Personal data processing rules

Information updated: 2022 m. April 19

DATA CONTROLLER

JSC SeeNext
Legal entity code 304240679
Registered address: Vytauto pr. 32-214, 44328 Kaunas
Tel. +370 642 90807
E-mail: projektai@seenext.lt

Data about UAB SeeNext is collected and stored in the register of legal entities of the State Enterprise “Registrų centras”.

GENERAL INFORMATION

This Privacy Policy provides information about what personal data we process when operating www.seenext.lt, in particular about our customers and users of our customer system (https://sistema.seenext.lt), whether we process this data based on consent or on another legal basis, for what specific purposes we use it, to whom we may transfer it and what your rights are in relation to the processing of your personal data.

WHAT PERSONAL DATA DO WE PROCESS?

If you use our services, we collect various types of data about you, such as contact details, etc. We monitor which services you view on our website, what actions you perform in our customer system, what devices you use to access our website, which offers sent by our email interested you. Based on this knowledge, we create new information about what offers we could send according to your wishes and how we could improve our services in the future. If you use our services, we process data such as your name, surname and other data necessary for concluding a contract and executing the shipment.

We process the following personal data:

  1. identification data, in particular your name and surname;
  2. contact data, which includes personal data. We need this to be able to contact you. This is usually your e-mail address, telephone number, delivery address, billing address;
  3. data about your orders. In particular, this includes data about the services ordered and the payment method, including your bank account number, and data about any claims you have made;
  4. data about your online habits, in particular data about the services you search for, the links you click on, your search methods and your navigation on our website, information about the devices you use to browse the internet, IP addresses and the locations associated with them, device IDs, their technical parameters, such as the operating system, version, screen resolution, the browser you use, its version, data collected by cookies and similar device recognition technologies;
  5. data about your behavior when reading the messages we send you, in particular the time you open the message and data about the devices you use to browse the Internet, IP addresses and their associated locations, device IDs, their technical parameters, such as operating system, version, screen resolution, selected browser and its version;
  6. derived data, including personal data obtained from your preferences, data about the services you purchase from us, data about your online habits and behavior related to reading the messages we send, mainly data about gender, age, user habits and attitude towards various services;
  7. information about the use of call center services, in particular the registration of telephone calls to the call center, identification of the messages you send to us, including identification data, such as IP addresses.

WHY DO WE PROCESS YOUR PERSONAL DATA AND ON WHAT BASIS DO WE DO IT?

We process your personal data in different situations for different purposes. If you visit pages of our website where we use cookies, we process your data to determine the number of visitors and to improve the services provided. If you use our services, we use your data to process your order, to protect our legal claims and to comply with our legal obligations. Using your contact information and other information, we can simultaneously display and send you customized offers. With your consent, we provide information to third parties to display the offer on other websites, as well as to enable you to use some additional services. We have the right to process your personal data based on the preparation or performance of a contract with you, the fulfillment of legal obligations, our legitimate requirements or your consent.

In the course of our activities, we process personal data for various purposes and to different extents:

  1. without your consent – ​​for the performance of a contract, for the purposes of our legitimate interest or to comply with legal or contractual obligations, or

  2. with your consent.

    What data we may process without your consent depends on the purpose of the data processing and your relationship with us – whether you are just a visitor to the website or a user of the customer system purchasing our services. We may also process your data if you are the recipient of services ordered from us, if you communicate with us.

For Website and Client System Visitors

When you visit our website or client system, we save and retrieve small files, such as cookies, from your device. A cookie is a small set of letters and numbers that we store in your web browser or on your computer’s hard drive. Some cookies allow us to associate your browsing activities on our pages from the moment you open your web browser window to the moment you close it. When you close your web browser window, the corresponding cookies are deleted. However, some cookies remain on your device for a set period of time and are activated each time you visit the websites that created them. We also use web beacons. These are small images that have a similar function to cookies. Compared to cookies stored on your computer’s hard drive, web beacons are an integral part of websites. For simplicity, we will only discuss cookies among these technologies. We store cookies on your device, and we read cookies that our websites have stored on your device. For simplicity, we will only discuss storage in this document.

Some cookies are stored directly on your device by our websites. These cookies help us:

  • to identify you when you switch between and revisit individual websites within our domain;
  • to determine whether you have given us your consent under this document, as well as whether you have decided to participate in a particular survey;
  • to ensure security, for example, so that we can check whether your referral to our domain has not been abused and whether someone is not taking actions on your behalf;
  • to identify, investigate and correct errors and shortcomings on our websites;

Such cookies and other files are essential for the operation of our website. If you disable cookies in your browser, our website may not function properly, which means that we will not be able to offer you some and/or all of the services.

We also store cookies from our websites on your device, which allow us to:

  • monitor the number of visits to our websites or individual content views, generate statistics, reviews and measure the effectiveness of advertisements;
  • show different variations of our websites if we test new features;
  • customize the content of our website according to your needs, for example, to prioritize the display of services that you have already searched for and to show other offers according to your preferences on our website;
  • store cookies for third parties, who may use them to: a) collect data about your behavior on our or other websites; b) display offers and advertisements tailored to your needs on websites outside our domain; c) connect to social networks, such as Facebook, including automatic login, to provide features such as clicking the “Like” button, display offers and advertisements tailored to your needs on social networks and other websites that are not related to our website.

In order to display tailored offers and advertisements on social networks and other websites that are not owned by us, we also send information about your online behavior to such websites and social networks. However, we do not send your identifying information to such partners.

Managing Cookies

You can manage and use cookies in various ways. However, please note that deleting or blocking cookies may negatively affect your online experience as a user and may limit your access to certain pages of our website and customer system.

Most browsers automatically accept cookies, but you can control whether to accept cookies using your browser controls, which are usually located in the “Tools” or “Preferences” menu of your browser.

Use of personal data of website visitors

If you visit our website, customer system, we process information about your online behavior based on our legitimate interests (i.e. without your consent) for the following purposes:

  • to create statistics and determine the number of views of our website or certain content, to evaluate the effectiveness of advertising. In this case, our legitimate interest is to calculate the effectiveness of our websites and advertising costs. For these purposes, we can obtain and use more relevant data based on your online behavior;
  • to test new functions before launch so that we can avoid problems with the operation of these new services that would worsen your experience of visiting our website, customer system. In this case, our legitimate interest is the flawless provision of our services;
  • to take measures to protect against attacks on our websites and disruption of their operation and to ensure the security of your data. In this case, our legitimate interest is the flawless operation of our services and the security of your data.

We receive data about your behavior on websites not only from cookies. We also supplement the data we receive with the following information:

  • your device’s IP address (the address of your device that you use to connect to other devices on the network);
  • your device’s operating system, its version, and language settings;
  • the browser you use on your device, its version, and language settings;
  • the address (URL) of the page from which you access our website.

For these purposes, we use personal data for a maximum of 38 months and store it anonymously.

We also process information about your behavior on the website based on our legitimate interests (i.e. without your consent) in order to prepare customized offers and advertisements that we display online. In this case, our legitimate interest is to provide you with the most customized and effective offers possible. We analyze this data and thus obtain additional data. Based on this, we can divide our users into various groups and then each group receives only customized offers. If you use our services, we will also collect data about your orders for these purposes.

In this case, your personal data will be used for 1 month, except when the data is used under a long-term service contract concluded between you and us.

Processing of your data for the purpose of contract execution

If you, as a natural person, visit our website, customer system, then we process your personal data in order to execute your order. This includes identification and contact data and data about your orders.

If you, as a legal person, visit our website, customer system, place orders as a representative of a legal person, then we process the same data for the same purposes, because we have a legitimate interest in concluding and executing a contract with the person you represent.

Using data for the purpose of executing your order means that we use the data specifically for the following cases:

  • so that you can place an order online, for example, so that data from a pending order is not deleted;
  • so that we can communicate with you, for example, regarding the sending of orders or to notify you about the execution/performance of services;
  • so that you can pay for services;
  • so that we can provide services. In this case, we may also provide your data to our partners who are involved in directly providing you with the service. You will be informed separately about such data transfer;
  • so that we can investigate claims regarding the services ordered/provided;s
  • o that we can fulfill any other requirements you submit to us, for example by calling the call center.

For these purposes, we process personal data for as long as is necessary to fulfill the order or contractual obligations, for example to investigate claims.

Processing of your data based on legitimate interests

If you use our services, we store your identification and contact information and information about your orders based on our legitimate interests (without your consent) to protect legal claims and to be able to carry out internal controls. Our legitimate interest in this case is the protection of legal claims and the regular control of the services we provide.

In addition, based on our legitimate interests (i.e. without your consent), we process your identification and contact information, your preferences and information about orders (if you use our services later) for the following purposes:

  • so that you can place an order online, for example, so that data from a pending order is not deleted;so t
  • hat we can communicate with you, for example, regarding the sending of orders or to notify you about the execution/performance of services;
  • so that you can pay for services;
  • so that we can provide services. In this case, we may also provide your data to our partners who are involved in directly providing you with the service. You will be informed separately about such a data transfer;
  • to enable us to investigate claims regarding services ordered/provided;
  • to enable us to fulfil any other requests you make to us, for example by calling our call centre.

We also use information about your orders to create tailored offers and advertisements for you, which we will display on the websites, as specified in the section “Website and customer system visitors”.

Using your contact information and other information, we can simultaneously display and send you tailored offers. In order to ensure legal requirements and internal data protection and control, we process the data for 3 years, and if the data is related to legal disputes that are not resolved after the expiration of the limitation period, then for another 1 year. If civil, criminal, administrative or other procedures are underway, we process your personal data for the duration necessary for such procedure and for the remainder of the limitation period after the end of the procedure.

In order to ensure legal requirements and internal data protection and control, we process the data until the expiration of the limitation period for the claim, which is 3 years, and if necessary, for 1 year after its expiration, if the legal dispute is still ongoing, then after the expiration of the limitation period. If civil, criminal, administrative or other proceedings are initiated, we process your personal data to the extent necessary for such proceedings and until the expiry of the limitation period when such proceedings end.

For other specified purposes, we process personal data for a maximum of 6 months.

You have the right to object to such processing, which is carried out on the basis of our legitimate interest.

Processing your data in accordance with legal requirements

We comply with legal requirements and are therefore obliged to fulfill the obligations set out in them. If we process your personal data for this reason, we do not need your consent for such data processing purpose. We process your identification and contact data and order data on this legal basis because we aim to comply with the following laws applicable at the time of conclusion of the contract:

  • Civil Code;
  • Consumer Rights Protection Act;
  • Value Added Tax Act;
  • Electronic Communications Act;
  • Act on the Prevention of Money Laundering and Terrorist Financing.

For this purpose, we process personal data for a maximum of 10 years (including the current year) after your last order.

If you are a recipient of our services

If you are a recipient of our services, we process your identification and contact information:

  • based on our legitimate interest in preparing, concluding and implementing a contract with our client. The implementation of this contract also meets our legitimate interest;
  • based on our legitimate interest in obtaining data that allows us to improve our services in the future, or data that allows us to create internal statistics and count reviews. In this case, our legitimate interest is to improve the services provided to our clients;
  • in order to comply with legal obligations, in particular the applicable laws listed in the previous section;
  • in order to perform our legal obligations, process internal data and perform their control. Our legitimate interest in this case is the protection of legal requirements and the regular control of the services we provide.

We use personal data to prepare, conclude and implement a contract with the client to the extent necessary for the provision and performance of the services. After this period, we continue to store the data for the purpose of safeguarding legal claims and for internal data protection and control and process it until the end of the limitation period of 3 years, and if necessary, 1 year after its end if the legal dispute continues after the expiry of the limitation period. If civil, criminal, administrative or other proceedings are initiated, we process your personal data to the extent necessary for such proceedings and until the expiry of the limitation period, when such proceedings end. Our legitimate interest in this case is the protection of legal claims and the regular monitoring of the services we provide. In order to fulfil our legal obligations, we process personal data for a maximum of 10 years after the completion of the order.

When you communicate with us through different means

If you communicate with us through different means, in particular if you contact the call center, write to us by email, use chat rooms and social networks, we process your identification and contact data and copies of your correspondence based on our legitimate interest (i.e. without your consent):

  • to fulfill your requests. If we have concluded a contract, then we may process the data for the purposes of the contract concluded with you;
  • to create an archive of your services in order to regularly and timely monitor their performance;
  • to collect evidence that we have received and processed your request, for example, if you have ordered a service from us or submitted a claim;
  • to analyze requests and thus obtain data on the basis of which we can improve the quality of our services.

We store personal data for these purposes for 3 months. For legitimate interests, we may store data until the end of the 3-year limitation period and for an additional 1 year if the legal dispute continues after the expiry of the limitation period. If civil, criminal, administrative or other proceedings are underway, we process your personal data to the extent necessary for such proceedings and until the limitation period after the end of the proceedings.

WHERE DO WE GET YOUR PERSONAL DATA FROM?

We usually receive personal information directly from you through our website, customer system or when communicating with you. We may also receive some other information from our partners, such as banks or other third parties, when it concerns, for example, payment services.

We usually process personal information that you provide to us directly when ordering services, creating and using an account in the customer system or when communicating with us, for example, by calling the call center. We also receive personal information directly from you by monitoring your online habits when you browse our website, customer system or read our messages.

If you use our services, we may receive additional information about your orders from banks, our partners who manage payment systems, such as information about your account number, successful payments.

WHAT RIGHTS DO YOU HAVE REGARDING THE PROCESSING OF PERSONAL DATA?

You have a number of rights in relation to your personal information. These include the right to access, the right to view, delete and restrict the processing of your data, request data portability, object to processing, and make requests and complaints. You can exercise the following rights:

Right of access

Simply put, you have the right to know what information we collect about you, for what purposes and for how long we keep it, where we get your personal information from, to whom we transfer it, who processes it other than us, and what other rights you have in relation to your personal data. However, if you are still not entirely sure what personal information we collect about you, you can ask us to confirm whether we are collecting personal information about you. If our answer is positive, you have the right to know what information we are collecting. Based on this right of access, you can request a copy of the data we process. We will provide the first copy of the data free of charge, and for each subsequent copy you will have to pay our set data copy fee.

Right to rectification

This applies when the information we have provided and are processing is inaccurate or contains errors. If you notice that the personal information we hold about you is incorrect or incomplete, you have the right to request that we correct or supplement it as soon as possible.

Right to be forgotten

In some cases, you have the right to request that your personal information be deleted. We will delete your personal information as soon as possible if at least one of the following conditions applies:

  • we no longer need your personal data for the purposes for which we processed it;
  • you have withdrawn your consent to allow the processing of personal data for which your consent is required and we have no other reason to continue processing it;
  • you have exercised your right to object to the processing of your personal data (see “Right to object to data processing”) where we have processed it based on our legitimate interests and we acknowledge that we no longer have legitimate interests that justify the further processing of such data;
  • you assume that our processing of personal data no longer complies with generally binding legal regulations.

Please note that even if one of these reasons applies, not all of your personal data will necessarily be deleted immediately. This right cannot be exercised if the processing of your personal data is necessary for us to comply with our legal obligations or to establish, exercise or defend legal claims (see “Why do we process your personal data and on what basis do we do so?”).

Right to restriction of processing

In some cases, in addition to the right to erasure, you may exercise the right to restrict the processing of your personal data. This means that in certain cases you can request that your personal data be specifically marked and not included in any processing operations – in which case your personal data will not be processed for a certain period of time, rather than permanently, as in the case of erasure. We must restrict the processing of your personal data in the following cases:

  • if you contest the accuracy of the personal information – until we agree which information is correct;
  • if we process your personal data without a proper legal basis (e.g. exceeding the intended scope) and you prefer the restriction of such data to the erasure (e.g. if you intend to provide this data to us in the future);
  • if we no longer need your personal data for the stated purposes, but you need it for the establishment, exercise or defence of legitimate interests;
  • if you object to the processing. The right to object is described in more detail below in the section “Right to object to data processing”. While we are processing your request, we must restrict the processing of your personal data.

Right to data portability

You have the right to receive from us all the personal data about you that you have provided to us and that we process in the performance of a contract. We provide personal data in a structured, commonly used and machine-readable format. Easy portability is only possible for data that we automatically process in our electronic databases.

Right to object to data processing

For reasons relating to your particular situation, you have the right to object to the processing of your personal data based on point (e) or (f) of Article 6(1) of Regulation (EU) 2016/679 and to object to the processing of your personal data for direct marketing purposes (see the section “Why do we process your personal data and on what basis do we do so?”). We will immediately cease processing your data for marketing purposes; otherwise, we will process your data until we no longer have grounds (grounds) for processing them.

Right to lodge a complaint

The exercise of the above rights in no way affects your right to lodge a complaint with a competent authority. You may exercise this right if you suspect that we are processing your personal data unreasonably or in breach of the legislation governing the protection of personal data.

You may lodge a complaint regarding our processing of your data with the State Data Protection Inspectorate, L. Sapiegos g. 17, Vilnius, tel. +370 5 271 28 04, e-mail: ada@ada.lt

HOW CAN YOU EXERCISE YOUR RIGHTS RELATED TO THE PROTECTION OF YOUR PERSONAL DATA?

To exercise your rights specified in these personal data processing rules, you can contact us using the contacts specified in the section “Data Controller”.

We will examine your request as soon as possible, but no later than within one month from the date of receipt of the request (in exceptional cases, from the date of receipt of all the information specified in the request). In cases where the request cannot be examined within one month due to its complexity, the deadline for examining the request may be extended to two months. We will inform you separately about the decision to extend the deadline for examining the request and the reasons for the extension of the deadline.

CHANGES TO THE PERSONAL DATA PROTECTION RULES

We reserve the right to partially or completely change the rules for processing personal data by notifying you about this on our website. Further use of our website and customer system means compliance with these rules.

DISPUTES AND THEIR REVIEW

We resolve all disputes through negotiations, except in cases where you submit a complaint regarding our data processing to the responsible authority, which takes over the resolution of the dispute and conducts an investigation of the cases and makes a decision.

The terms for the consideration of disputes are specified in the section “How you can exercise your rights related to the protection of your personal data”.