Privacy Policy

1. General Provisions This document (hereinafter – Privacy Policy) determines key principles of your (Client’s) personal data collection, processing and storage by Softera Baltic, UAB (data collected in Register of Legal Entities of the Republic of Lithuania, legal entity code 301566552, legal address V. Krėvės pr. 114C-23, LT-50315 Kaunas, e-mail address [email protected] (hereinafter – Company). Privacy Policy aims to protect Client’s personal data from unauthorized use. By processing personal data, we shall follow the Law on Legal Protection of Personal Data of the Republic of Lithuania, Law on Electronic Communications of the Republic of Lithuania and other directly applicable legislation regulating the protection of personal data, also instructions and recommendations by competent authorities.

Personal data means any information related to natural person – data subject who can be identified or identifiable by reference of relevant data.

Client means any person ordering, purchasing or using our Services or expressing intent to use or uses Company’s services in any way, or intends to buy or purchases Company’s goods, or is related to services or goods provided by the Company in any other way.

Processing means any operation which is performed on personal data (including collection, recording, storage, modification, access, inquiry submission, transmission, etc.).

Login information means Internet protocol (IP) address and Internet service provider used for connecting the device to the Internet, browser type and version, time zone settings, browser extension type and version, operating system and platform, connection location, font encoding, Uniform Resource Locator (URL), products viewed by you.

Regulation means 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 (General Data Protection Regulation).

The Company shall follow the following principles of personal data processing in its business activity:

• Personal data shall be collected for specified, explicit and legitimate purposes.
• Personal data shall be processed accurately and fairly.
• Personal data shall be processed lawfully, i.e., only in cases where:
  – data subject has given a consent, e.g., for receiving advertising information, unless such consent is not required in accordance with the requirements of legislation;
  – processing is necessary for the performance of a contract to which the data subject is party;
  – the Company is under obligation to process personal data in compliance with legislation;
  – personal data processing is necessary for the purposes of legitimate interests pursued by the Company or by a third party receiving personal data, except where such interests are overridden by the interests of the data subject.
• Personal data shall be accurate and regularly updated.
• Personal data shall be kept for no longer than is necessary for the purposes for which the personal data are processed.
• Personal data shall be processed only by employees who have been granted such right.
• All information about processed personal data shall be confidential.

Depending on the nature of supplied goods/services, the Company may collect the following data of the Client:

• main information of the Client: name, surname, telephone number, e-mail address;
• information about Client’s consent regarding direct marketing: information about Client’s consent/refusal regarding receipt of advertising information (news, offers, promotions, etc.), participation in opinion polls, data use;
• communication and Client service information: data about browsing Company’s sites and self-service websites (collected by using cookies and similar technologies); records of telephone conversations with Company’s representatives; information on correspondence with the Company (through self-service, via e-mail, applications, etc.); Client’s inquiries and Company’s replies on the matters to be addressed;
• other data: information about survey participants, newsletter subscribers.

The Company shall use collected data to be able to provide services, assistance, send notifications, offers and information about promotions, protect its own rights and interests as well as those of third parties, observe applicable legislation.

Information processing purposes:

• concluding and performing agreement (service provision), ensuring quality thereof, servicing Clients and providing information;
• direct marketing and general information about new products and services (if you have not unsubscribed from such notifications);
• accounting;
• performance of legal obligations, for example, debt management and recovery;
• administration and improvement of Company’s website, ensuring its security and presentation of its content in your devise in the most efficient way possible;
• performance of legal duties provided for in legislation;
• other purposes for which the Company has the right to process your personal data when you have given your consent, also, when processing is necessary for the purposes of the legitimate interests pursued by the Company or third parties, or when the Company is obliged to process data in accordance with relevant legislation. We may also process personal data for any other purpose, provided we have obtained consent of data subject.

We collect information about you in following ways:

• when you submit information to the Company yourself (e.g., filling in Company’s application, agreements and/or other documents (including through our partners), electronically on our website, by submitting inquiries, via e-mail, telephone, live video chats, other means of communication);
• your login data is recorded when you use Company’s website. The majority of information is collected through cookies and similar technologies (see Cookies Policy No. 13-14), depending on your acceptance/refusal (with the exception of strictly necessary cookies automatically downloaded to facilitate the use of the website);
• information about you is received from third parties with whom we collaborate (e.g., partners, state authorities, etc.).
• The Company uses Plaid Inc. (“Plaid”) to gather your data from financial institutions in the USA. By using Bankfeed, you grant the Company and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy.

The Company shall process personal data for no longer than is necessary for achieving and implementing the purposes specified in this Privacy Policy, taking into consideration the nature of goods/services provided to the Clients and agreements concluded with them, except in cases, where longer storage period of personal data and related documents is determined or permitted in accordance with applicable regulations and is necessary (e.g., mandatory document storage period, limitation period of a lawsuit, etc.).

To achieve purposes set in Privacy Policy, the Company may transfer you data to the following data recipients:

• data processors providing services and processing your data on behalf of the Company, in its interests or according to orders (e.g., IT service providers, etc.). Data processors shall process your personal data only according to explicit instructions provided by undertaking to ensure proper protection of personal data received from the Company and organization and technical measures complying with the requirements of security as specifically discussed in agreements concluded between the Company and subcontractors regarding data processing;
• entities engaging in debt and debtor database administration activity. Data shall be provided only to the extent and under conditions permitted by legislation;
• entities having the right to receive information according to the requirements of legislation (e.g., courts, state authorities and municipal institutions, etc.) to the extent necessary to properly comply with applicable legislation;
• other third parties on other legal grounds or according to your consent which may be obtained on a case-by-case basis;
• data processors receiving your personal data from the Company may be established outside the Republic of Lithuania, European Union or European Economic Area. Data shall be transferred to such data processors only if permitted by the laws by taking all necessary measures to ensure the protection of your privacy.

The Client shall have the following rights:

• contact us and discuss any issues related to personal data processing carried out by the Company;
• obtain Company’s confirmation whether personal data related to him/her are being processed; if such personal data are processed, he/she shall have the right to access personal data and related information;
• obtain personal data he/she submitted undergoing processing on the basis of consent or agreement in writing or in a commonly used electronic form; if possible, request the transfer of such data to other service provider;
• obtain from the controller the rectification of inaccurate personal data concerning him/her or complete incomplete data;
• obtain from the controller the erasure of personal data concerning him/her, as a Client of the Company, processed according to Client’s consent, if the Client withdraws his/her consent. This right shall apply if Client’s personal data requested to be erased are also processed on other legal grounds, such as processing necessary to perform agreement, performance of obligations in accordance with applicable legislation;
• obtain from the controller restriction of processing of his/her personal data, e.g., for a period enabling the Company to analyse whether the Client has the right to request restriction and if it is practically possible to erase his/her personal data;
• object to the processing of Client’s personal data to pursue legitimate interest of the Company or third parties if the basis for personal data processing is legitimate interest, also, if personal data are processed for the purposes of direct marketing, including profiling to the extent that it is related to such direct marketing;
• not to be subject to a decision based solely on automated processing, including profiling, if such decision making produces legal effects concerning Client or similarly significantly affects the Client. This right shall not apply if such decision making is necessary for entering into, or performance of, a contract with the Client, permitted by applicable legislation or is based on Client’s explicit consent;
• withdraw his/her consent for personal data processing;
• the Client shall be able to exercise his/her rights by submitting a specific request using contact information provided in Privacy Policy. Information related to the implementation of rights shall be provided to the Client free of charge. The company shall no later than within 1 month from the receipt of request, shall provide information to the Client about actions taken after receiving the request of the Client concerning the implementation of his/her rights or shall inform the reasons for not taking action.

The period for providing requested information may be extended by two further months where necessary, taking into account the complexity and number of the requests. Where the Client makes the request by electronic form means, the information shall be provided by electronic means as well.

The Company may refuse to act on the request or charge a reasonable fee where requests from a Client regarding the implementation of the rights are manifestly unfounded or excessive, in particular because of their repetitive character, also, in other cases provided for in regulations.

If, in Client’s opinion, his/her personal data are processed by violating his/her rights and legitimate interests under applicable legislation, the Client shall have the right to lodge a complaint concerning processing of personal data to State Data Protection Inspectorate.

If necessary, Privacy Policy may be updated. We have stored all previous Privacy Policy versions in the archive so you could get familiar with them. In case of material changes, we will make every effort to directly notify the Client.

If you have any questions, requests or comments on Company’s Privacy Policy or data processing, do not hesitate and contact us using the following contact information:
E-mail address: [email protected]
Contact person: Aiste Kytriene
Telephone number: +370 620 93555
Address: K. Donelaicio g. 62/V. Putvinskio g. 53 (BLC), 44248 Kaunas, Lithuania

Company’s website and products may contain references to third party websites. These third party websites have their own privacy policies. If you visit such websites, you will be subject to relevant policies.

Cookies are small text files that may be used in websites to improve user experience.

In accordance with legislation, we may store cookies on your devise only if they are necessary for the performance of this website. In connection with other types of cookies, we must obtain your consent. You may withdraw your consent for the use of cookies at any time. You may do so by changing website settings so that it would refuse cookies.

We use cookies to collect the following information: browser type, IP address, number of visits in website, viewed webpages, visit duration, demographic data, URL link of a page from which you came.

We use cookies for following purposes:

• ensuring website functionality;
• improving and developing the website;
• personalization of marketing content and flow analysis;
• presenting third party content.

This website uses the following cookies:

• strictly necessary cookies: to facilitate the use of the website, strictly necessary cookies activate main functions, for example, in browsing pages and enables access to protected areas of the site;
• statistical cookies: by using statistical cookies collecting anonymous information and reports, we are able to find out how the visitors interact with the website;
• marketing cookies: marketing cookies are used for monitoring visitors in many websites. The purpose is to display only customized advertisements that could be of interest to the user as such advertisements are of more value to the publishers and third party advertisers;
• third party cookies: the Company does not use or set these cookies. This is done by third parties. Third party needs cookies for sharing content on social networks or preparing statistics related to access. For this purpose, these cookies are forwarded to the users. The Company may not control recording of such cookies in the memory of visitor’s devise or the use thereof, therefore, the users must be interested in familiarizing with third party privacy policy and cookie policy.

Only the Company may use Company’s cookies. Third parties control third party cookies installed.

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