GENERAL INFORMATION
By this Privacy Policy, UAB Ovoko aims to inform you about the processing of personal data and your rights as a data subject (hereinafter referred to as “Privacy Policy”). The information contained in the Privacy Policy is relevant when you browse the website rrr.lt (hereinafter referred to as the “website”) and use the services provided therein, regardless of the device (computer, mobile phone, tablet, etc.) you are using.
The controller of the data processed on the website is UAB Ovoko, registered office at Žirmūnų str. 70 - 701, LT-09124 Vilnius, tel. +370 673 34330 , e-mail: help@ovokopack.com , legal entity number: 304401253, VAT number: LT100010771516.
Please note that UAB Ovoko provides intermediary services for the sale of goods that belong to third parties (sellers). UAB Ovoko is not liable for the lawfulness and security of the processing of personal data when sellers process your personal data in accordance with their procedures. With regard to processing of your personal data and exercising of your rights, you have the right to contact the person whose product you are purchasing.
It is very important that you read the Privacy Policy carefully as it contains important information about the processing of personal data and your rights.
We confirm that the data of visitors to the website shall be collected in accordance with the requirements of the applicable legislation of the European Union and Republic of Lithuania and the instructions of the controlling authorities. Technical and organisational measures appropriate to the risks of data processing are in place to protect the data we collect about visitors to the website against loss, unauthorised use and alteration.
The website and its services are intended for people aged 16 and over. Persons under the age of 16 must obtain the permission (consent) of their parents or other legal representatives before using the website and its services.
KEY TERMS USED IN THIS PRIVACY POLICY
Personal Data means any information relating to a natural person (data subject) whose identity is known or can be identified, directly or indirectly, by reference to personal data such as name, surname, personal identification number, address, e-mail address, Internet identifier, etc.
Processing means any operation or set of operations performed on personal data (collection, recording, use, access, storage, disclosure, etc.).
Other terms used in this Privacy Policy shall be understood as they are defined in 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) (hereinafter referred to as “Regulation (EU) 2016/679”), the Law on the Legal Protection of Personal Data, and other legal acts.
THE PURPOSES FOR WHICH WE PROCESS PERSONAL DATA AND THE CONDITIONS FOR THE LAWFULNESS OF THE PROCESSING OF PERSONAL DATA
In order to facilitate your using of our services, for the purpose of signing up on the website and administering your user account, we shall process your name, surname, telephone number, email address, IP address, login data, and other necessary data. Personal data shall be processed on the basis of the conclusion and performance of a contract for the use of the website in accordance with Article 6(1)(b) of Regulation (EU) 2016/679.
In order to enable us to conclude and perform a contract for the purchase of goods, to notify you about the progress of the order, to issue an invoice, to keep accounting records, we shall process your name, surname, address, telephone number, e-mail address, information about the goods ordered, invoice details, the chosen method of delivery of the goods, and other information on the performance of the contract, payment information, and other necessary data. The processing of personal data shall be carried out on the basis of the conclusion and performance of a contract and in order to comply with legal requirements, in accordance with Articles 6(1)(b), (c) of Regulation (EU) 2016/679.
For direct marketing purposes (when sending newsletters and advertising to website visitors, asking for their opinion on goods and services), we shall process email address and/or telephone number, information about orders placed, IP address, browsing data, other necessary data. Personal data shall be processed on the basis of consent, in accordance with Article 6(1)(a) of Regulation (EU) 2016/679, and for the purposes of the legitimate interests pursued by the Company, in accordance with Article 6(1)(f) of Regulation (EU) 2016/679 and Article 69(2) of the Law on Electronic Communications. Consent to the processing of personal data for direct marketing purposes shall be valid if given by a person aged 16 or over.
In order to be able to respond to your enquiry when you contact us through the website, we shall process your name, contact details, the content of the enquiry and the response, your IP address, and other information related to the enquiry. Personal data shall be processed on the basis of your consent in accordance with Article 6(1)(a) of Regulation (EU) 2016/679.
To ensure quality of service and to have evidence of communications that may have legal consequences we shall record conversations on the customer service telephone numbers published on our websites. Personal data shall be processed on the basis of consent and for the legitimate interests pursued by the company, in order to objectively resolve disputes with callers, in accordance with Articles 6(1)(a), (f) of Regulation (EU) 2016/679 and Article 61(2) of the Law on Electronic Communications.
For the purposes of publicity and advertising of the Company’s activities, we may process and publish on our websites and social network accounts images of persons, reviews of the Company’s activities, and other personal data that the person agrees to provide for the specified purposes. Personal data shall be processed on the basis of a consent, in accordance with Article 6(1)(a) of Regulation (EU) 2016/679.
In order to ensure that individuals can use the website and receive information society services, to analyse and improve the functioning of the website and the use of services, to display advertising messages, UAB Ovoko shall process personal data of website visitors obtained by means of cookies. For detailed information on the use of cookies, please refer to “Why and what cookies we use”. UAB Ovoko shall process personal data collected with the help of cookies on the basis of a consent and in accordance with the Law on Electronic Communications of the Republic of Lithuania.
UAB Ovoko may also process personal data for other purposes if it is necessary for the lawful conduct of its business, for complying with the requirements of accounting, tax and other legal acts, for defending against claims, lawsuits and for protection of the legitimate interests of UAB Ovoko.
Where personal data are processed on the basis of consent, the data subject may revoke his or her consent at any time by contacting UAB Ovoko using any of the contacts specified in the Privacy Policy, and where personal data is processed for the purposes of direct marketing – also by selecting the appropriate settings in the user account or by clicking the opt-out link in the e-mail. Please note that withdrawal of a consent does not affect the lawfulness of processing based on the consent carried out before the withdrawal of consent.
WHERE DO WE GET PERSONAL DATA FROM
We shall process the personal data that you provide when signing-up on the website and using our services, as well as the personal data generated while you are using the website (date and time of login, pages visited, etc.). The data collected shall include information about you, your device or your use of our website content.
We may also obtain personal data from third parties: payment service providers – on the payment you have made; social networking service providers – when you connect, for example, through your Facebook account; other parties, to the extent permitted by applicable law.
You can choose not to provide us with certain personal data, but this may restrict the functionality of certain features of the website or the provision of services (e.g. if you do not provide your contact details, we may not be able to respond to your enquiry, or if you do not provide the data necessary for a sales contract, we may not be able to enter into a contract and fulfill your order).
TO WHOM WE PROVIDE YOUR PERSONAL DATA
We undertake not to transfer your personal data to any unrelated third parties, except in the following cases:
- If you have consented to the disclosure of your personal data.
- We shall transfer your personal data to our partners who provide the delivery of goods or other services you have requested. We will only provide such service providers with as much of your personal information as is necessary to render the specific service.
- In order to be able to fulfil your order properly, we shall transfer your personal data to the seller whose product you are purchasing.
- To tax administration, law enforcement authorities and other public institutions in accordance with the procedure established by the legislation of the Republic of Lithuania.
We may transfer or make your personal data available to service providers of our choice (companies providing newsletter services, accounting services, maintenance of information systems, website hosting, data storage services, etc.). Service providers shall process personal data on behalf of and in accordance with the instructions of UAB Ovoko.
Your personal data may be transferred to third countries outside the European Union and the European Economic Area. We shall transfer personal data to third countries to the extent necessary to ensure the provision of our services and if at least one of the following conditions applies:
- The European Commission has issued a decision on the adequate level of data protection in a third country;
- The recipient has a contract in accordance with the standard contractual clauses approved by the European Commission, which provide for adequate safeguards;
- Where the provision of personal data is necessary for the performance of a contract concluded with you (e.g. the product must be delivered to a specified address), or in the implementation of pre-contractual measures taken at the data subject’s request (i.e. in the context of the condition laid down in Article 49(1)(b) of Regulation (EU) 2016/679).
HOW LONG DO WE STORE PERSONAL DATA
We shall store personal data for the periods set out below:
For the purpose of administering the user account, 5 years from the date of the last login to the account;
For the purpose of conclusion and performance of contracts for the sale of goods, for accounting purposes, during the term of the contract and for 10 years after the end of the contract;
for the purpose of administering and responding to enquiries, for 2 years from the date of the enquiry;
for direct marketing purposes, for 5 years from the date of consent or until you withdraw consent or object to the processing of personal data;
for 1 month, to ensure the quality of service and to have evidence of communication that could lead to legal consequences (recording of telephone conversations).
For the purposes of publicity and advertising of the company’s activities – as long as there is a need to publish the information, with a review of its relevance at least once every 2 years, or until the person withdraws consent.
Personal data collected by means of cookies shall be processed for the duration of the cookie.
After the expiry of the above time limits, the data shall be deleted so that they cannot be restored or shall be transferred to the State archives, if this obligation is imposed on UAB Ovoko by law.
HOW DO WE ENSURE THE SECURITY OF PERSONAL DATA
When processing personal data, UAB Ovoko shall implement the necessary organisational and technical security measures to protect personal data against accidental or unlawful disclosure or other unlawful processing. Data security measures shall be chosen taking into account the risks posed by the processing.
WHAT RIGHTS YOU HAVE
As a data subject, you shall have the following rights enforceable to the extent set out in Regulation (EU) 2016/679:
The right to know about the processing of your personal data;
The right to have access to and get a copy of your personal data;
The right to have inaccurate personal data rectified;
The right to request the restriction of the processing of personal data;
The right to have personal data erased;
The right to withdraw your consent to the processing of personal data;
The right to object at any time to the processing of personal data. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object to the processing of personal data without providing reasons for the objection. Where the processing of personal data is based on Article 6(1)(f) of Regulation (EU) 2016/679 (for legitimate interest), the reasons relating to the particular case must be stated.
The right to portability of personal data.
Data subjects may exercise their rights by contacting UAB Ovoko at Žirmūnų str. 70 - 701, LT-09124 Vilnius, or by e-mail to help@ovokopack.com . You can find out how to do this by reading the procedure for exercising the rights of data subjects, which is set out below.
If the data subject considers that his or her rights have been infringed, he or she shall be entitled to lodge a complaint with the State Data Protection Inspectorate (L.Sapiegos str. 17, Vilnius, LT-10312, www.vdai.lrv.lt) or the supervisory authority for data protection of another Member State of the European Union in which the data subject has his or her habitual residence or place of work (list of supervisory authorities: https://edpb.europa.eu/about-edpb/about-edpb/members_lt#member-lt). In all cases, please contact us before making a complaint so that we can find a suitable solution together.
If you have any questions regarding the processing of personal data or if you have any suggestions, please contact UAB Ovoko using the contact details above.
HOW YOU CAN APPLY TO EXERCISE YOUR RIGHTS
In order to exercise your rights as a data subject, you must submit a request to UAB Ovoko and provide proof of your identity. Please note that you do not need to submit a request if there are other ways to exercise your rights (e.g. by correcting personal data in your website user account, by clicking on an opt-out link in a direct marketing email, etc.). The request must specify which of the above rights you wish to exercise and to what extent.
The data subject may confirm the identity in the following ways:
Where the request is made by electronic means, it must be made from the email address provided by the user when signing-up on the website or be signed with a qualified electronic signature;
Where the request is submitted in person at the registered office of UAB Ovoko, an identity document must be produced;
Where the request is submitted by post, a notarised copy of the identity document or a copy of this document certified in accordance with another procedure established by legislation must be provided.
The requirement for the data subject to confirm his or her identity shall not apply if the data subject requests information on the processing of personal data pursuant to Articles 13 and 14 of Regulation (EU) 2016/679.
If UAB Ovoko has doubts about the identity of the data subject, or if we are unable to establish the identity of the data subject on the basis of the information provided in the request, UAB Ovoko may request additional information necessary to unambiguously confirm the identity of the data subject. When contacting UAB Ovoko, you can submit a free-form request.
UAB Ovoko will provide information on the action it has taken in response to the request no later than within one month from the date of receipt. In the case of complex or multiple requests, this period may be extended by a further two months, if necessary, depending on the complexity and number of the requests. In any event, UAB Ovoko will notify on the extension within one month from receipt of the request, by stating the reasons for the extension.
Should UAB Ovoko decide not to fulfil the request, it will notify you immediately, but not later than within one month from receipt of the request. You can challenge such a decision by appealing to the State Data Protection Inspectorate and seek other remedies.
THIRD-PARTY WEBSITES, SERVICES AND PRODUCTS ON OUR WEBSITE
The website may contain third-party banners and links to their websites and services, which are not under the control of UAB Ovoko. UAB Ovoko is not liable for the security and privacy of information collected by third parties. You must read the privacy provisions that apply to the third-party websites and services that you use.