Privacy Policy

1. What is this Privacy Policy about?

This Privacy Policy (the Privacy Policy) is intended to provide you with the information about how UAB “ELITAZ Grupė” (the Company) processes your personal data received: during employee recruitment; in the process of direct marketing done by the Company; when handling requests, responses, complaints; when organising lotteries and games; when you take actions on the social media accounts of the Company; during selection of project participants; when coordinating performance of contracts of project participants; when entering into and performing the contracts with freelancers; for the purpose of performing the contracts made between the Company and its counterparties (legal entities); for the purpose of ensuring protection of confidential information and business continuity; when you visit the Company’s website www.elitaz.lt (the Website); in the process of promoting the Company’s visibility and for the purpose of informing the public; in view of complying with the statutory obligations related to organisation of the Company’s business. All the persons whose data are processed by the Company are further in this document referred to as Data Subjects.

2. About the Company

UAB “ELITAZ Grupė”, entity identifier 302932166, domicile address at Smolensko g. 10-85, Vilnius, the Republic of Lithuania, the data about the Company are accumulated and kept by the Register of Legal Entities of the Republic of Lithuania. The contact e-mail of the person in charge of data protection at the Company is asmens.duomenys@elitaz.lt.

3. What constitutes personal data?

Personal data is any information collected by the Company concerning the Data Subject which can be used to identify the Data Subject and which is stored by electronic or other means.

Personal data encompasses any information, including the Data Subject’s name, surname, address, image, as collected by the Company concerning the Data Subjects for the purposes specified in this Privacy Policy or in a separate Data Subject’s consent or agreement with the Company.

4. Participating in employee recruitment

We collect and process your resume (CV) data (your name, surname, photograph, education, competences, personal qualities, work experience, other information provided in the CV), the date of birth; residential address, personal phone number and e-mail address and/or other information you provide to us when participating in employee recruitment for the purpose of employee selection on the basis of your consent which you express by sending your resume and/or motivation letter to the Company. If you do not provide your resume and/or motivation letter, we will not be able to assess whether you are suitable for the offered vacancy.

If you do not express a separate consent to processing of your personal data after employee recruitment is completed, we undertake to delete and/or destroy your personal data within 5 business days after an employment contract or a contract for services has been signed with the selected job applicant.

Based on your consent, we will store your data for the period specified in your consent. To make you a job offer best suited in terms of your experience and expectations, your personal data may be transferred to partners of UAB “ELITAZ Grupė” (Kūrybos namai ELITAZ).

5. Direct marketing

We will send offers concerning sale of goods or provision of services of the Company, newsletters and other advertising materials, and will share news about the Company by electronic means of communication (e-mail, phone, SMS) to the persons over the age of 14 years, who have provided their contact data and expressed a wish to receive information about the goods and/or services offered and selections conducted by the Company.

The Company will process the following personal data concerning you for the purpose of direct marketing: your phone number, e-mail address (these are mandatory data as we will not be able to send your direct marketing messages without them). Your data will be processed for the purpose of direct marketing for 3 years after giving the consent.

If you have acquired services provided by the Company and have not objected to receiving direct marketing messages of the Company, we will e-mail you messages regarding goods or services similar to the services provided to you or the goods purchased by you on the basis of our legitimate interest. In that case your data will be processed for the purpose of direct marketing for 1 year after your last purchase.

You have the right to object or refuse to receiving direct marketing messages any time by contacting us via e-mail asmens.duomenys@elitaz.lt.

6. Participation in lotteries and games

We will process your personal data on the basis of your consent for the purposes of organising lotteries and games. To that end, we will process the following personal data concerning you depending on the lottery: your photograph and/or video material, name, surname, social media account name, e-mail address, phone number, and also the winner’s home address. If you do not provide your e-mail address or phone number, we will not be able to identify or contact you if you win.

Your data for this purpose will be processed until winning is clear, and the winner’s data will be processed for 10 years after announcing of the win, and handing over the prize.

You have the right to withdraw your consent at any time by contacting us via e-mail asmens.duomenys@elitaz.lt.

7. Selection of project participants

If you take part in selections of project participants, we will process your data indicated in the entry form on the basis of your consent for the purpose of selecting you to participate in a project (or future projects if you consent to that). The data to be processed will include your name, surname, e-mail address, phone number, the participant’s number, the phone number of a family member / friend, the family status, the information related to reasons for taking part in the selection of participants, activities, hobbies, other information of personal nature about the participant’s life and character indicated in the first audition questionnaire or other entry forms, the image and voice recording (photo or video material).

If you do not provide the data specified above, we will not be able to determine if you are suitable for the project, but you may withdraw your consent at any time by letting us know about it via e-mail indicated in this Privacy Policy.

We store the data of selected participants for 5 years after the end of the project unless specified otherwise in the information concerning a specific project. If you are not selected to participate in a project, we will destroy your data after the project has ended unless you agree for your data to be stored for 5 years from the end of the project so that we can offer you to take part in the future projects.

Your data will be transferred to the project partners, producers, owners of project formats, and such broadcasters as TV or radio stations. Your data may also be transferred to third countries on the conditions stated in your consent in order to perform contractual obligations of the project organisers to the project format owners. Your data recipients are responsible for informing you about your personal data processing carried out by such data recipients.

8. Coordinating contract performance of project participants

If you as a project participant enter into a contract with our partner, we will coordinate its performance and process the following personal data concerning you on the basis of our legitimate interest (to ensure performance of the obligations assumed by business contracts): your name, surname, date of birth, address, phone number, e-mail address, correspondence, video material, photo material, voice recordings, other information obtained when performing the contract made between you and our partner. We will receive your personal data from our partner or directly from you.

Your personal data will be processed for that purpose for 10 years after the day of termination/expiry of the contract or relationship.

9. Entering into and performing contracts with freelancers

If you provide us services as a natural person on the basis of a contract with us, we will process the following personal data concerning you for the purpose of proper performance of the contract: your name, surname, address, date of birth, contract terms, bank account, phone number, e-mail address, self-employment certificate number, VAT invoice data, and the time spent for provision of services.

Your data will be stored for 10 years after the day of termination/expiry of the contract.

10. Performing contracts with legal entities as counterparties

For the purpose of serving its legitimate interest to ensure performance of the Company’s contracts entered into with legal entities as counterparties, the Company processes personal data of employees of such entities, i.e., their name, surname, position, e-mail address, phone number, and the content of correspondence. Such data are stored for 10 years after termination/expiry of the contract or relationship with customers.

11. Protection of the Company’s confidential information, and business continuity

For the purpose of serving its legitimate interest to ensure protection of the Company’s confidential information and business continuity, the Company may check its employees’ correspondence with counterparties. To that end, the Company processes the following data: the e-mail address, content of the information contained on the electronic devices used by the Company’s employees for work. Such data are stored for 10 years after the day of termination/expiry of the contract or relationship with customers.

12. Promoting the Company’s visibility and informing the public

On the basis of your consent, and for the purposes of promoting the Company’s visibility and informing the public (posting data on the Company’s social media accounts, Website), your photographs and/or video material, including but not limited to the content from the parties, events or shows / programmes organised or produced by the Company, also your name, surname, and the fact of participation will be used to inform the public about the events and produced projects to promote the Company’s visibility. We promise that such material will not be used in violation of your honour and dignity. Your photo images or video material may be posted on the Company’s social media accounts, Website, or used on the radio or television with your consent.

Media representatives may show your photographs or video material only in compliance with the requirements of the laws applicable to them, but the Company is not liable for the actions of media representatives.

Photographs will be used for 10 years from obtaining of your consent, save for the exceptions permitted by laws.

13. Contact us

You may contact the Company in several ways: by phone or e-mail. We accept, review and respond to all notifications ourselves. If you contact us, we may process the data you indicated to us, i.e., your name, surname, e-mail address, phone number, the date and text of communication.

Such data will be processed in order to answer the questions relevant to you. If you do not provide your contact details, we will not be able to contact you.

Correspondence will be stored for 1 year after receipt of the message, except for the information with different storage periods prescribed by the Privacy Policy or legal acts.

All the personal data which you provide when communicating with us are used only for the purposes referred to above and for reviewing of the notifications as well as administration and management of communication flows. We will refrain from using your personal data in the manner allowing to identify you as a person in any publications without your explicit consent.

Please note that we may need to contact you by post, e-mail or phone. Please kindly let us know about any changes in your contact details.

14. Website

A cookie is a small file of letters and digits, which with your consent we store in your browser or hard disc of your computer. We use different cookies for different purposes. Cookies also help us to distinguish you from other Website users, offering better experience of the Website use and allowing Website improvement.

Most browsers allow rejecting all cookies, while some browsers have an option to reject only cookies of third parties. In fact, you can use these options. Nevertheless, please note that blocking all the cookies will have an  adverse impact on the Website use, and not all services on the Website will be available to you without cookies. More information about the subject is available at AllAboutCookies.org or www.google.com/privacy_ads.html.

We use the cookies described below, and their detailed list is provided HERE:

• Absolutely essential cookies.

These cookies are necessary for our Website to function. The basis of data processed with this type of cookies is proper performance of the contract while you visit the Website, and we ensure quality and safety of your visit. These could be cookies which may allow you log on to and access protected areas of our Website, use the shopping cart function, or electronic invoicing services.

• Analytical and/or performance cookies.

These cookies enable us to recognise and count our Website visitors, and monitor movements of visitors on the Website when using it. They help us to improve the Website operation, e.g., to ensure that users easily find what they are searching for. The basis for processing the data collected by this type of cookies is your consent.

• Functional cookies.

These cookies are used to recognise you when you return to our Website. It enables us to provide the content adapted to your needs, and to remember the information relevant to you. The basis for processing the data collected by this type of cookies is your consent.

• Commercial cookies.

We use our and third-party cookies so that we can show you personalised advertisements on our and other websites. This is the so-called “repetitive marketing” which relies on the browsing behaviour, e.g., the goods you searched for or viewed.

15. Social media networks

Our Website contains links to our social media accounts. We currently have the following accounts:

on Facebook – https://www.facebook.com/knelitaz/, the privacy statement of which is available at https://www.facebook.com/privacy/explanation;

on Instagram – https://www.instagram.com/elitaz_official/?hl=en, the privacy statement of which is available at https://help.instagram.com/519522125107875;

on LinkedIn – https://lt.linkedin.com/in/elitaz, the privacy statement of which is available at https://www.linkedin.com/legal/privacy-policy?trk=public_authwall_company-scraping_join-form-privacy-policy;

on Twitter – https://twitter.com/en/privacy.

As administrators of social media accounts, we select the appropriate settings in view of our target audience and the purposes of managing and promoting our activities. When enabling us to set up and administer an account on the social media network, the social media network manager may restrict possibilities to change certain key settings, and then we are unable to affect collection of the information about you carried out by the social media network manager after we set up the account on that social media network. The scope of the obtained data depends on the settings chosen by us, the agreements with the social media network manager on ordering of additional services, and the cookies set by the social media network managers.

We recommend reading third-party privacy notices and contacting the service providers directly, should you have any questions as to their use of your personal data.

16. Processing of data of shareholders (natural persons) and members of management bodies

Complying with its legal obligations, the Company processes the names, surnames, personal ID numbers, home addresses, and dates of appointment of its shareholders (natural persons) and members of management bodies. Operation-related data of the Company are stored for 10 years.

17. Obtaining and disclosure of data

We obtain your data from you, your devices, customers and partners.

We can disclose information about you to our employees, agents and such service providers as debt management or collection agencies, the persons providing marketing services, IT services, or subcontractors, lawyers, auditors provided it is reasonably needed for the purposes specified in this Privacy Policy, and also in other cases specified in this Privacy Policy.

In addition, we may disclose information about you:

• if we are required to do so by law;
• for the defence of our rights or interests (including disclosure of your personal data to third parties for collection of your debts to us);
• in view of the sale of a part of business or assets of the Company, in which case we disclose your personal data to a potential buyer of the business or its part;
• upon the sale of the Company’s business or substantial part of its assets to third parties.

We do not provide your personal data to any third parties, except for the cases specified in this Privacy Policy.

The list of recipients or categories of recipients specified in the Privacy Policy may change, and if you wish to be informed about any changes in the recipients of your personal data, let us know your preference by sending us an email to the address indicated in this Privacy Policy, and stating the following: ‘I wish to receive information about any changes in the recipients of my personal data. [Your] name, surname’.

18. Security of your personal data

Your personal data will be processed in accordance with the General Data Protection Regulation, Law of the Republic of Lithuania on Legal Protection of Personal Data, and other requirements established by legal acts. When processing your personal data, we implement appropriate organisational and technical measures which ensure protection of personal data from accidental or unlawful destruction, alteration, disclosure, and from any other unlawful processing.

19. Your rights

This section provides information about your rights related to your personal data processing carried out by us, and the cases where you can exercise such rights. If you wish to receive more information about your rights or to exercise them, contact us by sending us an email to the address indicated in this Privacy Policy.

The Company will provide you with the information about actions taken upon receipt of your request to exercise your rights, and will send you the response without any unreasonable delay, but not later than within 1 month from receipt of the request. Depending on complexity of the request and the number of received requests, the above-mentioned time limit may be extended for 2 months. In any event we will inform you about the extension of the time limit and the reasons for that within 1 month from receipt of your request. The Company will deny your rights only in the cases stipulated by legal acts.

• Right to access your personal data

We want you to fully understand how we use your personal data and prevent any inconveniences in that respect. You may contact us at any time and ask if any of your personal data is processed by us. If we store or use your personal data in any format, you have the right to access such data. To do so, please send us a written request by email to the address indicated in this Privacy Policy, and prove your identity; when submitting such request, you are requested to follow the principle of fairness and common sense.

• Right to withdraw consent

If you have given us your explicit consent to your personal data processing, you can withdraw it at any time by sending us an email to the contact address indicated in this Privacy Policy.

• Additional rights

Here is the information about your additional rights which you can exercise following the procedure described below.

• You have the right to request us to rectify any inaccuracies in the data available to us. In such case, we may request you to confirm the updated information.
• You have the right to request us to delete your personal data. Please note that such right can be exercised only in the cases specified in Article 17 of General Data Protection Regulation (EU) 2016/679.
• You have the right to request us to restrict your personal data processing or not processing them entirely:
• for the period needed by us to verify the accuracy of your personal data, following your claims made regarding accuracy of the data;
• when collection, storage or use of your personal data carried out by us is unlawful, yet you decide not to request for data erasure;
• when your personal data is no longer necessary to us, but you need it for establishment, implementation or defence of a legal claim;
• for the period needed to establish whether we have an overriding legal basis to continue processing of your personal data, provided you have exercised your right to express your objection to personal data processing.
• You have the right to transfer of the data (data portability) which are processed by automated means and which we received from you with your consent or for the purposes of signing a contract. If you exercise this right, upon your request, we will transfer a copy of your provided data.
• You have the right to object to our use of your personal data in the procedure set out in Article 21 of the GDPR.
  • Right to request for more information

We hope you appreciate it that it is very difficult to discuss all possible methods of personal data collection and use. We do our best to provide as clear and comprehensive information as possible, and commit to updating this Privacy Policy once the process of personal data use changes. None the less, if you have any questions regarding the use of your personal data, we will be happy to answer them or provide additional information that can be disclosed. If you have any specific questions or do not understand the information provided, please contact us.

20. Complaints

If you think that the rights that you have as Data Subject are and/or may be infringed, please contact us immediately by sending your complaint to the email address indicated in this Privacy Policy. We can assure you that after your complaint is received, we will contact you within a reasonable period and inform you about the course of the complaint investigation, and later about its outcome.

If you are not satisfied with the investigation outcome, you can submit a complaint to the supervisory authority, i.e., the State Data Protection Inspectorate (www.vdai.lrv.lt).

21. Responsibility

You are responsible for the confidentiality of your data, as well as the accuracy, correctness and comprehensiveness of the data you provide to us. If the data you have provided changes, you must immediately notify us by email. In any event, we will not be liable for any damages incurred by you as a result of the fact that you have supplied incorrect or incomplete personal data or have not informed us of any changes in the data. You are also responsible for informing the third parties whose data you will provide to us about such data provision, and making them aware of this Privacy Policy.

22. Changes of Privacy Policy

We may update or change this Privacy Policy at any time. Such updated or amended Privacy Policy comes into effect from the day it is published on our Website. You should check it from time to time to see if you are satisfied with the effective version of the Privacy Policy.

The updating day specified below indicates the latest update of the Privacy Policy.

The Privacy Policy last updated on 17 September 2021.