We confirm that the Data Holder’s website visitor data will be collected while adhering to the laws laid out by the European Union and the Republic of Lithuania. We will ensure to take all sensible technical and administrative actions to ensure the data collected from our website users is secured from unlawful use, change or leaking.
Collection of Personal Data
We collect and save any information which you willingly provide:
You might have to submit your contact details, such as:
We may collect the following information about you:
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Notice. Some personal data are collected directly, for example when you set up an online account on our websites, or send an email to our Customer Services team. Other personal data are collected indirectly, for example, when you browse our websites or undertake online shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
We may anonymise and aggregate personal data for insight and research but this will not identify anyone.
Our websites are not intended for children and we do not knowingly collect data relating to children.
HOW WE USE YOUR DATA
„Banking Cluster LT“ (and trusted partners acting on our behalf) use your personal data:
„Banking Cluster LT“ use your personal data for marketing purposes and may send you postal mail, texts and/or emails to update you on our latest offers and events.
We aim to update you about products and services of interest and relevance to you as an individual.
You have the right to opt out of receiving promotional communications at any time, by:
1: Contacting our Customer Services team via firstname.lastname@example.org or by telephone on +370 5 248 7311; or
2: Making use of the simple “unsubscribe” link in our emails; and/or
This may not stop service messages such as order updates.
3. Personalisation and Automated Decision Making
In order to improve your shopping experience with us, when you visit any of our websites, you may receive personalised banner advertisements whilst browsing websites of other companies. Any banner advertisements you see will relate to your browsing activity on our websites from your computer or other devices.
We may collect data directly from you, as well as analysing your browsing and purchasing activity, both online and in store, and your responses to marketing communications. The results of this analysis, together with other demographic data, allow us to ensure that we contact you with information on products, services, events and offers that are relevant to you. To do so, we use software and other technology (automated decision-making including profiling).
We may do this to decide what marketing communications are suitable for you and this activity is based on our legitimate interests to develop and improve our products and services for you.
You have the right to opt out of any automated decision-making processes including profiling at any time by:
· Contacting our Customer Services team via email@example.com or by telephone on +370 5 248 7311.
In order to provide more personalised services and experiences, we may also ask your permission to review third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation. Some of our services enable you to sign-in via a third party service, such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow us to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible).
What are Cookies?
Some cookies collect information about browsing and purchasing behaviour when you access our websites via the same computer or device. This includes information about pages viewed, products purchased and your journey around a website. All data passed by cookies is anonymous and will never contain individual detail such as your name, address, telephone number or payment details. For more detailed information about how cookies work, please visit www.allaboutcookies.org
How Are Cookies Managed?
The cookies stored on your computer or other device when you access our websites are designed by:
What Are Cookies Used For?
Cookies are used with our marketing partners to present you with appropriate offers and advertising as you browse other sites on the internet, based on your browsing activity while on our sites. Cookies also allow us to work alongside our web analytics partners to see how you like to use our website, which pages or special functions you prefer and help us to promote them and make them better. This helps us to continually improve the relevance of our promotional communications, your shopping experience and our products and services.
The main purposes for which cookies are used are:
1: For technical purposes essential to the effective operation of our websites, particularly in relation to online transactions and site navigation.
2: For us to market to you, particularly web banner advertisements and targeted updates.
3: To enable us to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc.
4: To enable us to meet our contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.
What Cookies Do We Use?
There are two types of cookie that may be used during your visit to our site:
Session cookies are deleted after each visit to our site. For example, when you are browsing our site, it will remember you for the duration of your visit, but the cookie will be removed from your computer as soon as you close down your internet browser. Session cookies allow you to add an item to the basket and then move through the checkout. Disallowing these cookies via your web browser will mean you are unable to place an order on the site.
Persistent cookies remember you for a set period of time allowing wishlist products and/or previously viewed products to be displayed the next time you visit our site and whether you logged into or out of your account while browsing.
„Banking Cluster LT“ work with several partners who serve advertisements or present online offers on our behalf. Most of these marketing partners use both session and persistent cookies. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. All data collected by third party cookies is anonymous and will never contain your name, address, telephone number, email address or payment details.
Turning Off and Deleting Cookies
Most web browsers will provide the option to turn off or disallow cookies. How you do this depends on the web browser you're using. Instructions for disallowing cookies can usually be found in the browser's 'Help' menu. Note that in common with most other transactional websites, if you only disable third party cookies, you will not be prevented from making purchases on our websites but refusing the cookies we have used via your web browser will mean that you are unable to make a transactional purchase on our website. You may also find that the functionality of many other websites and services will be affected. Cookies can be deleted using your web browser. However, unless they are disallowed they will be re-applied the next time you visit a website.
If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
For Microsoft Internet Explorer:
1: Choose the menu "Tools" then "Internet Options".
2: Click on the “Privacy” tab.
3: Select the appropriate setting.
For Google Chrome:
1: Choose Settings > Advanced.
2: Under "Privacy and Security," click “Content Settings”.
3: Click "Cookies".
1: Choose Preferences > Privacy.
2: Click on “Remove all Website Data”.
For Mozilla Firefox:
1: Choose the menu “Tools” then “Options”.
2: Click on the icon “Privacy”.
3: Find the menu “Cookie” and select the relevant options.
SHARING DATA WITH THIRD PARTIES
We will never sell or rent your personal information to other organisations for marketing purposes.
We will not disclose your personal information to any third party, except for those referred to below.
We may share your data with:
· Other companies within our group;
· Purchasers, investors, funders and advisers if we sell our business or assets or restructure whether by merger, re-organisation or otherwise;
· Our legal and other professional advisers, including our auditors;
· Credit reference agencies where necessary for card payments;
· Governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so:
o To comply with our legal obligations and/or the administration of justice;
o To exercise our legal rights (for example in court cases);
o For the prevention, detection, investigation of crime or prosecution of offenders; and
o For the protection of our employees and customers.
· Our service providers and suppliers.
In order to make certain services available to you, we have partnered with certain trusted third parties including IT, mailing, payment services, delivery and marketing service providers. We may need to share your personal information with some of our service partners. We only allow our service providers to handle your personal information when they have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your information to provide services to us and to you, and for no other purposes.
LEGAL BASIS FOR USING DATA
We are required to set out the legal basis for our ‘processing’ of your personal data.
We collect and use customers’ personal data:
1: As necessary to perform our contract with you
o For the purposes of complying with our duties and exercising our rights under contracts for the sale of goods or services to customers; or
2: As necessary for the pursuit of our legitimate interests including:
o Selling and supplying goods and services to our customers;
o Promoting, marketing and advertising our products and services;
o Sending promotional communications which are relevant and tailored to individual customers (including administering loyalty schemes);
o To administer competitions and promotions and identify and contact competition winners;
o Understanding our customers’ behaviour, activities, preferences, and needs;
o Improving existing products and services and developing new products and services;
o Protecting customers, employees and other individuals and maintaining their safety, health and welfare;
o Good governance, accounting and managing and our operations and complying with our legal obligations;
o Preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
o Handling customer contacts, queries, complaints or disputes;
o Managing insurance claims by customers;
o Protecting our company, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
o Handling any legal claims or regulatory enforcement actions taken against us; and
o Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders or
3: As necessary for complying with our legal obligations including:
o Where you exercise your rights under data protection laws;
o For compliance with legal and regulatory requirements; or
o To establish or defend our legal rights; or
4: Based on your consent
You have the right to withdraw consent at any time. Where consent is the only legal basis for processing your personal data, we will cease to process your personal data for that purpose after consent is withdrawn.
HOW WE PROTECT YOUR DATA
UAB „Banking Cluster LT“ is committed to keeping your personal data safe and secure.
Our security measures include:
· Encryption of data;
· Regular cyber security assessments of all service providers who may handle your personal data;
· Regular planning to ensure we are ready to respond to cyber security attacks and data security incidents;
· Daily penetration testing of systems;
· Security controls which protect the our IT systems infrastructure and our premises from external attack and unauthorised access; and
· Internal policies setting out our data security rules for our personnel.
· Regular training for our employees.
WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
You should always be cautious when sharing your personal data. No one from our company will ever ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from UAB „Banking Cluster LT“ asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety
· Keep your account passwords private because anyone who knows your password may access your account or be compromised if your account is accessed without authority.
· When creating a password, use a difficult word/number combination of at least 8 characters and something that is not easily guessed by hackers such as dictionary words, your name, email address, or other personal data that can be easily obtained. Also, frequently change your password. You can do this accessing your account, clicking ‘your account’, clicking ‘your data’ and selecting ‘change password’.
· Avoid using the same password for different online accounts.
HOW LONG WE KEEP YOUR DATA
We will not retain your data for longer than necessary for the purposes set out in this Notice. Different retention periods apply for different types of information, and our Data Retention Policy sets out the length of time we will usually retain personal data and where these default periods might be changed.
In summary, various laws, accounting and regulatory requirements applicable to us require us to retain certain records for specific amounts of time. In relation to your personal data, we will hold this only for so long as we require that personal data for legal or regulatory reasons or for legitimate organisational purposes and we will not keep your data for longer than is necessary for the purposes for which we collect them.
To deliver products and services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws. If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to assess the laws and practises of the destination country and relevant service provider and the security measures that are to be taken as regards the data in the overseas location; Alternatively, we use standard data protection clauses.
You have the following rights:
If you wish to exercise any of the above rights, you can always:
· Contacting our Customer Services team via firstname.lastname@example.org or by telephone on +370 5 248 7311
Last updated: 2018.08.01