1. WHAT IS PERSONAL DATA?

Personal data is defined as any information about a natural person which could be used to directly or indirectly identify the person. For example: the name, surname, e-mail address, phone number, image and other information.

2. WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies when personal data is provided on the website www.girteka.eu, when the personal data of clients, suppliers, vendors, and/or their representatives is provided for the purposes of concluding and executing contracts, maintaining commercial relations, communicating with Girteka via phone, email, or other means of communication, as well as during video surveillance and audio recording of conversations.

3. WHAT IS THE PROCESSING OF PERSONAL DATA?

Any action (operation) performed on or with personal data, including collection, recording, storage, modification, granting of access, requesting, transfer, etc.

4.WHAT PERSONAL DATA DOES GIRTEKA COLLECT AND PROCESS AND FOR WHAT PURPOSES?

This section of the Privacy Policy provides information about the type of personal data processed by Girteka and its purposes.

4.1. DIRECT MARKETING 

Direct marketing performed by Girteka consists of:

• news, commercial offers and surveys by e-mail;
• news, commercial offers and surveys by phone;

The legal basis for the personal data processing is the consent given by a person for their personal data processing for direct marketing purposes or the Company’s legitimate interest, in the presence of the conditions established in the Paragraph 2 of the Article 81 of the Electronic Communications of the Republic of Lithuania.

The following personal data is provided by a person and is processed for direct marketing purposes: the person’s name, surname, e-mail, telephone number, company name.

For direct marketing purposes, we will send non-personalized messages (newsletters, promotions) via email to offer Girteka services and gather your feedback on them (surveys). These messages will be sent with your consent, or in cases permitted by law (when you are a Girteka client), based on our legitimate interest to inform you about services similar to those you already use from Girteka.

For direct marketing purposes, we carry out profiling (i.e., automated processing of personal data to evaluate specific personal aspects related to a natural person and assign website visitors performing the actions mentioned in this paragraph to certain categories). Profiling does not have legal consequences or similarly significant effects for you. Profiling is carried out solely based on your consent (provided by agreeing to the use of cookies), and personalized marketing is sent to you either with your consent (provided by agreeing to receive Girteka newsletters and offers) or based on Girteka‘s legitimate interest in promoting services and offering relevant proposals to you.

When sending personalized email messages, we may analyze the effectiveness of the marketing campaign. Typically, we use only anonymized and statistical data for this purpose. In exceptional cases, Girteka may have access to individualized data about the personalized email, your actions related to such an email, and analytical data about you as a client.

For direct marketing purposes, the collected personal data can be processed for 2 (two) years following the receipt of consent.

The person who has given the consent always has the right to unsubscribe to all or part of the direct marketing offers at any time. This can be done by clicking on the link in the newsletter/offer received, which allows to opt out of receiving all or part of the direct marketing offers. It is also possible to unsubscribe from direct marketing offers by writing an email to duomenuapsauga@girteka.eu. Declining direct marketing offers does not have negative consequences, only that the relevant offers, news or other direct marketing information will no longer be provided in the future.

Consent withdrawal does not affect the processing and outcomes of personal data already carried out prior to the consent withdrawal or the declaration of non-consent to the direct marketing.

4.2. PROCESSING OF DATA FOR SERVICE INQUIRIES 

When you submit a service inquiry via the website www.girteka.eu, Girteka employees will contact you using the contact details you provide to deliver the requested information.

The legal basis for processing personal data is the consent you provide when submitting an inquiry via the website www.girteka.eu for the purpose of receiving information.

Personal data processed for the purpose of responding to your inquiry includes:

Name, Surnam, Email address, Phone number, Company name (if applicable)

The personal data provided will be processed and stored for 9 (nine) months from the date of inquiry submission.

4.3. TELEPHONE CONVERSATIONS RECORDING 

Girteka manages conversation recordings for the purpose of quality improvement, training and conflict resolution.

Telephone conversations are recorded when:

• a person calls to Girteka himself;
• Girteka employees (company representatives) call a person.

The legal basis for personal data processing is the consent to the conversation recording. The consent to record conversations is given by a person choosing to continue a conversation (when the person calls Girteka) or confirming that he or she agrees for the conversation to be recorded (when Girteka calls the person).

If a person does not agree for the conversation to be recorded,  alternative means to contact Girteka are available: by e-mail info@girteka.eu or by visiting the Girteka office.

The following personal data is processed for conversation recording purposes: the phone number, name, surname, date of the call, time of start and end of the call, content of the conversation.

Conversation recordings are stored for 3 (three) years after the conversation was recorded.

4.4. VIDEO SURVEILLANCE

Girteka performs video surveillance on the Company’s territory and premises, including the employees’ workplace.

Video surveillance is carried out to ensure the protection of property rights, guarantee the security and inviolability of property, and the safety of employees.

Video recordings are processed in accordance with Article 6 of the GDPR 1 d. (f), i. y. the processing is necessary for the legitimate interests of the controller or of a third party.

Video recordings are stored for 30 calendar days.

4.5. EXAMINATION OF INQUIRIES (COMPLAINTS, SUGGESTIONS, ETC.)

Any suggestions, ideas, questions, complaints, feedback, and other inquiries can be submitted on the Girteka website www.girteka.eu.

The following personal data is processed for the purpose of submitted suggestions, ideas, questions, complaints, feedback: the name, surname, telephone number, e-mail address. For this purpose, personal data are processed on the basis of Company‘s legitimate interest.

Personal data is processed while the application is being processed.

4.5. PROCESSING THE DATA OF CUSTOMERS, SUPPLIERS, SELLERS AND/OR THEIR REPRESENTATIVES

Girteka handles customer, supplier, seller and / or their representatives’ personal data for the purposes of maintaining commercial relations, concluding and executing contracts. For these purposes, personal data is processed for the conclusion and execution of contracts on the basis of the legitimate interest of Girteka and its customers, sellers and suppliers.

Personal data processed for this purpose: the name, surname, workplace, office position, telephone number, e-mail address.

The provision of this personal data is necessary for the conclusion and execution of the contract.

Personal data is stored for 10 years from the start of data collection. The term is extended for another 5 years, if commercial relations with the mentioned customers, suppliers or sellers are continued.

5. WHO IS PERSONAL DATA PROVIDED TO?

Girteka can transfer personal data to:

• personal data managers acting on behalf of Girteka: companies providing information technology services; any other personal data managers with whom Girteka enters into agreements for personal data processing; Girteka group companies, which are established in EU Member States and/or other third countries (e.g. Girteka Business Services is established in Sakartvelo (Georgia) (Vake-Saburtalo district, Abashidze str. N34, commercial premises Na-3, Block I, Tbilisi, Georgia).
• data recipients: Girteka partners with whom services are provided in collaboration; other companies of the Girteka group, which are established in EU Member States and/or other third countries (e.g. Girteka Business Services is established in Sakartvelo (Georgia) (Vake-Saburtalo district, Abashidze str. N34, commercial premises Na-3, Block I, Tbilisi, Georgia) when it is necessary, in order to properly provide services to the data subjects, to respond to their requests or due to the organizational structure and accountability of the group; to any third parties in the cases allowed for and to the extent defined by legal acts.

6. WHAT RIGHTS DO YOU HAVE?

As a data subject, you have the following rights:

• to be aware of the processing of your personal data;
• to access the personal data we processing about you;
• to require rectification of any incorrect, inaccurate or incomplete data;
• to require limitations on data processing activities;
• the right to object to the processing of your personal data where the processing of personal data is based on a legitimate interest;
• to request the deletion of personal data (if you withdraw your consent);
• the right to data portability;
• to withdraw your consent at any time (when personal data are processed on the basis of consent);
• the right to lodge a complaint with the data protection supervisory institution, whose contacts can be found at vdai.lrv.lt.

If you intend to exercise your rights, contact Girteka by e-mail duomenuapsauga@girteka.eu, presenting your specific request in detail. Please note that in exercising your rights, you must properly verify your identity.

Girteka will process your application and provide the information within one month.

If you believe that Girteka does not properly process your personal data or does not properly exercise or does not exercise at all your rights, first of all contact Girteka, and Girteka will be ready to resolve the problems together with you. In case you are not satisfied with the response from Girteka, you also have the right to apply to the national data protection supervisory institution, for which all the information can be found at www.vdai.lrv.lt.

7. WHAT ARE YOUR DUTIES AND RESPONSIBILITIES?

You assume full responsibility for the correctness and accuracy of the personal information you provide.

In the event when any personal data or other relevant information you have provided changes, you must immediately correct the personal data or other relevant information you have provided.

8. WHAT RIGHTS DOES GIRTEKA HAVE?

When Girteka doubts the accuracy of the provided personal data or other relevant information, it has the right to request for the data or related information to be corrected and / or supplemented.

9. WHERE TO ADDRESS IF YOU HAVE QUESTIONS?

If you have any questions regarding the processing of your personal data, please contact Girteka by e-mail at duomenuapsauga@girteka.eu.