AutoMovi, UAB,
PRIVACY POLICY
I. GENERAL PROVISIONS
- AutoMovi, UAB, at the address Minijos g. 181, Klaipėda, Lithuania (hereinafter the Company), acting as the data controller, processes personal data for the purposes, on the legal grounds and in the manner set out below.
- The Company processes data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679, herein referred to as the GDPR, the Republic of Lithuania Law on Personal Data Legal Protection, as well as other legal acts and internal regulations of the Company. The Company implements all necessary technical and organisational security measures to ensure the security of the Data.
- If you use the Company’s website and/or the Company’s services, this Privacy Policy (hereinafter the Policy), which sets out the purposes and methods of personal data collection, conditions of processing and storage, your rights as a data subject, etc., shall apply to you without reservation. If you do not agree with this Policy, the Company will not be able to provide you the Services (on the website, social media accounts, and/or in the office).
- This Privacy Policy also applies to individuals processing personal data on behalf of the Company and to individuals authorized to process personal data on behalf of the Company.
II. PURPOSE, LEGAL BASIS AND SCOPE OF PERSONAL DATA PROCESSING
| Purpose of processing | Data subject categories | Personal data we process | Grounds for data processing | Period of personal data processing |
| Bookkeeping administration | Counterparties (natural persons) | Full name, address, current account number, signature, e-mail address. | Article 6(1)(c) of the GDPR – where a legal obligation of the Company exists | During the term of the contract and for 10 years from the date of its termination. |
| Representatives of contracting parties (legal persons) | Full name, email address, telephone number, workplace, position title. | |||
| Administration of insured events | Participants of insured events (natural persons) | Full name, address, telephone number, e-mail address, signature, driving licence issue date and number, other information provided by them. | Article 6(1)(f) of the GDPR – where the Company has a legitimate interest | Data are stored for 3 years from the date of the insured event |
| Representatives of insured event participants (legal persons) | Name, surname, telephone number, e-mail address, signature, position, other information provided by them. | |||
| Persons administering or otherwise involved in the insured event process (e.g. insurance company representative, experts, etc.) | Full name, e-mail address, telephone number, position title, workplace, other information provided by them. | |||
| Communication by means of information technology and other tools with third parties (correspondence, telephone calls, etc.). | Persons with whom communication is maintained | Full name, alias, position title, phone number, email address, content of communication, and other data provided by the individual. | Article 6(1)(a) of the GDPR – with the consent of the data subject.
Article 6(1)(b) of the GDPR – for the performance of a contract.
Article 6(1)(f) of the GDPR – where the Company has a legitimate interest. |
Data received via email is retained during the communication and for 3 years after the last received email, then deleted and destroyed within 1 working day after the retention period ends.
Data obtained during phone calls is retained until consent is revoked, then deleted within 1 working day after the revocation of consent. |
| Staff selection | Candidates | Full name, phone number, email address, education and qualification data, work experience, and other information provided by the candidate at their discretion or with the candidate’s consent (content from social media accounts, images, etc.). | Article 6(1)(a) of the GDPR – with the consent of the data subject. | Retention period – until the end of the selection process for the position applied for and, with the person’s consent – for the duration specified in the consent. |
| Administration of requests, complaints, inquiries, and other incoming documents | Applicants | Full name, alias, contact details, contents of the inquiry, and other information provided by the person when submitting a written inquiry | Article 6(1)(c) of the GDPR – in the event of a legal obligation on the part of the Company. | Data are stored during the processing of the request, complaint, inquiry, or claim and for 3 years after the date of completion of the request, complaint, claim, or inquiry |
| Execution and administration of contracts with counterparties (contracting parties) | Counterparties (natural persons) | Full name, e-mail address, telephone number, signature, current account number, residential address. | Article 6(1)(b) of the GDPR – for the purpose of concluding/performing a contract. | Data are stored during the validity of the contract and for 10 years from the date of termination of the contract |
| Representatives of contracting parties (legal persons) | Full name, email address, telephone number, workplace, position title. | Article 6(1)(f) of the GDPR – where the Company has a legitimate interest. | ||
| Administration of traffic law violations and other offences committed while operating a motor vehicle | Vehicle operator (natural person) | Full name, e-mail address, other data requested by persons having a legal basis. | Article 6(1)(c) of the GDPR – in the event of a legal obligation on the part of the Company. | Data are stored for 3 years from the date on which the Company became aware of the violation Traffic Regulations or other offences. |
III. PRINCIPLES OF DATA PROCESSING
- When managing data, the Company adheres to the following principles:
1) Data is processed in accordance with the principles of lawfulness, fairness, and transparency;
2) Data are collected for specified, clearly defined and for legitimate purposes, and not further processed in a way incompatible with those purposes (the purpose limitation principle);
3) Are adequate, appropriate data and necessary only for the purposes for which they are processed (the data reduction principle);
4) The processed data is accurate and updated, if necessary (principle of accuracy);
5) Data are stored in such a form that the subjects can be identified for no longer than is strictly necessary for the purposes for which personal data are processed (the principle of limitation of the length of the storage);
6) Data are processed in such a way as to ensure the adequate protection of personal data, including the protection against unauthorised processing or processing of unauthorised data and unintentional loss, destruction or damage by appropriate technical or organisational measures (the principle of integrity and confidentiality).
IV. TO WHOM DO WE DISCLOSE YOUR DATA?
- Without separate consent, the Company may disclose data to:
1) Courts and other law enforcement and dispute resolution institutions when exercising legal powers or at the Company’s initiative, declaring, enforcing, or defending legal claims;.
2) TO: State Tax Inspectorate
3) To insurance companies;
4) UAB Klaipėdos terminalo grupė;
5) Police officers;
6) Lawyers, bailiffs, consultants, financial institutions, information technology maintenance service providers, electronic communications service providers, companies providing archiving services and other services to the Company;
7) Other persons having a legal basis for the receipt of personal data.
V. YOUR RIGHTS AS A DATA SUBJECT
- The Data Subject has the right to:
1) To familiarize oneself with the data;
2) To request correction of inaccurate, incomplete, or incorrect data;
3) To restrict data processing until the lawfulness of the processing is verified at the request of the data subject;
4) To request the deletion of data;
5) To object to data processing for direct marketing purposes;
6) To request the transfer of data to another Company or to receive data directly in a convenient form (applies to data provided by the data subject and processed by automated means on the basis of consent or on the basis of a request or the conclusion and performance of a contract);
7) To withdraw consent, without affecting the lawfulness of data use prior to consent withdrawal;
8) To file a complaint with the supervisory authority – the State Data Protection Inspectorate.
8. Any request related to the processing of personal data may be submitted by the data subject to the Company by e-mail at aurimas@automovi.lt, by signing the request with a qualified electronic signature, or by visiting the Company’s office.
9. Considering the nature of the request and aiming to ensure the confidentiality of the data processed by the Company, the Company reserves the right to request additional information from the individual submitting the request, necessary to verify the individual’s identity, and/or confirm identity in a specific manner (for example, by personally visiting the office and providing a valid identity document). If the person fails to fulfil such a request, the requested information may not be provided.
10. The Company undertakes to respond to all requests related to personal data processing in accordance with the procedures established by the General Data Protection Regulation (GDPR).
11. Any person has the right to lodge a complaint with the State Data Protection Inspectorate at any time regarding the processing of their data by the Company (A. Juozapavičiaus g. 6, 09310 Vilnius, tel. 8 5 2712804, fax 8 5 2619494, e-mail ada@ada.lt, www.ada.lt).
- COMPANY CONTACT INFORMATION
AutoMovi, UAB
Registration number of legal person 306337301
Registered headquarters address: Minijos g. 181, Klaipėda
Tel. +370 611 18459
E-mail address: aurimas@automovi.lt
