1.              GENERAL PROVISIONS

1.1. UAB Mediafon Technology (hereinafter referred to as “we”, “our”) is committed to protecting and respecting your privacy. We make every effort to ensure that our processing of personal data complies with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the Protection of Individuals with Regard to the Processing of Personal Data and on the Free Movement of Such Data of 27 April 2016 and repealing Directive 95/46/EC (General Data Protection Regulation).

1.2.  The controller of your personal data is UAB Mediafon Technology, legal entity code 304067476, address Olimpiečių st. 1-33, LT-09235 Vilnius, e-mail: dataprotection@mediafon.lt 

1.3. Please read this Privacy Policy carefully to understand the purposes for which we collect your data and how we will use it.

1.4.    The privacy policy covers the following topics:

1.4.1. The purposes for which your personal data will be used;

1.4.2. cases of transfer of personal data to third parties and data transferred;

1.4.3. The period of storage of your personal data;

1.4.4. marketing messages;

1.4.5. Your rights;

1.4.6. use of cookies;

1.4.7. processing of children's personal data;

1.4.8. Privacy Policy changes;

1.4.9. ways to contact us.

1.5.   When you visit our website for the first time, we will ask you to confirm that you agree to the use of cookies in accordance with the terms and conditions of this Privacy Policy, or that we will only use the necessary cookies, we will not collect your data or ask for your consent.

 

2.               HOW WE USE YOUR PERSONAL DATA

 

How do we use data?	How long do we store?	Goals. Why do we use them?
1.1          The history of your communication with us  (Information you provide, such as by phone (recording of a phone call or voice message left when you call our customer service line or when you are called by our staff) or via email)
By providing services and assistance to ensure uniform and good quality service and to protect our interests.	We will keep the data of such communication for this purpose for no longer than 2 (two) years from the end of the communication.		This is necessary in order for us to be able to fulfil our contractual obligations to you and to have evidence in the event of a dispute over the quality of services and/or the fulfilment of your contractual obligations. Also to provide you with the highest level of service.
To perform the tenders. You provide us with your personal details when you send us your CV, cover letters. If you contact us in writing or via email, we will save the correspondence data.	We will keep your data for this purpose for no longer than 3 (three) months from the end of the tender. The personal data subject shall be deemed to have given his or her consent to the processing of his or her personal data for the purpose of the competition by submitting his/her CV or filling them in on an electronic card.		Processed for the purpose of tendering, statistics and document management
1.2        Information about your device Information you provide to us while browsing our website, including Internet Protocol (IP) address and device type, screen resolution and (if you choose to share information with us) your location data (IP geolocation), as well as information on how to you use our website)
In order to improve our website as well so that we can set default options for you.	We will keep your data for this purpose for a maximum of 2 (two) years from the date of your last login.		In this way, we aim to ensure the most enjoyable browsing experience possible.
On fraud prevention and detection. To protect our website and applications.	We will keep your data for this purpose for a maximum of 2 (two) years from the date of your last login.		This is necessary to prevent fraud and detect fraud to protect you and Mediafon.

 

 2.11.  We use your personal data for the purposes set out in this Privacy Policy and where it is necessary to comply with or defend legal requirements. For this reason, we process your personal data on the basis of a legitimate interest in order to protect and ensure your, you and rights of others.

2.12. We may also process your personal data when it is necessary to fulfil a legal obligation to which we are bound or to protect the vital interests of you or another natural person.

 

3.    WHAT PERSONAL DATA DO WE TRANSFER TO THE THIRD PARTIES

3.1.                We want to gain and maintain your trust, so we will only transfer your personal data when necessary.

3.2. We may transfer your personal data to the following categories of data recipients:

3.2.1. We may disclose your personal information to any of our group companies (including our subsidiaries and our holding company and all of its subsidiaries);

3.2.2. We may transfer your personal data to our insurers and professional advisers for risk management, professional advice or to make, enforce or defend legal claims;

3.2.4. For specific services, we may transfer your personal data to other service providers, such as website hosting service providers, server and maintenance service providers, email service providers, customer service centres, and service providers of data protection officer.

3.3. We shall use only those service providers who have implemented appropriate technical and organizational measures to ensure an appropriate level of security of data processing complying with the risk of infringement of the rights or freedoms of the natural persons whose data will be processed under the Data Protection Agreement and such processing of data would ensure the requirements of the General Data Protection Regulation.

3.4. We may transfer your personal data not only in the above cases, but also in fulfilment of our legal obligations, as well as in the event that there is a need to protect the interests of you or other persons. For the purposes of direct marketing, we may, with your consent, transfer personal data to our partners who provide us with marketing services.

3.5. The recipients of the data referred to in this Part may also be established outside the Republic of Lithuania, the European Union or the European Economic Area. We will only transfer your personal data to third parties who comply with the requirements of the General Data Protection Regulation.

4.    HOW LONG DO WE STORE YOUR PERSONAL DATA

4.1.  In all cases, we store your personal data for no longer than is necessary to achieve specific purposes. Detailed information about the storage periods of personal data can be found in the "How do we use your personal data" section of this Privacy Policy.

 

5.    MARKETING ANNOUNCEMENTS

5.1.        Your data is not processed for direct marketing purposes and direct marketing messages are not provided to you.

 

6.    YOUR RIGHTS

6.1.                 In this section of the Privacy Policy, we review your rights under data protection law. Some rights cover many aspects, so we only cover the basic ones in this Privacy Policy. We recommend that you look into the relevant legislation and supervisory guidelines to be fully aware of these rights.

6.2. You have the following personal data protection rights:

6.2.1. the right to receive information on the processing of personal data;

6.2.2. the right of access to our personal data which we store;

6.2.3. the right to request the rectification of your personal data, which we store;

6.2.4. the right to ask us to remove your personal data ("right to be forgotten");

6.2.5. the right to restrict the processing of your personal data;

6.2.6. the right to object to the processing of your personal data;

6.2.7. the right to object to the processing of your personal data for direct marketing purposes;

6.2.8. the right to data transfer;

6.2.9. the right to withdraw consent to the processing of your personal data;

6.2.10. the right to submit a complaint to the supervisory authority.

6.3. If you want to exercise your rights, or have questions about the processing of your personal data or the implementation of rights, write to us by e-mail dataprotection@mediafon.lt 

6.4. Right of access to the processing of personal data. We provide information about the processing of your personal data during data collection. You can also always find it in this Privacy Policy or by receive by email dataprotection@mediafon.lt 

6.5. The right of access to your personal data that we process. You have the right to receive confirmation from us do we process your personal data. When we process your personal data, you have the right to access the processed personal data and information about their processing, such as the purposes of personal data processing, categories of personal data, recipients of personal data, etc. We will provide you with a copy of your personal data. You have the right to receive your personal data in a structured, commonly used and computer-readable format. However, you will not be able to exercise this right in cases where it may adversely affect the rights and freedoms of others.

6.6. We have the right to refuse to provide the data we process if the circumstances specified in the legislation under which personal data are not provided are established.

6.7. The right to request the rectification of your personal data, which we store. You have the right to correct any inaccurate personal data and, in accordance with the purposes of the processing, to supplement any incomplete personal data.

6.8. The right to delete your personal data. You may exercise this right when: (i) personal data are no longer needed for the purposes for which they were collected or otherwise processed; (ii) you withdraw your consent and there is no other legal basis for processing the data; (iii) you do not consent to the processing of personal data in our legitimate interest or of a third party; (iv) personal data are processed for direct marketing purposes, (v) personal data have been processed unlawfully; (vi) personal data must be deleted in accordance with the requirements of the legislation applicable to us. Please note that in certain cases you will not be able to exercise this right due to applicable exceptions. These exceptions cover cases where the processing of personal data is necessary in order to: (i) exercise freedom of expression and information; (ii) fulfil our legal obligations; or (iii) make, enforce or defend legal claims.

6.9. The right to restrict the processing of your data. This right may be exercised in the following cases: (i) if you dispute the accuracy of personal data; (ii) when personal data is processed unlawfully but you do not want it deleted; (iii) when personal data is no longer needed for the purposes of our processing, but you request it for the purpose of making, enforcing or defending legal claims, or (iv) if you do not consent to them being processed in our legitimate interest or by a third party until the grounds for your objection have been verified. If the processing of personal data is restricted, we may continue to store your personal data, but we will not further process it, except: (i) with your consent; (ii) filing, enforcing and defending legal claims; (iii) to protect the rights of other natural or legal persons; or (iv) due to important public interest.

6.10. The right to object to the processing of your personal data. You may exercise this right for any purpose related to your particular situation, but only to the extent that we use the data for our or third party's legitimate interests. If you object, we will no longer process personal data unless we can prove that the data are processed for reasonable legitimate reasons which take precedence over your interests, rights and freedoms, or to assert, enforce or defend legal claims and/or our lawful requirements.

6.11. The right to object to the processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you do not agree, we will no longer process your personal data for this purpose. We do not currently process your personal data for this purpose.

6.12. Right to data transfer. You will be able to exercise this right in cases when we process your personal data by automated means (computers, etc.) and the legal basis for the processing of personal data is:

6.12.1. Your consent (we do not currently collect such data), or

6.12.2. Performance of the contract or actions performed at your request prior to the conclusion of the contract.

6.13. The right to withdraw consent to the processing of your personal data. In cases where the legal basis for the processing of your personal data is consent, you have the right to withdraw the consent at any time. Withdrawal of consent will not affect the lawfulness of the processing prior to the withdrawal.

6.14. Right to submit a complaint to the supervisory authority. If you believe that we are violating personal data protection legislation by processing your personal data, you have the right to lodge a complaint with the State Data Protection Inspectorate, whose registered office address is L. Sapiegos str. 17, LT-10312 Vilnius, www.vdai.lrv.lt. In all cases, please contact us before filing a complaint so that we can find a suitable solution together.

7.    HOW DO WE USE COOKIES

7.1. Our website, like many others, also uses cookies. These are small data files stored on your computer that help us deliver content faster and more reliably. When you visit or use our websites, as well as through our services,  applications, tools or messaging channels, we or our authorized service providers may use cookies to help us serve you better, faster and more reliably, as well as for promotional purposes.

7.2. Cookies do not normally contain any information that could directly identify the user, but your personal information that we process may be linked to your use of a computer or other device, including browsing websites and other information obtained and stored through cookies.

7.3. There are three ways to manage your cookies:

7.3.1. External sources;

• We use Google Analytics service on our website to find out how visitors use the content of the website. For example, Google Analytics uses a set of cookies to collect information and report site usage statistics on Google without personally identifying individual visitors.
• You can read more about Google's privacy policy here.
• If you do not want your browser to use Analytics, you can install the Google Analytics Opt-out Browser Extension.

7.3.2.            Browser settings;

Many web browsers and additional add-ons designed specifically for this purpose allow users to cancel or delete cookies. These steps vary depending on the specific browser and its version. You can access the latest information on how to block or remove cookies yourself from service providers' own websites, such as Chrome, Firefox, Internet Explorer, and Safari.

Please note that by deleting or disabling cookies in advance, you will continue to be able to use our website properly.

 

7.3.3.   Cookies on our website.

 

Necessary

To make the website easier to use, the necessary cookies activate basic functions, such as browsing the pages and accessing the protected areas of the website. Without these cookies, the website will not work properly.

 

Name	Provider	Purpose	Expiry	Type
cookieDirective	mediafoncs.lt	Remembers whether consent has been given for the use of cookies	24 h	HTTP Cookie
carrierservices	mediafoncs.lt	Used to save a session ID during a single visit. Does not collect private information. Is required for website operation.	Until end of the session	HTTP Cookie
_ga	Google	The main cookie used by Google Analytics is _ga. The _ga cookie allows the service to distinguish between different users without personally identifying individual visitors. It is used on any website that has Google Analytics installed.	2 years	HTTP Cookie
_gat	Google	Uses Google Analytics to limit the speed of queries.	24 h	HTTP Cookie
_gid	Google	Uses Google Analytics to differentiate users.	24 h	HTTP Cookie

 

7.4.                 Third Party Websites

7.4.1. We may work with third parties (commonly referred to as service providers) who, with our permission, have the ability to place third party cookies on websites or in our service locations, or on our applications and tools. These service providers help us to serve you better, faster and more reliably.

7.4.2. Please note that third-party cookies are subject to the privacy policies of third parties, and we do not accept any responsibility for the privacy practices of third-party cookies.

 

8.    PROCESSING OF PERSONAL DATA OF CHILDREN

8.1.  The services provided on our website are intended only for persons over 16 years of age.

9.    CHANGES TO THE PRIVACY POLICY

9.1. We may periodically change this Privacy Policy to properly reflect how we handle your personal information.

9.2. If we make significant changes, we will notify you on the Website so that you can review these changes before continuing to use our website.

10.   HOW TO CONTACT US

10.1. We always want to hear feedback from our customers and are ready to answer any questions you may have.

10.2. Feel free to contact us if:

10.2.1. you have any questions or feedback regarding this Privacy Policy;

10.2.2. you want us to stop using your personal data;

10.2.3. you want to exercise your rights under the Privacy Policy or file a complaint.

10.3. You can contact our data protection officer at dataprotection@mediafon.lt 

 

Version 1.01 Updated: March 30, 2021