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Privacy Notice

 

1. Who is this Privacy Notice for?

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The purpose of this privacy notice ("Privacy Notice") is to inform data subjects about the processing of personal data carried out by the Centric IT Solutions Lithuania, UAB (Company or we). In this Privacy Notice, we provide the visitors of the website, our clients, suppliers and other partners, natural persons related to them, candidates, correspondence counterparties, and other data subjects indicated in the Privacy Notice with information about how we process their personal data. Any person whose personal data we process is referred to in this Privacy Notice as a Data Subject.

Due to the nature of its activities, the Company also acts as a data processor in individual cases. This Privacy Notice does not cover such cases, i. e., this Privacy Notice provides information on how the Company processes personal data in its capacity as a data controller.​

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2. About the Company

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The Company means the Centric IT Solutions Lithuania, UAB, legal entity code 304771516, registered office at 7 Jonavos St., LT-44269 Kaunas, the Republic of Lithuania. Contact email for personal data protection issues info.LT@centric.eu.

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3. What is Personal Data?

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Personal Data is any information collected by the Company about a Data Subject that can be used to identify the Data Subject and is stored electronically or otherwise.

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Personal Data includes any information, including the name, surname, address of the Data Subject, IP address of the visitor of the website, which the Company collects about Data Subjects for the purposes set out in this Privacy Notice or in the Data Subject's individual consent or agreement with the Company.

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4. Contact Us

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There are several ways you can contact the Company: by phone, email, social media accounts, by sending a letter to the Company's registered office address, or by using the contact form on this website. All communications are received, reviewed and responded to by us. If you contact us, we will process the data you provide to us, i.e. email address, name (if provided), username (if the request is sent via a social networking account), workplace (if provided), date, time, recipient, sender (if the message is addressed to you), content of the messages sent and received.

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Such data will be processed in order to answer your questions and ensure smooth communication with you. If you do not provide your contact details, it will not be possible to contact you.

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Correspondence is stored for 1 year from the date of receipt of the message, except for information for which other time limits are set out in the Privacy Notice or by law.

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Any personal data you provide when you interact with us is only used for the purposes set out above and to view messages and administer and manage communication flows. We undertake not to use your personal data in any publications in a way that could identify you without your explicit consent.

Please note that we may need to contact you by post, email or telephone. Please notify us of any changes to your personal data.

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5. Personal Data Processed when Entering into and Performing Contracts with Clients, Suppliers, and other Partners

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6. Protecting Confidential Information of the Company and ensuring Business Continuity

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The Company may review its employees' correspondence with contractors in order to protect the Company's confidential information and the continuity of the Company's business in its legitimate interest. For these purposes, the Company processes the following personal data of its employees and of persons who send or receive employee communications: e-mail address, name of the sender or recipient, date, and content of information contained in electronic work tools. Such data shall be kept for 4 years.

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7. Defending Rights and Legitimate Interests of the Company

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We continue to store contracts for goods, works, services, and acts of acceptance of goods, works and services and data related to the performance of contracts even when they are no longer needed for the original purpose (usually – for concluding and performing the contract). We do so in order to preserve evidence and be able to defend our rights and legitimate interests if any kind of dispute arises. We store data for 10 years after the termination of the contract and do so on the basis of our legitimate interest.

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The Company also shall, on the basis of its legitimate interest to defend its rights, including in the event of civil disputes, process the names, surnames, personal identification numbers, case background, other information related to the case, and publicly available information of the persons involved in the case or of their employees. The data may be communicated to law enforcement authorities, lawyers or bailiffs for the purpose of debt collection. The data shall be destroyed 1 year after the final settlement of the case and the full satisfaction of the Company's claims (if satisfied).

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8. Accounting

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We continue to store certain personal data related to the performance of the contracts even when they are no longer needed for the original purpose (name, surname, details of services received/provided and goods sold / bought, and other personal data in invoices and other accounting documents) . We do so for accounting purposes in order to comply with the legal obligations set forth in the legislation. Such personal data are stored within the time limits laid down by the legislation governing the keeping of accounting records and in accordance with the General Index of Document Retention Periods approved by Order No V-100 of the Archivist of the Republic of Lithuania dated 9 March 2011.

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9. Direct Marketing Activities

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We provide individuals who have given their contact details and have consented to their processing for direct marketing purposes with promotional communications. For the purpose of providing promotional communications, we process the following personal data: the name of the organisation represented, position, email address, telephone number, content and dates of the messages sent. Personal data is processed for 3 years after the consent is obtained. Direct marketing communications are delivered on the basis of your consent.

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If you are our customer and you did not object to direct marketing of our goods or services similar to the services you have purchased at the time of ordering the services (by entering into a contract), we may send direct marketing communications to the email address specified in the contract on the basis of legitimate interest. In this case, direct marketing communications will be sent to the email address specified in the contract for the duration of the contract and for 1 year after its termination, unless you object to the further processing before that time. In this case, we will immediately stop sending you direct marketing communications.

Personal data processed for the purpose of direct marketing shall be transferred to processors which are necessary for the purpose of direct marketing.

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You have the right to opt out of receiving direct marketing communications at any time by contacting us at the email address set out in section 2.

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10. Social Media

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Our website provides links to our social media accounts ("Accounts"). We currently administer the following Accounts:

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We process the information contained in our Accounts for the purpose of administering the Accounts on the basis of your consent. We do not separately store the information contained in the Accounts where the data is processed for the purpose of administering the Accounts, but the data may be stored if it is necessary to process the data for another purpose, such as for the purpose of enforcing rights.

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When you visit our Accounts, the administrators of the social networks place cookies on your device. Cookies collect personal data. Cookies are stored both if you are a registered user of a social network and if you do not have an account with the relevant social network. We do not have access to the personal data collected about you and can only obtain statistical information about the traffic of the Accounts from the administrators of the social networks.

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We recommend that you read the privacy notices of third parties and contact the service providers (owners, administrators of the social media networks) directly if you have any questions about how they use your personal data.

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11. Cookies and Other Tracking Technologies

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Cookies are used on the Website. A cookie is a small text file in alphanumeric format that we place with your consent on your browser or hard disk. We use different cookies for different purposes. Cookies also help us to differentiate you from other users of the Website, thus providing a more pleasant experience of using the Website and allowing us to improve the Website.

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Most browsers allow you to reject all cookies, and some browsers allow you to reject only third-party cookies. However, please note that blocking all cookies will have a negative effect on the use of the Website, and without cookies you will not be able to use all the services provided on the Website. More information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.
We use the cookies described below, for a detailed list of which you will find HERE.

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(a) Strictly Necessary Cookies.

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These cookies are necessary for our website to work. The basis for the use of such cookies is Paragraph 4 of Article 73 of the Law on Electronic Communications of the Republic of Lithuania. These cookies are necessary for the operation of the Website and cannot be disabled on our systems. We ensure the quality and security of the visit. These can be cookies, which, for example, allow you to log in and access secure areas of our website, use the shopping cart feature or email account services.

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(b) Analytical and / or Performance Cookies

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These cookies allow us to identify and count visitors to our website and to track how visitors navigate our website. This helps us improve the performance of the site, such as ensuring that users can easily find what they are looking for. Cookies are not intended to identify or influence your browsing experience while you are visiting the Website. If you do not agree to the use of these cookies, you will not be recorded in the visit statistics. The basis for the processing of the data collected by these cookies is your consent.

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​(c) Functional Cookies

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These cookies are used to identify you when you return to our website so that we can tailor the content provided to your needs, remember the information relevant to you. The basis for the processing of the data collected by these cookies is your consent.

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(d) Advertising Cookies

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We use our own and third-party cookies to display personalized advertising on our own and other websites. This is called "remarketing," which is based on browsing activity, such as the products you search for and view.

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Social networks plugins are also used on this website.

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12. Candidate Search and Selection

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We collect and process the following candidates’ personal data: your workplace, email address, date of birth, address, education, surname, telephone number, first name, preferred job, date of receipt of your CV, information about your personal qualities, your work experience (last workplace, length of service with the workplace, your last job title, other work experience), information on your knowledge of foreign languages (language, reading, writing, speaking levels), your ability to work with computer programmes, and any other information contained in your CV, letter of recommendation and/or cover letter; your preferred salary, for the purpose of the selection process, on the basis of your consent, which you express to the Company by sending your CV and/or cover letter. If you do not submit your CV and/or cover letter, we will not be able to assess your suitability for the position offered.

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With your consent, we will contact your current employer and we will contact your former employer on the basis of our legitimate interest (to select a suitable candidate) and on the basis of Article 5(2) of the Law on the Legal Protection of Personal Data of the Republic of Lithuania in order to verify information about your qualifications, professional abilities and professional qualities (such as your work performance, relations with clients and/or colleagues, evaluation of your work, etc.). We will also collect information from public professional social media profiles on the basis of our legitimate interest (to select the right candidate). You may withdraw your consent or, as the case may be, object to us contacting your former employer at any time by notifying us at the email address set out in section 2 of the Policy.

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In the event that you do not express your explicit consent to the processing of your personal data at the end of this selection procedure, we will delete and/or destroy your personal data within 3 working days after the signature of the contract with the successful candidate or the decision to close the selection procedure, unless you have given your explicit consent to the retention of the candidate's personal data for a specified period.

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On the basis of our legitimate interest, we will process data about the person (name, surname, email, telephone number, information provided by the person) indicated by the candidate – a former or current employer or a person providing a reference, and the information provided by the person - for the purpose of selecting the candidate. In this case, our legitimate interest is to select the right candidate for the position we are seeking. We will delete this data within 3 days after the contract with the selected candidate has been signed or the decision to close the selection has been taken.

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13. Transfer of Personal Data to Third Countries

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Data controllers of social media networks (Facebook, Instagram, LinkedIn, YouTube) are established in third countries for which the European Commission has not taken a decision on eligibility.

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The data of Facebook and Instagram social networks users residing in the European Union are processed by the data controller Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland). Information on how you can exercise your rights as a data subject is available at https://facebook.com/privacy/explanation/. If you have any complaints regarding the processing of your personal data by Meta Platforms Ireland Limited data or the exercise (non-exercise) of your rights as a data subject, you have the right to complain to Meta Platforms Ireland Limited's supervisory authority, the Irish Data Protection Commission or the State Data Protection Inspectorate.

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The data of LinkedIn social network users residing in the European Union are processed by the data controller LinkedIn Ireland Unlimited Company (Wilton Plaza, Wilton Place, Dublin 2, Ireland). Information on how you can exercise your rights as a data subject is available at https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy. If you have any complaints regarding the processing of your personal data by LinkedIn Ireland Unlimited Company or the exercise (non-exercise) of your rights as a data subject, you have the right to lodge a complaint with the LinkedIn Ireland Unlimited Company's supervisory authority, the Irish Data Protection Commission or the State Data Protection Inspectorate.

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The data of YouTube social network users residing in the European Union are processed by the data controller Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Information on how you can exercise your rights as a data subject is available at: https://policies.google.com/privacy?hl=en. If you have any complaints regarding the processing of your personal data by Google Ireland Limited or the exercise/non-exercise of your rights as a data subject, you have the right to lodge a complaint with Google Ireland Limited's supervisory authority, the Irish Data Protection Commission or the State Data Protection Inspectorate.

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14. Receipt and Disclosure of Personal Data

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We receive your data from you, from our employers, collect them from public sources (e. g. social network accounts of the candidates) or software you use.

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We disclose information about you mostly to our data processors that process personal data under our instructions, i. e. providers of the specific software, servers, marketing, recruitment and similar services.
In addition to the specific recipients of the data identified in this Privacy Notice, we may disclose information about you:

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  • if that's what we have to do by law;

  • when you intend to sell the business or part of its assets by disclosing your personal data to a potential buyer of the business or part of the business;

  • the sale of the Company's business or a substantial part of its assets to a third party.

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Except as set out in this Privacy Notice, we do not provide your personal data to any third parties.

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The list of recipients or categories of recipients referred to in the Privacy Notice is subject to change, so if you wish to be informed about changes in the recipients of your personal data, please notify us by sending an e-mail to the e-mail address specified in this Privacy Notice, with the following indication in the body of the e-mail: "I wish to be informed of changes in the recipients of my personal data, name and surname".

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15. Security of Your Personal Data

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

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16. Your Rights

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In this section, we provide information about your rights in relation to our processing of your personal data, how and when you can exercise these rights. If you would like to receive more information about your rights or to exercise them, please contact us at the email address set out in this Privacy Notice.

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The Company will provide you with information on the action taken following your request for the exercise of your rights without undue delay, but at the latest within one (1) month of receipt of the request. Depending on the complexity of the request and the number of requests received, the aforementioned time limit may be extended for a further 2 (two) months. In this case, we will inform you within 1 (one) month of receipt of the request of such extension and the reasons for it. The company will only refuse to exercise your rights in cases provided for by law.

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17. Right of Access to Your Personal Data

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We want you to fully understand how we use your personal data so that you do not experience any inconvenience. You can contact us at any time to enquire whether we are processing any of your personal data. If we store or use your personal data in any way, you have the right to access it. To do so, please make a written request to us at the email address set out in this Privacy Notice, provide us with proof of your identity. Please mind the principles of fairness and reasonableness when making such a request.

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17.1. Right to Withdraw Consent

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If you have given us your explicit consent to the processing of your data, you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of consent-based processing carried out before the withdrawal of consent.

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17.2. Additional Rights

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Below you will find information about additional rights that you may have, which you can exercise by following the procedures described below.

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(a) You have the right to ask us to rectify any inaccuracies in the data we hold. In this case, we may ask you to confirm the rectified information.

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(b) You have the right to ask us to erase your personal data. This right shall be exercised in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679.

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(c) You have the right to ask us to restrict or not to process your personal data in the following events:

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  • for the period of time necessary to verify the accuracy of your personal data when you make a complaint about the accuracy of the data;

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  • where our collection, storage or use of your personal data is unlawful, but you choose not to request erasure;

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  • where we no longer need your personal data, but you need it to establish, exercise or defend a legal claim;

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  • for the period necessary to determine whether we have an overriding legitimate interest to continue processing your personal data if you have exercised your right to object to the processing of personal data.

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(d) You have the right to the transfer of data processed by automated means which we have received from you in a structured, commonly used and computer-readable format with your consent or for the purposes of concluding a contract. If you exercise this right, we will, at your request, transfer a copy of the data provided by you to you or to a data controller of your choice.

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(e) You have the right to object to our use of your personal data in accordance with Article 21 of the GDPR. You have the right to object when your personal data is processed on the basis of legitimate interest (for each of the above purposes of processing, it is indicated on which basis the data is processed) or for direct marketing purposes.

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17.3. Right to Request more Information

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We hope that you will understand that it is very difficult to discuss all possible ways of collecting and using personal data. We are making efforts to provide as clear and complete information as possible and we undertake to update this Privacy Notice if the process of using personal data changes. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or do not understand the information provided, please contact us.

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18. Complaints

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If you believe that your rights as a data subject have been and/or may be violated, please contact us immediately at the email address provided in this Privacy Notice. We ensure that only upon receipt of your complaint, we will contact you within a reasonable period of time to inform you about the progress of the investigation and the outcome of the complaint.

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If you are not satisfied with the results of the investigation, you can lodge a complaint with the supervisory authority, the State Data Protection Inspectorate: https://vdai.lrv.lt/en/.

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19. Responsibility

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You are responsible for maintaining the confidentiality of the data you provide to us and for ensuring that the data you provide to us is accurate, correct and complete. If there is any change in the data you have provided, you must inform us immediately by e-mail. In no event shall we be liable for any damage caused to you as a result of your providing incorrect or incomplete personal data or your failure to inform us of any change in the data.

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20. Changes to the Privacy Notice

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We may update or change this Privacy Notice at any time. If you would like to receive an updated Privacy Notice, please notify us at the email address set out in Section 2.

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