Privacy Policy

Policy Objectives

This Privacy Policy (hereinafter also referred as “Policy”) refers to personal data processed by Equite, legal entity code 305747607 (hereinafter referred to as the “Company”, “Equite” or “we”).

This Policy applies to all persons who use, have used, or are going to use our services, as well as those who are indirectly related (for example, to business representatives or other employees), persons who have any contractual relationship with Equite, or their personal data have become known to us, as well as to anyone who visits our websites (hereinafter referred to as “You” or the “Customer”).

Our goal is to ensure the protection of personal data. In pursuing this goal, we consistently adhere to the requirements of the European Union and national legislation. The basic legal acts governing the processing of personal data are the national legislation and the General Data Protection Regulation (2016/679) (hereinafter referred to as the “GDPR”). The GDPR applies to the processing of personal data relating to citizens of the European Union (natural persons) which is carried out by a natural person, a company, or other organisation for business or other non-personal purposes. The reference to “Personal data” in this Policy refers to any information which you can reasonably use to identify you as one of the above persons (hereinafter referred to as “Personal Data”).

The Policy provides a general overview of how we process Personal data. Additional information on the processing of Personal data may be provided in service contracts and in other documents.

We ensure the confidentiality of Personal data in accordance with the requirements of the applicable law and we have appropriate technical and organisational measures in place to protect Personal data from unauthorised access, disclosure, accidental loss, alteration, destruction, or any other unlawful processing.

We can use data processors to process Personal data. In such cases, we will take the necessary steps to ensure that such data processors process Personal data in accordance with our instructions and applicable laws and require the implementation of appropriate Personal data security measures. We ensure that we make every effort to guarantee the confidentiality and integrity of the Personal data of our current, future, and past Customers.

Personal Objectives

We use the information provided by you to send you messages on the latest events, services provided, as well as information about any planned events that may be of interest, including training seminars, breakfasts on relevant topics, etc. You can find more information about the use of your personal data for marketing purposes in our Marketing Privacy Policy.

We use cookies on our websites.

We will use the Personal data you provided to us when sending us your CV or a cover letter. We will keep the data you provide for as long as the recruitment process lasts, or for a longer period only with your consent to save your CV in the database of potential employees of the Company.

We collect the information necessary for us to do business, sign contracts or start any business relationship with you. Such Personal data collection is strictly necessary for us to fulfil our obligations to you as well as for the provision of services to current and future Customers. In certain cases, we may receive your data from other sources.

Execution of legal obligations and identification. We are subject to the obligations related to the requirements of the Law on Money Laundering and Terrorist Financing Prevention (hereinafter referred to as the “Law”). By providing the services, we process Personal data in order to meet our anti-money laundering obligations (AML) and learn more about our customers (KYC).

Fundamentals to Data Processing

Agreement – a contract between us and you, which provides the fundamentals for processing your Personal data;

Consent – the consent given by you through which you have granted us the right to process your Personal data for the purposes stated in your consent and only for such purposes;

Legitimate interest – in some cases, in order to be able to perform the tasks arising from our activities, we process data on the basis of a legitimate interest. Before we begin to process Personal data on this basis, we must verify that legitimate interests do not have a significant impact on the rights and freedoms of those persons.

Legal obligation – this obligation is imposed on us by the European Union and national legislation, such as the Law.

Most of the time, we receive your Personal data from you, our data subjects, but in some cases we may also receive Personal data from third parties. For example, Personal data are provided to us by a representative of a potential Customer, when we sign various agreements containing the representatives’ data, and other cases.

Personal Data Recipients

Our service providers when such services are related to the processing of your Personal data (administration, obligation to combat money laundering, learning more about customers, and for marketing purposes);

Partners with whom we jointly provide services or products;

State institutions and authorities, other persons performing functions delegated to them by law (for example, law enforcement agencies, tax administration, financial crime investigation institutions);

Financial institutions, third parties (such as banks), auditors, legal and financial advisers; our authorised data processors, third parties, managing various registries (including loan registers, the Population Register, the Register of Legal Entities or other registers in which Personal data are processed) or who mediate in the provision of Personal data from such registers.

Other persons who provide services to us, such as IT maintenance companies, communications and mail providers, third parties, whose services we use to ensure the performance of your contract with our Customer or in the performance of administrative functions.

All service providers to whom we transmit your Personal data must follow our instructions on how they must process your Personal data. Your personal data transfer is governed by the data processing conventions we have contracted with independent service providers. All independent service providers are considered as data processors and must guarantee that your Personal data will be processed with the same care and diligence as we take, and they will be legally responsible for the non-performance of such guarantees. All service providers must have technical and organisational measures in place and ensure a level of data protection that is at least as high as ours.

Transfer of Personal Data to Third Parties

As a general rule, Personal data are processed within the territory of the European Union/European Economic Area (EU/EEA), but may, in certain cases, be transmitted and processed outside the EU/EEA.

Personal data may be transmitted and processed outside the EU/EEA where the transfer is necessary for the conclusion and execution of a contract where Personal data may be stored using data storage solutions whose servers are outside the European Economic Area or the Customer has given their consent, and if there are adequate safeguards in place.

By submitting Your Personal data to us or by consenting to the processing of Your Personal data You agree to the processing of Your data, including both data storage and data transfer, outside the EU for the purposes set out in this Policy. We will take all reasonably necessary precautions to ensure that the processing of Your Personal data complies with all applicable Personal data protection Laws. We may transfer Your Personal data based on:

  • – an adequacy decision by the European Commission;
  • – standard data protection clauses elaborated by the European Commission;
  • – standard data protection clauses elaborated by data protection authority;
  • – using other possible safeguards and derogations where it is allowed by the applicable laws.

Your Rights as a Data Subject

Right to access – you have the right to request access to any of your Personal data that may be stored, including, for example, the right to know whether we process your Personal data, which categories of Personal data we process, and to know for which purposes we process the data.

Right to correct – you have the right to request that we correct any of your Personal data if you believe that they are inaccurate or incomplete.

Right to disagree – you have the right to disagree with the corresponding processing of your Personal data, including, for example, processing your Personal data for marketing purposes or, if your data processing is otherwise based on legal interest.

Right to delete – you may also request that your Personal data are deleted if they are no longer required for the purposes for which they were collected, or if you consider that the processing is illegal, or if you believe that Personal data must be deleted in order not to violate the legal requirement. In certain cases, under statutory regulation, where the laws of the relevant jurisdiction prohibit us from deleting our data stored and processed, we will not be able to fulfil such an obligation, even if you ask us, but we will inform you of the obligations that apply to us.

Right to data transfer – if your Personal data are processed automatically with your consent or on the basis of mutual contractual relations, you may request that we provide such Personal data in a structured, customary and electronic form. You can also request that Personal data be transferred to another controller. Please note that this can only be done where technically possible.

Right to withdraw your consent – in cases where the data are processed with your consent, you have the right at any time to withdraw your consent to the processing of data.

Right to refuse marketing messages – at any time you can opt out of our outgoing communications in which we send you information about our events or any other material that we think may be of interest to you. You can send your refusal at any time by contacting us.

If you are concerned about a potential violation of privacy laws or any other violation of the laws, please contact us by e-mail at privacy@equite.lt or write to any of our employees. The responsible person will investigate and transfer the message to the responsible employee, and provide information on further consideration of the complaint.

If you are not satisfied with the investigation of the complaint, you have the right to file a complaint with your country’s data protection authority. You also have the right to apply to the competent jurisdiction court. Information about the authorities responsible for the enforcement of personal data protection legislation:

Lithuania:

The State Data Protection Inspectorate

Žygimantų g. 11-6a

011042 Vilnius

Tel. + 370 5 279 14 45

E-mail: ada@ada.lt

http://www.ada.lt/

Social Networks and other Websites

All information that you provide to us via social media (including messages, usage of Like and Follow button clicks, and other communication) is controlled by the social network controller.

We may be linked to third-party sites; links can be made to and from such websites. We have not reviewed neither confirmed, have no influence, and are not responsible for the content or privacy practices of websites that we may be linked to. We do not support third-party sites and we cannot provide guarantees concerning any information, software or other products or materials contained therein that you can find there and the results obtained through the use of it.

Policy Changes

This Policy may be changed or updated. The latest version of it will always be published on our websites, so we invite you to familiarise yourself with the latest version from time to time.

Where to get Information

You have the right to contact us in order to submit inquiries, cancel your issued permissions, and submit requests for the exercise of the rights of the data subject and complaints regarding the processing of personal data.

Our contact details are available on the websites listed at the top of the Policy, and you can also contact us by e-mail at privacy@equite.lt.

Marketing Privacy Policy

This Marketing privacy policy is intended to describe the practices Equite follows with respect to the privacy of all individuals whose personal data is processed and stored by Equite for direct marketing purposes.

1. Who can see your data?
Equite means Equite, UAB, company code 305747607, address – A. Tumėno str. 4, Vilnius, Republic of Lithuania. Equite manages contact databases in Lithuania.
Equite acts as the controller for its own contact data stored in the Contact databases.
2. Why do we need information?
The Contact databases are client’s/contact’s relationship management tools of Equite, that support the marketing operations of companies of Equite. We use this information for sending invitations to seminars, workshops and other events as well as newsletters, surveys or other direct marketing communications related to the various services offered by Equite in the Republic of Lithuania and other countries.

Personal data processed in the Contact databases is used for the purposes of sales and marketing. Processing your contact information allows us to communicate with you via electronic mailings, text messages or via phone.

Equite relies on the following basis to legitimize the processing of personal data in its Contact databases:

  • – Equite has obtained individual’s consent for the processing of personal data in the Contact databases systems; or
  • – when its permitted by applicable law (example: to provide related services).

3. What type of personal data is processed?
The Contact databases process personal data of former, current and prospective customers (including individuals within a corporate client) of Equite. The Contact databases also contain data of other business contacts (such as consultants, regulators, etc.) as well as data of employees (former and current).

The following data categories are processed in the Contact databases:

  • – Name, surname, occupation, address, e-mail address, phone numbers, name of the company;
  • – Marketing preferences;
  • – Invitation responses and event attendance confirmations;
  • – opt-out list.

4. Sensitive Personal Data
Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.

Equite does not intentionally collect any sensitive personal data from you to store in its Contact databases.

5. Who can access your information?
Access to your personal data is limited by need. All marketing and sales employees of Equite in the Republic of Lithuania and other countries, if any, shall have access to your contact information.

We will only disclose your personal data to third parties:

– If such third party is engaged by Equite to facilitate, maintain or support its Contact databases (for example, to provide information technology and other administrative support services);

– When explicitly requested by you;

– When it is required by applicable law.

6. International transfer of data
Ordinarily, Equite will not transfer your data to countries outside the European Economic Area. In some cases, personal data can be saved on storage solutions that have servers outside the European Economic Area (EEA), [for example, Dropbox or Google]. Only those storage solutions that provide secure services with adequate relevant safeguards will be employed.

Transfers of personal data to third countries, in principle, will only be allowed if an adequate level of protection is ensured in the recipient country and in accordance with applicable law. Equite undertakes to ensure the compliance with security requirements.

7. Data retention
Data of contacts who have been out of active use for more than 5 years will be deleted from our Contact databases, unless you will agree to renew your consent. Data in opt-out list will be deleted after 12 months after the date when we received your request to delete your information from our Contact databases.

If you want to have your data deleted from our Contact databases or if you wish to object to the processing of your personal data for direct marketing purposes, please contact us via e-mail privacy@equite.lt.

8. Security
Equite is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, Equite has technical and organizational measures to safeguard and secure your personal data. All Equite employees and third parties that Equite engages to process your personal data are obliged to respect your data’s confidentiality. Obligation of confidentiality ensures that the Equite employees shall process all the Personal Data with respect of strict confidentiality.
9. Data transfer to third parties
Equite will not transfer your personal data to third parties (other than any external parties referred to in section “Who can access your information” above) unless we have your permission or its required by law.
10. Your rights
At any time, you can contact us with request:

  • – To access of your personal data;
  • – To see the list of recipients or categories of recipient to whom the personal data have been or will be disclosed;

after you get acquainted with your personal data, you are entitled to:

  • – To require to rectify any inaccurate or incomplete personal data;
  • – To object to the processing of any personal data;
  • – To require to limit the processing of your personal data;
  • – To require the erasure of your personal data;
  • – To require to suspend the processing of your personal data.

After the receiving of such request, we will give you an answer in your preferred way.

11. Rectification, erasure, restriction of processing or data portability
In order to confirm that your personal data is accurate and current or to request rectification, erasure, restriction of processing or a readily portable copy of your personal data, you can contact us by sending an e-mail privacy@equite.lt.
12. Complaints
If you are concerned about an alleged breach of privacy law or any other regulation, contact us via e-mail privacy@equite.lt, by phone +370 (5) 2 644741, by post A. Tumėno str. 4, East entrance, 10 floor, Vilnius, the Republic of Lithuania. You can also contact any of our employees. Responsible person will investigate your complaint and provide information how it will be handled.

If you are not satisfied with how we resolved your complaint, you have the right to complain to the data protection authority. You can also refer the matter to a court of competent jurisdiction.

13. Other questions
If you have any questions or concerns, contact us by e-mail privacy@equite.lt.

Introduction

Our website, www.equite.lt uses cookies and other related indicators that are mentioned below (for convenience all cookies and indicators are referred to as “cookies”). Cookies are also placed by third parties we have engaged. In the document below we inform you about the use of cookies on our website.

What are cookies?

A cookie is a small simple file that is sent along with pages of this website and stored by your browser on the hard drive of your computer or another device. The purpose is to allow the site to remember your actions and settings (such as login name, language, alphanumeric settings, and other image settings) for some time, so that you do not need to enter them every time you re-visit the website or browse through individual websites. The information stored therein may be returned to our servers or to the servers of the relevant third parties during a subsequent visit.

  • First party cookies are cookies set by the website you’re visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies;
  • Persistent cookies are cookies saved on your computer and that are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.
  • Third Party cookies are cookies that are stored under a different domain than you are currently visiting. Third party cookies are mostly used to collect user data for web analytic purposes, to track users between websites and display more relevant ads between websites. Please note that third party cookies that we use and information on the usage and sharing of data by third parties are specified in section 6. Please note that section 6 contains the links to the websites that belong to third parties and which we have no control over and are not responsible for their content. By accepting third party cookies you are also consenting to the privacy policies of the respective service providers. If you have any questions regarding this matter – please contact us via email privacy@equite.lt.

What are scripts?

A script is a piece of program code that is used to make our website function properly and interactively. This code is executed on our server or on your device.

What is a web beacon?

A web beacon (or a pixel tag) is a small, invisible piece of text or image on a website that is used to monitor traffic on a website. In order to do this, various data about you is stored using web beacons.

Cookies

Technical or functional cookies

Some cookies ensure that certain parts of the website work properly and that your user preferences remain known. By placing functional cookies, we make it easier for you to visit our website. This way, you do not need to repeatedly enter the same information when visiting our website and, for example, the items remain in your shopping cart until you have paid. We may place these cookies without your consent.

Statistics cookies

We use statistics cookies to optimize the website experience for our users. With these statistics cookies we get insights in the usage of our website. We ask your permission to place statistics cookies.

Marketing/Tracking cookies

Marketing/Tracking cookies are cookies or any other form of local storage, used to create user profiles to display advertising or to track the user on this website or across several websites for similar marketing purposes.

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