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1. WHO WE ARE AND SCOPE
1.1. This Privacy Notice explains how companies forming part of Pineca Group process Personal Data of customers, prospective customers, website users, suppliers, business partners and their representatives, telephone Call Participants and other persons interacting with Pineca Group.
1.2. The Controller of your Personal Data is the Pineca Group company with which you interact or which otherwise determines the purposes and means of the relevant Processing (the Company). Information identifying the relevant Company is provided through the relevant website, contract, communication or other appropriate means.
1.3. AV Projektai, UAB may centrally administer certain Personal Data Processing activities and data protection functions within Pineca Group. Its role in relation to a particular Processing activity may be that of a Controller, Joint Controller or Processor, as applicable.
1.4. This Privacy Notice does not apply to Employees or job candidates where separate privacy information is provided to them.
2. PERSONAL DATA, PURPOSES AND LEGAL BASES
2.1. Depending on your relationship and interaction with the Company, we may Process Personal Data for the following purposes:
2.1.1. Provision of products and services and management of contractual relationships – identification and contact details, order, delivery, payment, contractual and communication information. The Processing is based on the performance of a contract, steps taken before entering into a contract and/or compliance with legal obligations.
2.1.2. Customer service, communications, enquiries, complaints and disputes – contact details, communications, order or service information and, where telephone calls are recorded, voice, statements, telephone number, call date, time and duration and information discussed during the call. Such Personal Data may be Processed for handling enquiries and complaints, documenting and verifying business communications, resolving disputes, quality assurance and training, investigating suspected irregularities and establishing, exercising or defending legal claims. The Processing is based on the performance of a contract and/or the legitimate interests of the Company or a Third Party, as applicable.
2.1.3. Supplier and business partner management – identification, professional and contact details, contractual information and communications. The Processing is based on the performance of a contract and/or the legitimate interests of the Company in managing its business relationships.
2.1.4. Website, account and IT security – account, device, technical, access and usage information. The Processing is based on the legitimate interests of the Company in operating and protecting its websites, systems and services and/or consent where required by applicable law.
2.1.5. Accounting, tax and legal compliance – identification, transaction, invoice and other information required for compliance with applicable legal obligations. The Processing is based on compliance with legal obligations.
22.1.6. Direct marketing – contact details, marketing preferences and relevant interaction information. The Processing is based on consent or legitimate interests, where permitted by applicable law.
2.2. Where we rely on legitimate interests, Personal Data is Processed only where such interests are not overridden by your interests, rights and freedoms.
2.3. Where Processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of Processing carried out before its withdrawal.
3. SOURCES AND RECIPIENTS OF PERSONAL DATA
3.1. We generally obtain Personal Data directly from you, including when you place an order, enter into or perform a contract, use our websites or services, communicate with us or otherwise interact with a Company. Where permitted by applicable law, Personal Data may also be obtained from other Group Companies, business partners, service providers, public sources or other Third Parties.
3.2. Personal Data may be disclosed, where necessary and lawful, to other Group Companies, service providers and Processors, including providers of IT, hosting, communications, payment, delivery, accounting, professional and other services, as well as to public authorities, courts, advisers or other recipients where required by law or necessary for the establishment, exercise or defence of legal claims.
3.3. Where a service provider Processes Personal Data on behalf of a Company, appropriate contractual and data protection requirements shall apply.
4. INTERNATIONAL TRANSFERS AND RETENTION
4.1. Personal Data may be transferred to or accessed from countries outside the European Economic Area where necessary for the relevant Processing. Where such transfers are not covered by an adequacy decision, appropriate safeguards, such as Standard Contractual Clauses, or another lawful transfer mechanism shall be used as required by applicable law.
4.2. Personal Data shall be retained only for as long as necessary for the purposes for which they were collected and in accordance with applicable legal, contractual and business requirements. Applicable retention periods may vary depending on the category of Personal Data and Processing activity.
4.3. Telephone call recordings are normally retained for 6 months from the date of the call. A Recording may be retained for a longer period where necessary for a complaint, investigation, dispute, legal claim or other documented lawful reason.
4.4. Personal Data may be retained for a longer period where required by law or where necessary for the establishment, exercise or defence of legal claims. Personal Data shall be deleted or anonymised when no longer required.
5. YOUR RIGHTS, CONTACT AND COMPLAINTS
35.1. Subject to the conditions and limitations established by applicable law, you may have the right to access, rectify or erase your Personal Data, restrict or object to Processing, receive your Personal Data in a portable format and withdraw consent where Processing is based on consent.
5.2. Where Processing is based on legitimate interests, you have the right to object to such Processing on grounds relating to your particular situation. Where Personal Data is Processed for direct marketing purposes, you may object to such Processing at any time.
5.3. To exercise your rights or raise questions concerning the Processing of your Personal Data, you may contact the relevant Company or the central Pineca Group data protection contact:
AV Projektai, UAB
Verkių g. 25C-1, LT-08223 Vilnius, Lithuania
Email: [email protected]
5.4. You also have the right to lodge a complaint with the competent data protection Supervisory Authority. You may in particular contact the Supervisory Authority in the EEA country of your habitual residence, place of work or place of the alleged infringement.
5.5. This Privacy Notice may be updated where necessary to reflect changes in our Processing activities or applicable legal requirements.