UAB LATGALA (hereinafter referred to as “we“ or „Data controller“) is the controller of this website. By these privacy policies we determine and explain how your personal data is collected and further processed when you use this website. The terms of these privacy policies apply to you whenever you access the content and / or service we provide, regardless of which device (computer, cell phone, tablet, TV, etc.) you use.
Data controller requisites
Legal entity code: 304430582
E-mail: [email protected]
We confirm that your data will be collected in accordance with the requirements of the valid legal acts of the European Union and the Republic of Lithuania and the instructions of the controlling authorities. All reasonable technical and administrative measures will be applied in order to protect our collected data about site visitors from loss, unauthorized use and / or changes of data. The Data controller`s employees made a written commitment not to disclose or disseminate information received at the workplace to third parties, including information about visitors of the web site/social network accounts
Persons under the age of 14 cannot provide any personal information through our site / social networking accounts. If you are a person below the age of 14, before submitting personal information, you must obtain the consent of your parents or other legal guardians.
The terms used in these rules are understood as defined in the General Data Protection Regulation No. 2016/679 (EU).
It is very important that you carefully read these privacy policies, because each time you visit this site, you agree to the terms described here. If you do not agree to these terms, please do not visit our web site, do not use our content and / or services. Click on “Find out more” in each section to find detailed information about the processing of your personal data and the specifics of our business.
How do we collect information about you?
Your personal data, e.g. any information about you that allow us to recognize you is collected in various ways:
- you may provide us with information directly (i.e. filling in a registration form);
- we may collect information automatically (i.e. when you access our website, social account, use our apps);
- we may acquire information from third parties and collect information about you from publicly available (e.g. through LinkedIn social network, your company website or otherwise).
We may collect information that you provide directly. Typically this will happen when you:
- register on our website;
- sign service or other contract with us;
- install our apps;
- subscribe to our newsletter or other communication;
- participate in surveys.
We may collect information about you automatically. Typically this will happen when you:
- submit queries through our website or through our social networking accounts;
- use our website (with the help of cookies and similar technologies data is collected. You can find further information about cookies that we use down below.);
- publish public posts on social networking platforms that we are following.
Where permitted by law, we may acquire information about you from third parties. This may be the information provided by our partners, marketing agencies, your public profile information (LinkedIn, Facebook, Twitter, Instagram). We may associate the information we receive about you from yourself, public and commercial sources with other information we receive from you or about you.
We may collect information about you in other cases that are not covered by these privacy policies as well. If this happens, we will inform you additionally.
What information about you do we collect?
Although we try to collect as little information about you as possible, we collect the following information for our activities:
- information necessary to provide our services to you ( i.e. provided in the registration form);information you give us in surveys;
- information about your preferences and interests;
- information necessary to verify your age and identity;
- information about the device you are using.
Information that we collect from you directly will be apparent from the context in which you provide it. For example:
- to provide services, we handle the following information: full name, e-mail address, phone number, digital wallet address, information about your interests and specific needs.
Information that we collect automatically will generally concern:
- Information about how you use our websites (Device information: i.e. IP address, operating system version and settings for the device you use to access content / products; login information: the usage time and duration of your session, query terms that you enter in our website and any information stored in the cookies we had set on your device (the cookies policy is provided below); location information: i.e. a device`s GPS signal, or information about upcoming Wi-Fi access points and cellular towers that may be passed to us when you use the content of our site.
Information that we collect from third parties or publicly-available sources usually is:
- your e-mail address, full name, special preferences and interests.
You may choose not to provide us certain information (for example, information requested on the registration form), however in this case we will not be able to provide to you our newsletters and other updates via e-mail allow our online reservation system to be used.
For what purposes do we use information about you, and on what legal basis?
Subject to the above, information is processed for the following purposes:
- to provide information about healthy lifestyle, Lympo tokens (LYM) for sharing and achieving health goals
- to provide information, which was requested by you, related to the provision of services;
- for marketing purposes, e.g. to provide tailor-made advertisements and promotional content and to send reports about promotional activities, to evaluate and analyze market, customers, products and services (including collecting your opinion on products and services, organizing customers / partners surveys, contests or promotional activities to the extent permitted by law);
- to find out how people use our online services in order to improve them and create new content, products and services;
- to defend our interests in court or in other institution;
- for other purposes, with your consent⃰.
⃰ We inform you that at any time you have the right to refuse to receive the content of our direct marketing, informing us of your determination by e-mail [email protected] or by using the refusal link in the newsletter.
The legal basis for our use of information about you is one or several of the following:
- compliance with legal obligations to which we are subjects;
- performance of the contract with you;
- a legitimate business interest that is not overridden by interests you have to protect the information;
- in certain cases, your consent.
The purposes for which we use information about you, with corresponding methods of collection and legal basis for use are presented in this table.
|Purpose||Legal basis for Processing||Personal data|
|To provide information about healthy lifestyle, Lympo tokens (LYM) for sharing and achieving health goals.||Performance of the contract with you
A legitimate business interest that is not overridden by interests you have to protect the information
|Full name, digital wallet address, other information that may be required for service such as your phone or e-mail for sending confirmation of services, information about your interests and specific needs.|
|To provide information, which was requested by you, related to the provision of services||This information is provided to you due to we have a legitimate interest in providing accurate information about our services, availability of them, additional services, etc.||In order to answer your inquiries by, e-mail, social networking environment and other ways, we can ask for your, e-mail address or other convenient contact.|
|For marketing purposes, e.g., to provide tailor-made advertisements and promotional content and to send reports about promotional activities, to evaluate and analyze market, customers, products and services (including collecting your opinion on products and services, and organizing customer surveys).||For this purpose we process your personal data with a legitimate interest in informing you about our services, events, news and other relevant information.||Social network account details ,e-mail, , your interests.|
|To find out how people use our online services in order to improve them and create new content, products and services
|For this purpose we process your personal data with a legitimate interest to monitor the quality of the services provided, develop and improve the content that we provide, and ensure the security of the website.||IP address, operating system version and parameters of the device you use to access content / products, the usage time and duration of your session, query terms that you enter on our website, and any information stored in the cookies that we have detected on your device, GPS signal of the device, or information about the closest Wi-Fi access points and cellular towers that may be passed to us when you are using our website content.|
|Defend our interests in court of other institution||Compliance with legal obligations to which we are subjects
Legitimate interest to defend against claims and pretenses.
|Depending on the claim or pretense, we may handle all of your personal data contained in our possession in these privacy policies.|
Where we do not base our use of information about you on one of the above legal bases, we will ask for your consent before we process the information (these cases will be clear from the context).
In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.
Who do we share your information with?
We may share information about you:
- For companies that provide services on our request.
- For other third parties, where required or permitted by law, or is necessary to protect our legitimate interests.
We use third-party services and/or content on our site. When you use such third-party services or when third-party content is displayed, communication data are exchanged between you and the respective provider for technical reasons.
For further information regarding the scope and purpose of such collection and processing of your data, please consult the privacy statements of the providers whose services and/or content we use and who are responsible for the protection of your data in this context: Google analytics, Facebook Pixel, Mailerlite.
Other third parties that may be provided with our available information about you when it is necessary to protect our legitimate interests are the governmental authorities, pre-trial investigation officers, courts, etc.
Where might information about you be sent?
When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards. In such cases, we do our best to ensure the security of your personal data being transmitted.
When the data controller sends your personal data to countries outside the European Economic Area, we will make sure that one of the following security measures will be applied:
- the agreement signed with the data recipient should be based on the Standard Terms and Conditions approved by the European Commission;
- in case of transferring data to a group of companies, mandatory companies rules are applied;
- the data recipient is located in a country that is to be recognized by the European Commission as applying adequate data protection standards;
- permission from the Data Protection Inspectorate.
How do we protect information about you?
We have implemented intelligent and appropriate physical and technical measures to protect the information we collect for content / service purposes:
- Administrative measures. Access to your personal data is limited to authorized personnel who have a legitimate need to access it based on their job descriptions. In case third-party contractors process personal data on our behalf, similar requirements are imposed.
- Technological measures. Personal data is transmitted in encrypted format using SSL technology. We use up-to-date firewall protection and high-quality antivirus and anti-malware software.
However, keep in mind that while we are taking appropriate action to protect your information, no website, online transaction, computer system or wireless connection is completely safe.
How long will information about you be kept?
We will retain information about you for the period necessary to fulfill the purposes for which the information was collected. After that, we will delete it, unless legal acts obliges us to store information for tax purposes or data may be required for pre-trial investigation. When this term expires, the data will be deleted in such a way that they cannot be restored.
Typically, personal data is stored in the following terms:
|Personal data||Storage period|
|Marketing records||3 years after your last visit to our website|
|IT system records (logs)||Up to several months|
|Business analytics||Business analytics data is typically collected automatically when you use our website and anonymised / aggregated shortly afterwards|
What rights do you have?
The data subject whose data is processed by the data controller, depending on the situation, has these rights:
- to be informed about personal data being processed (right to be informed);
- to access personal data and get information about how personal data is being processed (right to access);
- to obtain from the controller the rectification of inaccurate personal data concerning data subject and have the right to have incomplete personal data completed (right to rectification);
- to erase personal data (right to be “forgotten”);
- to require the data controller to restrict the processing of personal data for one of the legitimate reasons (right to restriction of processing);
- to transmit personal data to another controller (right to data portability);
- to object at any time to processing of personal data concerning data subject which is based on the performance of a task carried out in the public interest or for the purposes of the legitimate interests pursued by the controller or by a third party. In order for the controller to process personal data, he is responsible to prove that the processing is conducted for legitimate reasons and those reasons are beyond the interests of the data subject;
- lodge a complaint with the supervisory authority in your country.
We offer you easy ways to exercise these rights. You can do this by writing to us at [email protected], or by using certain links at the bottom of the promotional content provided by us.
We may not give you the conditions for the implementation of the above mentioned rights, where in the cases provided by the law, it is necessary to ensure the prevention of crimes, offenses of professional or ethical conduct, as well as to ensure the protection of the rights and freedoms of the data subject or other persons.
Your rights will be fulfilled once your identity is confirmed live, by electronic signature or, if these two options are not possible, remotely via Telegram.
|Your right||Certain limitations|
|Right to be informed||Before processing your personal data, you have the right to receive information about processing of your data in a concise, transparent, intelligible and easily accessible form, using clear and plain language.|
|Right to access||This is confirmation of:
Upon identification of your identity, we will provide you the information listed above, if such information will not violate the rights and freedoms of other persons.
|Right to rectify or update personal data||This applies if the information we hold is inaccurate or incomplete.|
|Right to erase personal data (Right to be “forgotten”)||This applies if:
– the information we hold is no longer necessary in relation to the purposes for which we use it;
– we use the information on the basis of your consent and you withdraw your consent;
– we use the information on the basis of legitimate interest and we find that, following your objection, we do not have an overriding interest in continuing to use it;
– the information was unlawfully obtained or used.
|Right to restrict the processing of personal data||This right applies temporarily while we look into your case, if you:
|Right to object||You can exercise this right:
|Right to data portability||This right can be implemented if you have provided data to us and we use that data, by automated means, and on the basis either of your consent, or on the basis of discharging our contractual obligations to you.|
|Lodge a complaint with the supervisory authority in your country||www.ada.lt|
Cookies, signals and similar technologies
In these privacy rules we use the term “cookies” for cookies and other similar technologies, such as Pixel Tags, Web Beacons, clear GIFs.
When you visit our website, we want to provide content and features tailored to your needs. This requires cookies. Cookies are small items of information stored in your web browser. They help the data controller to recognize you as the previous visitor to a certain website save the history of your visit to the site and adapt the content accordingly. Cookies also help ensure the smooth running of websites, allow you to monitor the duration, frequency of visits to websites and collect statistical information about the number of site visitors. By analyzing this data, we can improve our sites and make them more user-friendly for your use.
Cookies used in our website:
|_ga||2 years||Used by Google analytics to distinguish users.|
|_gat_UA-110575875-1||Used by Google analytics to limit the amount of data recorded by Google on high traffic volume websites.|
|_gid||24 hours||Google ID Used to distinguish users.|
|test_cookie||Session||Used by Google DoubleClick to check if the user’s browser supports cookies.|
|__cfduid||1 Year||Claudflare cookie used to override any security restrictions based on the IP address the visitor is coming from.|
|_hjIncludedInSample||Session||This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate Heatmap|
|fr||3 months||Encrypted Facebook ID and Browser ID used for Facebook Advertisement|
|ct0||Persistant||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|dnt||Never||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|eu_cn||1 Year||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|external_reference||7 Days||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|guest_id||2 Years||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|kdt||2 Years||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|lang||Session||This cookie is set due to Twitter integration and sharing capabilities for the social media.|
|Session cookie||Session||Session cookies only last for the duration of your visit to a website as this type of cookie is destroyed when the browser is closed. Session cookies are not tracking cookies and are for storing information that is required for the website to function.|
When you use browser to access the content we provide, you can configure your browser to accept all cookies, reject all cookies or get notified when a cookie is downloaded. Each browser is different, so if you do not know how to change cookie preferences, look in its help menu. Operating system of your device may have additional cookie controls. If you do not want the information to be collected using cookies, use easy-to-use procedure in most current browsers that allows you to stop using cookies. To learn more about managing cookies, visit: http://www.allaboutcookies.org/manage-cookies/.
However, do not forget that some services may be designed to work only if there are cookies. Turning them off, you will no longer be able to use such services or certain parts of them.
Please note that our social networking accounts are subject to the appropriate social networking cookie policies.
Contact with us
If you notice a discrepancy between these privacy policies, a security loophole on our website or other issues related to the processing of your personal data, please contact us:
Legal entity code: 304430582
Adress: Šv. Stepono str. 7, Vilnius, Lithuania
E-mail: [email protected]
These privacy policies are reviewed at least once every two years. When our privacy policies updates, we will notify you, in our opinion, essential changes by posting a notice on a specific website. If you connect or use our content and / or services after posting such notice, we will assume you agree to the new requirements specified in the updated versions.
The document was approved on 2018-05-25.
Last modified 2018 May 25d.