All your data lawfully collected either under your consent, or for the performance of a contract with us or on our website, transferred, processed and maintained is treated in accordance with the principles as stated by the General Data Protection Regulation (GDPR) (EU) 2016/679. We recognize our responsibility to keep your information confidential and secure. Any personal information about you which we obtain in connection with our services provided to you we undertake to keep safe.
UAB Finolita Unio
Lvovo g. 25, Vilnius LT-09320, Lithuania
‘Personal Data’ means any information relating to a natural person who can be identified, directly or indirectly (‘data subject’).
How we collect information
Personal data is usually provided to us by yourself, however, some information is collected automatically, by using cookies, and some information can be provided by third parties, such as credit rating agencies. All personal data, processed by us is treated as private and confidential.
To enable us to provide our services, we need to obtain your Personal Data including your name, your e-mail address, and other relevant details to tailor your needs. The data you enter in the online form or that you share with us at events or exhibitions includes your name, your job title, email address, telephone number and your place of work. All this information can be considered personally identifiable information.
How we use your information lawfully
Your Personal Data will only be processed for specific, explicit and legitimate purposes and in the context of lawfulness. In particular, Personal Data will be processed for the following purposes and where one or more of the following conditions apply:
· To identify customers. The legal basis for processing is compliance with our statutory license obligation.
· To implement obligations under the laws on money laundering and terrorist financing prevention. The legal basis for processing is compliance with a legal obligation to which Finolita UAB is subject.
· To conclude and execute agreements and provide services. The legal basis is performance of a contract to which you are a party to.
· To respond to your inquiries and fulfil your requests, such as to respond to your questions and comments. The legal basis for data processing is our legitimate interest – to provide a good customer service
· To send administrative information to you, for example, information regarding our websites and changes to our Terms and Conditions. The legal basis for data processing is performance of a contract to which you are a subject to.
· To re-contact you if we have not heard from you in a while. The legal basis for data processing is our legitimate interest – to provide good customer service and keep data updated.
· To offer and facilitate the provision of services upon your request
· To improve our service and developing new services. The legal basis for data processing is our legitimate interest – to provide a good customer service and improve our business.
· To resolve conflicts, manage litigation, resolve issues, and provide you customer service (including troubleshooting in connection with customer issues). The legal basis for data processing is our legitimate interest – to provide a good customer service in connection with our administration duties.
· The execution of risk management. The legal basis for processing is compliance with a legal obligation.
· The processing of transactions The legal basis is the performance of a contract to which you are a party to.
· To complete and fulfil your service-order, have your order delivered to you, communicate with you regarding the service and provide you with related customer service. The legal basis is the performance of a contract to which you are a party to.
· To provide you with updates and announcements concerning our products, promotions and programs and to send you invitations to participate in special programs (direct marketing). The personal data collected for direct marketing purposes may be processed only with the unambiguous active consent of you which clearly indicates that you agree with the processing of your personal data for direct marketing. You have a right to withhold your consent or withdraw previously given consent without any adverse effect. The legal basis for data processing is our legitimate interest – to update you with our new products and services.
· To personalise your experience on the website by presenting products and offers tailored to you. The legal basis for data processing is our legitimate interest – to provide for you a good service experience.
· For our business purposes, such as analysing and managing our businesses, business mergers and acquisitions, market research, audits, developing new products, enhancing our websites, identifying usage trends, determining the effectiveness of our promotional campaigns and gauging customer satisfaction. The legal basis for data processing is our legitimate interest – to improve our services for your needs.
· As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. The legal basis for processing is compliance with a legal obligation.
· Protection of the legal rights and interests of UAB Finolita Unio, including, but not limited to, the discovery, conduct or defense of legal rights. The legal basis for processing is compliance with a legal obligation.
We want to inform you that whenever you use our service or visit our websites, we collect information that your browser sends to us that is called Log Data. This Log Data includes information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our service that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
In the course of your visit to our website, your computer may be issued with cookies. Cookies are files containing a small amount of data that is commonly used as an anonymous unique identifier. These are sent to your browser from our website when you visit and are stored on your computer’s hard drive.
Our website uses these “cookies” to collect information and to improve our service. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, some portions of our service will not be available any longer.
Cookies are commonly used on the Internet and do not harm your system. Cookies have a number of uses.
The cookies used on our website (http://www.finolita.com) fall into three categories:
Functional: These cookies are used to enable core website functionality and do not contain any personal information.
Analytics: These cookies allow us to count page visits and traffic sources, so we can monitor and improve the performance of our website.
Advertising cookies: We partner with affiliate networks and other websites to help promote UAB Finolita Unio. If you use their websites, or have come to our site via these affiliates, then their cookies will be sent through our website.
When you enter our websites for the first time, we provide you with an opportunity to accept or decline the usage of cookies, You can also delete and block cookies at any time from this site through your browser, but some features on this site will not function without cookies.
You can change the preferences or settings in your web browser to control cookies. In some cases, you can choose to accept cookies from the primary site but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies.
Transfer of Data to Third-Parties
We employ third-party companies and individuals that may be located outside of the European Economic Area (EEA) due to the following reasons:
· To facilitate our service
· To provide the service on our behalf
· To perform service-related services
· To assist us in analysing how our service is used
We want to inform our service users that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
Personal information will only be transferred in the following circumstances:
· To other companies that provide us services. We share Personal Data with other partners who perform services and functions on our behalf. These partners, for example, provide services to you as defined in our service contracts.
· To financial institutions with whom we work together to develop or provide a product or service
· To other parties when you use their services, such as: to merchants, and service providers: We may disclose information to other participants in your transactions when you use the services. The information we share includes: person-related data required to complete the transaction
· Personal Data needed by other transactional participants to resolve conflicts and to investigate and prevent fraud
· Anonymised data and performance analytics that help better understand the use of our services and increase the satisfaction of our customers
· To third parties for our business purposes or as permitted or required by law
· To protect the essential interests of a person
· To investigate violations of any User Agreement or other legal provision applicable to our services or to enforce such legal instruments to protect our assets, services and rights
The following categories of recipients of personal data are located outside of the European Economic Area. Personal Data only are transferred where applicable upon the performance of a contract to:
· Payment Providers in Australia, UK, and Russia and
· Credit card organizations in USA
Should you wish to receive a list of our data recipients, please contact our Data protection officer using contact details below.
To fulfil some of our processes we must pass your Personal Data to other parts of our group companies, which may be in other countries. We make sure that they agree to apply the same levels of protection as we are required to apply to information held in Lithuania and to use your information only for the purpose to provide our service to you. In any event UAB Finolita Unio will capture and process such personal information in accordance with the requirements set out in the Data Protection Regulation (EU 2016-679).
Currently, your Personal Data is transferred to our following group companies located outside the European Economic Area, based on standard data protection clauses:
· PXP Financial Limited
The Corn Mill – 1 Roydon Road Stanstead Abbots, Hertfordshire SG12 8XL, UK
· PXP Services Private Limited
402, 4th floor, CSR Estate, Plot No. 8, Sector-1, HUDA Techno enlave, Madhapur Main Road,
Hyderabad – 500081, Telangana, India
Links to Other Websites
Storage of Data
We retain personal information in an identifiable format as long as required by law or regulation, or as needed for our business purposes. We retain personal information for longer periods of time than is legally required if it is in our legitimate business interests and is not prohibited by law.
Data Protection Rights
As the Affected Person, you have the right at any time to obtain information about your stored Personal Data, its origin and the recipient as well as the purpose of the data processing. You also have the right to correct and transmit your data and, if necessary, to object to, restrict the processing of, or deleting of, your Personal Data.
If you want us to execute your Data Protection Rights as described above, you can send an email to our Data Protection Officer at firstname.lastname@example.org
If you believe that the processing of your Personal Data by UAB Finolita Unio violates the applicable data protection law or your data protection claims have been violated in another way, you may file a complaint with the competent supervisory authority.
We do not knowingly collect personal identifiable information from or about children under 16 years of age. In the case we discover that a child under 16 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take necessary actions.
Data encryption and Technical Security Measures
To prevent the illegal manipulation through a third person, the IP address of the logged-on computer will be requested and saved. In addition, all your Personal Data is protected from unauthorised access by a firewall – a computer that is fitted with complex security technology specifically designed to shield the company’s network from the Internet. We also use encryption and other security technologies to protect private information from unauthorized access. We ensure that information, personal data and data under our responsibility is properly backed up and that arrangements for recovery processes are in place. Additionally, the company uses reliable internal data protection mechanisms combined with a restrictive security system.