The purpose of the privacy policy is to provide the natural person – the data subject – with information on the purposes for which the personal data are processed, the applicable legal basis, the scope of processing, protection and processing time during data collection and processing of the data subject’s personal data.
DATA CONTROLLER AND HIS CONTACT DETAILS
1. The controller of personal data processing is UAB PROGRESSIVE BUSINESS SOLUTIONS Įm. Code: 300572584, registered office address Molėtų plentas 71, LT-14259 Vilnius, (hereinafter – PBS);
2. PBS contact details on issues related to personal data processing – info@pbs.lt. By using this contact details or by contacting the PBS headquarters, you can ask questions about the processing of personal data. An application for the exercise of your rights may be made in accordance with paragraph 23.
3. PBS contact details for informing about possible data protection violations: info@pbs.lt
GENERAL PROVISIONS
4. Personal data is any information relating to an identified or identifiable natural person.
5. The Privacy Policy applies to ensure the protection of the privacy and personal data of the following groups (hereinafter – the Clients):
5.1. natural persons – clients of PBS, (including, potential, past and present);
5.2. Visitors to the PBS office and other premises, including those using a video surveillance system;
5.3. Visitors to websites created by PBS;
5.4. persons whose personal data are processed on social networks and are involved in marketing activities organized by PBS.
6. PBS takes care of the Clients ‘privacy and protection of personal data, respects the Clients’ rights to the lawfulness of the processing of personal data in accordance with the applicable legal acts – the Law on the Protection of Individuals, the European Parliament and the Council of 2016. April 27 Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter “the Regulation”) and other applicable legislation relating to privacy and data processing.
7. The Privacy Policy applies to the processing of data, regardless of the form and / or environment in which the Customer provides personal data (in person, on the PBS website, in paper format or by telephone).
PURPOSE OF THE PROCESSING OF PERSONAL DATA
8. PBS processes personal data for the following purposes:
8.1. Provision of services and consulting of clients:
8.1.1. to identify the customer;
8.1.2. drafting and concluding contracts;
8.1.3. to provide services;
8.1.4. to develop new services;
8.1.5. for the advertising and development of goods and services or for commercial purposes;
8.1.6. to serve customers;
8.1.7. to examine statements of opposition or claims;
8.1.8. to retain customers, to increase loyalty, to conduct satisfaction surveys; 8.1.9. to administer settlements;
8.1.10. to recover and recover debts;
8.1.11. to maintain and improve websites and mobile apps;
8.2. Business planning and analysis;
8.3. To protect customer safety and company assets;
8.4. For other specific purposes for which the Client’s consent has been obtained by providing specific data to PBS.
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
9. PBS processes the Client’s personal data on the basis of the following legal basis:
9.1. conclusion and performance of the contract – in order to conclude the contract at the request of the Customer and ensure its performance (an oral agreement on the purchase of a good or service is also considered a contract);
9.2. Enforcement – in order to fulfill an obligation under binding external legislation in the PCA;
9.3. based on the consent of the Customer, the data subject;
9.4. legal (legitimate) interests – in order to implement the existing relations or concluded agreement between PBS and the Client, or PBS (legitimate) interests provided by law.
10. The legal (legitimate) interests of the PCA are:
10.1. engage in commercial activities;
10.2. verify the Customer’s identity before purchasing services; 10.3. to ensure the fulfillment of contractual obligations;
10.4. to save the Clients’ requests and applications related to the provision of services;
10.5. take steps to attract and / or retain Customers;
10.6. to segment the customer database to ensure more efficient service provision;
10.7. create and improve goods and services;
10.8. advertise your services by sending commercial messages;
10.9. to send other notifications about the progress of the contract execution and events significant for the execution of the contract, as well as to conduct customer surveys about the goods and services and the experience of their use;
10.10. to prevent fraud against the company;
10.11. to ensure the company’s management, financial and business accounting and analysis;
10.12. to ensure efficient company management processes;
10.13. to ensure and improve the quality of services;
10.14. administer payments;
10.15. to inform the company about the ongoing activities.
PROCESSING OF PERSONAL DATA
11. PBS processes customer data using state-of-the-art technology, taking into account the existing privacy risks and the organizational, financial and technical resources available to PBS.
12. PBS may perform automated decision making with respect to the client. The Client is informed of such actions in PBS separately in accordance with the legislation.
13. Automated decision making that has legal consequences for the Customer (for example, approval or rejection of the Customer’s request) may be performed only at the time of concluding or executing the agreement between PBS and the Customer, or with the Customer’s explicit consent.
PROTECTION OF PERSONAL DATA
14. PBS protects the Customer’s data using the capabilities of modern technology, taking into account the existing privacy risks and the organizational, financial and technical resources available to PBS, including the following safeguards:
14.1. firewall;
14.2. intrusion prevention and intrusion detection programs;
14.3. other safeguards, taking into account the possibilities related to the development of current technologies.
CATEGORIES OF RECIPIENTS OF PERSONAL DATA
15. PBS does not disclose to third parties the personal data of the Customer or any information received during the provision of services and the validity of the contract, including information about the received goods and services, except:
15.1. based on the Client’s explicit and unambiguous consent;
15.2. to persons provided for in external legal acts upon their reasoned request, in accordance with the procedure and scope provided for in external legal acts;
15.3. in cases provided for in external law, for the protection of the legitimate interests of the PCA, for example by bringing an action before a court or other national authority against a person who has infringed the legitimate interests of the PCA.
TRANSMISSION OF PERSONAL DATA
16. PBS shall not transfer Personal Data to third parties except to the extent necessary to conduct a reasonable business, ensuring that the relevant third parties maintain the confidentiality of Personal Data and ensure the applicable protection.
17. PBS has the right to transfer Personal Data to PBS suppliers, subcontractors, strategic partners and others who assist PBS and their customers in the course of commercial activities in order to implement the cooperation. However, in such cases, the PCA requires the data recipients to undertake to use the information received only for the purposes for which the data were transmitted and in accordance with legal requirements.
ACCESS TO PERSONAL DATA BY THIRD PARTY ENTITIES
18. The PCA does not transfer personal data to third countries (outside the European Union and the European Economic Area).
PERSONAL DATA RETENTION PERIOD
19. PBS stores and processes the personal data of the Clients until one of the following criteria is applied:
19.1. only as long as the agreement concluded with the Customer or the service provided to the Customer is valid;
19.2. the data are necessary for the purpose for which they were collected;
19.3. until the contents of the Customer’s request are fully reviewed and / or executed;
19.4. until PBS or the Client can realize its legitimate interests in accordance with the procedure provided for in external legal acts (for example, to submit feedback or file a lawsuit);
19.5. As long as PBS has a legal obligation to store data;
19.6. as long as the Customer’s consent to process the relevant personal data is valid, if there is no other legal basis for data processing.
20. After the circumstances mentioned in Clause 19 are no longer valid, the Customer’s data shall be deleted. Audit records shall be kept for at least one year from the date of their performance.
ACCESS TO PERSONAL DATA AND OTHER CUSTOMER RIGHTS
21. The Client has the right to receive the information provided for in legal acts related to the processing of his / her data.
22. Subject to the law, the Customer has the right to require PBS to grant access to its personal data, as well as to require PBS to supplement, correct or delete them, or to restrict the processing to the Customer, or the right not to consent to the processing (including processing of personal data by legitimate interests of the PCA) as well as the right to data portability. These rights shall be exercised in so far as the processing relates to PBS obligations imposed under applicable law and in the public interest.
23. In order to exercise his right, the Client may submit a request in the following ways:
23.1. In writing to PBS (address: Molėtų plentas 71, LT-14259 Vilnius, Lithuania) or by post;
23.2. electronically by signing a secure electronic signature and sending an e-mail. email info@pbs.lt
24. Upon receipt of the Client’s request to exercise his / her right at Molėtų plentas 71, LT-1425 Vilnius, the Client’s identity shall be verified, the request shall be examined and executed in accordance with legal acts.
25. PBS shall send to the Client by post, by registered mail or by e-mail to the contact address indicated by him. by post, signing with a secure electronic signature (if the request is submitted signed with a secure electronic signature), taking into account, as far as possible, the response form specified by the Customer.
26. PBS ensures the fulfillment of data processing and protection requirements in accordance with legal acts, and after the submission of claims by the Customer, takes useful steps to resolve the complaint. However, if this fails, the Customer has the right to apply to the supervisory authority – the State Data Inspectorate.
27. The Client has the right to receive one copy free of charge with the personal data submitted for processing in his PBS.
28. The receipt and / or use of the information referred to in paragraph 27 of this document is restricted in order to prevent adverse effects on the rights and freedoms of others (including PBS employees).
29. PBS is committed to ensuring the accuracy of Personal Data and trusts its customers, suppliers and other third parties who transfer Personal Data to ensure the completeness and accuracy of the transferred Personal Data.
CUSTOMER’S CONSENT TO DATA PROCESSING AND RIGHT TO WITHDRAW
30. The Client shall give his consent to the processing of personal data, the legal basis of which is consent (for example, to receive a commercial communication, analysis of personal data) in person in writing on the PBS website or elsewhere where PBS organizes marketing activities.
31. The Customer has the right to revoke the consent given for data processing at any time in the same way as it was given and / or in accordance with the procedure set forth in Clause 23. In this case, the processing of data based on the prior consent for a specific purpose will not take place.
32. The revocation of the consent does not affect the data processing performed during the validity period of the Customer’s consent. 33. Following the withdrawal of consent, the processing of data on other legal grounds may not be terminated.
COMMERCIAL COMMUNICATIONS
34. PBS shall send commercial communications related to PBS and / or third party services and communications not related to the provision of other directly performed services (such as customer surveys) in accordance with the procedure provided for in external legal acts or with the consent of the Customer.
35. PBS may communicate, as well as send commercial messages, using an automated calling system or electronic means of communication.
36. The Client consents to the commercial communications of PBS and / or its partners by personally signing the PBS website or elsewhere where PBS organizes marketing activities.
37. The consent given by the Client to receive commercial communications is valid until its revocation (also after the expiry of the service contract). The customer may at any time refuse to continue to receive commercial communications in one of the following ways:
37.1. by sending an e-mail email address: info@pbs.lt
37.2. by calling: +370 5 210 2302;
37.3. By submitting a written request to the PBS office;
37.4. using the automated option for commercial communication to opt out of further notifications by clicking the opt-out link at the end of the relevant commercial message (e-mail).
38. PBS terminates the sending of commercial messages as soon as the Customer’s request is processed. Application processing depends on technological capabilities, which can take up to three days.
39. By expressing his opinion in the surveys and leaving his contact details (e-mail address, telephone number), the Client agrees that PBS may contact him using the contact information provided in connection with the assessment provided by the Client.
VISITING WEBSITES AND MANAGING COOKIES
40. PBS websites may use cookies:
40.1. Cookies are files that a website stores on users’ computers in order to identify the user and make it easier for the user to use the website. Web browsers can be configured to alert the customer to the use of cookies and to allow them to choose whether the customer agrees to accept them. Failure to accept cookies does not prevent the customer from using the website, but this may limit the customer’s ability to use the website.
40.2. PBS websites may contain links to third party websites that have their own rules of use and protection of personal data, the completeness of which PBS is not responsible for.
OTHER PROVISIONS
41. PBS has the right to change and supplement the Privacy Policy, as well as to create conditions for the Client to get acquainted with it, to publish it on the PBS website.
42. PBS retains previous versions of the Privacy Policy and these are available on the Website.