Privacy Policy

This Privacy Policy provides the information on the processing of personal data required under Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR) (hereinafter referred to as the “Regulation”).

The data controller determining the purposes and means of processing your personal data is UAB ALWARK, legal entity code 300638080, registered address Ukmergės g. 451, Klevinė, LT-14199 Vilnius District, Lithuania, telephone +370 5 264 6330, e-mail: [email protected].

The provisions of this Privacy Policy apply to natural persons visiting our website, communicating with our Company, or otherwise providing personal data in the situations described below.

Please review the current version of this Privacy Policy regularly, as it may be updated from time to time. Terms used in this Privacy Policy shall have the meanings assigned to them in the Regulation.

The information below covers the following purposes of personal data processing:

  • (i) employee recruitment and administration of the candidate database;
  • (ii) communication by e-mail and other electronic means;
  • (iii) use of cookies;
  • (iv) use of social media;
  • (v) administration of the loyalty programme, distribution of newsletters, and other direct marketing activities;
  • (vi) administration of complaints, enquiries, and orders.

This Privacy Policy also describes your rights as a data subject, the disclosure of personal data to recipients, and other personal data processing conditions applicable to all personal data processed by the Company for the purposes listed above.

Employee Recruitment

If you submit your CV for inclusion in our candidate database, or submit your CV in response to a vacancy advertised on our website or on a specialised recruitment and job search website, we will process the personal data you voluntarily provide, together with the other personal data specified below, for the purpose of employee recruitment.

Personal data submitted in connection with a recruitment process will be processed until the recruitment process has been completed, i.e. until we hire a selected candidate, the candidate’s probationary period has ended, or we decide to close the recruitment process without selecting a candidate. This period is generally approximately four (4) months.

Unless you object, we will retain your personal data for three (3) years after the recruitment process has ended. Should a suitable vacancy arise during this period, we may contact you regarding future employment opportunities. Upon expiry of the three-year retention period, your personal data will be securely deleted.

If you do not wish us to retain your personal data after the recruitment process has ended, please indicate this either in your e-mail or on the information form provided for your signature during the recruitment process.

If you submit your CV and other personal data without responding to an advertised vacancy, we will retain your data for three (3) years based on your voluntary submission of the information, without requesting separate consent.

Your personal data will be processed based on your intention to participate in the recruitment process or to have your data included in our candidate database. Following completion of the recruitment process, your personal data will be processed on the basis of our legitimate interest.

Providing your personal data is voluntary. However, without such data we may be unable to assess your suitability for employment. You may withdraw your participation in the recruitment process or request the removal of your data from our candidate database at any time.

Please note that, where permitted under applicable data protection legislation, we may contact your previous employers to request references regarding your qualifications, professional skills, and work performance. However, we will not contact your current employer without your prior explicit consent.

Communication by E-mail and Other Electronic Means

The processing of personal data provided during electronic communication is based on your voluntary decision to communicate with us and to provide certain personal data during such communication, i.e. your consent.

Personal data may also be processed where necessary for the conclusion or performance of a contract, or for compliance with legal obligations.

In addition to contract-related purposes, your personal data may also be processed for internal administration and the provision of consultations or support.

Your e-mail address, the content of correspondence, and related information will be processed in accordance with the principle of proportionality.

Such information will primarily be accessible to the employee with whom you are communicating directly by e-mail or other electronic means. However, in certain circumstances, your correspondence may also be accessed by other authorised employees, for example:

  • for workplace monitoring purposes;
  • when investigating potential violations of legal requirements or internal policies;
  • to ensure business continuity during an employee’s absence;
  • or in other similar situations where access is necessary and lawful.

Use of Cookies

A cookie is a small file consisting of letters and numbers that is stored in your browser or on your computer’s hard drive.

Different types of cookies are used for different purposes. Cookies also help distinguish you from other website users, providing you with a better browsing experience and enabling us to improve our website.

Most web browsers allow you to refuse all cookies, while some browsers allow you to refuse only third-party cookies. You are free to make use of these options.

Please note, however, that disabling all cookies may negatively affect the functionality of the website, and certain services or features may become unavailable.

Our website uses the following categories of cookies:

  • Strictly Necessary Cookies – these cookies are essential for the proper functioning of the website and collect general (anonymous) information about website usage in order to improve its performance.
  • Analytical Cookies (Google Analytics) – these cookies enable us to recognise and count website visitors and analyse how visitors navigate through the website. This helps us improve the website, for example by ensuring that users can easily find the information they are looking for.
  • Functional Cookies – these cookies recognise returning visitors and enable us to personalise website content, including content displayed through social media, and remember information relevant to users’ preferences.

A complete list of the cookies used on our website is provided below.

Cookie Name Purpose of the Cookie Retention Period
PHPSESSID Strictly necessary cookie required for the website to function During the session
_ga Collection of statistical information about user behaviour on the website 2 years
_gat Collection of statistical information about user behaviour on the website 1 day
_gid Collection of statistical information about user behaviour on the website 1 day
ads/ga-audiences Marketing During the session
IDE Marketing 1 year
pagead/1p-user-list/# Marketing During the session
test_cookie Marketing 1 day

How to Manage and Delete Cookies

Most web browsers are configured to accept cookies automatically. Having information about how and why cookies are used enables you to decide whether to accept them or disable them in your browser.

Most browsers allow you to manage cookies through their settings. If you do not wish to accept cookies, you can configure your browser to reject all cookies or to notify you whenever a cookie is being placed.

For more information about managing cookies, please visit:

http://www.allaboutcookies.org/managecookies/

Please note that if you choose to disable cookies, some website features may no longer function properly or may become unavailable.

In addition to the cookies used by the Data Controller, certain third parties may also be permitted to place and access cookies on your device. In such cases, the use of cookies is governed by the respective third parties’ privacy policies.

Use of Social Media

Our Company maintains official accounts on the following social media platforms:

Information you provide through social media (including messages, use of the “Like” and “Follow” functions, and other interactions) is controlled by the respective social media platform operator.

We recommend reviewing the privacy policies of these third parties and contacting them directly if you have any questions regarding the way they process your personal data.

Newsletters and Other Direct Marketing Activities

If you are our customer, have subscribed to our newsletter through our website, or have otherwise expressed your wish to receive direct marketing communications, the personal data you voluntarily provide, including your e-mail address and telephone number, will be used to send you information about our products and services, news, promotions, events, and other marketing communications.

Direct marketing by e-mail without your prior consent will only be carried out where you are our existing customer and where such marketing is permitted under applicable legislation.

You have the right to object to such direct marketing at any time by contacting us using the contact details provided in this Privacy Policy.

Your personal data will be processed for direct marketing purposes for five (5) years from the date you provided your consent or from the end of your relationship with our Company.

Every marketing e-mail we send will include an option allowing you to unsubscribe from future marketing communications.

You may also withdraw your consent at any time by contacting us using the Company’s contact details.

Administration of Complaints, Enquiries and Orders

If you submit a complaint, claim, enquiry, or order by e-mail, in writing, or by any other means, the personal data you voluntarily provide will be processed for the purpose of administering your complaint, claim, enquiry, or order.

Where your complaint or claim relates to a potential legal dispute, possible damages, or similar circumstances, or where the processing of an order results in the establishment of contractual relations, your personal data may be retained for ten (10) years.

Where the personal data contained in a complaint or claim are not related to any potential dispute, they will be deleted within a shorter period once they are no longer necessary for the purpose for which they were collected.

The processing of your personal data is based on your voluntary decision to submit a complaint, enquiry, or order. In certain cases, however, the continued retention of such data may be required by applicable law.

Disclosure of Personal Data to Recipients

Your personal data may be disclosed to:

  • providers of IT, hosting, server, postal, and courier services;
  • lawyers, attorneys, consultants, auditors, bailiffs, and debt collection agencies;
  • law enforcement authorities, supervisory authorities, courts, and other dispute resolution bodies;
  • potential or existing purchasers of our business or any part thereof, as well as their authorised advisers or representatives.

Personal Data Protection Principles

When collecting and processing your personal data, including personal data obtained from other lawful sources, we comply with the following principles:

  • your personal data are processed lawfully, fairly, and in a transparent manner (lawfulness, fairness, and transparency);
  • your personal data are collected for specified, explicit, and legitimate purposes and are not further processed in a manner incompatible with those purposes (purpose limitation);
  • your personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (data minimisation);
  • your personal data are accurate and, where necessary, kept up to date (accuracy);
  • your personal data are retained in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation);
  • your personal data are processed in a manner that ensures appropriate security through suitable technical and organisational measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage (integrity and confidentiality).

Exercising Your Rights as a Data Subject

You have the following rights under the GDPR:

  • the right to access your personal data and obtain information about how they are processed;
  • the right to request the rectification of inaccurate personal data or the completion of incomplete personal data;
  • the right to request the erasure of your personal data or the restriction of processing (except where retention is required by law);
  • the right to request restriction of processing;
  • the right to data portability;
  • the right to lodge a complaint with the State Data Protection Inspectorate of the Republic of Lithuania;
  • the right to withdraw your consent at any time;
  • the right to object to the processing of your personal data.

To enable us to exercise your rights, we must verify your identity. If your identity cannot be established, we cannot ensure that the request is being made by the relevant data subject and therefore may be unable to fulfil your request.

We may refuse to act upon a request or charge a reasonable fee where the request is manifestly unfounded or excessive, or in other cases permitted under applicable legislation.

If you wish to exercise your rights as a data subject or have any questions regarding the processing of your personal data, please contact us using the Company’s contact details provided above.