1.1. UAB Mediafon Carrier Services (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 Carrier Services, legal entity code 304065315, address Olimpiečių st. 1-33, LT-09235 Vilnius, e-mail: [email protected]

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.

2.11.  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.

3.1.  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.

4.1.  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.

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

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 [email protected]

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 [email protected]

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.

7.1. 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 two ways to manage your cookies:

7.3.1.            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.

7.3.2.   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.

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.

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

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.

10.1. 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 [email protected]

Version 1.01 Updated: March 30, 2021

In this notice, we inform you how and where Mediafon Carrier Services, UAB (legal entity code 304065315, registered office address Olimpiečių g. 1-33, Vilnius), hereinafter referred to as “Company”, processes the data of the Company’s visitors in connection with the surveillance of the Company’s office by video cameras. 

Visitors to the Company’s office are informed about ongoing video surveillance by means of information signs with a video camera symbol and data controller details, which are presented before entering the monitored territory and/or room. 

The view is observed in the premises of the Company’s office (entrance to the reception area, the space from which access to workplaces provided for the Company’s employees, entrance to the manager’s office). 

The video surveillance in the stores is continuous. 

The Company ensures that video data is processed only by persons authorized by the Company who are introduced to the legal acts regulating legal protection of personal data. 

What categories of personal data do we collect? 

The image of the Company’s visitors and records related to the Company’s visitors, as well as all other personal data and actions of the Company’s visitors in the coverage area of the video surveillance cameras. 

When performing video surveillance, we collect the following information: videos, date and time of video capture, location. 

Why do we collect this personal data? 

We process the personal data of the Company’s visitors in order to:  

• first, perform real-time video surveillance in order to ensure the safety of persons (employees, other visitors to the Company’s premises) and the physical protection of material resources and information (hereinafter –  the Company’s property) managed by the Company’s ownership right or other legal basis;  
• second, manage video surveillance recordings in order to investigate security incidents of persons and Company assets. 

On what legal basis do we collect this personal data? 

Protection of our legitimate interest and essential interests. 

Where do we get this personal data? 

We collect personal data using technical means, i.e., IP cameras and records are stored in the data array inaccessible from the external network. This system does not use facial recognition and/or analysis technologies, nor does the image data recorded by them be grouped or profiled by a specific data subject (person). 

We may transfer personal data to: 

We may transfer personal data to: 

• first, service providers (such as security companies, software and hardware maintenance and service providers); 

• second, if the companies of the group of companies need to achieve the defined goals, it is possible that we will transfer your personal data to the related companies; 
• third, law enforcement authorities, state, and local authorities, upon their request or in pursuit of our legitimate interest, to state, exercise and defend legal claims (theft, damage to property or person, etc.). 

Your personal data is neither transferred nor processed in countries other than the EU and EEA countries. 

How long do we retain this personal data? 

Video surveillance recordings will be stored for a maximum of 14 (fourteen) days unless the records contain the information necessary to achieve the defined purpose. In this case, the record will be stored until the identified problem is clarified or the relevant investigation is completed. 

What rights do you have with regard to this personal data? 

You shall have the right to: 

• first, access to personal data; 
•  second, to demand correction of your personal data. Please be informed that due to the nature of video surveillance, there is no possibility to correct any personal data; 
• third, the right to object to the processing of personal data. Please be informed that due to the nature of video surveillance, we cannot guarantee that your right to object the processing of your personal data will be fully implemented, as the data is collected automatically; 
• fourth, the right to demand erasing your personal data. Please be informed that due to the nature of video surveillance, it is impossible to erase specific personal data; 
• fifth, in certain circumstances, you have the right to restrict the processing of your personal data. Please be inform that due to the nature of video surveillance, we cannot guarantee that it will be possible to fully implement your right to restrict the processing of personal data, as the data is collected automatically. 

Where do you apply for the exercise of the rights of data subjects? 

For questions related to the exercise of the rights of the data subject, please contact [email protected] and submit a properly completed data subject inquiry form, which you can fill in in in the following link: Form. You can also download, fill in and deliver the data subject’s inquiry form upon arrival at the following address: Olimpiečių g. 1-33, Vilnius, from 8 to 17, Monday to Fridays.