The Privacy Policy (hereinafter referred to as the Policy) regulates the principles of collecting, processing and storing personal data of the visitors of UAB “Baltic Capital Partners” (hereinafter referred to as the Company) website https://balticcapitalpartners.com/ and the recipients of the social network accounts and newsletters, as well as determines the purposes and means of processing their personal data.
This Policy has been drawn up in accordance with the provisions of 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 (the “General Data Protection Regulation”) (“the Regulation”).
This Policy informs visitors to the Company’s website and social media accounts and recipients of newsletters about the processing of their personal data.
Terms Used
Personal data – any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, a personal identification number, location data and an online identifier, or to one or more factors specific to the natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.
Data Subject – a natural person – a visitor to the Company’s website and social media accounts and/or a recipient of newsletters, whose personal data is collected and processed by the Company.
Consent of the data subject – any freely given, specific and unambiguous indication of the data subject’s wishes, by means of a statement or an unambiguous action, by which he or she freely consents to the processing of personal data concerning him or her.
Data subject rights – the data subject’s ability to participate in and control the controller’s and/or processor’s activities when processing his/her personal data – to know, to be informed about the processing of his/her personal data; to have access to his/her personal data and how they are processed; to request the rectification or destruction of his/her personal data or the suspension, with the exception of storage, of the processing of his/her personal data where the processing is not carried out in accordance with the provisions of the legislation; to object to the processing of his/her personal data; to request the erasure of his/her personal data; to obtain the data concerning him/her which he/she has provided to the controller; and to lodge a complaint with a supervisory authority (the State Data Protection Inspectorate).
‘Processing’ – any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, sorting, organisation, storage, adaptation or alteration, retrieval, access, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination with other data, restriction, erasure or destruction.
Automatic processing – processing operations carried out wholly or partly by automatic means. These include any information and communication technology capable of carrying out processing operations on personal data, such as: computers, communication networks, etc.
Data Controller – Baltic Capital Partners UAB (legal entity code: 306386946; address: Konstitucijos pr. 7, Vilnius; e-mail:success@balticcapitalpartners.com; Tel. +370 520 84866)
Processor – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient – the natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether or not to a third party. However, public authorities which, under European Union or Member State law, may receive personal data in the course of a specific investigation shall not be considered as recipients.
Cookie – is a small text file that a website stores on your computer or mobile device when you visit it.
Personal data breach – a breach of security resulting in the unintentional or unauthorised destruction, loss, alteration, unauthorised disclosure, unauthorised access to, or unauthorised transmission, unauthorised storage or unauthorised processing of personal data.
Other terms used in this Policy shall have the meaning given to them in the Regulation and in other legal acts regulating the processing of personal data.
Principles for processing personal data
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The Company is guided by the following principles when processing your personal data:
- Personal data shall be processed only for the legitimate purposes set out in this Policy and shall not be further processed in a manner incompatible with those purposes (purpose limitation principle)
- Personal data is processed accurately, fairly and lawfully in accordance with the requirements of the law (principle of lawfulness, fairness and transparency);
- Personal data is processed in such a way that it is accurate and kept up to date as it changes (principle of accuracy);
- The Company shall process personal data only to the extent necessary to achieve the purposes of the processing (data minimisation principle);
- Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data were collected and processed (principle of limitation of storage period);
- When processing personal data, the Company shall apply appropriate technical and organisational measures to ensure adequate security of personal data, including protection against unauthorised or unlawful processing of personal data and against accidental loss, destruction or damage (integrity and confidentiality principle)
- The Company is responsible for ensuring compliance with the principles set out in this Policy and must be able to demonstrate compliance with them (accountability principle)
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Company processes your personal data:
- for the purpose of pursuing legitimate interests, as well as for the purpose of proper management and administration of the website, monitoring its traffic, ensuring its security, improving its performance, facilitating the search for information, and ensuring the provision of requests from Data Subjects, as well as for the purpose of marketing and marketing purposes (sending newsletters with the consent of the Data Subject).
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For the purposes set out in paragraph 2 of this Policy, the Company collects and processes the following data about you:
- Personal data: name, surname, nationality, name of country of residence, city of residence, age, telephone number, email address (if provided by you);
- Other personal data/information provided to the Company in your request/order;
- Personal data is obtained from you when you are required to provide such data by law or when you voluntarily provide such data.
- The Company also processes your personal data when you contact the Company by e-mail, by submitting a request on the Company’s website, by subscribing to newsletters, by sending information to the contacts indicated on the Company’s website or on the Company’s social network accounts. In such cases, the Company processes your personal data in order to administer requests and/or send newsletters, to ensure the quality of the services provided, and to defend and protect its legitimate interests.
- Irrespective of the manner in which the data are collected, they shall be kept only to the extent and for the period of time necessary to achieve the objectives set out, but not longer than the periods set out in the Index of General Document Retention Periods in the current version approved by Order of the Chief Archivist of Lithuania No. V-100 dated 9 March 2011 or in any other legal acts
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As a data subject, you have the right to:
- To know/be informed about the processing of your personal data;
- To know your personal data and how it is processed. The right to request information from the Community about what and for what purpose your personal data is processed
- Request rectification of your personal data. If you discover that the Company has processed inaccurate or incomplete personal data about you, you have the right to request that such personal data be corrected or supplemented;
- The Company shall process personal data only to the extent necessary to achieve the purposes of the processing (data minimisation principle);
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Request the erasure of your personal data (“right to be forgotten”). You have the right to ask the Company to erase your personal data on one of the following grounds:
– the personal data are no longer necessary for the purposes for which they were collected or otherwise processed
– you have withdrawn the consent on which the processing was based and there is no other legal basis for processing your personal data;
– You do not consent to the processing and there are no overriding legitimate reasons for processing;
– personal data have been processed unlawfully.
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Request to restrict the processing of your personal data. You have the right to request the Company to restrict the processing of your personal data on one of the following grounds
– You contest the accuracy of the data for a period of time during which the Company may verify the accuracy of the personal data;
– the processing of the personal data is unlawful and you do not consent to the erasure of the data and instead request the restriction of its use;
– You have objected to the processing pending verification that the Company’s legitimate reasons for processing the personal data override those of the data subject.
- To object to the processing of personal data. You have the right to object to the processing of certain optional personal data about you. Such objection may be expressed by not completing certain sections of the documents, or by subsequently requesting the cessation of the processing of your optional personal data. Upon your request, the Company will provide you with information on which of your personal data is processed on an optional basis. Upon receipt of a request to cease processing of personal data that is processed on an optional basis, the Company shall immediately cease such processing, unless this is contrary to legal requirements, and shall inform you thereof
- Move data. You have the right to receive personal data relating to you that you have provided to the Company in a structured, commonly used and computer-readable format and you have the right to transfer that data to another data controller, and the Company must not impede this
- The Company shall implement and ensure appropriate organisational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure or any other unauthorised processing
- Only those persons who have the right of access to such data shall have access to your personal data collected and processed by the Company and only when it is necessary to achieve the purposes set out in this Policy.
- The Company ensures proper network management, maintenance of information systems and implementation of other technical measures necessary to ensure the protection of your personal data.
- Your personal data may be disclosed to third parties who provide services to the Company to ensure the operation and maintenance of the information systems used by the Company. In such cases, your personal data is disclosed to third parties only to the extent necessary for the proper provision of their services.
- Your personal data may be disclosed to law enforcement authorities in accordance with the procedure provided for by the legislation of the Republic of Lithuania.
- In all other cases, your personal data may be disclosed to third parties only with your consent or on other lawful grounds.
- The information collected by cookies enables the Company to improve the performance of the website, ensuring that you can find information in a convenient and efficient way.
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The main cookies used on the Company’s website are:
Cookie Name Purpose of Processing Cookie Type Period of Validity track_uid .balticcapitalpartners.com Other 1 year _gcl_au .balticcapitalpartners.com Analytical 3 months query_parameters .balticcapitalpartners.com Other 1 month _ga_* .balticcapitalpartners.com Analytical 1 year 1 month 4 days _ga .balticcapitalpartners.com Analytical 1 year 1 month 4 days of.cookiesSupported .balticcapitalpartners.com Other Session _fbp .balticcapitalpartners.com Analytical 3 months _uetsid .balticcapitalpartners.com Functional 1 day _uetvid .balticcapitalpartners.com Functional 1 year 24 days MUID .bing.com Promotional 1 year 24 days MSPTC .bing.com Other 1 year 24 days ofs .balticcapitalpartners.com Other Session of.firstVisit .balticcapitalpartners.com Other Session of.lastPageviews .balticcapitalpartners.com Other Session of.humanVerified .balticcapitalpartners.com Other Session of.humanVerified.event .balticcapitalpartners.com Other Session JaH-CN2fmJ4ZENfk0b49,61290991770 .balticcapitalpartners.com Other Never lastExternalReferrer .balticcapitalpartners.com Other Never JaH-CN2fmJ4ZENfk0b49,61290991770_expiresAt .balticcapitalpartners.com Other Never _7h4CO6bmJ4ZENfk0b49,442045773335_expiresAt .balticcapitalpartners.com Other Never lastExternalReferrerTime .balticcapitalpartners.com Other Never _uetsid_exp .balticcapitalpartners.com Other Never _7h4CO6bmJ4ZENfk0b49,442045773335 .balticcapitalpartners.com Other Never _uetvid_exp .balticcapitalpartners.com Other Never wpEmojiSettingsSupports .balticcapitalpartners.com Required Session - Consent to the use of cookies is expressed by clicking on the “I AGREE” button on the website, when a message appears on the website stating that “In order to improve the quality of your browsing experience, for statistical and marketing purposes, this website uses cookies, which you can cancel at any time by changing your browser settings and deleting the cookies you have saved”
- You can withdraw your consent at any time by changing your browser settings and deleting the cookies you have saved. The procedure for doing this depends on the operating system and web browser you are using.
- If you delete the cookies that have been stored, some of the features of the Company’s website may not function as intended.
- With the Data Subject’s consent, the Company may send newsletters to the Data Subject for marketing and marketing purposes, containing information about the services provided, relevant customer information and other direct marketing content.
- The Company shall send newsletters to the Data Subject until the Data Subject’s consent is withdrawn.
- The data subject shall be given the opportunity to easily opt-out of receiving newsletters and to object to further such direct marketing content. This option is made available to the Data Subject by clicking on a link in the email containing the newsletter itself.
- If the Data Subject opts out of receiving further newsletters containing direct marketing content, the newsletters shall no longer be sent to the Data Subject.