different cookies for different purposes. Cookies also help us to distinguish you from other users of the website, thus ensuring a more pleasant experience and enabling us to improve the website.

Most browsers allow you to reject all cookies, and some browsers allow you to reject only third party cookies. Therefore, you can take advantage of these opportunities. 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. For more information, visit AllAboutCookies.org or www.google.com/privacy_ads.html.

We may use the types of cookies described below, but for a detailed and up-to-date list of cookies used on this website, please see the Annex below.

Strictly necessary cookies.                     

These cookies are essential for our website to work. The basis for the use of such cookies is Article 73(4) of the Republic of Lithuania Law on Electronic Communications. These cookies are essential for the operation of the website and cannot be disabled on our systems. They are usually used in response to what you do on the website, such as starting to browse or choosing your privacy settings. These cookies do not store any personally identifiable information about you and are deleted as soon as you turn off the website.

Analytical and/or performance cookies.

These cookies allow us to count the number of visits to the website and to monitor the flow of visitors to the website so that we can improve the performance of the website. They allow us to know which pages of the website are the most or least visited and to monitor how visitors navigate the site. The data collected is not accessible to any other party. The information collected by cookies is anonymous and is not intended to identify you or influence your browsing experience while you are on the website. If you do not accept the use of these cookies, you will not be included in the visitor statistics. The processing of data collected by these cookies is based on your consent.

Commercial cookies.

These cookies are used by us and by third parties to display offers or other promotional information that may be of interest to you. We use cookies to collect data about your browsing history and to identify your areas of interest so that we can show you relevant marketing information. The processing of data collected by these cookies is based on your consent.

12. Managing your social media accounts

The information you provide us on social media (including notifications, use of the Like and Follow fields, and other communications) shall be controlled by the social network manager.

We currently have the following account on the Vilniaus degtinė social network LinkedIn.

We process the information contained in social account for the purpose of administering it on the basis of your consent. We do not separately store information contained in Social Account (where the data is processed for the purpose of administering the Social Account, but the data may be stored if it needs to be processed for another purpose, such as the protection of rights).

When you visit Social Account, social network administrator add cookies to your device that collect personal data. Cookies are stored both if you are a registered user of a social network or if you do not have an account with that social network. We do not have access to the personal data about you and can only obtain statistical information from the administrator of the social network about the usage of Social Account.

We recommend you to read the privacy notices of third parties and to directly contact the service providers if you have any doubts on the way they use your personal data.

13. Data acquisition and disclosure

We receive your data from you, your employers, your contractors or generate it from software.

Certain personal data may be transferred to our authorized data processors, such as companies providing IT or cloud services (e.g., if we rent servers from an IT Company, your personal data will be physically hosted (stored) by that IT Company), archiving service providers, and similar entities. We require our data processors to ensure appropriate protection of your data and guarantee that your personal data is processed by them only to the extent that we instruct and solely for the specified purposes.

Personal data may also be transferred to data recipients who act as data controllers (independently or jointly with us). For example, to lawyers, social media platform operators, banks, etc. Most categories of data recipients are specified in the information regarding specific data processing purposes.

If you have any questions regarding our service providers, please contact us at the email address specified in the Privacy Policy.

In addition to the specific categories of data recipients mentioned in this Privacy Policy, we may also disclose information about you:

• if we are required to do so by law (e.g., upon receiving a court order or a request from a law enforcement authority);
• intending to sell a part of the Company’s activity or its assets, disclosing your personal data to a potential buyer of the activity or part thereof;
• after the sale of the Company’s activities or a substantial part of its assets to third parties.
• When it is necessary to protect our rights and legitimate interests.

Except as provided in this Privacy Policy, we do not provide your personal data to any third parties.

14. Security of your personal data

Your personal data will be processed in compliance with the General Data Protection Regulation, the Law on Legal Protection of the Personal Data of the Republic of Lithuania, and other regulations. By managing your personal data, we implement organizational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, modification, disclosure, and any other unlawful processing.

15. Your rights

In this section, we provide information about your rights in relation to our processing of your personal data and when you can exercise these rights. If you would like further information about your rights or you want to exercise them, please contact us at the e-mail address provided in this Privacy Policy:

The Company will unreasonably immediately, but not later than within 1 (one) month from the receipt of the request, provide you with information on the actions taken upon receipt of your request for the exercise of your rights. Depending on the complexity of the application and the number of applications received, the said term may be extended for another 2 (two) months. In such a case, we shall inform you within 1 (one) month from the receipt of the request about such extension and the reasons for it. The Company shall refuse to exercise your rights only in cases provided by law.

16. Right to access your personal data

It is our intention that you fully understand the way we use your personal data, and you suffer no inconvenience as a result. You may contact us at any time to enquire whether we process any of your personal data. If we store or use your personal data in any way, you have the right to access it. In order to do so, submit a written request to us at the e-mail address provided in this Privacy Policy, verify your identity; and in making such a request, adhere to the principles of fairness and reasonableness.

16.1. Right to withdraw your consent

If you have granted us explicit consent to process your data, you can withdraw it at any time. Withdrawal of the consent shall not affect the lawfulness of the data processing carried out prior to the withdrawal of the consent.

16.2.  Additional rights

Below you will find information about additional rights that you may have, which you can exercise by following the procedures described therein.

a) You have the right to ask us to correct any inaccuracies in the data we collect. In such a case, we may ask you to confirm the corrected information.

b) You may request deletion of your personal data. This right shall be exercised in the cases provided for in Article 17 of General Data Protection Regulation (EU) 2016/679.

c) You have the right to ask us to restrict or not process the processing of your personal data:

• in the period we need to make sure that your personal data is exact, should you file a claim concerning precision of such data;
• when collection, storage or use of your personal data is unlawful, but you choose not to request deletion;
• when we no longer need your personal data, but you need it to establish, exercise or defend a legal claim;
• during the period necessary to determine whether we have any overriding legal basis to continue processing your personal data if you have exercised your right to object to the processing of your personal data.
• You have the right to the transfer of data processed by automatic measures and which we have received from you in a structured, commonly used and computer-readable format with your consent or for the purpose of concluding a contract. If you exercise this right, we will transfer a copy of your data to you or to a data controller of your choice upon your request.

d) You have the right to object to the use of your personal data by us in accordance with Article 21 of the GDPR.

e) You have the right to object when your personal data is processed on the basis of a legitimate interest (for each of the abovementioned purposes of processing, the basis on which the data is processed is indicated) or for the purpose of direct marketing.

16.3.  Right to seek additional information

We hope you will understand that it is very difficult to discuss all possible ways of collecting and using personal data. We endeavour to provide as clear and complete information as possible and we undertake to update this Privacy Policy as and when we change the way we use personal data. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or do not understand the information provided, please contact us.

17. Complaints

If you believe that your rights as a data subject have been and/or may be violated, please contact us immediately at the email address provided in this Privacy Policy. We ensure that as soon as we receive your complaint, we will contact you within a reasonable period of time to inform you of the progress of the investigation and the outcome.

If you are not satisfied with the results of the investigation, you can file a complaint with the supervisory authority, the State Data Protection Inspectorate: https://vdai.lrv.lt/.

18. Liability

You are responsible for the confidentiality of the information you provide and for ensuring that the information you provide to us is accurate, correct and complete. If the data provided by you changes, you must notify us thereof immediately by e-mail. In no event shall we be liable for any damage caused to you as a result of your provision of incorrect or incomplete personal data or your failure to inform us of any change in such data.

19. Changes to Privacy Policy

We may update or amend this Privacy Policy at any time. If you wish to receive an updated Privacy Policy, please notify us at the e-mail address provided in Section 2.

Last version: 25-02-2025

Text in the cookie window:

This website uses cookies. You can express your preference for the acceptance of cookies by selecting one of the following options. Please read our Privacy Policy and the information contained therein before choosing. If you choose ‘Accept All’, you agree to the use of all types of cookies, including marketing cookies. You can change your choice at any time. Your consent is not required for the acceptance of essential cookies, but in this case you have the right to reject their use. For more information about cookies and your rights, please see our Privacy Policy.

Comment: possible cookie bar options (all must be the same colour, same design, there must be no incentive to choose any of the options):

Comment: if you select ‘More options’, a window (table) should open allowing you to express your preference for different types of cookies and to confirm your choice by clicking the ‘Confirm your choice’ button: