1. Controller of the personal data to be processed:
1.1. The Controller of the personal data to be processed is Skrivanek Translation Agency UAB, company number: 300023429, registered address: Švitrigailos g. 11B, LT-03228 Vilnius, mobile phone: +370 655 21919 (hereinafter “Skrivanek”), website: www.skrivanek.lt (hereinafter “Website”).
2. Processor of the personal data:
2.1. Skrivanek processes the Customer’s personal data in such scope and arrangements as required and permitted by the regulatory acts of the Republic of Lithuania and the European Union. Other processors of the personal data engaged by Skrivanek also have the right to receive and process Customer data. You can learn more about Skrivanek’s data processing partners by completing the relevant form in the Contacts section of the website.
3. Applicable legislation:
3.1. 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;
3.2. Law on Legal Protection of Personal Data;
3.3. Other legislation governing the protection of personal data.
4.3. Any modifications to the Policy shall take effect from the date of their publication on the Website. In accordance with this, an individual who visits the Website is responsible for ensuring that they are aware of the latest version of the Policy – which will be available on the Website – and by continuing to use the services on the Website they accept these modifications.
5. What personal data does Skrivanek process?
5.1. The categories of personal data processed by Skrivanek depend on the services provided to the Customer. Skrivanek has the right to process the following categories of personal data for the purposes cited in clause 7 of the Policy:
5.1.1. forename, surname, personal identification number / date of birth, correspondence address, telephone number, and email;
5.1.2. bank details;
5.1.3. details of personal identification documents (document number, date and place of issue, etc.);
5.1.4. information provided to Skrivanek by the Customer themselves;
5.1.5. CCTV recordings and images.
5.2. Skrivanek processes the following data regarding the use of services in accordance with the provisions in clause 7 of the Policy:
5.2.1. cookie data (website browsing data) on the visits to the Skrivanek Website (www.skrivanek.lt) (hereinafter “Skrivanek Website”).
6. What is the legal basis for the processing of the Customer’s personal data?
6.1. Customer consent: the Customer (in the capacity of a data subject) consents to the collection and processing of their personal data for specified purposes. The Customer’s consent is an expression of their free will. Such consent may be granted at any time by allowing Skrivanek to process personal data for the prescribed purposes. The Customer’s consent is binding if it was given verbally (during a telephone call after the Customer’s identity has been verified) or in writing (by filling in the relevant form in the offices of Skrivanek, sending an electronic enquiry after the Customer’s identity has been verified or by using the Website. The Customer has the right to withdraw their previous consent, at any time, via the provided communication channels of Skrivanek (see the Contacts section of the Website). Any requested changes will enter into effect within 3 working days. A withdrawal of consent shall not affect the lawfulness of data processing which was based on consent before its withdrawal.
6.2. A contract to be concluded and implemented: it is a requirement for Skrivanek to be able to enter and implement a contract with the Customer for the provision of good-quality services and provide support to the Customer; the personal data, which were collected before the conclusion or during the performance of the contract with Skrivanek, are processed for the above-mentioned purpose.
6.3. Legitimate interests of Skrivanek: in the interests of Skrivanek, which are based on a high level of quality and timely services to the Customer, Skrivanek has the right to process the Customer’s personal data to an extent that is objectively necessary and sufficient in accordance with the provisions set out in clauses 7.1-7.3 of this Policy. The legitimate interests of Skrivanek include the processing of personal data as part of direct marketing activities resulting in the provision of new and/or personalised Skrivanek service offers to the Customer (see also clauses 8.2 and 8.3 of this Policy). Given that Skrivanek is part of the SKRIVANEK Holding SE Group (see also clause 12.4 of this Policy), Skrivanek has a legitimate interest in processing its Customers’ data by transferring them to other companies, which are part of the Group, for internal management purposes, including to offer services that meet modern requirements to the Customer by the companies belonging to the SKRIVANEK Holding SE Group.
6.4. Compliance with legal obligations: Skrivanek has the right to process personal data in such a way as to meet the requirements of regulatory acts, as well as the legitimate requirements of state and municipal bodies.
6.5. Protection of vital interests: Skrivanek has the right to process personal data in order to protect the vital interests of the Customer or another natural person – for example, if data in video recordings are needed to deter or expose criminal activities.
7. What purposes does Skrivanek process Customers’ personal data for?
7.1. Skrivanek processes personal data to ensure a good quality of service under a Contract with Skrivanek during its validity period:
7.1.1. To examine Customer claims and provide assistance (including technical support) with respect to the services provided;
7.1.2. To enable effective management of cash flows, including Customer payment and arrears management;
7.1.3. To make the Customer aware of other services offered by the companies which are part of the SKRIVANEK Holding SE Group;
7.1.4. To carry out CCTV monitoring for property protection purposes.
7.2. Skrivanek processes personal data to promote business development and offer new services to Customers, including:
7.2.1. developing new services and presenting related offers;
7.2.2. conducting market analysis and developing its business model, both of which require the processing of statistical data of Skrivanek customers.
7.3. Skrivanek processes personal data to shape and support the company’s internal processes, and ensure document sharing and other internal processes (e.g. archiving contracts and other documents) to the extent necessary and sufficient for these purposes.
7.4. Skrivanek has the right to process the following data, including for other purposes, under the explicit, freely given and unambiguous consent of the Customer, in order to:
7.4.1. Check the Customer’s personal data in a credit history database before entering into a contract in order to evaluate the Customer’s creditworthiness; such verification is necessary for the purpose of offering new and improved services to the Customer during the validity of the contract.
7.4.2. Promote the image of Skrivanek in the market by sending greetings to the Customer, offering promotions, and holding surveys aimed at helping improve existing services and develop new ones.
8. Does the Customer have the right to object to processing of their personal data?
8.1. Profiling of the Customer’s personal data as a form of data processing:
8.1.1. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning the individual’s personal preferences, interests, reliability, behaviour, location or movements;
8.1.2. While processing the Customer’s personal data, Skrivanek may carry out profiling for the purpose of personalised offers to be prepared and presented. Automated personalised decisions are made exclusively for business purposes and will not have legal implications for the Customer. The Customer has the right to object to the automated decision-making at any time and not be subject to such a decision by notifying Skrivanek thereof (see also the provisions in clause 8.3 of this Policy).
8.2. Direct marketing is used as a basis for sending commercial communications to Customers. Skrivanek engages in direct marketing sending commercial communications to Customers to keep them informed, at all times, of any new services and/or services tailored to the Customer’s request, as well as special contractual conditions (e.g. discounts) on the basis for the processing of personal data indicated in clause 6.3 of this Policy. The Customer has the right to unsubscribe, at any time and free of charge, from commercial communications by informing Skrivanek thereof (see also the provisions in clause 8.3 of this Policy).
8.3. The Customer has the right to object, at any time, to the profiling of their personal data (see clause 8.1) or unsubscribe from commercial communications (see clause 8.2) by informing Skrivanek thereof verbally (via a telephone call on +370 655 21919 after the Customer’s identity has been verified) or in writing (by filling in the relevant form in the offices of Skrivanek or sending an electronic request to email@example.com accompanied by an advanced electronic signature). The requested modifications will come into effect within 3 working days. Such modifications will not affect the lawfulness of processing of personal data that took place before the Customer’s objection and/or cancellation of subscription was received.
9. What are cookies and how may Skrivanek use them?
9.1. Cookies are small text files stored on a Customer’s device (computer, tablet, mobile phone, etc.) that are uploaded when they visit the Skrivanek Website. Cookies remember the user’s actions and basic information, and improve the experience on the Skrivanek Website.
10. How does Skrivanek obtain a Customer’s personal data?
10.1. Skrivanek receives a Customer’s personal data when the Customer:
10.1.1. uses the services of Skrivanek (in the offices of Skrivanek or remotely after the Customer’s identity has been verified);
10.1.2. subscribes to the news, communications or other services from Skrivanek;
10.1.3. requests more information from Skrivanek about its services offered to Customers or contacts Skrivanek in relation to a complaint or a request for additional information after the Customer’s identity has been verified;
10.1.4. participates in competitions, prize draws or surveys;
10.1.5. visits or browses through the Skrivanek Website;
10.1.6. is filmed by Skrivanek CCTV equipment on Skrivanek property.
10.2. Skrivanek can process a Customer’s personal data obtained from third parties if the Customer consents to this (e.g. from the proprietor of the credit history database).
10.3. Skrivanek may process a Customer’s personal data obtained from other companies as well as the companies and representative offices which are part of the SKRIVANEK Holding SE Group (see the provisions in clause 12 of this Policy).
11. How long will a Customer’s personal data be processed for?
11.1. Skrivanek processes the Customer’s personal data for the duration of any of the following circumstances:
11.1.1. as long as there is a Contract between the Customer and Skrivanek in force;
11.1.2. the time period for the storage of personal data as defined or established by the regulatory acts of the Republic of Lithuania and the European Union;
11.1.3. as long as is necessary for the enforcement and protection of the legitimate interests of Skrivanek;
11.1.4. unless the Customer’s consent on the processing of personal data is withdrawn.
12. Sharing of the Customer’s personal data.
12.1. For the purposes of the services to be provided to the Customer, Skrivanek may share the Customer’s personal data with:
12.1.1. companies which are part of the SKRIVANEK Holding SE Group;
12.1.2. partners or bodies involved in ensuring the provision of services ordered by the Customer or the services that they use;
12.1.3. debt collection agencies, credit bureaus, managers of credit history databases or other debt recovery organisations;
12.1.4. assignees – in order to ensure the effective management of cash flows; however, Skrivanek retains the right to lodge claims against a debtor or debtors.
12.2. Skrivanek must provide information concerning the individual to the following institutions and authorities:
12.2.1. law-enforcement agencies, courts or other state and municipal authorities, if this requirement is established in normative acts or is requested by the appropriate authorities;
12.3 Skrivanek will provide the Customer’s personal data only for explicit and legitimate purposes, provided there is legal basis therefor, and to a sufficient and necessary extent, in accordance with the requirements of regulatory acts and taking into account the objective circumstances of a particular situation.
12.4. Where required, Skrivanek has the right to transfer the Customer’s personal data to other companies which are part of the SKRIVANEK Holding SE Group or other service providers if this is necessary in order to provide better-quality services to the Customer. Information about the companies which are part of the SKRIVANEK Holding SE Group, debt collection agencies, credit bureaus, managers of credit history databases or other debt recovery organisations may be obtained by filling in the relevant form in the Contacts section of Skrivanek Website at www.skrivanek.lt.
13. How does Skrivanek protect a Customer’s personal data held by the company?
13.1. Skrivanek ensures the implementation, continuous reviews and improvements of safeguards in order to protect the Customer’s personal data from unauthorised access, accidental loss, disclosure or destruction. For this purpose, Skrivanek uses state-of-the-art technologies along with technical and organisational measures, including the use of firewalls, software for detecting intrusions and analysis, and data encryption.
13.2. Skrivanek carefully carries out checks on all service providers that process the Customers’ personal data on behalf of Skrivanek and inside the company; Skrivanek also assesses whether its partners (processors of personal data) invoke appropriate safeguards to ensure that the processing of a Customer’s personal data is carried out only within the limits of what is permitted by Skrivanek and the requirements of regulatory acts. Partners are not permitted to process a Customer’s personal data for their own purposes.
13.3. Skrivanek does not accept responsibility for any unauthorised access to personal data and/or loss of personal data that does not involve Skrivanek because it occurred, for example, due to the Customer’s fault and/or negligence.
13.4. In the event of any threat to the Customer’s personal data, Skrivanek shall inform the Customer thereof.
14. What rights does a Customer have?
14.1. A Customer may contact Skrivanek to obtain a copy of their personal data held by Skrivanek.
14.2. A Customer may have all their personal data held by Skrivanek rectified and notify about the changes by sending an email with an electronic signature to firstname.lastname@example.org, by calling +370 655 21919 or by visiting the offices of Skrivanek.
14.3. A Customer has the right to receive information about natural or legal persons who have obtained information about the Customer from Skrivanek over any given period of time. Skrivanek will not provide information about public authorities launching criminal proceedings, intelligence bodies or other institutions about which it is prohibited by law to provide information to the Customer.
14.4. A Customer may request the cessation or restriction of the processing of personal data when it is no longer necessary for the purposes for which they were collected and processed (‘the right to be forgotten’).
14.5. A customer may contact Skrivanek to receive the personal data concerning them, which they have provided to Skrivanek, in a structured, commonly used and machine-readable format, and to forward the data to another data controller or require that Skrivanek directly transfer such personal data to another data controller, where technically feasible.
14.6. A Customer may contact Skrivanek or the supervisory authority for the processing of personal data (Lithuanian State Data Protection Inspectorate, www.ada.lt) should the Customer have any queries regarding the processing of personal data.
14.7. A Customer may contact the Data Protection Officer at Skrivanek to receive information on the processing and protection of the Customer’s personal data.
14.8. Contact details for the Data Protection Officer at Skrivanek: Rusnė Juozapaitienė, email: email@example.com, tel.: +370 698 34316 (MB Asmens duomenų apsauga).
1. Controller of the personal data to be processed: