PRIVACY POLICY

By sending personal inquiries, concluding cooperation agreements or contacting the representatives of UAB Šypsenos akademija, you are providing your personal data and giving us the right to process it to the extent, in the manner and for the purposes provided for in this Policy (hereinafter referred to as the “Policy”).

If you do not agree with the Rules, this Policy or any particular terms and conditions thereof, unfortunately, we will not be able to provide you with access to all or any of the services provided by Šypsenos Akademija (hereinafter referred to as the “Services”).

In this Policy, you will find all the information about what data we collect and process, where we use this data, how long we store it for, etc. This information is important, so we hope you will read it carefully.

We would like to draw your attention to the fact that both the Policy and the Rules may be changed, supplemented or updated.

Personal data means any information that can be used to identify a person, as well as any information about a person that has already been identified.



Šypsenos Akademija collects and processes your personal data listed in these Rules on the following legal bases:

- Your agreement to the terms and conditions set forth in the Rules and this Policy;
- Our legitimate interests;
- Fulfilment of the legal obligations arising and applied by Šypsenos Akademija.
In accordance with the scope and under the applicable legislation, one or more of the above legal bases may apply to the processing of your personal data.

1. What data relating to you do we process?

1.1. Administration and communication

We collect all your personal data through enquiry forms on our website, or by contacting you directly by e-mail. All of this data is used exclusively for administrative and communication purposes.

Data:

Data categories / a person

Your name, surname, e-mail address and phone number

Legal basis for the data processing

Your consent to use the services on the terms and conditions set out in the Rules.

Term of the data processing

We may retain the consent you have given and the proof of it for as long as you use the Services, and for a longer period if necessary, in order to defend ourselves against any claims, demands or actions brought against us.

How long do we process and store your personal data?

We will process and store your Enquiry and the related data until we have processed the Enquiry, provided you with a response and implemented the decisions we have taken, and for up to two (2) months after the Enquiry has been resolved, but not less than:

– Email enquiries - 2 months
– Website enquiries - 2 months
– Facebook private messages - 2 months

If a legal dispute is initiated, or is likely to be initiated in relation to the Enquiry, we may keep your data for a longer period of time, until the expiration of the statutory periods of limitation for lodging a complaint or bringing an action and/or until a final judgment has become final.

After the expiry of the processing and storage period set out in this Policy, we will delete or reliably and irretrievably depersonalise your data as soon as possible, within a reasonable and soundly-based period of time for taking such a step.
2. From which sources do we collect personal data?

We receive your personal data only directly from yourself: by filling in the enquiry form on the website or by providing your contact details by e-mail or private message via the Facebook platform to initiate feedback.
3. In what cases and to what third parties do we disclose your data?

We may transfer your data to third parties for processing in cases where it is related to the settlement of disputes, following the procedure established in the legislation. Your data shall not be transferred to third parties in any other way or case. If the specifics of the work require the involvement of a third party, please contact them personally and transfer the data that you have agree to transfer.

If we use a website analytics service (e.g. Google Analytics), which is used to determine how you use the information provided on the www.sypsenosakademija.lt website, we may share your depersonalised data with third parties who refer to this information for the purposes of evaluating the use of the website, compiling reports for the website operators on the performance of the website, and for the purpose of providing other services relating to the use of the website. For more information, please see our Cookie Policy.
4. In what territories and jurisdictions do we process your personal data?

We process your personal data only in the territory of the Republic of Lithuania. We currently have no intention to transfer, and we do not transfer your personal data to third countries.

5. What rights does the data protection legislation provide and how can you exercise those rights?

Data protection legislation gives you many rights that you can freely exercise, and it is our responsibility to ensure that you can do so. We provide information about your particular rights and how to exercise them in this Policy below, so please read it carefully.

5.1. The right to get acquainted with your personal data processed by us;
You have a right to obtain our confirmation as to whether we are processing your personal data, as well as a right to have access to your personal data processed by us and to information about the purposes of the processing, the categories of data processed, the categories of the recipients of the data, duration of processing, sources of receipt of the data, the automated decision-making, including profiling, and the meaning of the processing and its consequences for you.

We provide most of this information to you in this Policy and believe it is useful to you.

5.2. Right to correct your personal data
If you believe that the information we process about you is inaccurate or incorrect, you have a right to request that this information be changed, revised or corrected.

5.3. Right to withdraw your consent
In cases where we process your data on the basis of your consent, you have a right to withdraw your consent at any time and the processing based on your consent will cease. In some cases, this may mean that we may no longer be able to provide you with further access to our Services.

You may correct (cancel or provide again) your consent by notifying us personally by e-mail at info@sypsenosakademija.lt. We are committed to responding within 2 working days.

In any case, we may retain your consent you have given and the proof of it for as long as you use the Services, and for a longer period if necessary, in order to defend ourselves against any claims, demands or actions brought against us.

5.4. Right to file a complaint
If you believe that we are processing your data in breach of the data protection law, we always ask you to contact us directly first. We believe that, with your goodwill, we will be able to resolve all your doubts, satisfy your requests and correct our mistakes, if any.

If you are not satisfied with our proposed solution or if, in your opinion, we do not take the necessary action in response to your request, you will have a right to file a complaint with the supervisory authority, where the State Data Protection Inspectorate is in the Republic of Lithuania.

5.5. Right to object to data processing where the processing is based on legitimate interests.
You have a right to object to the processing of your personal data when the personal data is processed in accordance with our legitimate interests. However, taking into account the purposes of the provision of the Services and the balance between the legitimate interests of both parties (you as the data subject and us as the controller), your objection may mean that if we cease to process your personal data based on our legitimate interest, we may not be able to provide you with the ability to continue using the Services.

If you want to exercise the right set out in this clause, please submit a written request to info@sypsenosakademija.lt

5.6. Right to delete your personal data (right to be forgotten)
In certain circumstances listed in the data processing legislation (where personal data is processed illegitimately, the basis for processing has ceased to exist, etc.), you have a right to ask us to delete your personal data. If you want to exercise the right set out in this clause, please submit a written request to info@sypsenosakademija.lt

5.7. Right to restrict the data processing
You shall also have the right to restrict the processing of your personal data under certain circumstances specified in the data processing legislation (when your personal data is processed illegitimately, you contest the accuracy of the data, you have submitted an objection to the data processing on the basis of our legitimate interest, etc.). However, we should note that due to the restriction of the data processing and during the period of such a restriction, we may not be able to provide the Services to you.

If you want to exercise the right set out in this clause, please submit a written request to info@sypsenosakademija.lt

5.8 Right to data portability
You have a right to transfer the data that we process to another controller on the basis of your consent, and where the processing of that data is carried out by automated means. We will provide you with the data you have requested to be transferred in a format that is commonly used in our systems and that is computer-readable or, at your request and if technically feasible, we will transfer the data directly to the other data controller you have indicated.

If you want to exercise the right set out in this clause, please submit a written request to info@sypsenosakademija.lt

5.9. Request handling procedure
In order to protect the data of our patients from unauthorised disclosure, we will have to identify you when we receive your request for data provision or to exercise your other rights.

Gavę Jūsų prašymą dėl bet kurios Jūsų teisės įgyvendinimo ir sėkmingai atlikę aukščiau nurodytą patikrinimo procedūrą, mes įsipareigojame jį išnagrinėti ne vėliau nei per 7 d.d., o reaguoti ir įgyvendinti ne ilgiau nei per 14 d.d., nuo sprendimo priėmimo.

Upon the receipt of your request for the exercising of any of your rights, and upon a successful completion of the abovementioned verification procedure, we will undertake to process your request within 7 working days at the latest, and to respond and implement the request within 14 working days at the latest after the date of reaching a decision.

If your request is submitted by electronic means, we will also respond to you by electronic means, unless this is not possible (e.g. due to an extremely large volume of information), or if you ask us to respond to you in another way.

We will refuse your request with a reasoned reply when the circumstances set out in the legislation have been established and shall inform you thereof in writing.

6. What are the ways and contact details we can use to contact you?

You can contact us in the following ways for all data processing issues:
- by e-mail info@sypsenosakademija.lt;
- by calling us at: +370 643 52525;
- mailing address – Švitrigailos g. 11G, Vilnius LT-03228.
7. How secure is your data?

We use a variety of security technologies and procedures to protect your personal information from its unauthorised access, use or disclosure. However, the security of the transmission of information over the internet or by mobile phone cannot be guaranteed; therefore, any transmission of information to us by these means is done at your own risk.
8. Longer data storage

After the expiry of the processing and storage period set out in this Policy we will delete your data, and in the cases provided for in the Policy, we will reliably and irretrievably depersonalise your data as soon as possible, within a reasonable and soundly-based period of time for taking such a step.
The storage of your personal data for a longer period than is specifically set out in this Policy may only be carried out where:

- it is necessary to enable us to defend ourselves against claims, demands or actions and to enforce our rights;
– there are reasonable suspicions of illegal activities in respect of which an investigation is being conducted;
– your data is required for the proper examination and settlement of a dispute or a complaint;
– in the case of any other bases stipulated in the legislation.
9. Cookies

We use cookies (a cookie is a small information file that is sent to your computer or other device (such as a mobile phone) when you visit our website and is stored in your browser). A cookie is sent to your computer or other device to store data so that we can recognise you as a user of the Services when you visit our website. The information collected by cookies allows us to ensure your ability to browse more conveniently, and to learn more about the behaviour of the users of the website, analyse trends and improve both the website and the Services provided to you.

Google Analytics are used:
- to track the number of visitors to our website;
- to collect a remarketing audience;
- to make a statistical and data analysis.
10. Policy validity and amendments

This Policy comes into effect on 24 May 2018. If we make amendments to this Policy, we will post an updated version on this website.
11. Policy application

The Policy applies exclusively to the processing of data by Šypsenos Akademija in all forms; it includes the operation of the website and the collection of data, personal enquiries via e-mail addresses or the enquiry forms belonging to us, and private messages via our Facebook profile.