This Privacy Policy (hereinafter referred to as the “Privacy Policy”) establishes the Privacy Policy of UAB “Saudingos autotransportas” (legal entity code 141776948, address Metalistų g. 6B, LT78107 Šiauliai, tel.:+37041502777, e-mail address info@saudingos.lt) (hereinafter referred to as “the Company”, “we”), which operates a website www.saudingos.lt (hereinafter referred to as the “Website”) of visitors and other natural persons (hereinafter referred to as the “Data Subjects”, “You”), the conditions for the processing of Personal Data, as well as the procedure for the exercise of the rights of the Data Subject.
We may revise and amend this Privacy Policy to ensure that it complies with the requirements of the law and to provide you with up-to-date information about how we process your Personal Data, so we recommend that you periodically check to make sure that you are familiar with the current version of this Privacy Policy.
1. DATA COLLECTION
The Company collects your Personal Data:
1.1 provided by you (directly from the Data Subject), e.g. when you interact or have a legal relationship with our Company, such as purchasing services and/or goods or contacting us for information, employment etc;
1.2 that are generated when you use our services, for example, when you use our services (visit our website, order and pay for our services, etc.);
1.3 which we obtain from other sources, for example, if justified, from other institutions or companies (the State Social Insurance Fund Board under the Ministry of Social Security and Labour of the Republic of Lithuania (for records of incapacity for work), the Migration Department under the Ministry of the Interior of the Republic of Lithuania (for issuing visas or residence permits in Lithuania), publicly available registers etc.
2. PERSONAL DATA PROCESSED
Depending on who you are (customer, employee, job applicant, supplier, etc.) and how you communicate with the Company (in person, online, over the phone, etc.), the Company may process different types of your Personal Data. The Company collects and processes the following categories of Personal Data:
Categories of personal data | Personal data |
Personal identification and contact details | Name, surname, personal identification number, date of birth, identity document details (ID card, passport), etc. El. postal address, telephone number, actual and declared place of residence (address), country. |
Data obtained and/or generated in compliance with legal requirements | Data obtained in response to requests from law enforcement authorities, courts and bailiffs, or in the context of training provided for in legislation on occupational safety and health, or data required to be submitted to the Migration Department under the Ministry of the Interior of the Republic of Lithuania for the recruitment of foreign nationals (e.g. gender, nationality, place of birth, etc.). |
Financial data | Account data (e.g. bank, bank account number, owner’s name), the amount and date of payment of salaries calculated and paid, the amount of income tax and compulsory social security or other benefits to Data Subjects, and other Personal Data processed for the purposes of contract processing, settlements or purchases from natural persons. |
Data collected by electronic, communication and other technical means | Data collected when Data Subjects arrive at the Company or use the Company’s information resources or visit the Company’s Website, such as unique device identifiers, Internet Protocol (IP) address, the actual location of the Data Subject who drives a long-distance vehicle belonging to the Company as determined by the IP address or other location technologies, travel routes, stopping places and parking times, driver’s work mode, etc. |
Personal data of employees, representatives or contacts of business partners (suppliers, customers, etc.) or potential business partners | Name, surname, email. postal address, telephone number, title, signature, number of the customer’s natural person’s business certificate or individual activity certificate, dates of issue and expiry, VAT number (if VAT registered), etc. |
Special categories of Personal Data | Data relating to the Data Subject’s health and/or legal offences. In certain cases, in order to provide the Company with health services, to prevent accidents at work, to carry out incident investigations or otherwise to ensure the implementation of legal requirements, the Company is required to process special categories of Personal Data (e.g., periodic breathalyzer tests for long-distance drivers, etc.). |
Details of close persons | Information about the Data Subject’s family and other related persons, where the Company is required to comply with the provisions of laws granting social and other benefits to the Data Subject or, to the extent necessary, for the purpose of notifying the occurrence of an accident at work. |
Data relating to occupation and qualifications | Details of education and professional activities. |
Any other information that you choose to share freely with the Company | Feedback, opinions, comments, evaluations, the content of communications, information provided in documents you submit to the Company, when applying for services, employment, disputes and other topics. |
3. LEGAL BASES AND PURPOSES OF DATA PROCESSING
The Company collects and processes your Personal Data only for lawful purposes for the performance of its activities. Below you will find a list of the purposes for which the Company may use your Personal Data:
3.1 Consent. The Company shall, in certain cases, request the consent of Data Subjects to process their Personal Data. The Company processes Personal Data of Data Subjects for the purpose of applying for employment and for the use of images (photographs) of individuals captured during events. Data subjects may withdraw their consent at any time.
3.2 Enforcement of legal obligations. In order to ensure compliance with the legal obligations applicable to the Company, the Company is obliged to process Personal Data in accordance with the requirements of the applicable legislation. Such processing includes the following purposes:
3.2. comply with the requirements of laws and other legal acts relating to record-keeping and the provision of information to public authorities;
3.2.2 ensuring a safe and healthy working environment and occupational health requirements;
3.2.3 to comply with legal requirements to enable the Data Subject to exercise special rights in the field of employment and social security law;
3.2.4 to comply with the requirements of other legal acts applicable to the Company’s activities, as well as with the requirements of court orders and bailiffs’ orders.
3.3 Performance of the Contract. The main purpose of the Company’s processing of Personal Data is to enter into, perform and administer contracts with employees and other Data Subjects. This processing of Personal Data includes processing for the following purposes:
3.3.1 Establishing and enforcing employment and traineeship contracts and providing work equipment;
3.3.2 the selection of a staff candidate with a view to concluding a contract of employment;
3.3.3 selection of a candidate for employment who is not a citizen of Lithuania for the purpose of concluding an employment contract, and for this purpose the processing of the candidate’s Personal Data for the purpose of obtaining a work visa and/or residence permit in Lithuania;
3.3.4 calculation, payment, transfer and transmission of salaries, bonuses, allowances, allowances, gratuities and other benefits to public authorities, as well as bookkeeping (not related to the employment relationship).
3.4 Protecting the vital interests of the data subject or another natural person. On this basis, the Company may process Personal Data where it is necessary to provide first medical aid in cases where the Data Subject is unable to give his or her own consent for physical or legal reasons.
3.5 Legitimate interest. The Company processes the Personal Data of natural persons for legitimate interest purposes. Such processing is necessary where the legitimate interest of the Company, in the Company’s assessment, outweighs the interest of the natural person in relation to his or her right to privacy. Such processing includes the following purposes:
3.5.1 protect the legitimate interests of the Company’s customers, the Company itself and/or the Company’s employees by implementing appropriate security measures;
3.5.2 maintain relationships and communication with clients and business partners;
3.5.3 to ensure proper management and administration of the Company’s infrastructure, assets and information resources;
3.5.4 to ensure the quality of the Company’s services, the protection of information related to the provision of services to the Client, as well as to improve, develop and maintain the software, technical and information technology tool systems;
3.5.5 to bring, pursue and defend legal claims, to answer and settle claims or disputes.
If the Company asks you to provide your Personal Data but you choose not to provide it, in some cases the Company may not be able to provide services, sign a contract with you or otherwise communicate with you.
For detailed information about your rights, please refer to the Privacy Policy under “Data Subject Rights”.
4. DATA RECIPIENTS AND OTHER DATA PROCESSORS
We may only provide your Personal Data in strict compliance with the requirements for the protection of personal data, only in justified cases and only to recipients who undertake to adequately protect them:
4.1 to companies of the UAB AVERTO LT group of companies, where this is necessary for internal administrative purposes and only to the extent permitted under the legislation governing the protection of personal data.
4.2 To processors (subcontractors) and/or companies that provide services to us (carry out work) and process your Personal Data on behalf of the Company as the data controller. Processors shall have the right to process Personal Data only in accordance with the Company’s instructions and only to the extent necessary for the proper performance of their obligations under the contract concluded with the Company. The data processors we use operate in the following main areas: contractors providing electronic communications and website maintenance services, information technology service providers providing information systems maintenance and other services to the Company, etc.
4.3 Legal, insurance, auditing and other professional service providers, bailiffs executing court orders, etc.
4.4 State and municipal authorities and other persons performing functions assigned to them by law. The Company may transfer the processed Personal Data to state authorities investigating criminal offences and incidents (e.g. the Police, the State Labour Inspectorate, etc.), other state authorities (e.g. the Internal Revenue Service, the State Tax Inspectorate, the Social Security Agency, the Migration Department), in the cases provided for by law. We transfer your Personal Data to state and municipal authorities and to other persons performing functions entrusted to them by law upon their request or in order to assert, exercise or defend legal claims in the Company’s legitimate interest.
Data recipients may be established outside the Republic of Lithuania, the European Union (EU) or the European Economic Area (EEA). If the Company transfers your Personal Data to such recipients, we will take all necessary measures provided for by law to ensure that your Personal Data and your right to privacy continue to be properly protected.
5. ENSURING DATA SECURITY AND CONFIDENTIALITY
In order to protect your Personal Data, the Company has responsibly implemented organisational and technical data security measures to protect Personal Data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.
The security measures implemented by the company also include the protection of personnel, information, IT infrastructure, internal and public networks, as well as office buildings and technical installations, compliance with fire safety rules and the implementation of other technical measures necessary to ensure data protection.
6. DATA RETENTION PERIODS
6.1 Personal data processed by the Company shall be stored in accordance with the “Index of General Document Retention Periods” (Order of the Chief Archivist of Lithuania No.V-100 of 9 March 2011) and/or the periods approved by the Company’s Manager. The Company applies different retention periods for Personal Data depending on the purpose for which the Personal Data is processed, where it is possible to specify such retention and/or deletion period.
6.2 Data may also be retained for longer than necessary to assert, exercise and defend legal claims or the Company’s legitimate interest, as well as to comply with applicable data protection laws, provided that this does not infringe the rights of the Data Subjects, is in accordance with the legal requirements, and the retention is properly documented.
6.3 Upon expiry of the retention period or if the lawful basis for the retention of the Personal Data ceases to exist, the Personal Data shall be destroyed immediately. Data stored in electronic form is destroyed by erasure without possibility of recovery, paper documents containing data are shredded and the residue is disposed of in a secure manner.
7. SELECTION OF CANDIDATES FOR EMPLOYMENT
When the Data Subject participates in the Company’s recruitment process for vacancies, the Company processes the data in accordance with the “Policy on the Processing of Personal Data of Candidates for Employees”, which is published in the PROCESSING POLICY
8. RIGHTS OF DATA SUBJECTS
8.1 As a Data Subject, you have the right to:
8.1.1 know (be informed) about the processing of your Personal Data;
8.1.2 have access to the processing of their Personal Data;
8.1.3 request the rectification of your Personal Data;
8.1.4 to request the erasure of his or her Personal Data (“right to be forgotten”), if this can be justified on one of the grounds set out in Article 17 of GDPR. 1 d.;
8.1.5 restrict the processing of your Personal Data;
8.1.6 to request the restriction of the processing of your Personal Data in one of the cases provided for in Article 18(1) of the GDPR;
8.1.7 to object to the processing of your Personal Data if it is processed on the basis of legitimate interest.
8.1.8 withdraw your consents given to the Company at any time;
8.1.9 If you believe that the processing of your Personal Data by the Company violates the data protection legislation, you have the right to lodge a complaint with the State Data Protection Inspectorate at the following address: L. Sapiegos g. 17, LT10312, Vilnius, by email to ada@ada.lt or by other means published on the website of the State Data Protection Inspectorate, but you are always welcome to raise your concerns with the Company first so that we can answer your questions.
8.2 The rights of data subjects shall be provided free of charge. Where your requests are manifestly unfounded or disproportionate, in particular due to unreasonable repetition, the Company may charge a reasonable fee, taking into account the administrative costs of providing the information or the notifications and/or actions requested, or it may refuse to act on the request on the basis of reasons.
8.3 Data Subjects may submit requests to the Company regarding the exercise of any Data Subject right in several ways – directly to the Company, by post or by e-mail. means of communication. When making requests, Data Subjects are required to verify their identity in the following ways: 1) by submitting the request directly to an employee of the Company – by providing proof of identity; 2) when submitting the application by post, a copy of the identity document, certified in accordance with the procedure established by the legislation; 3) by submitting an email. by means of communication, by signing it with a qualified electronic signature or by forming it by electronic means which ensure the integrity and unalterability of the text.
9. CONTACT
If you have any questions or wish to exercise your rights, please contact us at the email address of the Data Protection Officer. email duomenuapsauga@saudingos.lt or visit us at our head office at Metalistų g. 6B, LT78107 Šiauliai, Lithuania.
Contact details for the Data Protection Officer: +370 620 63563; email. E-mail: duomenuapsauga@saudingos.lt