Last time updated on: 2023-02-13
1.1. We care about your privacy and security of your personal data, therefore we have drawn up this privacy policy (hereinafter referred to as the Privacy Policy) which outlines how your personal data are processed and stored, what are your rights and provides other information about processing of your personal data.
1.2. A definition “personal data” used in this Privacy Policy (hereinafter referred to as the Personal Data) shall mean any information or set of information which can be used to identify you directly or indirectly, such as your name, surname, e-mail address, telephone number, etc.
1.3. In processing of personal data, we shall comply with the requirements of the General Data Protection Regulation No. 2016/679 (EU) (hereinafter referred to as the BDAR) and the legal acts of the Republic of Lithuania as well as with the instructions from the supervisory authorities.
1.4. The Privacy Policy shall be applied when you are using our website at https://www.iv.lt/ (hereinafter referred to as the Website), using the client service system accessible on our Website, web hosting and other services (hereinafter referred to as the Services), visiting our social accounts on LinkedIn, YouTube, Twitter, Instagram and Facebook (hereinafter referred to as Social Accounts), expressing interest in our proposals, contacting us by telephone, other channels of electronic communication or contacting us with other issues.
1.5. The Website and Social Accounts may include links to external websites, for example, websites of business partners, websites promoting our services. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or collection of the Personal Data on these websites. Please check the relevant privacy policy before you submit any Personal Data to these websites or use related services.
1.6. If you use the Services, visit the Website or Social Accounts, contact us, subscribe to our news, fill in the candidate’s form for an open position or contact us for any other issue, we shall consider that you have read and agreed with the terms and conditions of the Privacy Policy as well as the purposes, means and procedure for the use of the Personal Data specified therein. If you do not agree with the Privacy Policy, you cannot use the Services, Website, Social Accounts and contact us with regard to the Services, proposals or other issues.
1.7. This Privacy Policy may be amended, therefore, we ask you to visit the Website from time to time and to read the latest version of the Privacy Policy.
2.1. The website, Social Accounts shall be managed and administered and the Services shall be provided by the controller Interneto vizija UAB, the private limited liability company established in the Republic of Lithuania, legal entity’s registration number 126350731, address J. Kubiliaus g. 6, LT-08234, Vilnius, data are collected and processed in the Register of Legal Entities of the public entity Centre of Registers (hereinafter referred to as the “Company” or “we”).
2.2. When we receive and process Personal Data while our clients use the Website and Social Accounts, we act as the controller of Personal Data. When we provide the Services to our clients and process the data they have entrusted to us, we act as the processor of Personal Data. Our, as the data processor’s, activities are described in the Data Processing Agreement.
3.1. Your Personal Data shall be processed in the following ways:
3.1.1. When you provide your Personal Data to us, for example, during the registration, when using the Website, ordering our Services, contacting us by e-mail or telephone, etc.;
3.1.2. When we collect your Personal Data automatically while you use the Website, Social Accounts, for example, history of the use of services, your IP address, cookies, history of visits of the Website, options, opened URL links, etc.;
3.1.3. When we receive Personal Data from other persons, for example, when information is received from public registers, state or local municipal authorities or institutions, our partners, other third persons, for example, payment institutions about made payments, etc.;
3.1.4. When we are provided, with your consent, with your Personal Data, by other persons, including the companies that order our Services (our clients), for example, when our clients indicate your contact details, specify you as the authorised person, etc.;
3.2. We process Personal Data to offer and provide Services, fulfil our contractual obligations as well as to pursue our or third parties’ legitimate interests, to fulfil the instructions or obligations of the legal acts.
3.3. A person who provides us with his/her Personal Data shall be liable for correctness, completeness and relevance of such Personal Data as well as for the consent of a person whose data are provided to us. We may ask for confirmation, if a person has a right to provide us with Personal Data (for example, when filling-in the forms of order of services or registration). If necessary (for example, when a person asks us about the receipt of his/her Personal Data), we will specify who has provided such data.
3.4. We will process your Personal Data for the following purposes and under the following terms and conditions:
You shall have a right to object data processing or to withdraw your consent to processing at any time, when the Personal Data are processed on the basis of your consent.
3.5. On our Social Accounts, we provide information about ourselves and our activities, we may also organise contests, surveys, share our job advertisements about open positions. Users of the Social Accounts shall be subject to this Privacy Policy as well as the privacy policies of the controllers of the social networks with the Social Accounts. When you contact us on the Social Accounts, we can see certain information of the user’s account depending on the selection of the privacy settings, for example, profile name, surname, picture, sex, e-mail address, location. If the user provides information while communicating with us on the Social Accounts, depending on the selection of the privacy settings, provided information may be made public (for example, provided on our specific Social Account).
3.6. In some cases, we may use the contacts you have provided to send the messages related to the order or provision of the Services, for example, to inform about order confirmation, expiry of the ordered Services, changes in the terms of the provision of Services. Such notices are necessary for provision of our Services and they shall not be considered as advertising messages.
3.7. You shall have the right to change and update your information provided to us by making changes on your account on the Website or by contacting us. In some case we need to have accurate and up-to-date your information, therefore we may ask you, on regular basis, to confirm that the information we have about you is correct.
3.8. When processing payments, we shall not collect data of your payment cards and we shall involve the following partners: BitPay (USA), PayPal (Luxembourg), Paysera (Lithuania), Alipay (China), DOKU (Indonesia), Stripe (USA), BitPay (USA), Coinify (Denmark), Payssion (Hong Kong), Kevin (Lithuania). Before you choose the payment method, please read the privacy policy of the respective partner.
3.9. We may publicly announce your non-identifying data, provide them to our partners, e.g., to demonstrate trends about the general use of our services.
4.1. We respect your privacy, therefore we collect and process only the Personal Data necessary to meet the specified purposes of processing.
4.2. While processing your Personal Data, we:
4.2.1. Comply with the requirements of valid and applicable legal acts, including the GDPR;
4.2.2. Process your Personal Data lawfully, fairly and in a transparent manner;
4.2.3. Collect your Personal Data for the specified, explicit and legitimate purposes and do not further process them in a manner that is incompatible with those purposes, except to the extent permitted by the legal acts;
4.2.4. Take every reasonable step to ensure that Personal Data that are not accurate or detailed, having regard to the purposes for which they are processed, are corrected, supplemented, stopped being processed or erased without delay;
4.2.5. Keep them in a form which permits identification of you for no longer than is necessary for the purposes for which the personal data are processed;
4.2.6. Do not provide Personal Data to any third parties and make them publicly available in any other way than specified in the Privacy Policy or applicable legal acts;
4.2.7. Ensure that your Personal Data are processed in secure manner, ensure technical and organisational security measures as well as grant access to the Personal Data only to the employees who need such access for their job functions.
5.1. Your Personal Data will be transferred only in the ways specified in this Privacy Policy.
5.2. We may transfer your Personal Data to:
5.2.1. Our partners or consultants, such as auditors, lawyers, tax consultants, etc., as well as our processors of Personal Data, such as providers of additional services, IT companies, companies providing advertising and marketing services, companies providing accounting services, etc. We request our processors to store Personal Data, process them and handle them as responsibly as we do and only under our instructions. We have involved the following partners and processors:
5.2.1.1. Marketing and advertising partners:
5.2.1.1.1. APG Media UAB (Lithuania);
5.2.1.1.2. Kokosas UAB (Lithuania);
5.2.1.1.3. MailerLite Limited (Ireland)
5.2.1.1.4. The Rocket Science Group LLC d/b/a Mailchimp (USA) (data shall be transferred to the service provider by signing the standard EU contractual clauses for data transfers outside the EEA approved by the European Commission);
5.2.1.2. Payments:
5.2.1.2.1. Stripe Payments Europe Limited (Ireland);
5.2.1.2.2. Stripe, Inc. (USA) (data shall be transferred to the service provider by signing the standard EU contractual clauses for data transfers outside the EEA approved by the European Commission);
5.2.1.3. Insurance – Compensa Vienna Insurance Group ADB (Lithuania);
5.2.1.4. Accounting, financial services – Finvalda UAB (Lithuania);
5.2.1.5. Couriers and delivery services – SAMUS UAB (Lithuania);
5.2.1.6. Cloud, hosting providers, IT solutions, IT security maintenance and technical services:
5.2.1.6.1. Leaseweb Global B.V. (Holland);
5.2.1.6.2. Evitus UAB (Lithuania).
5.2.2. To announce your content on the Social Accounts, we shall provide data to the following operators of social networks:
5.2.2.1. LinkedIn Ireland Unlimited Company (Ireland);
5.2.2.2. LinkedIn Corporation (USA) (data shall be transferred to the service provider by signing the standard EU contractual clauses for data transfers outside the EEA approved by the European Commission);
5.2.2.3. Meta Platforms Ireland Ltd. (Ireland);
5.2.2.4. Meta Platforms Inc. (USA) (data shall be transferred to the service provider by signing the standard EU contractual clauses for data transfers outside the EEA approved by the European Commission);
5.2.2.5. Twitter International Company (Ireland);
5.2.2.6. Twitter, Inc. (USA) (data shall be transferred to the service provider by signing the standard EU contractual clauses for data transfers outside the EEA approved by the European Commission);
5.2.2.7. YouTube Inc. (USA), Google Inc. (USA) (data shall be transferred to the service provider by signing the standard EU contractual clauses for data transfers outside the EEA approved by the European Commission) and Google Ireland Ltd. (Ireland)..
5.2.3.State or local municipal authorities and institutions, law enforcement and pre-trial investigation institutions, courts and other institutions considering disputes, other persons who carry out the functions assigned to them by laws of the Republic of Lithuania. These subjects shall be provided with the information as set forth by the laws or specified by the subjects themselves;
5.2.4.Other third parties such as payment institutions, etc.;
5.2.5.If necessary, to the companies who would intend to buy or would buy the Company’s business or would be engaged in joint activities with us or would cooperate in any other form as well as to the companies established by us.
5.3. Usually (while being the controller as well as the processor) we process Personal Data in the European Economic Area but sometimes your Personal Data may be transferred outside the EEA. Your Personal Data shall be transferred outside the EEA only under the following conditions:
5.3.1. Data shall be transferred only to our reliable partners who ensure the provision of our services to you;
5.3.2. Contracts, including, if necessary, standard contractual clauses approved by the European Commission, for data processing and transfer that ensure security of your Personal Data shall be signed with such partners;
5.3.3. The European Commission has adopted the decision on the eligibility of the country where our partner is established, i. e. an appropriate level of security is ensured; or
5.3.4. A special permit of the State Data Protection Inspectorate of the Republic of Lithuania for such transfer has been obtained;
5.3.5. You have given your consent for transfer of your Personal Data outside the EEA.
5.4. When we act as processors of Personal Data, a client has granted a general permit to us to involve other persons (sub-processors) for processing of Personal Data. The above processors may also act as sub-processors. Information on the intended changes of the sub-processors shall provide by publishing general information and updating the list in the Data Processing Agreement as well as in writing, including by e-mail, before the sub-processor starts processing of Personal Data.
6.1. You, as the data subject, shall have the following rights related to your Personal Data:
6.1. You, as the data subject, shall have the following rights related to your Personal Data:
6.1.1. To know (be informed) about the processing of your Personal data (right to be informed);
6.1.2. To access your Personal Data and to know how they are processed (right of access);
6.1.3. To request rectification or, having regard to the purposes for which the Personal Data are processed, completion of incomplete Personal Data (right to rectification);
6.1.4. To request erasure of your Personal Data or stopping processing of your Personal Data (except for storing) (right to be forgotten);
6.1.5. To request restriction of processing in case of one of the legitimate grounds (right to restriction);
6.1.6. Right to data portability (right to portability). This right shall be exercised only if there are grounds for exercising thereof and appropriate technical measures ensuring that portability of the requested Personal Data would not cause the risk of breach to other person’s personal data.
6.1.7. To object to the processing when the Personal Data are processed on the grounds of legitimate interest of the Company or a third party, including profiling. In case you object, we will be able to continue processing of your personal data only in case of compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
6.1.8. To withdraw consent for processing of your Personal Data when such data are processed or are intended to be processed for the purposes of direct marketing, including profiling, to the extent that it is related to such direct marketing (according to the Personal Data you have provided, profiling may be conducted for the purposes of direct marketing in order to offer individually customised solutions and suggestions. You can withdraw your consent for automated processing, including profiling, or object to it).
6.2. If you do not want your Personal Data to be processed for the purpose of direct marketing, purposes of organisation of contests, surveys, including profiling, you can withdraw such processing without specifying the reasons of withdrawal (objection) by sending an e-mail to info@iv.lt or in any other way specified in the message you have received (for example, by clicking the link in the newsletter).
6.3. We can refuse exercising of the above rights, except for disagreement to processing for the purpose of direct marketing or in any other cases where the Personal Data are processed under your consent, when we cannot satisfy your request under the provisions of the GDPR, when prevention, investigation and detection of crimes or breaches of official or professional ethics and the protection of rights and freedoms of the data subject, us and other persons must be ensured.
6.4. You can fulfil a part of your, as the data subject’s, rights by yourselves by changing the settings of your account and information provided therein. Any request or instruction related to the processing of Personal Data can be submitted by e-mail vadovams@iv.lt. When submitting such request, in order to understand the content of your request better, we may ask you to fill in necessary forms and to present an identity document or other information that would help us to identify you. If a request is presented by e-mail, having regard to its content, we may ask you to visit us or make a written request.
6.5. Upon receipt of your request or instruction regarding the processing of Personal Data, we shall, within 1 month from the day of application at the latest, provide you with a response and perform the actions specified in the request or inform about our refusal to perform them. That period may be extended by 2 further months where necessary, taking into account the complexity and number of the requests. In such case, we shall inform you of any such extension within 1 month of receipt of the request.
6.6. If the Personal Data are erased under your request, we shall store only copies of information that are necessary in order to protect our and other persons’ legitimate interests, comply with the obligations set by the state authorities, settle disputes, identify malfunctions or comply with any agreements that you have made with us.
7.1. When we receive your consent, we can use your Personal Data for the purpose of direct marketing to provide you with newsletters, proposals and information on our services that, in our opinion, may interest you and to ask for information regarding the quality of our services and your experience.
7.2. News can be sent by e-mail, SMS or messages on your account. Your contact details may be transferred to our partners/processors who provide the services of news delivery and quality assessment to us.
7.3. When we have sent the news, we can collect information about the persons who have received them, for example, what message has been opened, what links have been clicked, etc. Such information is collected in order to provide you with more relevant and customised news.
7.4. Even if you have given your consent to processing of Personal Data for the purposes of direct marketing, you can easily withdraw fully or partially such consent at any time. In order to do that, you can:
7.4.1. Notify us about your withdrawal in the way specified in electronic notices and/or proposals (for example, by clicking the newsletter link “withdraw subscription”, etc.); or
7.4.2. Send us a notice to the e-mail address specified in this Privacy Policy. If you request to withdraw your consent in such way, we may ask you to confirm your identity.
7.5. If you withdraw your consent, we will immediately try to stop sending news to your contact details.
7.6. Withdrawal of the consent shall not automatically oblige us to destroy your Personal Data or to provide you with information on the Personal Data we process, therefore a separate request should be submitted for this.
8.1. Your Personal Data shall be processed in responsible and secure manner and shall be protected against loss, unauthorised use and alteration. We have introduced physical and technical measures to protect collected information from accidental or unlawful destruction, damage, alteration, loss, disclosure as well as against any other unlawful processing. Security measures for the Personal Data shall be set according to the risks arising during the processing.
8.2. Our employees have undertaken in writing to not disclose and disseminate your Personal Data to any third unauthorised person.
8.3. We will seek to not store old and outdated Personal Data, therefore when the data are updated (e.g. information on the account is corrected or altered, etc.), only current information shall be stored. Historical information shall be stored, if this is necessary in compliance with the legal acts or performance of our activities.
9.1. Cookies are small text files that store information (often consisting only of a sequence of numbers and letters that identifies the device but they may also contain other information) that is used in the browser of the device (computer, tablet, mobile phone, etc.) (e.g. Google Chrome, Microsoft Edge, Firefox, Mozilla, Opera, etc.) according to their settings and stored on the device’s hard drive. In the Privacy Policy, the definition “Cookies” shall be used to describe cookies and other similar technologies such as pixel tags, web beacon, clear GIF. The use of cookies shall ensure a better and more effective functioning of the Website.
9.2. We use cookies to analyse information flows and user behaviour, to promote trust and to ensure security, as well as to ensure the proper functioning of the Website, its improvement, remembering your preferences in order to personalize the content you see, to link the Website with Social Accounts.
9.3. You can choose, if you want to accept cookies. If you do not agree to cookies being saved in your device’s browser or memory, you can mark your consent in the cookie bar, change the settings of the browser you are using and disable cookies (all at once or one by one or in groups) or follow the official instructions for the device. Note that in some cases opting out of cookies may slow down your browsing experience, restrict respective functions of the Website or block access to the Website. For detailed information on opting out of the cookies, see AllAboutCookies.org or Google.com/privacy_ads.html
9.4. We may use mandatory cookies that are necessary for the functioning of the Website, analytical cookies, functional cookies that are used to analyse Website visits, remember user preferences and adapt them to the Website, performance cookies, third-party cookies that are used by third parties, advertising cookies that show you personalized and general advertising.
9.5. We use the following tools from Google Inc:
9.5.1. Google Analytics which allows analysing the use of the Website, create reports, plan and forecast the activity of the Website. The data collected by Google Analytics is usually stored on a Google Inc server in the USA. You can change your browser settings to prevent Google Analytics from analysing information by changing browser settings. In this case, an opt-out cookie will be saved for you. However, if you delete all cookies, the opt-out cookie may also be deleted. You can also prevent Google from recording and processing the data generated by the cookie and based on your use of the Website by downloading and installing a browser add-on from https://tools.google.com/dlpage/gaoptout?hl=en.
9.5.2. Google Remarketing which allows users to re-receive advertisements on the websites of network of Google Inc’s partners. If you do not wish to receive customised advertising and/or wish to opt-out Google Inc cookies, you can disable Google Inc advertisements in the settings at https://www.google.com/settings/ads by changing the settings as needed. In this case, an opt-out cookie may be saved for you. However, if you delete all cookies, the opt-out cookie may also be deleted.
9.5.3. Google Tag Manager is the application used for the services analysing the use of websites. The information generated by the cookies about how you use the Website (including the IP address) is transmitted to and collected on a Google server in the USA. This information is used to analyse how you use the Website, prepare reports on the popularity of the Website for its operator, and provide other services related to the Website and its use. Google can transfer this information to the third persons, if this is required by the applicable legal acts or if such third persons process information on behalf of Google. Google will not relate your IP address with any other data held by Google. More information: https://support.google.com/tagmanager/answer/9323295?hl=en.
9.6. Other tools we use:
Name of cookie: | Purpose of cookie: | Moment when a cookie is created | Cookie expires in |
test_cookie | Used to check if the visitor’s browser supports cookies. | During the first visit | 1 day |
_GRECAPTCHA | This cookie is used to distinguish the visitor from the robot. | During the first visit | 180 days |
CookieConsent | The cookie is aimed at saving the visitor’s settings for the use of cookies. | When cookie settings are selected | 1 year |
intercom-id-# | The cookie is used to create a unique ID for Intercom correspondence. | During the first visit | 270 days |
iv_atad_session | The cookie MediaWiki is necessary for tracking visitor’s session. | During the first visit to the Help categories | Session period |
tr | The cookie used on Facebook to offer the best advertisements. | During the first visit | Session period |
VISITOR_INFO1_LIVE | The cookie is used to create a unique ID in order to collect statistics on which videos are viewed using the YouTube system | During the first visit | 180 days |
10.1. We act as data processor when we provide clients with hosting and server services, and manage Personal Data of visitors to our clients’ websites and their employees. Such data are received from the client or collected during the provision of services and processed for proper provision of our services. The data are processed when we administer the Website, solve tasks related to system operation and proper functioning, and provide services.
10.2. The data are not processed longer than for the period of the agreement between us and the client on provision of services, unless such data should be processed longer in order to prove proper provision of services. All the terms and conditions for processing of personal data controlled by the clients are set forth in the Data Processing Agreement.
11.1. If you have any questions related to the information provided in this Privacy Policy, please contact us:
E-mail: info@iv.lt;
Address: J. Kubiliaus g. 6, Vilnius, Republic of Lithuania;
By telephone: (+370 5) 232 4444.
11.2. If you want to make a complaint regarding our processing of Personal Data, make it in writing by providing as much information as possible. We will cooperate with you and will try to solve all the issues immediately.
11.3. If you believe that your rights granted by GDPR have been, you can file a complaint to our supervisory authority – State Data Protection Inspectorate; for more information and contact details, see the website of the inspectorate (https://vdai.lrv.lt/). We seek to settle all disputes in prompt and amicable manner, therefore, please contact us first.
12.1. We have the right to amend this Privacy Policy. Any amendments shall be published on the Website by uploading an updated Privacy Policy or in other usual ways of communication. Any supplements or amendments to the Privacy Policy shall enter into force on the date of updating specified in the Privacy Policy, unless another period for entry into force is indicated.
12.2. If you continue to use the Website, order services, use our Social Accounts, contact us after amendment of the Privacy Policy, it shall be considered that you have agreed to the amended terms and conditions of the Privacy Policy.
