Privacy and Personal Data Processing Policy
We, UAB Ekskomisarų biuras, registration No. 122755433, address: Eigulių 14, Vilnius (hereinafter referred to as “Ekskomisarų biuras”), respect and protect the privacy of every client and visitor of our website and undertake to process their personal data in a fair and legitimate manner.
1. Categories of personal data
Personal data may be obtained directly from the client or indirectly if such personal data are disclosed during the time he/she is using our services and from external sources, such as public and private registers and other third parties.
The main categories of personal data collected by Ekskomisarų biuras (the list is not exhaustive):
Personal identity information, e.g. name, surname, personal identification number, birth date, data of an identity document (passport, ID card).
Contact details, e.g. address, telephone number, e-mail address.
Data on relations with legal persons, e.g. contact details of the client’s (legal person’s) representative.
Financial data, e.g. bank account details, information about debts.
Data obtained and/or created in compliance with legal requirements, e.g. data indicated in requests of law enforcement agencies, notaries, tax administrators, courts and bailiffs.
Video surveillance data, e.g. data collected by video recorders.
Data relating to the provision of services, e.g., data on the performance or non-performance of contracts, valid or expired contracts, applications, and complaints. This also includes data on behavioural habits, preferences, and satisfaction on services, e.g., data on clients activity using our services and types of services provided to the client, client feedback, and information whether the client is satisfied with the services, including audio record.
2. Purposes of and basis for processing personal data
The main purposes of processing personal data collected by Ekskomisarų biuras:
- Solvency assessment. Ekskomisarų biuras has a legitimate interest to assess client’s solvency in order to conclude a contract.
- Joint debtors’ data file management. Ekskomisarų biuras has a legitimate interest to manage joint debtors’ data file.
- Internal administration (business management, clerical work management, finance and accounting management). Ekskomisarų biuras has a legitimate interest to process personal data for this purpose, and processes these data in order to fulfil legal requirements and internal administration objectives (proper management of company’s business, clerical work, finances, and accounting).
- Debt Management. We process relevant personal data in order to manage the client’s debt and when this is necessary for the performance of the contract.
- Submission of legal claims, fulfilment of obligations, and defence of rights. We process personal data in order to be able to submit legal claims, fulfil or transfer obligations, and defend our rights when this is related to the performance of the contract, fulfilment of our legal obligations, or our legitimate interests.
- Direct marketing, asking customer’s opinion, market research. After obtaining the client’s consent, the Ekskomisarų biuras processes personal data for direct marketing purposes.
- Request management. Ekskomisarų biuras has a legitimate interest to process your personal data in order to be able to answer your requests.
- Conclusion and performance of contracts. We process your personal data in order to be able to conclude and perform contracts.
- Video surveillance (protection of property and people). Ekskomisarų biuras monitors its premises (inside and next to the entrances) using video surveillance cameras. Ekskomisarų biuras monitors its premises using video surveillance cameras because of the nature of the work it is necessary to ensure the safety of the property and people, and other means or measures may be insufficient and/or unsuitable (legal basis for the processing of personal data – legitimate interest of Ekskomisarų biuras to protect clients’ and its own property). Ekskomisarų biuras is also the processor of video data in the event that other data controllers entrust the Ekskomisarų biuras with the installation of video surveillance equipment and monitoring of the data controller’s premises. In such a case, Ekskomisarų biuras shall process video data in accordance with the conditions and instructions specified by these controllers.
3. Data storage periods
We process data for no longer than necessary for the purpose for witch the data were collected. The storage period of personal data is determined in accordance with the legitimate interest of the Ekskomisarų biuras or the requirements of the law (e.g., accounting and archiving requirements, limitation of action, etc.).
4. Categories of data recipients
Personal data collected for the above mentioned purposes may be transferred to data recipients, such as public offices and institutions, law enforcement institutions, courts and other dispute settlement institutions, and other persons performing their functions assigned to them by law (e.g., bailiffs, notaries, debt collection companies, bankruptcy administrators). Your data may also be transferred to legal consultants or consultants of other fields.
Ekskomisarų biuras may entrust other data processors (e.g., other security companies, direct marketing service providers, market research or business intelligence service providers, database software providers, database administration service providers, data censers, hosting and cloud service providers) with the processing of personal data. In such a case, Ekskomisarų biuras shall take all the necessary measures to ensure that such data processors are processing personal data in accordance with the instructions of Ekskomisarų biuras and relevant legal acts, and shall request to implement adequate personal data security measures.
5. Data transfer outside the European Union
Usually, personal data are processed within the European Union territory/European Economic Area (EU/EEA), but in certain cases they may be transferred and processed outside the EU/EEA.
Personal data may be transferred and processed outside the EU/EEA if the transfer is necessary for the conclusion and performance of the contract or you have given your consent as well as for the implementation of appropriate security measures. Appropriate security measures:
- there is a contract containing standard terms and conditions set out by the European Commission or containing other approved clauses; codes of conduct, certificates, etc. that were approved in accordance with the General Data Protection Regulation;
- a country outside the EU/EEA in which the recipient of the personal data is located ensures a sufficient level of protection of personal data in accordance with the decision of the European Commission;
- the data recipient is certified in accordance with the requirements (applicable to recipients located in the United States of America) set out in the Data Protection Agreement between the EU and the USA (also known as the “Privacy Shield”).
6. Your rights
You have the right to withdraw your consent to receiving newsletters and to collecting and processing your personal data for direct marketing purposes at any time by sending an e-mail to email@example.com.
You have the right to file a complaint with the State Data Protection Inspectorate if you assume that Ekskomisarų biuras is not processing your personal data properly.
Cookies are small files that the browser of your device accepts from the Website you are visiting and stores them on your device. Cookies allow the Website to save the information about your browsing habits, actions, searches, and settings so that you could use all the functionalities of the Website, also this makes all your next visits on the Website much easier and more useful. Cookies are valid for one year.
Cookies that are used on our Website:
- Performance (session) cookies. They are intended to improve website performance and collect general (anonymous) information about the usage of the Website.
- Permanent cookies (tracking cookies from Google Analytics). These cookies are used to analyse the behaviour of the Website visitors and collect general (anonymous) information about the number of the visitors of the Website, the pages they have visited, and the time they spent on our Website.
- Targeting (advertising) cookies. They are used to display promotional information that meets your interests.
How to disable cookies? Many browsers are set to accept cookies automatically. Having this information about the cookies will help you decide whether or not to disable the cookies on your browser. We would like to warn you that you may not be able to use some features of the Website if you disable the cookies. To avoid receiving cookies you can set your browser to reject all cookies or send a warning when a cookie is created.
These provisions may be changed without separate notice as we comply with the laws regulating the usage of cookies and take into account the generally accepted practices related to the usage of cookies.
8. Links to other websites
9. Personal data security
It is important for us to protect your personal data. We understand the importance of data security and the methods that are needed to protect information. We take all the necessary measures to prevent loss, misuse, or alteration of the information we have collected from you.
You should be aware that browsing the web poses many dangers to you, such as theft of confirmation data (data theft), disclosure of unencrypted information, virus infection, and illegal listening of private conversations on your computer.
Using a computer without an antivirus program and not upgrading your system may cause the risk of viruses and spyware recording your actions on your computer or they may interfere with your activity. You are responsible for keeping your system and antivirus programs up to date.
Beware of fake e-mails. Fake e-mails are messages that seem like sent by us. Usually these messages contain a link to a page where you are asked to enter your data for different reasons. This is an unlawful attempt to obtain personal data of the e-mail recipient in order to be able to access his/her accounts.
Please note that we do not send e-mails to our clients asking them to update their personal data or log in, so never update your information via the link sent to you by e-mail.
10. Limitation of our responsibility
We are not responsible for events that we cannot control directly. We cannot guarantee that there will be no malfunctions in protecting your personal data. Furthermore, we are not responsible for any direct or indirect events or damage caused using and/or providing your personal data, including, but not limited to, personal data security risks related to errors, unauthorized access by third parties, and any other factors that we cannot directly control.
11. Contact details
UAB Ekskomisarų biuras
Eigulių 14, Vilnius, Lithuania
Telephone: 8 (5) 212 41 61
You can contact the Data Protection Officer of UAB Ekskomisarų biuras by e-mail: firstname.lastname@example.org or by phone: 8 (5) 212 41 61.