We apply this Policy when you are visiting the Company’s website, when you submit your data personally to the Company, when we receive the data related to you from public authorities or other sources, and when we attempt to implement the contractual obligations, the party of which you are, properly. Besides, this Policy informs you about other personal data processing operations performed in the Company and the main regulations that help to ensure your privacy. This Policy is not applied when you are browsing other companies’ websites or when you are using services of third parties.
When we are processing personal data, we act in compliance with the Data Protection Regulation No 2016/679 of the European Union, Law on Legal Protection of Personal Data of the Republic of Lithuania, other related legal acts, and instructions of regulatory authorities.
PERSONAL DATA PROCESSING PERFORMED BY “ES SECURITY” UAB
In order to ensure transparency and responsible personal data processing, we inform that the Company is processing the personal data for the following purposes:
- to administer the clients’ database in order to provide services and to enter into and execute contracts;
- to identify you in the Company’s information systems and website;
- to answer to your questions, comments or inquiries;
- to solve the problems related to provision, conveyance or use of the services;
- to contact you when the conditions of the services acquired by you change;
- to assess the clients’ solvency and to manage possible debts;
- for direct marketing, including sending of newsletters;
- to improve quality of services;
- to perform analytical and market researches;
- to ensure safety of clients, employees and premises (video surveillance);
- for other purposes related to internal administration, for example, when the data of the Company’s employees are processed;
- for audit;
- to implement the statutory rights and duties.
PERSONAL DATA THAT WE COLLECT AND PROCESS
The Company collects and processes personal data of the following categories:
- key data that are needed to pursue the goals listed above: name, surname, personal number and date of birth, health data, photo, data of personal identity documents (passport, personal identity card) (date and place of issue, date of expiry, number), contact data, domicile, sex, signature, employer’s name, names, surnames of immediate family, phone numbers, e-mail addresses, domiciles, data of credit/debit cards or other payment data, etc.;
- the data that are necessary to provide the services or to sell the goods: order’s data, information on the invoice, payment-related data, information about the services and goods you have acquired (their amounts, purchase dates, prices of acquired services, purchase history and other information related to the service acquisition), etc.;
- the data about your visit to the Company’s website that we may process: information about your browsing programme, your IP address, data and time of your visit to the Company’s website, links you have pressed, the websites, from which you have been referred to the Company’s website, information about your computer’s operating system; versions of mobile apps; language settings;
- if you are using a mobile device, the data may be also collected that would allow identifying the type of the mobile device, the device’s settings, and the geographical coordinates (longitude and latitude);
- video data recorded by the Company’s video surveillance equipment;
- other data collected on the basis of your consent that are defined exhaustively at the time when request for your consent is made.
LEGAL GROUNDS, ON WHICH PERSONAL DATA ARE COLLECTED
The Company may collect your personal data only in accordance with the lawful processing grounds specified in the legal acts. This means the legal ground of the contract’s conclusion and implementation, when you enter into the contract for services or some other contract with the Company, when you address the Company about certain issues, and when you visit the Company’s website. The legitimate interests of the Company may also serve as a ground to process the data, e.g., the Company is checking solvency, administers and/or recovers the debt. Your consent is one more ground for the Company to process the personal data (e.g., for the purpose of direct marketing when personalised offers are made on the basis of individual analysis of the client, and in other cases). The Company may process your personal data also to execute its legal obligations (to implement the requirements of the normative acts, to answer to lawful inquiries of the State or municipalities, etc.) or in case of other lawful processing grounds established in the legal acts.
PERSONAL DATA STORAGE TERMS
The personal data collected by the Company shall be stored in the printed documents and in the Company’s information systems. The storage term shall not exceed the term necessary to achieve the data processing goals or terms indicated in the legal acts, if they provide longer storage. The personal data are usually stored for the term, during which reasonable demands may arise from the contractual relations, or as long as it is necessary to implement and protect the Company’s legitimate interests. The personal data that are not needed any longer shall be destroyed.
The Company shall undertake all the measures to ensure accurate, fair and lawful processing of personal data, data processing only for the specified purpose and in strict compliance with clear and transparent personal data processing requirements established in the legal acts.
PERSONAL DATA PROCESSING AND COOPERATION WITH THIRD PERSONS
The Company may transmit personal data to data processors, who are carrying out certain works or providing certain services to the Company. The Company shall not authorise any supplier or third person to use your personal data in any other mode and it shall demand to use protection means of your personal data. The personal data may be transmitted to the third persons of the following categories:
- intermediaries, who are processing the data in order to make and administer contracts with clients and partners;
- companies of information technologies that are processing the data in order to safeguard development, improvement and support of the information systems;
- the companies that ensure sending of notices to the clients, that provide security and other services;
- accounting companies;
- the companies that manage joint files of debtors or that administer debts;
- the court, law enforcement authorities or public authorities in the scope established by legal acts;
- the partners, for example, cessionary of demand rights in the case when the Company transfers the right of demand to the amount payable by the client in order to assure effective debt management;
- other persons on the basis of your consent given for some particular case.
DATA COLLECTED ON THE COMPANY’S WEBSITE
We collect the following data on the Company’s website:
- when we administer the website and diagnose problems in the Company’s server, we may use IP addresses of the visitors’ computers. IP address is a unique code identifying the computer in the networks. It may be used to identify the visitor and to collect various demographical data;
- we use the cookies to collect data about use of the services. The information about the cookies, their types and purpose is provided below;
- when you complete the inquiry form on the website, we collect the basic information necessary to identify the user that you have given, i.e., name, e-mail address, phone number or other information you provide.
We store the collected data about the visitors of the Company’s website responsibly and protect them from loss, unlawful use and modifications. The premise, where the collected data are stored, is protected physically so that the persons not employed in the Company would not be able to have the data in their disposition. Besides, the database storing the data of the website’s visitors is protected against unlawful access via computer networks.
By using the services provided by the Company and entering into the contract for services/ supply of goods, you may give voluntary consent to use of your personal data for the Company’s marketing purposes. You may express the consent by signing in the appropriate box in the contract for services/ supply of goods or by writing a sperate written consent.
When you subscribe fora newsletter, the Company will use your e-mail address or phone number on the ground of your consent that you may revoke at any time. We may transmit your e-mail address or phone number to the third persons providing specialised services only for the single purpose of sending a newsletter to you.
Having sent the newsletter, the Company may collect statistical data about your behaviour, for example, whether you have opened the e-mail, what links have you clicked on.
We will manage your e-mail address and phone number for the purpose of sending the newsletters until you withdraw the consent to receive the Company’s offers. You may unsubscribe from the Company’s newsletters by clicking on the appropriate link in the bottom of the newsletter or using other methods indicated in this Policy or in the newsletter.
WHAT ARE COOKIES?
A cookie is a small text file that the website saves in your computer’s or mobile device’s browser when you visit the website. On the next visit to the website, this file may be read so that the website could recognise your computer or mobile device.
COOKIES USED BY THE COMPANY
The information collected by the cookies enables more convenient browsing for you, making attractive offers to you, learning more about behaviour of the website’s visitors, analysing the tendencies, and improvement the website, the client servicing, and the services provided by the Company.
The cookies on the Company’s website are usually used for the following purposes:
Technical cookies: we try to offer an advanced, easy-to-use website to our visitors that would adjust automatically to their wishes and needs. In order to achieve this, we use the technical cookies that help us to display our website and ensure its functionality. The technical cookies are necessary for appropriate functioning of our website.
Functional cookies: we are also using the functional cookies to remember your wishes and to help you to use our website and apps effectively and efficiently. For example, these cookies remember what language you prefer, searches. The functional cookies are not necessary for the website’s functioning, but they contribute to its functionality and improve your experience of the website’s use.
Analytical cookies: we use these cookies to acquire the insights about the way, how our visitors are using the Company’s website. In such a way, we are able to optimise and improve our website, to understand the effectiveness of advertising and communication, and to make sure that we remain interesting and relevant. We may collect the data about the websites you have viewed, the pages, from which you have come, the e-mails you have opened and reacted to, as well as information about date and time. It also means that we may use the information about you and the way you are using the website, e.g., frequency of visits, number of clicks on certain page, used search words, etc. We may use analytical cookies as a part of our advertising campaigns to learn, how the visitors are browsing our website after having seen the online ad. It also may include advertisements on the websites of third persons.
Commercial cookies: we use own cookies and cookies of the third persons to show the personalised advertisements on the websites. It is called “repetition marketing” that is based on the browsing actions, for example, the goods you have searched for or reviewed.
The cookies are also used to register whether you agree with the use of the cookies on the Company’s website, so that this question would not be repeated every time when you visit the website.
The Company’s employees, who are responsible for data analysis and website’s improvement, shall have access to the statistical data about the Company’s website visitors.
The Company’s partners may also have access to technical records, if they are providing management tools of the website’s content and similar services to the Company.
REFUSAL OF THE COOKIES
When you visit the Company’s website, you may choose whether you want to use the cookies. You may manage and/or delete the cookies as you wish. You may choose in the settings of browser Internet Explorer, Safari, Firefox, Chrome or another browser, which cookies you want to accept and which to refuse. You may delete all the cookies already present in your computer, while the majority of browsers allow setting that the cookies would not be recorded. The location of these settings depends on the browser that you are using.
If you do not agree to have the cookies recorded in your computer or another device, you may withdraw the consent for their use by changing the settings and deleting the already recorded cookies. If you choose to delete the cookies, do not forget that all the set options will be also removed. Besides, if the cookies are blocked completely, many websites, including the Company’s website, will not function properly. Therefore, we do not recommend to turn off the cookies when you use the Company’s website.
In order to learn more about the cookies, how to manage or delete them, visit the website www.allaboutcookies.org and the help page of your browser.
SAFETY OF PERSONAL DATA
Your personal data shall be processed responsibly and safely. When we determine the personal data processing tools and when we are processing the personal data, we are using the technical and organisational measures specified in the legal acts to protect your personal data from accidental or unlawful destruction, damage, modification, loss, disclosure, and any other unlawful processing.
The Company’s employees working with the personal data have signed the written pledge not to disclose to the third parties and not to spread the information received at work about the Company’s clients and other potential clients, including the visitors of the Company’s website, and other persons, whose data are transmitted to the Company.
The safety measures of personal data are determined with regard to the risks arising in the course of personal data processing.
The Company has no possibility to guarantee uninterrupted functioning of its website without any problems or mistakes, complete protection of the Company’s website from viruses or other harmful components. The website’s visitor is informed that any material that you are reading, downloading or receiving otherwise while using the Company’s website is received solely at your own risk and you are the only one to assume liability for the damage caused to you or your computer system.
YOUR RIGHTS AND OTHER RELEVANT INFORMATION
You have the right:
- to ask the Company to provide information about your personal data processed by the Company, from where and how the personal data are collected and how the Company is processing them. When you make a request, you should complete the form of request to access the processed personal data available on the Company’s website at https://essecurity.lt/;
- to ask the Company to rectify your personal data and/or to suspend processing of such personal data, save for storage, if, having accessed the personal data, you determine that they are incorrect, inaccurate or incomplete;
- to ask the Company to erase your personal data, when, having accessed the personal data, you determine that they are processed unlawfully or there are other legal grounds provided in the legal acts. When you make a request, you should complete the form of request to erase the processed personal data available on the Company’s website at https://essecurity.lt;
- to object to processing of your personal data when they are processed or planned to be processed for the purpose of direct marketing, or for the lawful interest aimed by the Company or the third person, to whom the personal data are transmitted;
- to demand not to apply automated data processing only for you, including profiling;
- to receive your personal data that you have provided to the Company in a structured, commonly used, machine-readable format, and to transmit it to another controller, or to request the Company to transmit such personal data to another data controller directly when it is technically possible (right to data portability).
- to refuse to submit your personal data. In such case, you waive automatically your right to file a claim regarding quality of the Company’s services because the requested data may be necessary to provide/supply properly the services/ goods desired or ordered by the data subject. In such a case, the Company shall have the right to refuse to provide services to you if their provision is related to receipt of your personal data.
All the questions about implementation of your rights or complaints should be e-mailed to the person responsible for personal data protection in the Company by firstname.lastname@example.org. You may also refer to the State Data Protection Inspectorate; however, we will always try to solve all the issues directly with you.
When you submit a request, you have to verify your identity in one of the following modes: 1) if the request is delivered by arriving personally to the Company – to present a personal identity document or its copy certified in accordance with the laws of the Republic of Lithuania; 2) if the request is mailed or e-mailed – to submit a copy of a personal identity document certified in accordance with the laws of the Republic of Lithuania; 3) if the request is submitted through the representative − to submit a copy of a personal identity document certified in accordance with the laws of the Republic of Lithuania together with the document confirming the right of representation (or a copy of the power of attorney certified in accordance with the laws of the Republic of Lithuania).
When the Company receives your written request, it shall submit the requested data or state the reasons of refusal to satisfy the request in writing (including the electronic communication means) not later than within 30 calendar days after receipt of your request.
The term of 30 days may be extended for two more months, if necessary, depending on the complexity and number of requests. The Company shall notify the person, who has submitted the request, about extension within a month after receipt of the request, stating the reasons of delay.
- in writing – by e-mail email@example.com;
- visit to V.Krėvės av. 129, Kaunas;
- by completing the form available on the Company’s website https://esseciurity.lt/kontaktai/
UPDATING OF PRIVACY AND COOKIES POLICY
If the Company updates this Privacy and Cookies Policy, its new version will be placed on the Company’s website www.essecurity.lt