AB “Dolomitas” (hereinafter referred to as the “Company”
) understands that Personal data protection issues are very important to you – our customers and other data subjects (hereinafter referred to as the “Data Subjects”
) – and undertakes to respect and protect the privacy of every data subject and process Personal data pursuant to the requirements provided in the applicable legislation.
- General Provisions
) regulates the processing of Personal data by the Company acting as the Data controller carried out whether or not by automated means.
This Policy is intended for persons who use or intend to start using Company services, purchase or intend to purchase Company goods and/or products, or visit the Company website https://www.dolomitas.lt/
“Personal data” means any information relating to an identified or identifiable natural person (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
In order to be able to fulfil our obligations to you as our customer, we need to obtain some of your Personal data.
The main categories of Personal data processed by the Company are as follows (the list is non-exhaustive):
- the main information identifying you as a customer (name, surname, personal number, address, e-mail address, telephone number);
- data required to obtain permits to access a military installation (name, surname, personal number, information about the vehicle);
- data of concluded agreements;
- financial data (account number, etc.);
- communication and customer service information (information about correspondence with the Company, etc.) (hereinafter collectively referred to as the “Personal data”).
The Company will only collect and further process your Personal data when and limited to what is necessary in relation to the purposes for which they are processed.
First, we use Personal data of our customers in order to place orders for goods/services and perform actions with respect to this, i.e.:
- in order to identify you;
- for the purpose of conclusion, amendment, administration, and performance of agreements;
- to obtain permits to access a military installation.
In addition, we collect and further process your Personal data for direct marketing purposes (upon obtaining a separate consent from you) and other legitimate purposes.
- Legal Basis
The Company carries out the processing of Personal data pursuant to the provisions of Regulation (EC) 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 (General Data Protection Regulation) (hereinafter referred to as the “Regulation (EC) 2016/679”
), the Republic of Lithuania Law on Legal Protection of Personal Data, the Republic of Lithuania Law on Electronic Communications, and other legislation regulating the protection and processing of Personal data, as well as the instructions of data protection supervisory authorities.
Normally, the legal basis for the processing of Personal data is an agreement concluded with the Company (or a request to conclude an agreement). Personal data may also be processed based on consent (for example, for direct marketing purposes) and when the Company is obligated to process Personal data by the respective legislation (for example, to obtain permits to access a military installation), as well as in cases when we need to process Personal data for the legitimate interests of the Company (except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal data). The consent shall be freely given, specific and unambiguous, and properly indicating the specific purpose(s) of Personal data processing.
The Company, inter alia
, adheres to the following basic principles for data processing:
- Personal data are processed lawfully, fairly and in a transparent manner;
- Personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- Personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Personal data are accurate and, where necessary, kept up to date;
- Personal data are stored for no longer than is necessary for the purposes for which the personal data are processed, or than is requested by the Data Subject, and/or provided by the legislation;
- Personal data are processed in a safe manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
- Personal data are processed only by the Company employees who have been granted such rights in accordance with their work functions or data processors under the agreement concluded with them.
Company customer or potential customer shall be responsible for ensuring that the data submitted by him/her to the Company are accurate, correct, and complete. If the Personal data submitted by him/her change, he/she shall promptly advise the Company thereof. The Company shall not take any responsibility for the damage to a person and/or third parties due to the fact that a customer or potential customer has provided incorrect, inaccurate and/or incomplete Personal data or has not contacted us to supplement and/or amend the data when they have changed.
- Collection of Personal data
Normally, the Company obtains Personal data from customers themselves.
- Provision of Personal data
The Company adheres to the confidentiality obligation with regard to the data of customers or potential customers. Personal data may be disclosed to third parties if this is required in order to conclude or perform an agreement, or due to other legitimate reasons. Information may also be provided to other parties on your request or pursuant to your contractual obligations to other parties, e.g., banks or other financial institutions.
We can provide your Personal data to Data processors who provide services (works) to us and process your Personal data on behalf of the data controller, having concluded a prior agreement with them.
Data processors have a right to process Personal data only in accordance with our instructions and only to the extent necessary for the duly implementation of obligations established in the agreement. The Company shall engage only such Data processors who sufficiently ensure that appropriate technical and organisational measures are implemented in such a way that data processing complies with the requirements of Regulation (EC) 2016/679 and the protection of the rights of Data Subject is ensured. The categories of Data processors are as follows (the list is non-exhaustive):
- information technology companies processing Personal data in order to ensure the development, improvement and maintenance of information systems;
- companies providing technology and system maintenance;
- companies providing accounting services to the Company;
- companies processing Personal data to provide the services of document scanning and administration and storage of archive documents (archives) to the Company;
- companies providing legal (including debt recovery) services to the Company.
The Company can also provide customer data in response to the requests of court, law-enforcement, or state authorities to the extent necessary in order to properly adhere to the applicable legislation and instruction of state authorities, also to companies which activities are related to debt recovery, and other data recipients based on the Data Subject's consent or request.
- Personal data Storage Terms
The Company for stores Personal data no longer than is necessary for the purposes for which the Personal data are processed, or requested by the Data Subjects, and/or provided by the legislation.
Personal data collected by us for the purposes of conclusion, amendment, administration, or performance of agreements are stored in printed documents and our information systems. Normally, Personal data are processed for these purposes for 10 (ten) years as of the expiry of contractual relations. In our practice, Personal data are stored as long as reasonable claims may arise out of contractual relations. Personal data that is not required any longer are destroyed.
Despite the fact that you can terminate the agreement and refuse our services, we will have to continue storing your Personal data until the expiry of data storage terms due to possible claims that could arise in the future.
The information is also stored so that if required, we are able to provide you with the requested information, have appropriate history of customer and Company relations, and can answer all questions related to your cooperation with us.
- Ensuring the Security of Personal data
It is very important to us to ensure the security of your Personal data. Personal data were processed and will be processed by the Company in a safe manner that ensures appropriate security of the Personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- Rights of Data Subjects
You have the following rights of Data Subjects.
|Right to access the Personal data
||You can contact us with a request to:
(a) confirm that we process your Personal data;
(b) provide you with a copy of these data;
(c) provide information on your Personal data that are being processed, for example, what Personal data belonging to you we collect, to what purpose we process them, to whom and for what purpose we provide and disclose them, whether we transfer these data outside the European Union, what security measures we apply to them, and other information on your Personal data.
|Right to rectification
||If having accessed your Personal data you establish that your Personal data are incorrect, incomplete or inaccurate and contact us, we will check your Personal data and, on your request, rectify inaccurate data and/or supplement incomplete Personal data.
|Right to erasure (“right to be forgotten”)
||You can contact us with a request to erase your Personal data in the following cases:
(a) when they are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) when you have withdrawn your consent (where your Personal data were processed based on the consent);
(c) when you exercised the right to object to the processing of Personal data concerning you;
(d) when you believe that your Personal data are processed illegitimately, etc.
We are not obliged to satisfy your request to erase your Personal data if the processing of your Personal data is necessary in order to fulfil a legal obligation provided in the legislation of the European Union or the Republic of Lithuania or in order to establish, exercise or defend legal claims.
|Right to the restriction of processing of your Personal data
||You can contact us with a request to restrict the processing of your Personal data, except for storage, if one of the following applies:
(a) you contest the accuracy of the Personal data for a period enabling us to verify the accuracy of the Personal data;
(b) the processing of your Personal data is unlawful and you oppose the erasure of your Personal data and request the restriction of their use instead;
(c) the data are no longer necessary in relation to the purposes for which they were collected, but they are required by the Data Subject for the establishment, exercise or defence of legal claims;
(d) you have objected to processing pending the verification whether our legitimate grounds override your legitimate grounds.
It is possible that due to the restriction of processing of Personal data and during the period of such restriction we will not be able to ensure the provision of services to you.
|Right to portability of your Personal data
||You can contact us with a request to receive Personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format, also you can submit a request for us to transmit your Personal data to another controller to the extent this is technically possible and when:
(a) the processing of your Personal data is based on your consent or performance of an agreement concluded with you; and
(b) the processing of your Personal data is carried out by automated means.
|Right to object
||You can contact us at any time and withdraw the consent to process Personal data concerning you due to reasons related to your particular case easily and free of charge when such data processing is carried out with your consent or may be necessary for the purposes of the legitimate interests pursued by us.
The withdrawal of consent shall not affect the lawfulness of processing of your Personal data based on consent before its withdrawal.
Nevertheless, in consideration of purposes of provision of our services and the balance of legitimate interests (both your as the Data Subject and our as the data controller), your objection may mean that upon the termination of processing of your Personal data based on our legitimate interest we will not be able to continue providing our services to you.
|Right to lodge a complaint regarding the processing of Personal data
||If you believe that we process your Personal data in breach of Regulation (EC) 2016/679 and/or other legislation regulating the processing of Personal data, we ask you to always contact us at first.
If you are not satisfied with the problem solution offered by us or, in your opinion, we have not taken actions that are necessary based on your request, you have a right to lodge a complaint with the State Data Protection Inspectorate or to bring a court action.
- Direct Marketing
Your Personal data may be processed for the purposes of direct marketing based on your consent or objection to the processing of Personal data for the purposes of direct marketing.
You have a right to object to the processing of Personal data concerning you for the purposes of such direct marketing at any time.
The Company shall stop processing the Personal data of the Data Subject for the purposes of direct marketing (destroy them without delay) as soon as the Data Subject objects to the processing of data for such purpose.
Your objection to receive offers and news will not prevent you from using our services; however, this will mean that we will not be able to provide useful offers to you. You can inform us about your objection or withdrawal of your consent via e-mail firstname.lastname@example.org or by phone +370 421 42683.
The Company shall process your Personal data for the purposes of direct marketing for 5 (five) years as of the moment of your consent, unless you withdraw your consent.
Cookies recording website traffic statistics are as follows:
||Term of validity
||2 (two) years
||24 (twenty four) hours
||1 (one) minute