The group of companies Penki Kontinentai (the list of the companies of the group is available at https://5ci.lt/grupe/) cares about the privacy and protection of your personal data and therefore undertakes to respect and protect personal information.
When processing customers’ personal data, the Group of Companies complies with the Law on Legal Protection of Personal Data of the Republic of Lithuania, the General Data Protection Regulation 2016/679 of the European Union, the Law on Electronic Communications of the Republic of Lithuania and other directly applicable legal acts regulating personal data protection, as well as the instructions of the competent authorities.
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PROCESSING OF PERSONAL DATA
When collecting and processing your personal data, the group of companies Penki Kontinentai follows, among other things, the following basic data processing principles:
- personal data are collected only for clearly defined and legitimate purposes,
- personal data are processed only lawfully and fairly,
- personal data are constantly updated,
- personal data are stored securely and for no longer than required for the established purposes of data processing or legal acts,
- personal data are processed only by those employees of the Group who have been granted such a right in accordance with their work functions.
The data are processed only if one or several lawful processing criteria exist: (i) to ensure the provision of services under the contract (i.e., to perform the contract or to take action at the request of the data subject before the conclusion of the contract), (ii) the consent of the data subject has been received, (iii) the processing is necessary to fulfil a legal obligation of the Group, (iv) the processing is necessary to protect the vital interests of the data subject or other natural person, (v) the processing is necessary to protect the vital interests of the Group or a third party.
When processing and storing personal data, the group of companies Penki Kontinentai implements organisational and technical measures that ensure the protection of personal data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing. Access to personal data processed by the group of companies Penki Kontinentai is limited to those employees of the group of companies Penki Kontinentai and auxiliary service providers who need it for the performance of work functions or to provide services to the group of companies Penki Kontinentai.
Data processors have the right to process the personal data only in accordance with the instructions of the group of companies Penki Kontinentai and only to the extent necessary for proper execution of contractual obligations.
PURPOSES OF THE PROCESSING OF PERSONAL DATA
The group of companies Penki Kontinentai processes personal data for the following purposes:
- to conclude and perform services agreements; for the accounting of customers and payments under the existing agreements; to protect creditor interests and prevent material losses; to recover debts of subscribers. The processing involves personal data necessary to ensure proper provision of services to the Group’s customers, accept and execute orders, properly serve customers, identify and eliminate various failures and incidents, issue invoices for equipment and/or services, perform credit control, recover debts, handle complaints, etc.
- for direct marketing purposes. The processing involves both depersonalised and personal data.
- to ensure the protection of staff, customers and other persons entering the area of video surveillance, and the protection of property (video surveillance, visitor registration).
- To ensure proper provision of services; to conclude and perform services agreements; to assess customer solvency and manage debts; to assess the quality of customer service; to protect and secure rights and legitimate interests of the group of companies Penki Kontinentai; to collect evidence. The Group processes recorded phone conversations with customers who call the Customer Service Centre of the group of companies Penki Kontinentai or receive calls from the Group’s employees, and the information provided during the phone conversations in order to be able to properly assess your solvency, debts, conclude agreements with you and ensure the quality of the services provided.
- for other purposes for which the group of companies Penki Kontinentai has the right to process your personal data with your consent, where the processing is necessary for the legitimate interest of the company or when the processing is required by the relevant legislation. Personal data may be processed for other purposes if your consent has been obtained. Personal data is also processed in order to properly fulfil the statutory obligations of customers related to accounting, provision of data to competent authorities, etc., when this is required by the applicable legislation.
TYPES OF PERSONAL DATA PROCESSED
- Key information: name, surname, national identification number, date of birth, address, details of the identity document, phone number, email address.
- Data relating to the provision of equipment and/or services, such as information about the service ordered and its order details, information on invoices issued, information on payment for services, telephone number, email address.
- Information on consent or absence of consent to the processing of personal data for direct marketing purposes.
- Data generated through the use of means of communication and services of the group of companies Penki Kontinentai, such as traffic data: connection start date, time, duration, the calling subscriber’s number, number of the subscriber receiving the call, the user’s IP address used during the connection, etc.
- Other information on the use of services, such as data collected using cookies and similar technologies related to web browsing.
- Video data captured by the video surveillance equipment of the group of companies Penki Kontinentai when you visit its stores in order to ensure the security of staff, customers and premises.
- Recorded phone conversations with customers calling the Customer Service Centres of the group of companies Penki Kontinentai or receiving calls from the employees.
WHERE DO WE GET YOUR PERSONAL DATA FROM?
The group of companies Penki Kontinentai processes your personal data:
- which you provide when you communicate with the employees of the Group or have a legal relationship with the Group, purchase PENKI services or register for services, subscribe to news or request information.
- which are generated when you use the Group’s network and services (e.g., send an email or visit the Group’s website).
- which we receive from other sources, such as other service providers or publicly available registers.
You are not required to provide any personal information, but if you so choose, the group of companies Penki Kontinentai may not be able to provide you with certain services.
When submitting your personal data, you assume responsibility for the accuracy, correctness and completeness of the data provided. If your personal data changes, you must immediately inform the Group thereof. The Group will not be liable for any damage caused to a person and/or third parties due to the fact that you provided incorrect and/or incomplete personal data or did not request the addition and/or change to the data as a result of any changes in the data.
WHOM WE SHARE YOUR PERSONAL DATA WITH?
Your data may be transferred to the following third parties, including but not limited to:
- state authorities and institutions, other persons performing the functions assigned by legislation (e.g. supervisory authorities, law enforcement agencies, tax administrator, bailiffs, notaries, lawyers),
- auditors, legal and financial advisors,
- public registers,
- courts, extrajudicial dispute resolution bodies, bankruptcy administrators,
- debt recovery companies, to which debt claims are transferred,
- service providers administering joint debtor data (e.g. CreditInfo Lietuva UAB),
- other persons who provide services to the group of companies Penki Kontinentai or are related to the services provided by the group of companies Penki Kontinentai (e.g. information technology service providers, postal service providers, archiving service providers, credit intermediaries, etc.).
TRANSFER OF DATA OUTSIDE THE EU/EEA
We normally process and store your personal data within the European Union or the European Economic Area (EU/EEA), but we may transfer your personal data outside the EU/EEA, for example when this is necessary for the conclusion and performance of a contract or if you have consented to such transfer. We transfer your personal data outside the EU/EEA if at least one of the following measures is implemented: the European Commission has recognised that the receiving country ensures an adequate level of protection of personal data; the contract is concluded in accordance with the standard conditions approved by the European Commission; compliance with codes of conduct is ensured or other safeguards under the General Data Protection Regulation are applied.
HOW LONG YOUR DATA WILL BE RETAINED?
Personal data shall be processed for no longer than necessary for achieving the purposes for which the data is processed or no longer than required by the Data Subjects and/or provided for by the legislation. Longer retention of personal data can only take place when: (i) there are reasonable suspicions of an illegal activity that is under investigation; (ii) your data is necessary for the proper resolution of a dispute or complaint.
If you withdraw your consent to the processing of data or the data processing period expires (when the data is processed on the basis of your consent), only the data confirming your consent (10 years after the expiry or withdrawal of the consent) will be retained to make, enforce or defend the legal claims of the group of companies Penki Kontinentai.
REGISTERING PHONE CALLS AND RECORDING PHONE CONVERSATIONS
In order to prove the content of the conversation, conclude or amend services agreements, ensure proper internal administration, staff training, the group of companies Penki Kontinentai processes the following personal data of persons calling the phone number of the group of companies Penki Kontinentai specified on the website: phone number, the date and time of the call, the specific service ordered, information on whether the caller is an existing/new customer, the result of the call, additional information, a record of the phone conversation. The phone conversations are recorded with the consent of the persons, other data about the call are collected in pursuit of the legitimate interest of the group of companies Penki Kontinentai to communicate effectively and to avoid disputes related to personal service. The recorded phone conversations are stored for 3 months and other data about the call are stored for 6 months after the date of the call. The recorded phone conversations regarding the conclusion or extension of a contract are stored for 10 years after the conversation was recorded.
The data of calls are transferred to the processors responsible for:
- administration of phone calls of and recording of phone conversations with persons calling the group of companies Penki Kontinentai,
- recording of missed phone calls and forwarding information to the group of companies Penki Kontinentai.
If you do not consent to the recording of the phone conversation, please do not continue the conversation and/or contact us by email firstname.lastname@example.org.
REGISTERING FOR SERVICES
For the purpose of customer registration and ordering of services, the group of companies Penki Kontinentai processes the following personal data: name, surname, phone number, email address, the desired service and the data specified in the field ‘Remarks’. In addition to the information provided by you for the above purpose, the group of companies Penki Kontinentai also processes the date of registration for the services.
The legal basis for the processing of this personal data is the future conclusion of a services agreement. The group of companies Penki Kontinentai stores personal data collected for the purpose of customer registration for one year from the date of customer registration. Your rights in relation to the processing of personal data are specified in the PROCEDURE FOR THE EXERCISE OF RIGHTS section of the Policy.
Each visitor to the website can subscribe to news about the services offered by the group of companies Penki Kontinentai and the available promotions (subscribe to the newsletter) by entering their email address in the newsletter subscription form at the bottom of each website page. The basis for processing a newsletter subscriber’s email address is the subscriber’s consent to receive newsletters.
The newsletters of the group of companies Penki Kontinentai are also sent to recipients of services in the legitimate interest of the group of companies Penki Kontinentai to inform them about the available promotions and similar services, unless the recipients of services objected to the processing of their personal data for direct marketing purposes before or after the service was provided. The following data of the recipients of services are processed for direct marketing purposes: name, surname, phone number, email address.
Both the subscribers to the newsletter and other recipients of the newsletter may unsubscribe from the newsletter of the group of companies Penki Kontinentai at any time by clicking on the unsubscribe link or sending a request to email@example.com. Personal data are processed for direct marketing purposes for five (5) years from the date of subscription to the newsletter or the last day the service was provided.
VIDEO SURVEILLANCE FOR THE PROTECTION OF THE GROUP’S PROPERTY AND INDIVIDUALS
Video surveillance is carried out at the following addresses: Kareivių g. 2, Kalvarijų g. 135 and 137, and Stulginskio g. 5, Vilnius. Video surveillance is carried out for the purpose of protecting the property of the group of companies Penki Kontinentai and individuals, on the basis of the legitimate interests of the group of companies Penki Kontinentai and third parties. The collected data: video recordings, date, time and place of recording.
Data recorded by video cameras in the group of companies Penki Kontinentai are stored for two (2) months from the moment of recording. Upon expiry of the video data storage period, the video data are automatically overwritten, thus deleting the data of the oldest period.
The video recordings may only be used to expose suspected criminal activities and administrative offences or as evidence of damage caused to the property of the Group’s employees, service providers, third parties or the group of companies Penki Kontinentai, and may be transferred only to the persons who have the right to receive such data in accordance with the laws.
Permission to view the video recordings may be given and, if necessary, the video recordings may be transferred to law enforcement authorities. If the video recordings are viewed outside the premises of a law enforcement authority or court, the viewing must take place in a closed room within the premises of the group of companies Penki Kontinentai. The persons who have the right to participate in such viewing are the data subject, the responsible employee of the group of companies Penki Kontinentai, representatives of law enforcement authorities.
When there is reason to believe that video surveillance materials have captured a crime or other illegal activity, the required video data/episodes are transferred to secure media and stored for as long as there is an objective need.
The data subject has the right to view the video recordings related to the processing of their data, if their retention period has not expired. At the request of the data subject, the Group may provide (by electronic means) images of the video recording or the video recording in the medium provided by the data subject (i.e., the applicant) or that of the group of companies Penki Kontinentai.
If upon receipt of the data subject’s request to provide the video recording it is found that third parties have been captured in the video recording beside the data subject, third parties seen in the video recording are digitally anonymised/blurred, and other information that may violate the privacy of third parties must be redacted or the possibility of identification of third parties must otherwise be eliminated.
PROCESSING OF DATA OF VISITORS
The following data of visitors are recorded in the registration log of the security post: name, surname, legal entity represented, date and time of visit, the person visited. These data are retained for up to 10 years.
PROCESSING OF PERSONAL DATA FOR PUBLICITY OF EVENTS
Photographs can be taken at events organised by the group of companies Penki Kontinentai. Photographs during these events are taken with your consent for the purpose of publicising the best moments of the events. The group of companies Penki Kontinentai may use third parties to assist in the organisation of events who may have access to personal data processed by the group of companies Penki Kontinentai. Photographs taken during the events are stored for ten (10) years after the end of the activities of the group of companies Penki Kontinentai.
PROCESSING OF PERSONAL DATA IN SOCIAL MEDIA
The group of companies Penki Kontinentai manages accounts on social media Facebook, LinkedIn, Twitter, YouTube, Instagram. The information that a person provides on social media (including messages, the use of the Like and Follow functions, and other communication) or that is obtained when a person visits the Group’s accounts on social media is controlled by the social network operators Facebook, Linkedin, Twitter, YouTube, Instagram.
For more information about the privacy policies of the managers of social networking sites, see:
PROCESSING OF PERSONAL DATA OF CANDIDATE EMPLOYEES AND TRAINEES
All personal data of persons wishing to get a job or an internship in the group of companies Penki Kontinentai are processed by the group of companies Penki Kontinentai only for the purpose of staff selection and recruitment, with a legitimate interest of assessing the candidate’s suitability for the desired job.
The group of companies Penki Kontinentai receives the personal data of candidates or trainees directly from the candidate when he/she sends his/her curriculum vitae (CV) to the group of companies Penki Kontinentai.
In addition to the data provided by the person wishing to take up employment in the group of companies Penki Kontinentai, the group of companies may collect and otherwise process other publicly available data of the candidate related to the job position he/she is applying for, i.e., search for information online, check the candidate’s social media profiles (e.g., LinkedIn, Facebook, Twitter), etc. The group of companies Penki Kontinentai can also contact the former employers mentioned in the candidate’s curriculum vitae (CV) and request information on the candidate’s qualifications, professional abilities and professional characteristics. In order to verify the authenticity of the qualifications (diplomas, certificates, etc.) provided by the candidate, the group of companies Penki Kontinentai may also contact the educational/training institutions indicated in the qualifications provided by the candidate.
The group of companies Penki Kontinentai retains the data provided by the candidate and collected independently for four (4) months from the end of the specific employee’s selection. The period of retention of personal data shall be extended only with the separate consent of the candidate. If the consent to store the candidate’s personal data for more than four (4) months after the end of the selection is not obtained, at the end of this period, all personal data (both provided by the candidate and collected by the group of companies Penki Kontinentai) shall be destroyed.
Your rights in relation to the processing of personal data are specified in the PROCEDURE FOR THE EXERCISE OF RIGHTS section of the Policy.
PROCEDURE FOR THE EXERCISE OF RIGHTS
All individuals whose personal data are processed by the group of companies Penki Kontinentai have the right:
- to have access to their personal data processed by the group of companies Penki Kontinentai. You can access your personal data and request the rectification of the data by submitting a written request to the registered office of the group of companies Penki Kontinentai or to firstname.lastname@example.org (if the application signed by e-signature is submitted). A request for access to personal data must specify what personal data you wish to have access to and which information listed in Article 15(1) of the Regulation you wish to receive.
The request to access a phone conversation record must additionally indicate the phone number from which the call to the group of companies Penki Kontinentai was made, and in case of more than one call, the date and approximate time of the call must be indicated. The right to access a phone conversation record is exercised by arriving to listen to the recorded conversation at the address of the registered office of the group of companies Penki Kontinentai, by retrieving a copy of the audio recording on an external data carrier or transmitting it electronically.
- to require the erasure of unlawfully processed data. You can exercise this right by submitting a written request to the registered office of the group of companies Penki Kontinentai or to email@example.com (if the application signed by e-signature is submitted).
- to require the group of companies Penki Kontinentai to restrict the processing of personal data, until the accuracy of the personal data has been verified and until it is established whether the interests of the data subject who does not consent to the processing of personal data take precedence over the interests of the group of companies Penki Kontinentai, and in cases where personal data are processed unlawfully, but the data subject does not consent to the deletion of the data. You can exercise this right by submitting a written request to the registered office of the group of companies Penki Kontinentai or to firstname.lastname@example.org (if the application signed by e-signature is submitted). When a request is made to restrict the processing of only part of the personal data processed by the group of companies Penki Kontinentai, the request must specify the categories of personal data the processing of which is requested to be restricted. If the request is justified, the processing of personal data shall be restricted within 5 working days from the receipt of the request.
- to data portability. You can exercise this right by submitting a written request to the registered office of the group of companies Penki Kontinentai or to email@example.com (if the application signed by e-signature is submitted). When a request is made to transfer only part of the personal data processed by the group of companies Penki Kontinentai, the request must specify the categories of personal data for which the right to data portability is exercised. If the request is justified, the group of companies Penki Kontinentai shall provide you or your designated data controller with your personal data in computer-readable format not later than within 30 days after receipt of the request.
- not to consent to the processing of their personal data. You can exercise this right by submitting a written request to the registered office of the group of companies Penki Kontinentai or to firstname.lastname@example.org (if the application signed by e-signature is submitted). If you express your disagreement with the processing of personal data, it shall be assessed whether your legitimate interest, for which you do not agree with the processing of personal data, takes precedence over the legitimate interest of the group of companies Penki Kontinentai, based on which the Group processes your personal data.
- to file a complaint with the supervisory authority. You can exercise this right by filing a complaint to the State Data Protection Inspectorate regarding any actions of the group of companies Penki Kontinentai related to the processing of your personal data.
IMPORTANT. In cases when you exercise your rights by sending a written request to the address of the registered office of the group of companies Penki Kontinentai by post, a notarised copy of an identity document (passport, identity card) must be submitted together with the application.
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ASHBURN International UAB
Kareivių g. 2, Vilnius
Tel. +370 52 51 4300
Data Protection Officer email@example.com
INTELLECTUAL PROPERTY RIGHTS
Articles, descriptions, trademarks, service marks and logos published on the website www.5ci.lt are intellectual property and are protected in accordance with the laws of the Republic of Lithuania. The textual and other information contained on this website may not be published, sent, reproduced, transmitted, copied and/or distributed or used in any way. All materials on this website are protected by the national intellectual property legislation and other laws and international agreements.
The group of companies Penki Kontinentai is not liable for privacy policies or practices of third-party websites.