WHO ARE WE AND HOW TO CONTACT US?
We, UAB “LAVTWINS”, are the administrator of the website https://lavtwins.com/ and the data controller of the personal data collected on it.
Contact details of the data controller: UAB “LAVTWINS”, company code 300868957, address: Saltoniškių g. 31, Vilnius, +37062026672, [email protected] (hereinafter – the Company).
We process the personal data of visitors of the website https://lavtwins.com/, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the GDPR) and applying the highest technical and legal standards of protection and taking all necessary measures to prevent possible breaches of personal data protection.
The term “personal data” shall mean any information relating to you as a natural person, a data subject whose identity is known or can be established directly or indirectly through the use of certain data (for example, name, surname, e-mail address, etc.).
WHAT PRINCIPLES DO WE FOLLOW?
When processing your personal data, we:
- comply with the requirements of valid and applicable legal acts, including the GDPR;
- process your personal data in a lawful, fair and transparent manner;
- will collect your personal data for specified, clearly defined and legitimate purposes and will not continue to process it in a way incompatible with those purposes, except to the extent permitted by law;
- take all reasonable steps to ensure that personal data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, suspended or destroyed without delay;
- will keep them in such a form that your identity can be established for no longer than is necessary for the purposes for which the personal data are processed;
- will ensure that your personal data is processed in such a way as to ensure adequate security of personal data through appropriate technical or organisational measures, including protection against unauthorised or unlawful processing of personal data and against unintentional loss, destruction or damage.
WHAT PERSONAL DATA DO WE PROCESS, FOR WHAT PURPOSE AND ON WHAT BASIS?
|Purpose of the processing of personal data. Why do we process personal data?
|Category of personal data processed. What categories of personal data do we process?
|Basis for lawful processing (Article 6 of the GDPR). On what legal basis do we process personal data?
|When you visit our website, cookies may be used in order to store your browsing data, login details (IP address of the connecting device, connection time), etc.
We use the necessary technical cookies to make the website work and/or third-party cookies to make your use of the website more convenient (we want to provide you with content and features that are tailored to your needs).
|Data relating to cookies and similar technologies shall be collected (processed) in accordance with Article 6 (1) (a) of the GDPR – with your consent, with the exception of essential cookies.
You can find more information about cookies here:
|Examination and responding to your inquiries
|You can contact us with questions of concern at our specified contacts. When we receive an inquiry, we shall process it and provide an answer.
If you contact us by e-mail, post or through the website, we may process the following personal data of you: name, surname, e-mail address, address and other information you provide. The details of your correspondence shall be retained until the inquiry is fully resolved and shall be retained for three months from the receipt of the last letter.
If you contact us by telephone, we shall retain your telephone number from which you are calling. The retention period is 6 months.
|All personal data we receive when you make inquiries to us by e-mail, mail, telephone or otherwise shall be processed solely for the purpose of administering the inquiry in order to provide you with an answer.
Such personal data shall be processed in accordance with Article 6 (1) (a) of the GDPR on the basis of your consent. You express your consent to the processing of personal data for this purpose by submitting an inquiry to us.
|Sending of newsletters, offers and other information related to our activities, organisation of various competitions, quizzes, voting (direct marketing)
|If you accept direct marketing offers, we shall send an e-mail to your e-mail address requesting confirmation of your e-mail address.
After confirming the e-mail email address, we shall send you newsletters, information about news on the website, various offers, competitions, invitations to vote, as well as offers of our partners about goods and services, various promotions, etc.
When you vote, we associate your vote with your e-mail address in order to determine more accurate voting results.
When you participate in promotions and games, if you win a prize, we shall inform you by personal message via your confirmed e-mail address.
If we need additional personal data for the purpose of organising the game, announcing the winner or transferring the prize, or if we wish to transfer your data to a third party (e.g. the supplier organising the game), we shall contact you in advance and coordinate all such actions with you.
Please note that you may opt out of direct marketing at any time by clicking on the appropriate link in our newsletters and/or notices.
|Personal data shall be processed for direct marketing purposes in accordance with Article 6 (1) (a) of the GDPR – with your consent.
Personal data may also be processed for the purpose of direct marketing under Article 6 (1) (f) of the GDPR, based on the legitimate interest of the data controller in offering similar products or services.
|Calculation of voting results on the website
|Visitors to the website who agree to receive direct marketing offers shall have the opportunity to express their views on various issues in the website, e.g. by voting, etc. For this purpose, after entering your e-mail address, we shall check to see if we have it on our direct marketing contact list. After you express your opinion, cast your vote, etc., your e-mail address shall not be published on the website.
|Personal data shall be processed for the specified purpose in accordance with Article 6 (1) (a) of the GDPR – your consent, which shall be expressed when you enter your e-mail address when voting, giving an opinion, comment, etc.
|Your contact, identification and purchasing details
|The following personal data may be collected when you purchase and order goods on the Website: your name, address, telephone number, e-mail address, the postal address, bank account details from which the goods were paid for, the delivery address of the goods, the goods, their name, type, quantity and other similar data are necessary for the sale of the ordered goods and delivery to the address specified by you.
The specific order and related data and documents are kept for 10 years after the order is fulfilled.
|Personal data shall be processed for the specified purpose in accordance with Article 6 (1) (b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
By submitting your personal data, you hereby confirm that it is accurate and correct and that you are at least 16 years old. In order to enable you to provide accurate and correct data, we may additionally apply authentication to the e-mail address you provide, such as requesting confirmation of your e-mail address. However, in all cases you shall be responsible for the accuracy and truthfulness of the data provided.
FOR HOW LONG DO WE STORE YOUR PERSONAL DATA?
We hereby ensure and take all necessary measures in order to ensure that outdated or unnecessary personal data about you is not stored and that your personal data is constantly updated and correct.
We shall use your personal data for the purpose of direct marketing for 5 (five) years after you give your consent, unless you revoke it earlier, or after the end of the contractual relationship (direct marketing of similar services or products).
After the expiration or revocation of the consent, your personal data about the consent shall be stored for 2 (two) years for the purpose of providing evidence during dispute resolution.
HOW DO WE PROTECT YOUR DATA?
We responsibly implement organisational and technical measures in order to ensure the security of personal data, which helps to protect personal data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing. The security measures we implement include the protection of personnel, information, IT infrastructure, internal and public networks, as well as office buildings and technical equipment.
In the event of a personal data breach that could seriously jeopardise your rights or freedoms, we shall notify you thereof immediately.
WHO IS YOUR DATA DISCLOSED TO?
We may share some of your personal information with the following categories of third parties:
- companies providing data centre, hosting, cloud, website administration and related services, companies involved in software development, delivery, maintenance and development services, companies providing information technology infrastructure services, companies providing communication services;
- our professional advisors, auditors, legal and/or financial advisers;
- our other service providers (data processors) or our subcontractors;
- companies providing advertising and marketing services;
- in accordance with the procedure provided by law, to state institutions, establishments, etc.;
- law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offence has been committed, as well as courts and other dispute resolution bodies; tax administrators;
TRANSMISSION OF DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
Your personal data shall normally be processed in European Economic Area (hereinafter referred to as EEA) countries. However, in certain cases, your personal data may be transferred to non-EEA countries. We remind you that in non-EEA countries, personal data may enjoy less protection than within the EEA, but we carefully assess the conditions under which such data shall be further processed and stored after the transfer to the abovementioned entities.
Please note that if the European Commission has decided that the third country, territory or one or more specified sectors in that third country or international organisation concerned ensures an adequate level of protection of personal data, the transfer shall follow the same procedure as within the EEA. Please note that the information on which the European Commission’s decision has been taken can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
In other cases, we shall take all necessary measures in order to ensure that your personal data is transferred securely to the recipient who processes the personal data. The measures we use:
- The contract with the recipient of non-EEA personal data shall include specific conditions for the secure processing of personal data;
- In certain cases of transfer, we shall ask for your consent to transfer your data outside the EU or the EEA.
RIGHTS GUARANTEED TO YOU
We hereby guarantee the exercise of your following rights and the provision of any relevant information upon your request or inquiry:
- to know (be informed) about the processing of your personal data;
- to access your personal data that we process;
- to demand the correction or supplementation, revision of incorrect, inaccurate, incomplete personal data;
- to require the destruction of personal data where they are no longer needed for the purposes for which they were collected;
- to demand the destruction of personal data if they are processed unlawfully or if you withdraw your consent to the processing of personal data or do not give such consent, which is necessary;
- to object to the processing of personal data or to withdraw your consent given previously;
- to require that, where technically possible, your personal data collected with your consent or for the purposes of performing the contract be provided in an easily readable format or to request to transfer such data to another data controller.
In order to exercise your rights, send us a request by e-mail: [email protected] or by regular mail to: Saltoniškių g. 31, Vilnius.
Upon receipt of your inquiry, we may ask you to provide proof of your identity or other identifying information in order to make sure that we exercise your rights as a data subject and prevent the unauthorised disclosure of personal data or information to other persons who are not entitled to receive it. If we are unable to identify you, we shall not be able to exercise your rights as a data subject.
We shall provide information about the processing of your personal data free of charge. If your request is unfounded, repetitive or disproportionate, we may charge a fee commensurate with our administrative costs.
If we refuse to comply with your request, we shall clearly state the grounds for such refusal.
If you consider that the processing of our personal data does not comply with data protection law, you shall also have the right to lodge a complaint with the supervisory authority (list of supervisory authorities by country: https://edpb.europa.eu/about-edpb/board/members_en). In all cases, we recommend that you contact us before making a formal complaint so that we can find the right solution.
WHAT WILL HAPPEN IF OUR BUSINESS IS TRANSFERRED?
LINKS TO OTHER WEBSITES
Our websites may contain links to other websites not operated by UAB “LAVTWINS”. We do not control how your data is collected, stored or used on such other websites; therefore, we encourage you to review the privacy policies of all such websites before providing them with data.
When you visit social networks, your information shall be processed by a specific social network, and we shall start processing your personal data when you visit us on social networks. We want to introduce you to our wide range of services/products through various social media channels and exchange ideas and opinions with you on important topics.
Your personal data provided on the social network shall be processed for the following purposes:
- to communicate with our social network visitors;
- to respond to visitor’s inquiries;
- to obtain statistical information;
- to conduct customer surveys, marketing campaigns, market analysis, lotteries, competitions or similar actions or events;
- if necessary, in the protection of the legitimate interests of the company in the institutions and in other cases.
Unless explicitly stated otherwise, the legal basis for the processing shall be Article 6 (1) (f) of the GDPR. Our legitimate interest is to be able to answer your messages or questions and analyse our reach on social networks, to present our products and services.
If we intend to process your personal data for any other purpose not mentioned above, we shall notify you prior to such processing.
Our pages on social networks are controlled by specific social networks; therefore, when you visit them, the processing of personal data shall be governed by the privacy policies of social networks. With some social networks, depending on the social network policy, the purposes and scope of the processing, we are considered as joint data controllers.
|Personal data we process
|Personal data we process as joint data controllers
YouTube, Google Ads, Google Analytics
|– Your username, when you comment, write us messages;
– Your activity on our website, e.g. your page views, duration statistics, inquiries, comment information, and more.
|We use statistical information (visits to our website, range of entries, visits and average video transmission times, information about the countries and cities our visitors come from). We receive anonymous statistics from Facebook, LinkedIn, Instagram, YouTube, Google Ads through their services.
AVIA SOLUTIONS GROUP PLC, a limited liability company incorporated and governed by the laws of the Republic of Cyprus, registration number HE 380586, with its registered office at 117 Arch. Makariou Ave., 5th Floor, Office 505, 3021 Limassol, Cyprus.