Panevezio statybos trestas AB (hereinafter ‘PST’, ‘the Company’) realizes that protection of personal data is important to our customers, suppliers, partners, employees and other persons (hereinafter ‘the Data Subjects’) whose data is processed by the Company. In view of this, we take all necessary measures to ensure that personal data of the Data Subjects are protected in our activities.
· Regulation (EU) 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;
· Law of the Republic of Lithuania on Legal Protection of Personal Data No. XIII-1426 of 30 June 2018;
· Law of the Republic of Lithuania on Electronic Communications No. IX-2135 of 15 April 2004;
· Guidelines of the State Data Protection Inspectorate.
The data controller determining the purposes and means for processing of personal data is Panevezio statybos trestas AB, legal entity code 147732969, address P. Puzino Str. 1, Panevezys, Lithuania, telephone (+370 45) 505 503, e-mail email@example.com.
Obtaining your personal data
The Company obtains your personal data:
· directly from you (e. g. for contract conclusion, making requests, writing e-mails to the Company, where you provide your personal data to the Company);
· from public data bases and information systems (e. g. Register of Legal Entities, Real Property Register, Credit info, etc.);
· performing video surveillance;
· from financial institutions (e. g. information on your payments made);
· from insurance companies;
· from competent state institutions (e. g. State Tax Inspectorate, State Social Insurance Fund Board, other institutions).
What are the purposes we process your personal data for?
The information provided hereinafter will cover the following purposes of data processing performed by the Company:
· direct marketing;
· selection of personnel, trainees and administration of the database for job, practical training candidates;
· administration of complaints, inquiries or orders;
· communication by e-mail;
· social networking;
· video surveillance;
· contract conclusion and performance.
If you are our customer or have expressed your will to receive any proposals from our company, your personal data provided voluntarily, including your e-mail address and phone number, will be used as contact data to provide information on services, news, stock, events or any other information related to direct marketing.
For the purposes of direct marketing, your personal data will be processed for the period of 5 years after the date of your consent or expiry date of relationship with you. Direct marketing may be based on consent or a lawful interest.
In every e-mail letter sent to you there will be a possibility to refuse receiving notifications (newsletters) of direct marketing. You may also express your refusal or withdraw your consent to receive them by contacting the company.
Selection of personnel, trainees and administration of database for job, practical training candidates
If you have sent your CV, motivation letter, references and/or any other documents or data for a specific job vacancy or place for practical training on the basis of a recruitment advertisement published on our website or a dedicated recruitment and job search website, your personal data, which have been submitted by you voluntary and other personal data mentioned hereinafter will be processed for the purposes of personnel selection.
For the purposes of selection, we will process your personal data as long as we take the decision to recruit or approve for practical training a particular candidate, his/her probationary period expires or the decision has been taken to end the selection without selecting a candidate. This period usually does not exceed four months. If you do not object to such processing of your data, we will keep your CV and other data submitted for the purpose of administering the database for job candidates for 12 months after the selection ends so that we could contact and invite you to participate in a new selection or offer a job, place for practical training.
Your personal data will be processed on the basis of your consent to take part in the selection process and, after the selection ends, will be stored based on a lawful interest. Certain actions can also be carried out in compliance with the obligations imposed by the legislation. Submission of your personal data in order to participate in the selection is voluntary, however, if you do not provide any data, we will not be able to assess the eligibility of your application. You can express your objection to storing your data after the selection ends, in which case we will destruct your personal data and will offer no jobs in future unless you voluntarily participate in a new selection or resend your data. If you do not agree that your data will be stored after the selection ends, you should notify us about that when sending us your CV and any other data, by replying to an e-mail or signing a notification form during the meeting.
Be advised that exercising the right granted by the legislation governing the personal data protection, we may refer to your previous employers and ask for their opinion on your qualifications, professional skills and qualities. However, your present employer will not be contacted without your express prior consent.
Administration of complaints, inquiries or orders
If you have submitted a complaint, claim, inquiry or order by e-mail, in writing or otherwise, your voluntarily submitted personal data will be processed for the purposes of administering this complaint, claim, inquiry or order.
In case your complaint or claim is related to a potential dispute, potential damage, etc., as well as if a contractual relationship occurs in the process of any order execution, your personal data may be stored for a maximum period of 10 years. If any personal data related to a complaint or claim are not related to a potential dispute, they will be destructed within a shorter period of time when the data is no longer needed to achieve the purpose. Normally this period does not exceed 1 year.
The processing of your personal data will be based on your free will, i.e. your consent to provide data, however, in certain cases (for example, in case of a potential or ongoing dispute), further storing of your complaint may be based on the legislation.
Communication by e-mail
In accordance with the Regulation, the content of e-mail correspondence is considered personal data even if such correspondence is between staff of legal entities. In this context, the content of electronic communication as well as e-mail addresses are subject to the rules on the processing of personal data binding by the Regulation.
The basis for the processing of your personal data is expression of your free will to communicate via e-mail and provide certain data therein, i.e. your consent. In addition to that, performance of a contract and statutory obligations may also form the basis for the data processing.
Your e-mail address, the content of correspondence and any related data will be processed in accordance with the principle of proportionality. This data will be primarily visible to the person you communicate directly with by email. However, in certain cases, your correspondence may also be read by other staff, for example, for the purposes of internal administration, investigation of potential violations of the legislation or internal rules, employee substitution and any other purposes related thereof, as well as in any other similar situations.
A cookie is a small file of letters and figures stored in the browser or hard disc of your computer. Different cookies are used for different purposes. The cookies also help to distinguish you from other users of the website, thus providing a more enjoyable experience of using the website and allowing to improve it.
Most browsers allow opting all cookies out, and some browsers have the functionality of opting only the third-party cookies out. Therefore, you can take advantage of these functionalities. However, it should be noted that blocking all cookies will have a negative impact on your use of the website, and without cookies you will not be able to use all the services provided on the website.
The following cookies are used on our website:
· cookies ensuring the website functioning (session). They are designed to improve the website operation and collect general (anonymous) information about the website use;
· analytical (monitoring cookies from Google Analytics). These cookies allow visitors to be recognized and counted as well as they help tracking how visitors are moving within a website. This helps to improve the website functioning, for example, ensure that users could easily find what they are searching for. The basis for processing the data collected by these cookies is your consent;
· functional cookies. These cookies are used to recognise the website visitors when they return to the website. This allows delivering the content that is tailored to the needs of the website visitors in social networks, memorizing information relevant to customers. The basis for the processing of the data collected by these cookies is clients’ consent.
The list of cookies used on our web sites is provided in the table below:
To ensure the appropriate level of security in data processing, PST has implemented proper technical and organizational measures. The Company follows the following guidelines in selection and implementation of proper technical and organizational measures to ensure security of data processing:
· Guidelines of the State Data Protection Inspectorate: https://vdai.lrv.lt/uploads/vdai/documents/files/VDAI_saugumo_priemoniu_gaires-2020-06-18.pdf.
How to manage and remove cookies
Most browsers are set to accept cookies automatically. With the information on how and what for they are used, you can decide whether to keep cookies or disable them in your browser. Most browsers allow managing cookies through their setting options. If you do not want to accept cookies, you can choose a setting not to accept all cookies or send a warning when a cookie has been created in your browser. To find more information on managing of cookies, visit: http://www.allaboutcookies.org/manage-cookies.
It should be noted that you may lose access to some features if you opt the cookies out. If you do not wish to get cookies, you can set your browser to reject all cookies or send a warning when a cookie has been created.
Our company has an account in the Facebook social network, the Data Policy of which is published at https://www.facebook.com/privacy/explanation.
Information provided to the social media (including messages, use of Like and Follow, and any other communication) will be controlled by the manager of the social network.
Inside the premises (at the entrance door, in the storage room, garage) and within the area (at the parking entrance) the company carries out video surveillance for safety of assets and persons. Video surveillance is carried out based on a lawful interest. The video records are stored for the period of 30 days.
Contract conclusion and performance
For the purpose of concluding and performing the contracts, we will process only the data provided by you for the contract conclusion as well as the data that is obtained in the process of the contract performance by you. If you do not provide your personal data, we will not be able to identify you and conclude any contract with you.
The basis for the processing of your personal data for this purpose is the performance of the contract or any actions at your request prior to the contract conclusion. Performance of the statutory obligations may also form the basis for the processing of certain personal data, for example, compliance with obligations under the tax legislation.
Your personal data will be stored for the period of maximum 10 years from the expiry date of the contract concluded with you.
Whom the company may provide your personal data to?
The law stipulates that the Company may use your personal data not only in its activities, but also transfer your personal data to other persons.
Your personal data may be provided lawfully and reasonably:
· the companies included in the Company Group;
· public registers and information systems;
· competent state authorities (e.g. State Tax Inspectorate, State Social Insurance Fund Board, State Consumer Rights Protection Service, Competition Council, etc.);
· notary public, bailiffs, lawyers, consultants, auditors, debt collection companies;
· law enforcement and supervisory authorities, courts, other dispute resolution bodies;
· Service providers of the Company (e.g. financial institutions, providers of IT, server, mail, archiving, marketing, accounting, post and courier services);
· insurance and brokerage companies;
· successors of the Company's business or a part thereof, or their authorized consultants or persons.
What personal data protection principles do we follow?
The following principles are complied with in collecting and using your personal data provided by you as well as obtained from other sources:
· your personal data will be processed lawfully, fairly and in a transparent manner (‘lawfulness, fairness and transparency’);
· your personal data will be collected for a specific, explicit and lawful purposes, and will not be further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
· your personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
· processed personal data is accurate and updated, if required (‘accuracy’);
· your personal data is kept in a form that that identifies you for no longer than is necessary for the purposes for which your personal data is processed (‘storage limitation’);
· your personal data is processed in a manner that proper safety of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures is ensured (‘integrity and confidentiality’).
Implementation of your rights
Be advised that you have the following rights of the Data Subject:
· the right to access his/her data, i.e. find out what personal data is stored by the Company and how it is processed. This can be done by submitting a written request to the Company;
· the right to obtain a copy of your data processed by the Company (provided such data is not subject to special processing);
· right to rectify or, taking into account the purposes of the processing of personal data, complete any incomplete personal data of a person;
· the right to request to erase your data (‘right to be forgotten’), i.e. submit a request to erase your personal data if you believe that your data is being processed unlawfully or unfairly;
· the right to suspend of any processing activities related to their data (except mandatory storage);
· the right to restrict processing of personal data;
· the right to data portability;
· the right to withdraw the consent that has been given to the Company to process your personal data (such withdrawal will not affect any data processing that took place before the withdrawal) and object to processing of your personal data;
· the right to file a complaint with the State Data Protection Inspectorate.
You can exercise your rights in the following ways:
- By sending us a free-form request to P. Puzino Str. 1, Panevezys, Lithuania, telephone (+370 45) 505 503 or e-mailing thereof to firstname.lastname@example.org. Such request should be signed electronically or, if signed by a physical signature, a notarized copy of an identity document should be attached to the request for verification of your identity.
- If the request is sent by registered mail to P. Puzino Str. 1, Panevezys, Lithuania, such request should be signed. a notarized copy of an identity document should be attached to the request for verification of your identity.
You can also exercise your rights through a proxy. In this case, your proxy must provide his/her name, surname, contact details, a notarized copy of an identity document, information about you: name, surname, other data on the basis of which we may identify you, as well as a notarized copy of a document supporting your representation.
The request should be signed, it should include the name, surname, place of residence and other contact details of the Data Subject, information on which of the Data Subject's rights and to what extent the Data Subject wishes them to be exercised.
We will respond to your request no later than within 30 (thirty) calendar days from the date when your request is received. In exceptional cases requiring additional time, we will, after notifying you thereof, have the right to extend the deadline for submitting the requested data or processing other requirements specified in your request to 60 (sixty) calendar days from the date when your request is received.
In order to enforce your rights of the data subjects, your identification is necessary. Without your identification, it will not be possible to verify whether access is performed exactly by the person whose personal data is being processed, therefore your rights will not be enforced.
Your request related to enforcement of rights may be rejected or may be subject to a relevant fee provided such request is apparently unreasonable or excessive, as well as in other statutory cases.
If you wish to enforce your rights of the data subject or have any other questions regarding the processing of your personal data, please contact the company using the information hereinabove.