This Privacy Policy (hereinafter referred to as the Privacy Policy) provides information on how the private limited company "Albars," company code 302920228, registered address Ukmergės g. 120-1, 08105 Vilnius, Lithuania (hereinafter referred to as "we" or the "Company," the Data Controller), as a data controller, processes your personal data when you visit our website www.sauga365.lt. For more information on how the Data Controller processes personal data, please refer to our general Privacy Policy.

This Privacy Policy defines how we process the personal data of visitors to the Company’s website www.sauga365.lt and other individuals (hereinafter referred to as "you"), the types of personal data we collect, the sources from which we obtain it, the parties to whom we may disclose it, the purposes for which we use it, how we ensure its security, and how we implement your rights as a data subject.

When processing personal data, we adhere to the European Parliament and Council Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the Regulation), the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other applicable legal acts governing personal data processing and privacy protection, as well as the international standard LST ISO/IEC 27001, and the guidelines/recommendations of supervisory and other competent authorities.

Personal data – any information processed by the Company about a natural person whose identity can be directly or indirectly identified (e.g., name, surname, contact details, residential address, etc.), which we receive directly from you or other sources.

Data subject – a natural person (you) whose personal data is processed by the Company (e.g., individuals who contact the Company).

Data processing – any operation performed on personal data (e.g., collection, recording, storage, deletion, etc.).

Other terms used in this Privacy Policy are defined in the Regulation and other legal acts of the Republic of Lithuania governing personal data processing and privacy protection.

The Company, when processing your personal data, undertakes to ensure that personal data is:

1. Processed lawfully, fairly, and transparently (principle of lawfulness, fairness, and transparency);

2. Collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes (principle of purpose limitation);

3. Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (principle of data minimization);

4. Accurate and, where necessary, kept up-to-date (principle of accuracy);

5. Stored in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed (principle of storage limitation);

6. Processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, by using appropriate technical or organizational measures (principle of integrity and confidentiality).

The Company processes the following personal data for the stated purposes:

Personal data is processed based on consent only if there are no other legal grounds specified in the Regulation to process personal data.

If you are our client, we may use your email address and/or phone number for direct marketing purposes to market our own similar services, providing you with a clear, free, and easily exercisable opportunity to object or opt out of the use of such contact data for the above purposes, provided you did not initially object to such use.

In all other cases, we may use your contact information listed in this section for direct marketing purposes only with your prior consent.

We provide you with a clear, free, and easily exercisable option to withdraw your consent at any time. You are informed that you have the right to opt out of receiving our direct marketing messages at any time by notifying us of your decision via email at info@sauga365.lt or by using the unsubscribe link in the direct marketing message.

Principles of personal data processing

Privacy policy

Processed personal data

Direct marketing

Automated decision-making

In some cases, we may use automated decision-making, i.e., a decision based solely on the automated processing of your personal data. Automated decision-making means data processing that uses, for example, software code or an algorithm without human intervention.

When processing your personal data, we may use automated decision-making for certain services and products. If you are dissatisfied with an automated decision, you may request a manual review to verify its accuracy.

For more information on your rights, see the "Your Rights" section.

Methods of obtaining personal data

We obtain your personal data in the following ways:

1. When you contact us directly (e.g., by email, social media message, etc.) and provide your personal data;

2. When we enter into a contract or agreement with you;

3. When we receive your personal data from third parties because it relates to the services or advice we provide to third parties;

4. Publicly accessible sources – we may use sources that help us maintain accurate and up-to-date contact information.

Principles and duration of personal data storage

We will store your personal data for as long as it is needed for the purposes for which the data was collected and processed, but no longer than required by applicable laws and regulations. This means that we keep your data as long as necessary to provide services and as required by personal data storage laws and other regulations.

Personal data will be stored for the duration of the contractual relationship between the parties and up to ten (10) years after the relationship ends.

Accounting and financial asset management data is stored in accordance with the General Document Retention Terms Register, approved by the Chief Archivist of Lithuania, Order No. V-100, dated March 9, 2011.

Personal data submitted through our website is retained only as long as necessary to fulfill your request and further cooperation but no longer than six (6) months from the date of the last communication.

If the laws of the Republic of Lithuania do not specify a retention period for personal data, we will determine it based on the legitimate purpose for retaining the data, the legal basis, and the principles of lawful data processing.

In certain cases, your personal data may be stored longer:

1. If necessary for the Company to defend itself against claims, complaints, or lawsuits and to exercise its rights;

2. If there are reasonable suspicions of illegal activity under investigation;

3. If the personal data is necessary to resolve a dispute or complaint properly;

4. Upon receiving a request to access personal data;

5. In other cases specified by law.

Upon expiration of the retention period, we will delete or irreversibly anonymize your data as soon as possible, within a reasonable time required to carry out this action.

Your rights

As a data subject, you have the following rights:

1. To be informed about the processing of your personal data (right to be informed);

2. To access your personal data and understand how it is processed (right of access);

3. To request the correction of personal data (right to rectification);

4. To request the deletion of personal data (the "right to be forgotten") when personal data is processed based on your consent. This right does not apply if you request the deletion of your personal data processed on other legal grounds, e.g., when processing is necessary to enter into/perform a contract or when there is a legal obligation;

5. To restrict personal data processing in certain cases (right to restriction);

6. To object to decisions based solely on automated processing that have legal or similarly significant effects. You have the right to:

• request human intervention,

• express your opinion,

• receive an explanation of the decision made after evaluation, and

• challenge the decision.

7. To data portability in certain cases (right to data portability). This right applies to the personal data you have provided, processed through automated means based on consent or the necessity of a contract;

8. To object to data processing in certain cases (right to object);

9. To withdraw consent. Withdrawal of consent does not affect the lawfulness of data processing carried out based on consent before withdrawal.

10. To submit a complaint to the State Data Protection Inspectorate if you believe that your personal data is processed in violation of your rights and legitimate interests regarding personal data protection.

Implementation of your rights

To exercise your rights, submit a written request that includes proof of your identity and a signature. Requests can be delivered in person to the Company’s registered office, by regular mail, or by email at dpo@albars.eu. If submitted by email, the request must be in electronic form, identifiable, open, and processed through electronic document management systems or other information technology tools we use.

Requests should be submitted in the official language and be legible. The request must indicate which right you wish to exercise and to what extent, as well as specify the preferred method of receiving the response. If you are unable to submit the request in Lithuanian, you may submit it in English.

The Company will provide you with information on the actions taken in response to your request to exercise your data subject rights within 1 (one) month of receiving your request. If necessary, the response period may be extended by 2 (two) months, with prior notification, if the request involves a large volume of personal data or other requests under review. We will provide the response in the format you indicated as your preferred method.

The Company may restrict the exercise of your rights in cases where applicable laws require the prevention, investigation, and detection of criminal offenses or violations of professional ethics, as well as the protection of the rights and freedoms of others, or if the rights cannot be exercised according to the Regulation.

You may file a complaint about the processing of your personal data in the same manner as outlined in this section of the Privacy Policy.

You also have the right to contact the State Data Protection Inspectorate with a complaint about the processing of your personal data if you believe that your personal data is being processed in a manner that violates your rights or lawful interests under applicable data protection laws. You can contact the State Data Protection Inspectorate following the complaint handling procedure, available here: https://vdai.lrv.lt/lt/veiklos-sritys-1/skundu-nagrinejimas.

Security of your personal data

To ensure the appropriate security of your personal data, including protection against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, we implement suitable organizational and technical measures. These measures include logical and physical security means, such as antivirus software, access control policies, regular reviews of information collection, storage, and processing practices, physical security measures to prevent unauthorized access to our systems, data encryption, etc.

We and any third-party service providers who may process personal data on our behalf are contractually obligated to adhere to the principles and requirements of personal data confidentiality.

Transfer of your personal data

We may transfer your personal data to:

1. Other parties who provide services to the Company or are associated with the services provided (e.g., website development and administration providers, IT service providers, postal service providers, archiving service providers, etc.);

2. State institutions and agencies, other parties performing legally assigned functions (e.g., law enforcement agencies, bailiffs, notaries, attorneys, etc.);

3. Courts, non-judicial dispute resolution bodies, insolvency administrators;

4. Debt collection companies to which claims on debts are assigned;

5. Auditors, legal and financial consultants;

6. Successors of the Company’s rights and obligations.

The Company ensures that personal data is transferred only in accordance with applicable legal requirements. Service providers (data processors) contracted by the Company process your personal data only for specific purposes defined in data processing agreements.

International transfer of personal data

If your personal data is transferred outside the European Economic Area (EEA), we will take necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy. We will ensure compliance with applicable legal requirements for the protection and transfer of personal data by various means, including:

• The country, territory, or specific sector within a third country or international organization is recognized by the European Commission as providing an adequate level of protection;

• The recipient has signed or included in their service terms (service agreement) the standard contractual clauses approved by the European Commission;

• A specific authorization from a supervisory authority has been obtained.

We may transfer personal data to a third country using other measures if they ensure adequate protection as provided in the Regulation or rely on derogations.

Contact us

The Company’s contact information is also published on our website at www.sauga365.lt.
If you have questions about the information in this Privacy Policy or other inquiries regarding the processing of your personal data, please contact us in any of the following ways:

• By mail: Ukmergės g. 120-1, 08105 Vilnius, Lithuania;

• By email: dpo@albars.eu

Cookies

The Company’s website www.sauga365.lt uses cookies. For more information on cookie management and browser settings, please refer to our Cookies Policy.

Changes to the privacy policy

This Privacy Policy may be updated to reflect changes in legislation and the Company’s operations. We will notify you of any changes to the Privacy Policy on our website www.sauga365.lt.

We will not reduce your rights under this Privacy Policy or applicable data protection laws. We recommend reviewing this Privacy Policy regularly to stay informed about any updates.