INTRODUCTION
This Privacy policy (hereinafter – Privacy policy) is prepared in an easily understandable language, so that You could understand who we are, what data about You we collect, why it is collected and what is it used for.
Personal data (hereinafter – Personal data) means any information or set of information, which can used to directly or indirectly identify You, first of all, according to an identifier, e.g.: name, surname, email address, telephone number, etc.
This Privacy policy may be amended or supplemented at any time for the purpose of meeting the requirements of legal acts and to provide You with relevant information how we, as the manager of data, manage your Personal data when You use the website of Private Limited Company “NAUJASIS NEVĖŽIS”, legal entity number 132345137, Ilgakiemis village, Jiesios st. 2, LT-53288 Kaunas distr. mun. (hereinafter – Company) – www.nevezis.lt (hereinafter – Website) or during other communication with the Company.
The Company recommends to take Your time and familiarize with the Privacy policy.
If You do not agree with management of Your personal data according to the provisions of the Privacy policy, You have the right to not provide Personal data to the Company. Also, if we manage certain Personal data on the basis of Your consent to management of Personal data, You may withdraw Your consent at any time, without affecting the legality of data management based on a consent until the withdrawal of it.
This Privacy policy explains how the Company collects and uses Your Personal data, when You:
- visit the Company’s Website;
- agree to receive direct marketing notifications sent by the Company or subscribe to the newsletter of the Company;
- contact the client service department of the Company;
- participate in events, surveys, contests and promotions organized by the Company;
- communicate or cooperate with the Company as a consumer, client or potential client, supplier, contractor or another person/entity having business or consumer relations with the Company.
The Company is a production company, specializing in production and sales of breakfast cereals, crisps, cereal bars, snacks, porridges, semi-finished products.
Contact details of the employee responsible for fulfilment of the data protection policy in the Company:
- Head of the Company Gediminas Krutulis;
- Address: Ilgakiemis village, Jiesios st. 2, LT-53288 Kaunas distr. mun.;
- Email: info@nevezis.lt;
- Telephone: +37037 394561.
PERSONAL DATA COLLECTED BY THE COMPANY
The Company can manage different Personal data taking into account who You are (consumer, client, supplier, etc.) and how you communicate with the Company (in person, via Internet, phone, etc.).
The categories of Personal data we may collect are indicated below:
Personal data, which the Company may receive directly from You for administration and management of the Website, on the basis of Your voluntary actions
| Categories of Personal data | Personal data |
| Personal identification data | Name, surname |
| Contact details | Email address, telephone number |
| Any other information, communicated to the Company at Your free will | Reviews, opinions, comments, ratings, information You provide to the Company in documents, etc. |
Personal data automatically collected by the Company
The Company can automatically collect Your Personal data when you visit or use the Company’s Website, order electronic newsletters of the Company or otherwise contact the Company through digital media, i.e. the Company can collect information sent to the Company by Your computer, telephone, another kind of end device or means of contact, as required by applicable legal acts.
More information is available in “Use of cookies and other tracking technologies by the Company”.
Personal data received by the Company from third parties
To the extent of applicable legal acts, along with the information You have provided Yourself, and information collected through the website, software or other digital means, the Company can also receive information about You from third parties, i.e. marketing partners, social networking platforms and other third parties.
USE OF YOUR PERSONAL DATA BY THE COMPANY
When managing and administrating the Website, the Company collects and manages Your Personal data only for its legitimate business purposes.
In any case, the Company is committed to ensure that Your Personal data collected and used by the Company is intended and suitable for the purposes it was collected for, and it would not cause a threat to your privacy.
Below is a list of aims, for which the Company may use Your Personal data received during Your use of the Company’s Website:
| Aims | Data management actions |
| Client service | Providing assistance using communication means, e.g., through the employees responsible for client service |
| Direct marketing (with Your consent) | Promoting communication with consumers and/or clients, advertising emails, calls, SMS messages, other types of notifications, market research, personalized suggestions of goods and services (e.g., on the Website of the Company or via other communication means) |
| Organizing events, surveys, contests, promotions | Participation in events, surveys, contests, promotions, etc. organized by the Company |
| Analysis of user activity on the Website using cookies | Processing, analysis of acquired information – the behaviour (actions) of visitors of the Website |
In certain cases, the Company may not be able to ensure operation of the Website if the Company requests You to provide Personal data, but You choose not to.
LEGAL BASIS, UNDER WHICH THE COMPANY MANAGES PERSONAL DATA
The Company can manage Personal data received through Your use of the Website on various legal bases, including:
- Your consent. If management of Your Personal data is carried out on the basis of Your consent, You may withdraw it at any time;
- Conclusion of performance of an agreement, as well as necessary actions before conclusion of an agreement;
- Necessity to fulfil legal obligations and raise, perform or defend legal claims;
- Any other legal basis allowed by applicable legal acts.
DIRECT MARKETING
The Company uses your Personal data (provided by You, collected automatically or received from third parties) for direct marketing only after receiving Your prior consent, which can be withdrawn at any time by emailing us at info@nevezis.lt.
If we have your consent, we can use Your Personal data managed for direct marketing for the purpose of profiling, i.e. in order to identify what might interest You, what you would like or need.
If Your Personal data is used for profiling, we undertake to inform You about such management of data and enable You to request human intervention, express Your opinion and challenge the decision.
WHO YOUR PERSONAL DATA IS PROVIDED TO BY THE COMPANY
The Company shall not provide Your Personal data to anyone, except cases established in this Privacy policy.
If it is necessary for the purpose of Personal data management aims established in this Privacy policy, the Company can disclose and provide Your Personal data to the following persons/entities:
State institutions and authorities: when required according to the provisions of legal acts or when it is necessary for protection of the Company’s rights, the Company can share Your Personal data with institutions overseeing the activity of the Company or institutions with jurisdiction over it.
Managers of data: The Company has the right to transfer Your Personal data to managers of data used for managing the Personal data of the Company, providing services (carrying out work) to the company and managing Your Personal data on behalf of the Company, as the manager of data. Managers of data have the right to manage Personal data only according to your directions and only to the extent necessary for proper fulfilment of our obligations established in our mutual agreement. When using managers of data, the Company shall take all necessary measures for ensuring that the managers of data employed by the Company have necessary organisational and technical security means and will maintain the confidentiality of Personal data.
Third parties assisting the Company in provision of services: The Company has the right to transfer Your Personal data to third parties employed for carrying out activity, who are not managers of data, but provide services to the Company, and in some cases disclosure of Your Personal data is necessary for provision of the services, e.g. financial institutions, debt recovery companies, courier services, etc. The Company shall take all necessary measures for ensuring that the third parties employed by the Company have necessary organisational and technical security means and will maintain the confidentiality of Personal data.
Third parties, as far as it is necessary for business transactions: The Company can also share your data during business transactions, e.g. sale of the business or part thereof to another company, any reorganisation, merger, founding of a joint company, or other transfer of the Company’s business, assets or shares (as well as those associated with bankruptcy of any similar procedure). In such case the Company must ensure the confidentiality of data.
TRANSFER OF PERSONAL DATA ABROAD
Your Personal data can be managed outside of Your country of residence if it is necessary for the aims established in this Privacy policy.
If you are located within the European Economic Area, the Company can transfer Your data to countries outside the European Economic Area. Some of such countries are recognized by the European Commission as ensuring a sufficient level of Personal data protection. When data is transferred outside of the European Economic Area to countries not recognized by the European Commission as ensuring a sufficient level of Personal data protection, the Company shall take appropriate measures for protecting Your Personal data, e.g. organisational and legal means (rules compulsory for companies and terms of standard data transfer agreements certified by the European Commission). You can get a copy of these measures by contacting the employee responsible for fulfilment of the data protection policy in the Company using the contact details indicated previously.
PERSONAL DATA STORAGE PERIOD BY THE COMPANY
The Company stores your Personal data for the period necessary for fulfilment of aims, for which it was collected (the detailed description of such aims is indicated in section “How is Your Personal data used by the Company”). We would like to draw Your attention that in certain cases the law requires or allows longer data storage periods.
Among other things, the criteria used by the Company for determining the data storage period, include:
- How long will the data be required for the Company to be able to supply its goods to You, carry out its activity, reply to Your inquiries?
- Is the Company legally, contractually or otherwise obligated to store Your data? For example, we may be subject to obligations established by the laws of certain countries in regards to data storage periods, instructions from authorities to store certain data or we will have to store the data for the protections of our rights;
- Has Your consent, on the basis of which the Personal data is managed by the Company, not been withdrawn?
HOW THE COMPANY ENSURES DATA SECURITY
In order to protect Your Personal data the Company has undertaken means, corresponding to the laws and regulations for data security and protection, including the requirement for service providers/managers of data employed by the Company to use suitable means for protection of your Personal data and the confidentiality thereof.
Depending on modern technologies, the price of implementing the means and the nature of data protected, the Company has technical and organisational means for protecting Personal data from certain dangers, such as destruction, loss, alteration, unauthorized disclosure or access.
YOUR RIGHTS
We would like to remind You that You have the obligation to ensure that the data provided to us is accurate, complete and updated. Furthermore, if You provide data of other persons to us, You are obligated to receive such information and provide it to us according to legal requirements. For example, You have to inform other persons, the data of whom You provide to the Company, about the contents of this Privacy policy and receive their consent regarding provision of Personal data.
RIGHTS THAT YOU HAVE AS THE DATA SUBJECT
The Company aims to enable You to familiarize with Your data.
You can always contact the employee responsible for fulfilment of the data protection policy in the Company if You want to implement Your (as the data subject) rights, among other things:
- The right to be informed about the management of data carried out by the Company: to receive information about managed Personal data, sources of the Personal data, Personal data management aims, legal basis, Personal data storage periods and persons/entities the Company shares Your Personal data with, rights of the data subject, the ability to submit claims to supervisory authorities, if applicable, information about the existence of automated decisions (including profiling), applicable Personal data protections measures;
- The right to familiarize with Your Personal data managed by the Company: to receive information if the Company is managing Your Personal data, if yes, to receive a copy of it or other associated information;
- The right to correct Your Personal data managed by the Company: to correct incorrect or to supplement incomplete data. In such case we may need to verify Your newly provided data;
- The right to delete data: to demand to “be forgotten”, if Your Personal data is no longer required for the initial collection purpose, You withdraw Your consent to management of Your Personal data, if management of data is based on Your consent, we manage Your Personal data based on legitimate interests and you do not object to such management and there are no overriding legitimate reasons for management of the data, we must delete Your Personal data in fulfilment of our legal obligations or if Your data has been managed illegally. We would like to note that we will not be able to always fulfil this right in the event of legitimate reasons, e.g., we may be obligated to store Your Personal data for a certain period under the provisions of legal acts. Such legitimate reasons will be indicated when You apply for fulfilment of the right to “be forgotten”;
- The right to limit data management: to limit the management of data carried out by us if You dispute the accuracy of data and we are verifying it, Your data was managed illegally, but You object to deletion of Your Personal data, if Your Personal data is no longer necessary for the initial collection purpose, but it is necessary for raising, carrying out or defending legal claims, if You have objected to data management as described below, until the importance of the Company’s legitimate reasons is compared to Yours;
- Right to object to management of data: to object to management of Your Personal data for the purposes of direct marketing, to object to management of Your Personal data for public interests or legitimate interests of the Company, unless the interests are more important than Your reasons;
- The right to portability of data: to receive the Personal data provided by You or the right to request transfer of such data to another manager of data in a systemized, commonly-used, digital format, if management of Your Personal data is based on Your consent or our mutual agreement and Your Personal data is managed via automated means.
The Company undertakes to make efforts to be able to reply to Your requests in a timely manner and free-of-charge, except cases, when disproportionate effort is required. The Company can request a reasonable fee if Your requests are clearly unreasonable, repetitive, or excess.
In certain cases, the Company may request You to confirm Your identity before starting to carry out Your request. We shall request it for security reasons, in order to ensure that Your Personal data is not disclosed to persons without such right.
COMPLAINTS
If You are not satisfied with the response regarding fulfilment of Your rights, or You believe that Your Personal data is managed illegally, You can always submit a claim to the State Data Protection Inspectorate or another competent institution, if applicable.
Although, we would appreciate the opportunity to solve Your complaint before You apply to supervisory authorities, therefore we ask you to first send any of Your complaints to us by email info@nevezis.lt.
USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES BY THE COMPANY
Cookies (small files saved on the user’s hard drive) are used on the Company’s Website for distinguishing You from other visitors of the Company’s Website. The information gathered using cookies enables the Company to ensure a better browsing experience. The Company uses cookies for analysing information flows, adapting services, content to specific aims, assessment of advertising efficiency, promoting trust and ensuring security.
You can choose if You want to accept cookies. If you do not wish to save of cookies on Your computer or another end device, You can change Your browser settings and disable all cookies or enable/disable them one-by-one. Although we would like to drawn Your attention to the fact that in certain cases this may decrease Internet browsing speed, limit the functions of certain websites or block Your access to the Website. For more info please visit AllAboutCookies.org or www.google.com/privacy_ads.html.
The Company uses the following cookie categories:
| Type of cookie | Name of cookie | Data management purpose | Expiry date | Description |
| Functional cookies | PHPSESSID | Ensuring functionality of the Website | Until end of session | The cookie has a random unique number or a line of letters/digits. It allows identifying you as the same person, not a new visitor. |
| Google Analytics | _ga | Assessment and analysis of Website traffic | 2 years | The cookie collects info about the behaviour of visitors on the Website and is used for saving statistical information. |
| _gat | Assessment and analysis of Website traffic | 1 minute | Used for identifying new sessions/visits | |
| _gid | Assessment and analysis of Website traffic | 24 hours | The cookie collects info about the behaviour of visitors on the Website and is used for saving statistical information. |
COLLECTION OF CHILDREN’S DATA BY THE COMPANY
The Company does not collect information purposefully from children under the age of 14.
Special note for children under the age of 14: If You are under the age of 14, the Company suggests that You should consult Your parents or carers and receive their permission before providing your data to the Company.
Special note for the parents of children under the age of 14: we recommend checking and monitoring how Your children use the Company’s Website to make sure that your child does not provide Personal data to the Company without Your permission.
UPDATING THE PRIVACY POLICY
The Company may need to update this Privacy policy for the purposes of expanding its business or services. For this reason, the Company recommends to periodically visit the Website, where You will find the most recent version of the Privacy policy.
Significant changes in the Privacy policy will be announced in advance on the Company’s Website.