PRIVACY POLICY

1. GENERAL PROVISIONS

1.1. The Controller – Law Firm of Attorney Martynas Kalvelis “LEXTRA”, address at Konstitucijos av. 21A, LT-09306, Vilnius, Republic of Lithuania respects the privacy of Website‘s visitors, Firm‘s clients, partners/suppliers and/or its representatives, also candidates for job vacancies and other persons, who provide the Personal data to the Firm or the Firm, having legitimate ground for receive and processing of the Personal data, receives such data, including from third parties (hereinafter, you or yours).

1.2. On this basis, the Firm collects, stores and discloses or otherwise processes your Personal data only as described in this Privacy Policy and (or) applicable legal acts, including GDPR, LLPPD, also in other information provided to you. We draw your attention to the fact that additional and (or) more detailed information about how we process your Personal data may be provided in the contracts and other communication and documents provided by the Firm (e. g., consents, etc.).

1.3. This Privacy Policy describes the principles of collection, use or otherwise processing of information we use on the Website, as well as other information about the Personal data processed in Firm's activity, policies and principles applied in order to ensure the protection of Personal data.

1.4. By using the Website and (or) by providing the Personal data to us (unless we have to receive your explicit consent under applicable legal acts), you agree that the Personal data you provide to the Firm would be processed in accordance with this Privacy Policy.

1.5. Provision of your Personal data in cases described in the Website or otherwise requested by the Firm is usually voluntary, but is necessary in order, for example, to respond to your inquiries, to execute the agreement concluded by the Firm with you or the person you represent, to consider your candidacy for a job vacancy and etc.

1.6. We kindly ask you to familiarise with the information contained in this Privacy Policy your existing or future representatives (individuals, who represent you in relations with us, if you are, for example, our client or supplier), as well as other persons to whom this information may be relevant due to the fact that you submit their Personal data to us.

2. DEFINITIONS

2.1. In the Privacy Policy definitions and expressions, which are written in the capital letter, shall have the same meaning as defined down below:

a) LLPPD – the Law on Legal Protection of Personal Data of the Republic of Lithuania;

b) Personal data – any information about you, as a natural person, whose identity has been identified or can be identified (the Data subject); the natural person, whose identity can be identified, is the person, whose identity can be identified directly (using an identifier such as name and surname, internet identifier) or indirectly (according to one or more physical, physiological, genetic, psychological, economic, cultural or social identity features);

c) GDPR – 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;

d) Controller or Firm, or we, or us, or our – Law Firm of Attorney Martynas Kalvelis “LEXTRA”, address at Konstitucijos av. 21A, LT-09306, Vilnius, Republic of Lithuania;

e) You or your – any person who visits the Website and uses its functionalities (e. g.,. submits the inquiry) or is Firm‘s client, partner/supplier and (or) its representative, candidate for Firm’s job vacancy, and provide the Personal data to the Firm or the Firm, having legitimate ground for receive and processing of the Personal data, receives such data, including from third parties;

f) Privacy Policy – the principles, rules and requirements provided by the Firm that establishes the procedure of collection, storage, use and any other processing of information, including the Personal data, related to the use of the Website and its functionalities, also processed in Firm's activity, as well as other relevant provisions;

g) Direct marketing – the activity for the supply of services to the individuals and (or) ask for the opinion of individuals on offered services by post, telephone or other direct means;

h) Website – website that is available at www.lextra.legal, the administrator of which is the Firm.

3. CONNECTION TO THE WEBSITE

3.1. Each time you visit the Website, servers of the Website temporarily store information about the connecting device in the login file. In this procedure, regardless your actions, the following data is automatically collected and stored for as long as it is automatically and (or) manually deleted, i. e. the IP address of connecting device, date and time of connection, information about browser you are using and its version, type of the device, and other technical details. This information is collected and processed in order you could use our Website, also to guarantee the continued security and stability of the system, technical administration of the network infrastructure, as well as for internal statistical purposes. In addition, the IP address may be investigated and used in case of violations of the Privacy Policy, attacks against the Website’s infrastructure and in other cases, if this is provided in this Privacy Policy or applicable legal acts.

4. PURPOSES OF THE PROCESSING OF PERSONAL DATA, SOURCES OF DATA, CATEGORIES OF THE DATA SUBJECTS, OTHER INFORMATION RELATED WITH THE PROCESSING OF YOUR PERSONAL DATA

In order to ensure transparency and responsible processing of Personal data, we inform that the Firm can process your Personal data for the following purposes and under the following conditions:

4.1. Conclusion and performance of contracts. In order to conclude and properly perform contracts with our clients, partners/suppliers, including record concluded transactions, control its execution and payment, recover debts, we may process the Personal data of clients or partners/suppliers and their representatives/employees.

Processed Personal data: Client’s or supplier’s/partner’s name, surname, address (including delivery address), telephone number, e-mail address, amounts, date and basis of occurrence of debts/partial payments, personal code, other information related to contractual obligations and, when the Personal data of client’s or supplier’s/partner’s representative/employee are processed – his/her name, surname, telephone number, e-mail address, position, address of division;

Legal basis for the processing of Personal data: Personal data of the client or supplier/partner are processed in order to perform the contract to which the Data subject is party and, when the Personal data of representative/employee of client or supplier/partner are processed – on the basis of the Firm’s legitimate interest to identify representative and fulfil Firm’s contractual obligations with the client or supplier/partner.

Period of storage of the Personal data: 10 (ten) years from proper execution of the contract and, when the Personal data of representative/employee of Firm‘s client or supplier/partner are processed – 5 (five) years from the last contact with the person (as client’s or partner’s /supplier’s representative/employee).

Source of the Personal data: Personal data of supplier/partner are obtained from Data subject itself and when Personal data of its representative/employee are processed – they can be obtained from employer of representative or other representative (client, partner/supplier of the Firm).

4.2. Management of available material and financial resources. In order to ensure our independent functioning and manage our available financial and material resources, including Firm‘s bookkeeping, invoicing clients, keeping accounting of incoming invoices, we may process the Personal data of our clients or partners/suppliers and their representatives/employees.

Processed Personal data: Client’s or supplier’s/partner’s name, surname, e-mail address, address, telephone number, copy of individual activity certificate, information about payable/receivable amounts of money, and when client/supplier/partner (natural or legal person) is represented by own representative/employee – his/her name, surname, telephone number, e-mail address, position.

Legal basis for the processing of Personal data: Personal data of the client or supplier/partner are processed in order to perform the contract to which the Data subject is party, also to fulfill the legal obligation applicable to the Firm to properly maintain accounting, and, when the Personal data of client’s or supplier’s/partner’s representative/employee are processed – on the basis of the Firm’s legitimate interest to fulfill its contractual obligations with the client or supplier/partner and contact the representative/employee for accounting purposes.

Period of storage of the Personal data: 10 (ten) years from the relevant accounting operation and, when the Personal data of the client’s or supplier’s/partner’s representative/employee are processed – 5 (five) years from the last contact with the person (as client’s or partner’s/supplier’s representative/employee).

Source of the Personal data: Personal data of client or supplier/partner are obtained from the Data subject and, when the Personal data of its representative/employee are processed – it can be obtained from the employer of representative or other person being represented (client, partner/supplier of the Firm).

4.3. Selection of personnel. In order to ensure our independent functioning and to select the most suitable candidates for job vacancies available at the Firm, we may process the Personal data of persons, who apply for job vacancies available at the Firm and submit (including send by e-mail or by other channels) to the Firm the Personal data necessary for this purpose. When you apply for job vacancies available at the Firm, you are informed that we have the right to contact your specified former employer in order to obtain information about your qualifications, professional skills and business features. When you submit contact person details of your former employer, you should inform him/her about the submission of such data to the Firm and that he/she may be contacted by the Firm for the purposes of your recruitment.

Processed Personal data: CV, name, surname, date of birth, telephone number, e-mail address, information about education, information about work experience, other information provided by the candidate (including during the interview) or received during an evaluation (tests results), including recommendations, information related to qualification, professional skills and business features received from the former employer of candidate.

Legal basis for the processing of Personal data: Personal data are processed on the basis of the Data subject‘s consent, which can be expressed by submitting CV to the Firm or otherwise applying for job vacancy. Data from the former employer are obtained on the basis of the legitimate interest of the Firm to receive information about the candidate from its former employer.

Period of storage of the Personal data: Until the end of the relevant selection of personnel to the specific position (if and when it is possible to identify the particular position to which the candidate applies) and 1 (one) month thereafter (as much as necessary to technically delete the data),
in any case no more than 6 months from the date of submission of the candidate’s CV or other data necessary for this purpose.

Source of the Personal data: Personal data of the potential candidate are obtained from the Data subjects, also, from the third parties – the representative of the former employer of the candidate, and can also be obtained from third parties providing the Firm with personnel selection services, which should inform you about the provision of your Personal data to us.

4.4. Administration of inquires or complaints received by Firm‘s contacts (including e-mail) or other functionalities available on the Website, including submission of responses. In order to ensure opportunity for you by using the means available on the Website (for example, form of inquiries, if available on the Website) or by using contacts of the Firm (for example, e-mail specified in the Website or this Privacy Policy) to submit for us the inquiries or complaints, as well as to submit you the answers to your inquiries or complaints, we can process your Personal data (as person, who submitted inquiry/complaint).

Processed Personal data: Name, surname, e-mail address, telephone number, message’s content, as well as any other Personal Data submitted in the inquiry or complaint.

Legal basis for the processing of Personal data: Personal data are processed on the basis of the Data subject‘s consent, which may be expressed by submitting an appropriate inquiry or complaint to the Firm.

Period of storage of the Personal data:1 (one) year from the date of submission of the relevant inquiry or complaint.

Source of the Personal data: Personal data are obtained from the Data subject.

4.5. Communication and publicity of the Firm’s activities (photography and filming). In cases when you participate in events, seminars or conferences organized by the Firm and are informed about the photographing or filming, or we obtain your consent in other way, we may process your image data captured in photos or in filmed material for the purposes of communication and publicity of the Firm's activities. The material obtained in this manner may also be made public, including in accounts of social networks administered by the Firm (Facebook, Instagram, etc.), on the Website or on other Websites administered by the Firm, in the media and through other channels. Please note that if you are participating in a particular event and do not want to be filmed or photographed, you should contact the person, who is filming or photographing, during the event and avoid cameras or other filming and shooting equipment.

Processed Personal data: Photos, videos.

Legal basis for the processing of Personal data: Personal data are processed on the basis of the Data subject‘s consent.

Period of storage of the Personal data: 2 (two) years or other term specified in the Data subject‘s consent

Source of the Personal data: Personal data are obtained from the Data subject when photographing or filming.

4.6. Direct marketing and advertising of products distributed by the Firm. In cases when we receive your separate consent for Direct marketing, we may process your Personal data in order to offer you the Firm‘s services and/or ask your opinion about offered services. Your Personal data will only be processed for the purpose and scope specified in the specific consent, for example, if you have agreed to receive the Direct marketing messages by email, we will not send you such messages by SMS. You have the opportunity at any time to disagree with the processing of Personal data for Direct marketing purposes and to withdraw your consent to process Personal data for this purpose. Additional information related to the processing of Personal data for this purpose is provided in section “Direct marketing” of the Privacy Policy.

Processed Personal data: Name, surname, telephone number, e-mail address, position, address of division, birth date (in specific cases).

Legal basis for the processing of Personal data: Personal data are processed on the basis of the Data subject‘s consent.

Period of storage of the Personal data: 2 (two) years from receipt of consent or another term specified in the Data subject‘s consent.

Source of the Personal data: Personal data are obtained from the Data subject.

5. STORAGE OF THE PERSONAL DATA

5.1. Your Personal data will be processed by the Firm for the periods established in this Privacy Policy above.

5.2. Please note that in some cases the longer period for the Personal data storage or our right to store the Personal data for the longer period may be established in applicable legal acts, e. g. in cases where the processing of Personal Data is necessary for compliance with a legal obligation to which the Firm is subject and which requires the processing of Personal Data, or when the processing of Personal Data is necessary for the establishment, exercise or defence of legal claims.

5.3. In such cases we may process your Personal Data for a longer period, but only to the extent necessary for these purposes of the processing of Personal Data. Such Personal Data will be erased as soon as the Personal data are no longer necessary in relation to the purposes for which they are processed.

6. THE DIRECT MARKETING

6.1. Your consent to the processing of Personal Data for the Direct marketing purposes is obtained in advance, i. e. prior to the processing of Personal Data for the Direct Marketing purposes.

6.2. Consent can be obtained in various ways, for example, at the time of signing a contract with the Data subject and at the same time requesting the consent of the Data subject, at the time of participating in events organized by the Firm, by filling in questionnaires and so on.

6.3. The Firm will use the Personal data for the Direct marketing purposes in order to provide information and/or promotional material about the Firm, the Firm's offers and news (including, but not limited to newsletters), information about events organized by the Firm (presentations, seminars, conferences, etc.) and invitations to participate in such events, also to organise such events, send greetings and etc.

6.4. The Direct marketing can be carried out in the following ways: by phone (during voice calls and/or via SMS), by email or by any other direct means.

6.5. Information on the exact Personal data processed for the Direct marketing purposes, data retention periods, legal basis for the processing and source of the Personal data is provided in the section “Purposes of the processing of Personal data, sources of data, categories of the Data subjects, other information related with the processing of your Personal data” of this Privacy Policy.

6.6. Right to object. You shall have the right to object at any time to the processing of Personal data for the Direct marketing purposes and to withdraw the given consent to the processing of Personal Data for this purpose (the withdrawal of the consent shall not affect the lawfulness of the processing of Personal data based on the consent before its withdrawal). Your withdrawal or disagreement will not affect your use of Firm’s services, but the Firm will no longer be able to provide you useful offers, information, news, etc.

6.7. You can revoke your consent by using functionality in the sent emails that allows you to unsubscribe, by replying to SMS sent by the Firm and expressing disagreement, as well as by contacting the Firm by email address indicated in this Privacy Policy below.

7. DISCLOSURE OF THE PERSONAL DATA

7.1. We may disclose your Personal Data only under the legitimate basis (for example, when required by legal acts, agreement concluded with you or when we have your consent) and in accordance with the requirements of applicable legal acts.

7.2. In addition to the cases already mentioned in this Privacy Policy, you are informed that we may transfer your Personal Data to the following entities:

a) service providers, who act as processors of the Personal Data and provide services to the Firm related to IT, Website support and maintenance, maintenance of applications used by the Firm, provision of servers and its maintenance, provision of platform for sending newsletter, etc.

b) in the cases specified in legal acts, to law enforcement and supervisory, as well as other state and municipal authorities, in order to comply with legal requirements, including to the State Tax Inspectorate;

c) persons providing services related to the performance of contracts concluded with you or your principal, including postal and parcel service providers;

d) bailiffs, courts, other bodies dealing with disputes;

e) other third parties, when you submit relevant request to submit your Personal Data, or to third parties, about which you are clearly informed in the other way and/or your consent is received and provision of the information is agreed while using the specific service;

f) companies providing Firm’s audit and related services, providers of legal and financial advisory services;

g) other business subjects, in case of Firm’s merger with other legal entity or acquisition, including to subjects carrying out legal due diligence.

8. YOUR (AS THE DATA SUBJECT) RIGHTS AND ITS IMPLEMENTATION

8.1. You, as the Data subject, have all rights specified in the applicable legal acts, including indicated down below.

a) Right to revoke the given consent. If you have given us your consent to process your Personal Data, you may revoke it at any time (withdrawal of the consent shall not affect the lawfulness of the processing of Personal data based on the consent before its withdrawal) by contacting us using the contact details specified in this Privacy Policy or by using other functionalities provided by the Firm (e. g., by clicking the link in the newsletter to unsubscribe the Direct marketing messages).

b) Right to request the access to your Personal Data. You can access your Personal Data, which are processed by the Firm. You can get information on how it is collected, period for which your data are stored and who and to what extent receive your data. However, your right of access may be limited by legal acts;

c) Right to request rectification of Personal Data. You may require the Firm to rectify processed Personal Data that is related to you, if it is incorrect, inaccurate or incomplete;

d) Right to object. Under the certain circumstances, you have the right to object the processing of your Personal Data, including when your Personal Data are processed on the basis of the legitimate interest. You also have the right to object the use of your Personal Data for the Direct marketing purposes (only if and when we process data for these purposes);

e) Right to restriction of the processing. If you think that your Personal Data processed by the Firm is incorrect or you disagree with the use of the data, you may require the Firm that the use of this data would be limited solely to storage. The use will be limited to the storage until the verification of the accuracy of the data or until the verification whether the legitimate grounds of the Firm override those of the Data subject.

f) Right to erasure. If your Personal Data are processed illegally, you disagree to such processing of your Personal Data or there are other legal grounds, you shall have the right to obtain from the Firm the erasure of the Personal data in accordance with the restrictions specified in legal acts.

g) Right to data portability. You have the right to get the Personal Data related to you, which you submitted to the Firm, in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller in accordance with the procedure established by legal acts.

h) The right to lodge a complaint. You also have the right to lodge a complaint to the State Data Protection Inspectorate, if you consider that the processing of Personal data relating to you infringes requirements of legal acts. However, we kindly as you to firstly contact us using the contacts indicated in this Privacy Policy.

i) Procedure of implementation of the Data subject’s rights. If you have additional questions or you want to implement your rights indicated in this Privacy Policy and related to the processing of the Personal Data, you should contact us by using the contacts indicated in this Privacy Policy (by email, by post (by sending to the indicated address) or physically upon arrival at the Firm's registered office). When submitting requests on rights related to the processing of Personal Data, you will be asked to confirm your identity (e. g. in case you submit an application by electronic means, you must sign it by electronic signature, in case you apply to the Firm upon physical arrival/send request by post, you must provide an identity document or a its copy confirmed in a manner prescribed by legal acts). We will only accept those requests on implementation of the Data subject’s rights that will be completed/submitted in a coherent and understandable state language (Lithuanian language), in readable characters, does not contain offensive or disrespectful expressions, clearly and specifically specifies the right(s) to be used and circumstances related to the implementation of the right. We will consider the request on the right(s) of the Data subject as unjustified and may not execute it in cases where it does not specify the right(s) to be implemented, as well as any other information required by the Privacy Policy or the GDPR. We may also not execute your request if we do not process your Personal Data, the appropriate documentation to identify your (or your representative) identity are not provided together with the request, the person submitting the request is not duly authorized or has no right to make the request (no Power of Attorney or other document granting the right to represent you is submitted) or legal acts do not provide possibility of satisfying your request. Please note that in cases where you abuse your right to submit the request, we have the right to charge a fee for execution of the request. We will respond to all your requests related to the implementation of your, as the Data subject, rights without undue delay and no later than within 1 (one) month after receiving the request. That period may be extended by 2 (two) further months by informing you in advance.

9. INFORMATION SECURITY

9.1. We use reasonable technical and organizational measures in order to secure our information (including the Personal Data) from the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to the Personal data.

10. THIRD PERSONS

10.1. The Firm does not control privacy policies and (or) other rules that are applied to you by the third parties. Therefore, you, at your own discretion and risk, are liable and obligated to comply with them in those cases, when it is applied to you (e. g., when links to websites not managed by the Firm are provided in the Website).

10.2. The Firm is not liable for other websites’ privacy policies or any other content, when reference to the other websites are given on the Website, or the reference to the Website is given on other websites.

10.3. When you are pressing the reference, logo or any other element of the Website, or when using the services available in the Website, we draw your attention that at the time, when you press any mentioned element, you may leave the Website.

10.4. The Firm does not collect any information about you from third parties, except the cases specified in the Privacy Policy, also when the legal acts’ requirements or third parties rights’ are infringed.

11. AMENDMENTS OF THE PRIVACY POLICY

11.1. The Firm shall have the right at its own discretion to adjust (including change, edit, supplement, cancel, annul) this Privacy Policy or any part thereof and any related information.

11.2. The updated Privacy Policy will be posted on the Website and will take effect from the date of its publication (the link "Valid from" at the top of the Privacy Policy indicates when the Privacy Policy was last updated)

11.3. At the moment of visiting the Website or its functionality, we recommend you to check the Privacy Policy and its updates and make sure that you are satisfied with the current version of the Privacy Policy. If you use the Website or any other functionality after publishing an updated Privacy Policy, you agree to the updated Privacy Policy.

12. FINAL PROVISIONS

12.1. This Privacy Policy is governed by the laws of the Republic of Lithuania. Any disagreement over the implementation of this Privacy Policy shall be resolved by negotiation. If the parties are unable to agree, disagreements shall be resolved in the manner prescribed by the laws of the Republic of Lithuania.

12.2. If you have any questions, claims or need our help with the interpretation or application of the Privacy Policy, or if you wish to exercise your rights as the Data subject, please contact the Firm using the following contacts: info@lextra.legal or by phone + 370 65067644.

12.3. We will try to respond to all your requests regarding this Privacy Policy and submitted in a written form immediately (we shall respond to all your requests related to the implementation of your, as the Personal Data subject, rights no later than within 1 (one) month from the receipt of the request, except for the exceptions specified in the legal acts or this Privacy Policy).