1. The Controller of the personal data to be processed:

1.1. The Controller of the personal data to be processed is Skrivanek vertimų biuras UAB, legal entity number: 300023429, registered address: Švitrigailos g. 11M, LT-03228 Vilnius, mobile phone: +370 655 21919 (hereinafter referred as Skrivanek), website: www.skrivanek.lt (hereinafter referred to as the Website).

2. The Processor of the personal data:

2.1. Skrivanek processes the Data Subject personal data in such scope and arrangements as required and permitted by the regulatory acts of the Republic of Lithuania and the European Union. The processors of the personal data engaged by Skrivanek also have the right to receive and process Data Subject the personal 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 (hereinafter referred to as the Regulation);

3.2. The Law of the Republic of Lithuania on Legal Protection of Personal Data;

3.3. Other legislation governing the protection of personal data.

4. What is this Privacy Policy?

4.1. The Privacy Policy (hereinafter “Policy”) provides information on how Skrivanek collects, processes, stores, shares, deletes and protects the Data Subject personal data to ensure that such data are processed lawfully, fairly and transparently. This Policy applies to the processing of Data Subjects’ personal data.

4.2. Should Skrivanek update the Policy, the information about any modifications thereto will be published on the Website in the following section: About Us –>Privacy Policy.

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. 5. What personal data does Skrivanek process?

5.1. The categories of personal data processed by Skrivanek depend on the services provided by Skrivanek. For the purposes cited in clause 7 of the Policy, Skrivanek has the right to process such categories of personal data as:

5.1.1. forename, surname, personal identification number / date of birth, correspondence address, telephone number, and email;

5.1.2. job position, workplace, representation data;

5.1.3. language knowledge level, language knowledge testing results, learning group, learning method (usual/remote);

5.1.4. bank details;

5.1.5. details of personal identification documents (document number, date and place of issue, etc.);

5.1.6. information provided to Skrivanek by the Data Subject himself/herself;

5.1.7. CCTV recordings and images.

5.1.8. personal data contained in the documents of Skrivanek Data Subjects presented for translation, etc.

5.1.9. Data Subject’s profile in the social media, chat systems;

5.1.10. Data Subject’s CV, motivation letter, other data produced during the recruitment;

5.1.11. Data collected by the cookies used on the Website.

6. What is the legal basis for the processing of the Data Subject Data Subject’s personal data?

6.1. Data Subject’s consent: the Data Subject consents to the collection and processing of their personal data for specified purposes. The Data Subject 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). 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 Data Subject. 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 Data Subject or another person.

6.3.1. The legitimate interest 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 Data Subject (see also clauses 8.2 and 8.3 of this Policy).

6.3.2. 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 personal data by transferring them to other companies, which are part of the Group, for internal management purposes.

6.3.3. The basis of the legitimate interest of Skrivanek is considered to include the cases where Skrivanek processes personal data of customer representatives for contract conclusion or performance purposes, where Skrivanek processes personal data available in the documents produced by customers, etc., or where Skrivanek processes video data for asset protection purposes.

6.4. The basis of legitimate interest of third parties is considered to include the cases where the purpose of such processing is protection of the assets of third parties (e. g., video data, in order to protect the assets of third parties of Skrivanek employees stored in the premises of Skrivanek).

6.5. 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.

6.6. Protection of vital interests: Skrivanek has the right to process personal data in order to protect the vital interests of the Data Subject 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 Data Subjects’ personal data for?

7.1. Skrivanek processes personal data to ensure a good quality of service under a Contract concluded with a customer  during its validity period:

7.1.1. To examine Data Subject’s claims and provide assistance (including technical support) with respect to the services provided;

7.1.2. To enable effective management of cash flows, including Data Subject’s payment and arrears management;

7.1.3. To make the Data Subject aware of services offered by Skrivanek and other companies which are part of the SKRIVANEK Holding SE Group.

7.2. Skrivanek processes personal data to promote business development and offer new services to Data Subjects, 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 Data Subjects.

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 processes personal data for the purposes of protection of assets and individuals  (processing of visual data).

7.5. Skrivanek processes personal data during the selection of candidates to employees/trainees.

7.6. Skrivanek processes personal data for other purposes as well as long as this is necessary for the provision of services, customer service, defending, protecting the legitimate interests of Skrivanek, for the establishment of claims.

7.7. Skrivanek has the right to process the following data, including for other purposes, under the consent of the Data Subject:

7.7.1. During the check of the Data Subject  personal data in a credit history database before entering into a contract in order to evaluate the Data Subject  creditworthiness; such verification is necessary for the purpose of offering new and improved services to the Data Subject during the validity of the contract.

7.7.2. During the promotion of the image of Skrivanek in the market by sending greetings to the Data Subject, holding surveys aimed at helping improve existing services and develop new ones.

7.7.3. During the selection of job candidates/trainees, if the person did not apply for the specific job position or, if the candidate’s data are stored in the database of Skrivanek after the end of the selection.

8. The right to object to profiling and direct marketing

8.1. Profiling of the Data Subject  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 Data Subject  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 Data Subject. The Data Subject 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. Skrivanek engages in direct marketing sending commercial communications to Data Subjects to keep them informed, at all times, of any new services and/or services tailored to the Data Subject’s  request, as well as discounts, campaigns, etc., on the basis for the processing of personal data indicated in clause 6.3 of this Policy. The Data Subject 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 Data Subject 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 Data Subject’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 info@skrivanek.lt 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 Data Subject’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 Data Subject’s  device (computer, tablet, mobile phone, etc.) that are uploaded when they visit the Website. Cookies remember the user’s actions and basic information and improve the experience on the Website.

9.2. The use of cookies results in the processing of data on the user’s normal behaviour and their browsing history on the website; it helps identify operational issues and failures of the website, collect user behaviour statistics, and ensure full and easy accessibility of the website’s functionality.

9.3. Skrivanek will ask for Data Subject’s consent for saving function, tracking, advertising cookies and/or third-party cookies.

9.4. If the Data Subject does not wish to allow the use of cookies, the Data Subject can do so by changing their browser settings, but this may adversely affect the normal functioning of the Website. Any saved cookies may be removed in your device’s browser settings by deleting the saved cookie history. The Websites use functional, analytics, advertising and strictly necessary cookies. To find out more about cookies, please visit the Website and go to the following section: About Us–>Cookie Policy.

10. How does Skrivanek obtain a Data Subject’s  personal data?

10.1. Skrivanek receives a personal data when the Data Subject:

10.1.1. orders or uses the services of Skrivanek for himself/herself or for the person he/she represents;

10.1.2. subscribes to the news, communications or other services from Skrivanek;

10.1.3. requests more information from Skrivanek about its services or contacts Skrivanek for other purposes (including but not limited to recruitment);

10.1.4. participates in competitions, prize draws or surveys;

10.1.5. visits or browses through the Website;

10.1.6. is filmed by Skrivanek CCTV equipment on Skrivanek property;

10.1.7. communicates with Skrivanek on social networks or simply watches the activity of Skrivanek on social networks, visits the office of Skrivanek.

10.2. Skrivanek can process   personal data obtained from third parties if the Data Subject consents to this (e.g. from the proprietor of the credit history database).

10.3. Skrivanek can obtain personal data from the customers of Skrivanek (e. g., if the documents provided by the customers contain personal data). The customers of Skrivanek must inform Data Subjects about such transfers of personal data before transferring the data to Skrivanek.

10.4. Skrivanek can process 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 personal data be processed for?

11.1. Personal data shall be processed for no longer than necessary for achieving the purposes of the processing, or for no longer than requested by the Data Subjects and/or provided for in the legislation. Usually Skrivanek processes personal data during the provision of services, throughout the contract validity period and 10 years after the expiry of the contract or termination of the legal relationship, in order to comply with the statutory document archiving requirements applicable to Skrivanek and for the establishment, exercise or defence of legal claims of Skrivanek. Personal data and documents to be translated and translated documents are stored for a period not exceeding 3 years after the order fulfilment and handover to the client.

11.2. If the processing is based on consent, personal data are processed until the Data Subject’s consent to processing of personal data is  withdrawn or expires. If the Data Subject’s consent is withdrawn or expires, the data evidencing the Data Subject’s consent are stored for 3 years after the withdrawal or expiry of the consent.

11.3. As concerns the data presented by candidates and trainees, after the end of the specific selection when an employment contract is concluded with the candidate, a traineeship contract is not concluded with the trainee, or if the candidate presented his/her data without applying to the specific position, Skrivanek shall obtain the Data Subject’s consent and shall store the data for 1 year and until the Data Subject withdraws his/her consent for the processing.

11.4. For direct marketing purposes personal data are processed on the basis of consent for a period not exceeding one year after the consent is received or until the consent is withdrawn. For direct marketing purposes where notices of similar services are provided on the basis of legitimate interest, personal data are processed throughout the period of validity of the agreement with the Data Subject and for 3 years after its expiry or until the Data Subject objects against the receipt of such notifications.

11.5. Video surveillance materials containing personal data are stored for 2–4 weeks (depending on the cameras and number of events) from the data capture/receipt date.

12. Sharing of the Data Subject’s personal data.

12.1. For the purposes of the services to be provided to the Data Subject, Skrivanek may share 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 Data Subject 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, institutions, if this requirement is established in normative acts or is requested by the appropriate authorities;

12.3. Skrivanek will provide the Data Subject’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 Data Subject’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 Data Subject. 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 the Website.

13. How does Skrivanek protect a Data Subject’s  personal data held by the company?

13.1. Skrivanek ensures the implementation, continuous reviews and improvements of safeguards in order to protect the Data Subject’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 Data Subject’s 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 Data Subject’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 Data Subject’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 was caused, for example, due to the Data Subject’s  fault and/or negligence.

13.4. In the event of any threat to personal data, Skrivanek shall inform the Data Subject thereof.

14. What rights does a Data Subject have?

14.1. A Data Subject may contact Skrivanek to obtain a copy of their personal data held by Skrivanek.

14.2. A Data Subject may have all their personal data held by Skrivanek rectified and notify about the changes, if the personal data held by Skrivanek are incorrect, incomplete or inaccurate; to request suspending any processing actions in respect of  the incorrect, incomplete or inaccurate personal data.

14.3. A Data Subject has the right to receive information about persons who have obtained information about the Data Subject from Skrivanek or who produced Data Subject’s personal data to Skrivanek. Skrivanek will not provide information which it is prohibited by law to provide information to the Data Subject.

14.4. A Data Subject 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 Data Subject may request the destruction of personal data or restriction of data processing actions if, after reviewing his/her personal data, the Data Subject finds that the personal data are processed unlawfully or unfairly. The personal data the processing of which is restricted are retained.

14.6. A Data Subject may oppose the processing of personal data, unless the personal data are processed on the basis of a legitimate interest of Skrivanek or any other person to whom the personal data are provided, and there are no overriding interests of the Data Subject.

14.7. A Data Subject may withdraw any consents to the processing of personal data when personal data are processed on the basis of consent.

14.8. A Data Subject 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.

14.9. A Data Subject may contact Skrivanek or the supervisory authority for the processing of personal data (Lithuanian State Data Protection Inspectorate, www.ada.lt) should the Data Subject have any queries regarding the processing of personal data carried out by Skrivanek.

14.10. A Data Subject may file a complaint to the State Data Protection Inspectorate or the competent court regarding the personal data processing carried out by Skrivanek.

14.11. A Data Subject may ask for compensation for damage incurred as a result of a violation of the Data Subject’s rights by Skrivanek.

14.12. A Data Subject may contact the Data Protection Officer at Skrivanek to receive information on the processing and protection of the Data Subjects’  personal data. Contact details for the Data Protection Officer at Skrivanek: Rusnė Juozapaitienė, email: rusne@duomenuapsauga.eu, tel.: +370 698 34316 (MB Asmens duomenų apsauga).

15. How to exercise the Data Subject’s rights?

15.1. The Data Subject’s rights can be exercised by sending a request by e-mail with an electronic signature at info@skrivanek.lt, visiting the office of Skrivanek office, by mail, by sending a request to Skrivanek at Švitrigailos g. 11M, LT-03228 Vilnius, or by contacting the data protection officer of Skrivanek.

15.2. The request to exercise Data Subject’s rights must be legible and signed, it must specify the Data Subject’s name, address and/or other contact details for communication or for receiving the reply.

15.3. If the Data Subject exercises his/her rights through a representative, the representative must provide his/her name, address and/or other contact details to which the representative wishes to receive a reply, as well as the Data Subject’s name and other details necessary for the proper identification of the Data Subject and to produce the document evidencing his/her powers to represent or a copy thereof.

16. Skrivanek social media accounts

16.1. Skrivanek administrates Facebook and LinkedIn accounts. The information presented by a Data Subject on Facebook, LinkedIn (including messages, use of the fields “Like” and “Follow” and other communication) or received during Data Subject’s visits of Skrivanek accounts are controlled by the social network manager. Therefore it is recommended to read the privacy notices of the social network manager. More information on privacy of the controller of the social network Facebook is available at https://www.facebook.com/policy.php. More information about the privacy policy of the manager of the social network LinkedIn is available at https://www.LinkedIn.com/legal/privacy-policy.

16.2. As the administrator of the Facebook and LinkedIn accounts, Skrivanek selects the appropriate settings in accordance with its target audience and the activity management and promotion objectives. It is possible that the social network manager which allows Skrivanek to create and administer an account in the social network has restricted the possibility to change certain key settings; therefore, Skrivanek may be unable to influence what Data Subject’s information is collected by the social network manager.

16.3. Skrivanek can provide services remotely, using chat systems such as Skype. If the Data Subject selects such a service provision method, it is recommended to review the privacy policies of the chat system managers.

The Policy last updated on 10 May 2019.

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