Datenschutz-Bestimmungen

1. PRIVACY POLICY

1. Retiva UAB (hereinafter referred to as the „Company“ or "Retiva") respects and understands the particular importance of the protection of your personal data, and therefore collects and processes only those of your personal data that are necessary for the performance of the Company's activities. The processing of personal data shall be lawful, transparent and fair, for predefined purposes and only to the extent necessary to achieve the purposes. When processing personal data, we aim to ensure that it is accurate, secure, confidential, properly stored and protected.
2. When processing your personal data, we comply with the provisions of the General Data Protection Regulation (hereinafter referred to as "GDPR"), the Law on Legal Protection of Personal Data of the Republic of Lithuania (hereinafter referred to as "LPP"), the Law on Electronic Communications of the Republic of Lithuania (hereinafter referred to as "LEC"), as well as with the provisions of any other directly applicable legal acts governing the protection of personal data.
3. The following GDPR principles apply to the processing of personal data: purpose limitation (Processing of Data only for the purpose originally stated); data minimisation (Only as much Personal Data as necessary); lawfulness, fairness and transparency; accuracy; limitation of retention period (Only kept for as long as is necessary for the specific purpose); integrity and confidentiality; and the principle of accountability (The Controller shall provide evidence of compliance with its obligations).
4. The Privacy Policy applies to all persons whose data is processed by Retiva.

2. CONNECTIONS

1. GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council 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. Available at: http://eur-lex.europa.eu/legal-content/LT/TXT/?uri=CELEX%3A32016R0679 .
2. 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.
3. Person - any natural person whose Personal Data is processed (data subject), e.g. may be a Potential Candidate, Candidate, Temporary Employee, employee of the Administration or any other natural person.
4. Policy - Retiva Group Personal Data Processing Policy.
5. Data 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.
6. Data Subject - the natural person whose personal data is collected on the Portal.
7. Submission of data - disclosure of personal data by transmission or otherwise making them available (except publication in the media).
8. Data processing - any operation or sequence 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.
9. Data Processor - a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
10. Data Controller - UAB „Retiva“, a company incorporated under the laws of the Republic of Lithuania, code 304850497, registered office at Tilžės g. 116, Šiauliai, LT-77160, the Republic of Lithuania, the data about which are collected and stored in the Register of Legal Entities.

3. COLLECTION OF PERSONAL DATA

1.   We process your personal data received in the following ways:

2.     We may combine the personal data we receive from you with data collected by us from other public or accessible sources. For example, we may combine the personal data you provide with data obtained through the use of cookies on websites, data collected in the course of providing our services to you, or with data lawfully obtained from third parties. In exercising your rights, you will always be able to request the rectification of erroneous personal data.
3.   In exceptional cases, if special categories of Personal Data are processed, such as information on criminal records, health, trade union membership, etc., the Administration staff shall additionally check whether all the necessary steps have been taken and take additional steps (e.g. obtaining separate consent for processing) and measures (e.g. not storing in the Controller's database or in the applications used) where necessary.
4. PURPOSES AND GROUNDS FOR PROCESSING PERSONAL DATA

1.   Your personal data is processed in accordance with the following main grounds for processing personal data set out in the GDPR:

2.   We process your personal data for the following purposes:

3.   Where your personal data is processed with your consent, your personal data shall no longer be processed after you have withdrawn your consent or after the expiry of the term of validity of your consent, except for the storage of data evidencing that consent has been given for a maximum period of 10 (ten) years for the purpose of asserting, exercising or defending our legal claims.
4.   We do not process your personal data for any other purposes that are incompatible with the purposes listed above.

• PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES

1. With your additional consent and in accordance with the provisions of the GDPR and the EIR, we may use your personal data for the purpose of direct marketing in order to provide you with offers and information about our goods and/or services, those of our affiliates and partners, which we believe may be of benefit to you.
2. For this purpose, we process the following personal data: name, surname, telephone number, email address, date of birth, place of residence (address), IP address, education, gender, position, workplace, profession, work experience.
3. You can choose whether you allow us to use your personal data for direct marketing purposes. You can do this by ticking the consent text „I consent to the use of my personal data for direct marketing purposes (sending newsletters)“ or by leaving it unticked when registering on the websites.
4. By granting us the right to process your data for direct marketing purposes, you also grant us permission to contact you by means of communication (e.g. email, telephone, SMS) or other means of communication (e.g. Skype, Viber, etc.) for this purpose.
5. We may combine the information we hold about you with information lawfully held by third parties.
6. If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyse and improve the effectiveness of our websites, social media channels and market research, and for other company marketing and sales purposes. In this case, we will use your personalised data.
7. Even if you have given your consent to the processing of your personal data for direct marketing purposes, you can withdraw this consent at any time for all or part of the processing of your personal data. You can do this in the following ways:

1. to notify your unsubscription in the manner specified in the e-notifications and/or offers (e.g. by clicking on the „unsubscribe“ link in the newsletter, etc.), or
2. by coming to us and making a request. You must clearly state your name on the request. If you wish to withdraw your consent in this way, we may ask you to provide proof of identity;
3. send us a request to the email address specified in this Privacy Policy: info@retiva.lt. The request must clearly state your name and surname and other registration details (if any). If you wish to withdraw your consent in this way, we may ask you to provide proof of identity.

8.   If you withdraw your consent, we will stop processing your personal data for the purpose of direct marketing as soon as possible.
9.   Withdrawal of consent does not automatically oblige us to destroy your personal data or to provide you with information about our processing of your personal data, so if you want us to do this as well, you must make a separate request.
10. COOKIE POLICY

1.   Retiva uses cookies and other identification technologies in its applications, websites, emails and online advertisements.
2.     A cookie is a small text file that a website stores on your computer or mobile device when you visit it. It allows the website to „remember“ your actions and preferences (such as your registration name, language, font size and other display options) for a certain period of time, without you having to re-enter them each time you visit the website or browse its various pages.
3.   It is important to note that this Cookie Policy will apply not only to the use of cookies, but also to the use of similar tools for storing information on the terminal devices, such as computers, mobile phones, smartphones, of the subscriber or the actual user of electronic communications services (e.g., local storage technology). Accordingly, the term „cookies“ as used in this policy includes similar tools used on the website.
4.   We may collect the following information through cookies: internet address (IP), device used, web browser used, number of visits, pages viewed on our website, time spent on the website, websites visited before you came to our website.
5.     We use the information we receive from cookies for the following purposes:

6.   We may, without prejudice to the law, combine information obtained through the use of cookies with information obtained about you by other means (e.g. information about the use of websites, personal data you have provided, etc.).
7.   The following cookies may be used on websites:

8.   You can give your consent to the use of cookies in the following ways:

9.   You can revoke your permission to use cookies at any time. You can do this by changing the settings on your web browser so that it does not accept cookies. How you do this depends on the operating system and web browser you are using. For detailed information about cookies, their use and the options for refusing them, please visit http://AllAboutCookies.orgor http://google.com/privacy_ads.html.
10. In some cases, in particular for technical and functional cookies, disabling, not accepting or deleting cookies may slow down your browsing, restrict the functionality of certain websites, or even block access to websites.
11. Any information you provide via social media (including messages, the use of the „Like“ and „Follow“ boxes, and other communications) is controlled by the operators of the social networks. We recommend that you read the privacy notices of the social media controllers and contact them directly about their use of your personal data. You can find out more about the privacy policies of social network managers here: https://wwww.facebook.com/policy.php(Facebook); https://www.linkedin.com/legal/privacy-policy (LinkedIn).
12. Please note that cookies may also be used by the website operator's partners or other third parties that are not under the website operator's control for their own purposes. The Website Manager cannot and is not responsible for the actions of such persons. If you suspect that cookies are being used without your consent by the website operator's partners or other third parties not under the website operator's control, you should contact the partner or other third party concerned.
13.   Cookies used:

• RIGHTS OF DATA SUBJECTS

1. In the cases and to the extent specified by law, you have the following data subject rights, which we will exercise upon receipt of a request from you (by email: info@retiva.lt; by post: Tilžės g. 116, Šiauliai, LT-77160, Republic of Lithuania; or by submitting the request directly at the registered office of the Company: Tilžės g. 116, Šiauliai, LT-77160, Republic of Lithuania), and upon your proper proof of identity (for example, by enclosing a copy of your passport or ID card):

1. Know (be informed) about the processing of personal data;
2. To know your personal data and how it is processed;
3. Request the rectification of inaccurate personal data relating to you, as well as the completion of incomplete personal data.
4. Request that the Company erase personal data relating to you if:
   1. they are no longer necessary for the purposes for which they were collected or otherwise processed;
   2. you withdraw your consent and there is no other legal basis for processing your personal data;
   3. personal data have been processed unlawfully;
   4. other grounds set out in the Regulation.
5. Require the Company to restrict the processing of your personal data where:
   1. you contest the accuracy of the data for a period of time during which the controller can verify the accuracy of the data;
   2. the processing of the personal data is unlawful and you do not consent to the erasure of the data;
   3. The Company no longer needs the personal data for the purposes of the processing, but needs it for the establishment, exercise or defence of legal claims against you;
   4. you have objected to the processing of your personal data, pending verification that the Company's legitimate reasons override yours.
6. Receive personal data relating to you that you have provided to the Company in a structured, commonly used and computer readable format.
7. To object to the processing of personal data relating to you.
8. We will endeavour to guarantee the exercise of your rights as a data subject and to provide all the conditions for the effective exercise of those rights, but we reserve the right not to comply with your requests where it is necessary to ensure:

1. You may submit claims relating to the exercise of your rights to us in person, by post or by electronic communication. Upon receipt of your request, we may ask you to provide proof of identity, as well as other additional information we require in connection with your request.
2. Once we have received your request, we will respond to you no later than 30 calendar days from the date of receipt of your request and the submission of all the documents necessary to provide the response.
3. If we deem it necessary, we will suspend the processing of your data, with the exception of storage, until your request is resolved. If you lawfully withdraw your consent, we will cease processing your personal data immediately, but no later than 30 calendar days, except in the cases set out in Section 7, Paragraph 1.8 of this Privacy Policy and as required by law, i.e. where we are obliged to continue to process your personal data by applicable law, by a legal obligation to which we are subject, by a judicial decision or by a binding order from the authorities.
4. If we refuse to comply with your request, we will clearly state the reason for such refusal.
5. If you believe that your personal data is being processed unlawfully, you have the right to lodge a complaint with the State Data Protection Inspectorate.

• PROVISION OF PERSONAL DATA

1. We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without lawful basis, or used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy and the law. However, we reserve the right to disclose information about you if we are required to do so by law or if we are requested to do so by lawful authorities or prosecuting authorities.
2. We may transfer your personal data to companies belonging to the Headex group, as well as to companies assisting us in our activities (partners, customers, suppliers). We require such partners to process your data only in accordance with the instructions we have given them and in accordance with applicable data protection legislation. We enter into contracts with these parties which oblige the parties to comply strictly with the requirements for the protection of personal data.
3. The above service providers are limited in their ability to use your data and cannot use it for purposes other than to provide services to us.
4. A non-exhaustive list of persons and categories of persons to whom we transfer your personal data is set out in Section 2.2 of this Privacy Policy separately for each purpose of use of personal data.

• STORAGE OF PERSONAL DATA

1. We will not keep your personal data for longer than the purposes of processing or the law requires, unless a longer retention period is specified in the law.
2. We aim not to store outdated, irrelevant personal data, so that only relevant information is stored when it is updated (e.g. when your account is revised, information is changed, etc.). Historical information is kept where it is necessary for the purposes of the law or for the conduct of our business.
3. Section 2.2 of the Privacy Policy specifies the retention periods of your personal data separately for each purpose of personal data use.
4. The data we collect from you will be located within the European Union, but may be transferred or stored outside the EU. It may also be processed by our or our suppliers' staff working outside the EU. When we transfer your data outside the EU, we will take all necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy.
5. Unfortunately, the transmission of information over the internet is not completely secure. Although we take great care to protect your personal data, we cannot guarantee the security of the data when you transmit data to websites - you bear the risks associated with transmitting data to websites. Once we receive your data, we will apply strict procedures and security measures to protect your data from unauthorised access.
6. In the unlikely event that we become aware of a breach of security of your personal data which may pose a serious threat to your rights or freedoms, we will inform you immediately upon becoming aware of it and identifying the information accessed.
7. Websites may contain links to external websites, such as those of our business partners or websites advertising our services. If you follow such links to any of these sites, please note that these sites and the services available through them have their own separate privacy policies and we do not accept any responsibility or liability for these policies or for the personal data, such as contact or location data, collected on these sites or through these services. Please review these policies before submitting personal data to these websites or using any services.

• CHANGES TO THE PRIVACY POLICY

1. Retiva may change this Privacy Policy at any time at its sole discretion. Please note that if we change this Privacy Policy, it may take up to 30 business days to implement such changes. If you would like to keep up to date with changes to this Privacy Policy, please check this section of the Portal periodically.

• CONTACT US

1. If you have any questions or if you believe that this Privacy Policy does not answer any of your questions, please contact us at info@retiva.lt.
2. If you wish to make a complaint about our processing, please submit it in writing, providing as much information as possible, using the contact details at the end of this policy. We will co-operate with you and endeavour to resolve any issues promptly.
3. If you believe that your rights under the GDPR have been infringed, you can lodge a complaint with our supervisory authority, the State Data Protection Inspectorate, although we will endeavour to resolve any disputes with you in the first instance.