Date of last revision: 23-06-2023
1. GENERAL PROVISIONS
1.1. We are concerned about the privacy and security of your personal data, so we have developed this Privacy Policy (hereinafter – the Privacy Policy), in which we explain how we process and store your personal data, what rights we guarantee and provide other information about the processing of your personal data.
1. 2. Your personal data controller UAB “Energenas” (hereinafter – we or the Company), legal entity code 300058451, business address Breslaujos g. 3B, LT-44403 Kaunas.
1.3. The term “personal data” (hereinafter – “Personal Data”) used in this Privacy Policy refers to any information or the set of information which we can directly or indirectly identify you, for example, by your name, e-mail address, phone number, etc.
1.4. When processing Personal Data, we comply with the General Data Protection Regulation No. 2016/679 (EU) (hereinafter – GDPR) and the requirements of the legal acts of the Republic of Lithuania, as well as the instructions of the controlling authorities. Read the latest version of the Privacy Policy posted there.
1.5. The Privacy Policy is applied when you visit the website www.energenas.lt (hereinafter – the Website), view the information provided by us, contact us by phone or e-mail communication channels, and visit us. This Privacy Policy is not applied when you browse the websites of other companies or use the services of third parties. If you use the Website, it means that you have read and agree with this Privacy Policy and the purposes, methods and procedures for the use of your personal data set out in it. If you do not agree with this Privacy Policy or you do not understand it, you cannot use the Website.
1.6. The Privacy Policy is applied when you visit the website www.energenas.lt (hereinafter – the Website), view the information provided by us, contact us by phone or e-mail communication channels, and visit us. This Privacy Policy is not applied when you browse the websites of other companies or use the services of third parties. If you use the Website, it means that you have read and agree with this Privacy Policy and the purposes, methods and procedures for the use of your personal data set out in it. If you do not agree with this Privacy Policy or you do not understand it, you cannot use the Website.
2. WHAT PERSONAL DATA DO WE PROCESS?
2. 1. We process your Personal Data obtained in the following ways:
2. 1. 1. When you provide the Personal Data to us;
2. 1. 2. When we collect your Personal Data using the Website, when you contact us by phone or e-communication means, visit us;
2. 1. 3. When we receive them from other persons in accordance with the legal acts and Privacy Policy (e.g. when the information is provided by your employers when we receive the data from official registers, state or local authorities or institutions).
2. 2. We collect, use and otherwise process your Personal Data in order to offer and sell our products, to fulfil our contractual obligations, as well as to pursue our or third parties’ legitimate interest, performing instructions of the legal acts or duties.
2. 3. When providing the Personal Data to us, you are responsible for the correctness, completeness, and relevance of these Personal Data. When you provide the Personal Data of other people (such as your employees, etc.), you are responsible for the consent of such person that the person‘s Personal Data would be provided to us. If necessary (for example, such a person asks us about receiving his/her Personal Data), we will identify you as the provider of such data.
2. 4. We process your Personal Data for the following purposes and under the following conditions:
| Purpose of the Processing of Personal Data | Personal Data processed | Time limits for the processing of the Personal Data | Legal basis for the processing of the Personal Data |
| Conclusion of contracts with activity partners | Name, surname, position, personal identification code (only if necessary), address (only if necessary), telephone number, and e-mail address of the partner natural person or legal entity participant, representative, or other natural persons specified in the contract. | The data are stored
During the term of the contract and five years after the end of the contract. |
Processing of the data is necessary for the conclusion and performance of the contract (Art.6 p.1(b) of GDPR) |
| Sending of direct marketing informational communications and implementation of the market research. | Name, surname, telephone number, e-mail address, name of the workplace, name of the department where the client works, area of interest, date of birth (year, month and day if the client wishes to be greeted on the occasion of the birthday), e-mail interaction (information on whether the newsletter was read, when and how many times it was read/opened, whether it was forwarded, what operating system and e-mail server (its location) were used) | Data shall be stored for five years from the date of receipt of the consent. | Data subject’s consent (Art. 6(1)(A) of GDPR). |
| Management and administration of website www.energenas.lt | Name, surname, e-mail address, telephone (contact form on the website), IP address, information collected by cookies | The data provided in the contact form are stored for one year from the date of contact.
The IP address is stored for 14 days. Cookie retention periods are set out in Section 7 of the Privacy Policy |
Data subject’s consent (Art. 6(1)(a) of GDPR). |
| Execution of financial operations and bookkeeping, debt management
Video surveillance |
Name, surname, personal identification number, address, e-mail address, contact telephone number, account number, payment institution, transaction amount, date, time, currency, transfer amount, payment history, and debt details.
Image of the data subject |
The data are stored in accordance with the legislation governing financial transactions and accounting.
The data outside the scope of the above-mentioned legislation shall be stored for the entire duration of the contract and for ten years after the end of the contract. Personal data is stored for 7 (seven) days from the date of receipt of data. |
Conclusion and performance of the contract with the data subject (Art. 6(1)(B) of the GDPR).
Seeking to fulfil a legal obligation imposed on the controller (6(1)(c) of the GDPR). |
You have the right to object or at any time withdraw your consent to process your data for the above purposes when your Personal Data are processed on the basis of your consent.
2. 5. To the extent provided by applicable legal acts, in addition to the information you provide, our automatically collected Personal Data, when you use the Website, or other digital channels, we can also obtain the information about you from other sources, such as publicly available registers, databases, social networking platforms and other third parties.
2. 6. You have the right to modify and update the information provided to us. In some cases (for example, when selling our products), we need to have accurate, up-to-date information about you, so we can ask you to periodically confirm that the information we have about you is correct.
2. 7. We have accounts on certain social networks (Facebook, Linkedin, Youtube), where we store information about our company and our activities. Account users are subject to the privacy policy and rules of the social network that contains our account. This Privacy Policy, when you visit our accounts, is applied to your accounts and the information contained therein to the extent set forth in this Privacy Policy and to the extent that logically includes your actions.
3. HOW DO WE USE YOUR PERSONAL DATA, AND WHAT PRINCIPLES DO WE FOLLOW?
3. 1. We collect and process only the Personal Data that are required in order to achieve the purposes for which they are collected. We do not collect or store Personal Data that would be unrelated to our activities.
3. 2. When processing your Personal Data:
3. 2. 1. We comply with the requirements of valid and applicable legislation, including the GDPR;
3. 2. 2. We process your Personal Data in a lawful, fair and transparent manner;
3. 2. 3. We collect your Personal Data for specified, clearly defined and legitimate purposes and do not process the Data in a way incompatible with those purposes, except to the extent permitted by law;
3. 2. 4. We will take all reasonable steps to ensure that the Personal Data that is inaccurate or incomplete, in accordance with the purposes for which they are processed, would be rectified, supplemented, suspended or destroyed without delay;
3. 2. 5. We store 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;
3. 2. 6. We do not provide the Personal Data to third parties or make them public, except as specified in the Privacy Policy or applicable legal acts;
3. 2. 7. We ensure that your Personal Data would be processed in such a way that, by appropriate technical or organizational measures, the adequate security of personal data would be ensured, including protection against unauthorized or unlawful processing of data and against unintentional loss, destruction or damage.
4. WHICH ENTITIES CAN RECEIVE YOUR PERSONAL DATA FROM US?
4. 1. We may transfer your Personal Data:
4. 1. 1. If there is your consent to the disclosure of the Personal Data;
4. 1. 2. To companies of the Group of companies to which we belong: UAB “Inospectra”, UAB “Sophimeda”, UAB “Bonameda”;
4. 1. 3. To our partners or trusted third parties helping us to offer or sell our products, to carry out our activities, such as distributors, auditors, consultants, insurance companies, etc.;
4. 1. 4. State and local offices and institutions, law enforcement institutions, courts, and other persons performing functions entrusted by law, in accordance with the procedure provided for in legal acts of the Republic of Lithuania. We provide these entities with mandatory information required by law or specified by the entities themselves;
4. 1. 5. To use Personal Data processors (such as IT, server services, site administration companies, etc.). We require that processors would store, process and handle Personal Data as responsibly as we do and only in accordance with our instructions;
4. 1. 6. If necessary, to companies that intend to buy or would buy our business;
4. 1. 7. To debt collection companies to which claims on a customer’s debt are transferred, courts, out-of-court dispute resolution bodies and bankruptcy administrators.
4. 2. Your Personal Data may be transferred outside the European Economic Area (EEA). Your Personal Data will only be transferred outside the EEA under the following conditions:
4. 2. 1. The Data are transferred only to our reliable partners who ensure the provision of our services to you;
4. 2. 2. Data processing agreements have been signed with such partners, by which they ensure the security of your Personal Data in accordance with the requirements of the law;
4. 2. 3. The Commission of the European Union has decided on the suitability of the country in which our partner is established, i.e., an adequate level of security is ensured;
4. 2. 4. You have given your consent to transfer your Personal Data outside the European Economic Area.
5. RIGHTS OF THE DATA SUBJECT
5. 1. As a data subject, you have the following rights with regard to your Personal Data:
5. 1. 1. To know (be informed) about the processing of your Personal Data (right to know);
5. 1. 2. To access your Personal Data and to know how they are processed (right of access);
5. 1. 3. To require rectification or, taking into account the purposes of the processing of Personal Data, supplement the incomplete Personal Data (right to rectification);
5. 1. 4. To require the destruction of your Personal Data or suspend your Personal Data processing operations (except storage) (the right to destroy and the right “to be forgotten”);
5. 1. 5. To require to restrict the processing of Personal Data for one of the legitimate reasons (the right to restrict);
5. 1. 6. The right to transfer data (the right to transfer). This right will only be exercised if the grounds for its exercise and the appropriate technical means exist, and these means would ensure that the risk of the security breach of the data of other persons will not arise during the transfer of the required Personal Data;
5. 1. 7. To object to the processing of your Personal Data when we process the Personal Data on the basis of our legitimate interest or the legitimate interest of a third party, including profiling. If you object, we will only be able to further process your Personal Data for compelling legitimate reasons that take precedence over your interests, rights and freedoms or to make, enforce or defend legal claims;
5. 1. 8. To revoke your consent to the processing of your Personal Data when the Personal Data are processed with consent, including when such data are processed or intended to be processed for direct marketing purposes, including profiling *, insofar as it relates to such direct marketing.
* According to the Personal Data provided by you, for the purpose of direct marketing, profiling of your Personal Data can be carried out in order to offer you individually tailored solutions and offers. You may at any time revoke or object to your consent to the processing of the Personal Data by automated processing, including profiling.
5. 2. If you do not want that your Personal Data would be processed for direct marketing purposes, including profiling, you can refuse such processing by clicking on the appropriate link in the e-mail with news or by sending an e-mail info@energenas.lt or calling +370 37 280710.
5. 3. We may waive your rights listed above, except for refusing to process the Personal Data in cases where the Personal Data are processed with your consent, when the provisions of BDAR allow your request to be denied, or when in cases provided for by law, it is necessary to ensure the prevention, investigation and detection of criminal offences, breaches of official or professional ethics, also, the protection of the rights and freedoms of the data subject, other persons and protection of our rights and freedoms.
5. 4. When your Personal Data are processed on the basis of consent, you may revoke such consent at any time. We will immediately, within a reasonable period of time, terminate the processing of your Personal Data. Withdrawal of the consent does not automatically oblige us to destroy your Personal Data or provide you with information about the Personal Data we process. Therefore, if you want us to perform these steps as well, you must specify such a request separately.
5. 5. You may submit any request or instruction related to the processing of the Personal Data to us in writing in one of the following ways: by delivery directly to: Breslaujos St. 3B, LT-44403 Kaunas, by e-mail: info@energenas.lt. When making such a request, we may, in order to better understand the content of your request, ask you to complete the necessary forms, as well as provide an identity document or other information that will help us verify your identity. Upon submission of the request by e-mail, depending on its content, we may ask you to come to us or submit a request in writing.
5. 6. Upon receipt of your request or instruction regarding the processing of the Personal Data, we will respond no later than within one month from the date of the request and will perform the actions specified in the request or inform you why we refuse to perform them. If necessary, this period may be extended by a further two months, depending on the complexity and number of requests. In this case, we will notify you of such an extension within one month after receiving the request.
5. 7. If the Personal Data is deleted at your request, we will retain only copies of information that is necessary to protect our legitimate interests and others, to comply with the obligations of state or local authorities, to resolve disputes, to identify disruptions or to comply with agreements concluded.
6. WHICH AUTHORITIES CAN ACCEPT YOUR COMPLAINT?
6. 1. If you wish to make a complaint about our processing of the Personal Data, please provide it to us in writing, providing as much information as possible, using the contact details provided at the end of this Privacy Policy. We will cooperate with you and try to resolve any issues immediately.
6. 2. If you think that your rights have been violated in accordance with BDAR, you can file a complaint to our supervisory authority – the State Data Protection Inspectorate, more information and contact details can be found on the Inspectorate’s website (https://vdai.lrv.lt/). We strive to resolve all disputes promptly and peacefully, so we invite you to contact us first.
7. HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. 1. Our website uses cookies (small files stored on the hard drive of the website visitors’ device) in order that it would be possible to distinguish you from other visitors of the Website. The information collected by cookies allows us to ensure your ability to browse more conveniently.
7. 2. We use cookies for information flow analysis, trust building and security.
7. 3. You can choose whether you want to accept cookies. If you do not agree to the storage of cookies on your computer or other terminal device, you can change your Internet browser settings and disable all cookies or enable/disable them one by one. If you want to refuse cookies on your mobile device, you must follow the instructions of the device manufacturer. However, we would like to point out that in some cases, this may slow down your internet browsing, limit the functionality of certain websites, or block access to the website. For more information, visit AllAboutCookies.org or www.google.com/privacy_ads.html.
7. 4. We use cookies in the following categories:
7. 4. 1. Compulsory cookies: cookies are necessary for the system to work.
7. 4. 2. Functional cookies: cookies designed to analyze visiting of the website, memorize user preferences and customize them for the website so that we can provide enhanced functionality.
7. 4. 3. Third-party cookies: these cookies are used by third parties.
8. EXTERNAL SITES
8. 1. The Website may contain links to external sites, such as our partner sites or sites that promote our products. By following such links to any of the sites, please note that these sites and the services accessed through them have their own separate privacy policies, and we do not assume any responsibility or liability for these policies or the personal data that are collected on these sites. Please review these policies before submitting personal information on these sites or using any services.
9. CONTACT US
9. 1. If you have any questions about the information provided in this Privacy Policy, please contact: by post: Breslaujos St. 3B, LT-44403 Kaunas, by phone: +370 37 280710, by e-mail: info@energenas.lt.
10. FINAL PROVISIONS
10. 1. We reserve the right to change the terms of the Privacy Policy unilaterally. We will notify you of the changes by publishing the updated Privacy Policy on the Website or by other usual means of communication. Additions or changes to the Privacy Policy will be effective from the date of renewal specified in the Privacy Policy unless a different effective date is specified.
10. 2. If you continue to use the Website after changing the terms of the Privacy Policy, you are deemed to have agreed to the changed terms of the Privacy Policy.
10. 3. Disputes regarding the implementation of this Privacy Policy are resolved through negotiations. If the agreement is not reached, disagreements are resolved in accordance with the procedure established by the laws of the Republic of Lithuania.