PRIVACY POLICY

UAB “Avitelos prekyba”, legal entity code 142054984, registered address: Taikos pr. 15, LT-91135 Klaipėda, company data is collected and stored in the Register of Legal Entities (hereinafter – the company), is the controller of personal data obtained when a person uses the company’s products and/or services, as well as when visiting our websites. This means that UAB “Avitelos prekyba”, independently or jointly with others, determines the purposes and means of processing personal data and undertakes to respect and protect personal data and individuals’ privacy. UAB “Avitelos prekyba” manages the trademarks “Elesen”.

This privacy notice:

defines the company’s commitment and responsibility to protect and respect personal privacy;
explains how the company collects, uses, and safeguards (processes) personal data;
informs data subjects about how their personal data is processed and what rights each data subject has.

When processing data subjects’ personal data, we comply with the requirements of European Union legislation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other directly applicable legal acts regulating the protection of personal data, as well as the instructions of competent authorities.
This privacy notice (last updated in November 2020) applies when a person uses the company’s products and/or services, as well as when visiting our websites. The privacy notice does not apply when using other companies’ websites or services, even if they are accessed through the company’s network or services.

Definitions

Personal data – any information related to a natural person – the data subject – whose identity is known or can be directly or indirectly identified using relevant data.
Data subject – any natural person: a company customer, employee, partner, or visitor.
Customer – any person who orders, purchases, or uses the services of our company. A customer with whom the company has entered into a purchase agreement must ensure that all end users (e.g., family members) who use the services ordered by the customer are familiar with and comply with this privacy notice.
Anonymous data – information that is no longer related to a natural person, as all elements that would allow identification have been removed from the set of personal data.
Services – any products and/or services offered by the company, whether electronically or non-electronically.

How do we collect your personal data?

The company offers a wide range of goods and services. The information we collect about you depends on the details you provide when ordering products or registering on our websites. Sources of data collection. We collect the following data:

data you provide yourself, e.g., when you interact or have legal relations with our company, such as purchasing services or registering for services; subscribing to newsletters or contacting us to request information;
data generated automatically when you use our services, as permitted by applicable laws, for example, when you contact us or use our services (e.g., make a phone call, send an email, or visit our websites);
data we receive from other sources, such as other service providers or publicly available registers.

You are not required to provide any personal data to the company. However, in certain cases, if you choose not to do so, we may be unable to provide you with goods and/or services.

What personal data do we collect?

We collect data that falls into the following categories:

basic information such as name, surname, personal identification number, date of birth, address, identity document details, and contact information;
data related to the provision of goods and/or services, invoicing, payment details, information about consent or refusal to process personal data for direct marketing purposes and data sharing with third parties, contact information, and related records;
data generated through the use of communication tools, e.g., traffic data – connection start date, time, duration, calling subscriber number, receiving subscriber number, IP address used during internet session, etc.;
other data related to the use of services and/or goods, such as data collected through cookies and similar technologies related to online browsing, etc.;
video data recorded by our video surveillance systems when you visit our stores, to ensure the safety of staff, customers, and premises;
you may be captured in a crowd during photo coverage of events organized by the company;
recordings of phone calls when you contact the company’s customer service center or receive calls from company employees;
other data collected based on your consent and defined in detail at the time your consent is requested.

How do we use your personal data?

The company collects and further processes your personal data only on the basis of lawful grounds defined in data protection legislation – in order to conclude and/or perform a contract with you; based on your consent; when the company is required to process personal data by applicable legal acts; or when the processing is necessary for the legitimate interests of the company (only if the data subject's interests do not override those interests). The company processes personal data for the following purposes:

Conclusion and execution of electronic contracts, including but not limited to customer and payment accounting under concluded agreements. We process personal data necessary to ensure proper service provision to our customers – to accurately identify individuals, accept and fulfill orders, provide customer service, and issue invoices for goods and/or services. The legal basis is the performance of a contract with you (GDPR Article 6(1)(b)) and compliance with legal obligations (GDPR Article 6(1)(c)). Data for this purpose is processed for 10 years after the fulfillment of the contract.
Protection of our interests as a creditor and prevention of financial loss; debt recovery. We process personal data necessary to properly assess your creditworthiness, conclude contracts with you, perform credit control, recover debts, handle complaints, etc. The legal basis for data processing is our legitimate interest (GDPR Article 6(1)(f)) – our aim to protect our financial interests. You have the right to object to such data processing by submitting a justified objection. Data is processed for 5 years after the end of the debt relationship.
Direct marketing. We process personal data (name, surname, email address, phone number) for direct marketing purposes. We have the right to send our existing customers direct marketing messages about similar products and services via email, provided they do not object. The legal basis for data processing concerning existing customers is our legitimate interest (GDPR Article 6(1)(f)) – our aim to inform existing customers about similar products and services. You have the right to express your objection at the time of purchase. Based on this ground, we will send direct marketing messages if you do not object, and for no longer than 1 year after the last purchase. For potential customers, the legal basis for data processing is consent (GDPR Article 6(1)(a)). This means we will only send messages to potential customers if they have actively given their consent. Data is processed for this purpose until you withdraw your consent. You have the right to refuse to give consent or to withdraw your previously given consent at any time without any negative consequences.
Organization of games and promotions. For the organization of certain promotions and games, and the distribution of prizes, we may need your personal data such as name, surname, purchase receipt details, contact information, and data that may be required by the State Tax Inspectorate (VMI) for tax obligations. The legal basis for data processing is our legitimate interest – the smooth execution of the game/promotion (GDPR Article 6(1)(f)) and compliance with legal obligations – GDPR Article 6(1)(c). Please note that we profile game and promotion participants based on gender and age data. This data is collected for the purpose of obtaining statistical insights about our target audience. You have the right not to provide this data if you do not wish to be subject to profiling. Such profiling does not cause any legal or other negative consequences. Data of game and promotion participants is stored for no longer than 6 months, and winner data is stored as long as required by VMI regulations.
Protection of personnel, customers, and other individuals within the video surveillance area, as well as property protection (video surveillance). We process video data of our staff, customers, and other individuals who enter the surveillance area to ensure their and property security. The legal basis is our legitimate interest (GDPR Article 6(1)(f)) – to ensure safety and record possible violations. Video recordings are stored for up to 31 days. You have the right to object to such data processing by submitting a justified objection.
Customer service quality assessment; collection of evidence (telephone call recording). We process recordings of your phone calls when you contact the company's customer service center or receive calls from company employees, as well as the data provided during the calls, in order to ensure the quality of our services. The legal basis is our legitimate interest (GDPR Article 6(1)(f)) – to provide high-quality telephone services. You have the right to object to such data processing by submitting a justified objection. Call recordings are stored for up to 3 months.
Protection and defense of the company’s rights and legitimate interests. We process data for this purpose when responding to complaints and claims, or when submitting/responding to legal proceedings. The legal basis is our legitimate interest (GDPR Article 6(1)(f)) – to defend our interests and properly represent ourselves before supervisory authorities. You have the right to object to such data processing by submitting a justified objection. Data is stored until the date of the final decision and further as required by legal acts regulating document archiving procedures.
We may also process data for other purposes for which the company is legally entitled to process your personal data, e.g., in cases of internal or external audits, purchase-sale, reorganization, or other types of restructuring, consultations with legal or other professionals, in order to properly fulfill obligations established by law, such as accounting, providing data to competent authorities when required by law, defending our interests in court, etc. The legal basis for data processing in such cases may be your consent, our legitimate interest, or compliance with legal obligations.

In all of the above-mentioned cases, the company processes personal data only to the extent necessary to achieve the corresponding clearly defined and legitimate purposes, taking into account the protection of the data subject’s privacy. The company ensures that personal data is processed accurately, fairly, and lawfully; that it is processed only for purposes compatible with those established prior to the collection of personal data; and that it is processed strictly in accordance with the clear and transparent personal data processing requirements established by legal acts.

How do we protect your data?

To process your personal data, the company has implemented appropriate organizational and technical security measures that help protect personal data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing. The company’s security activities include, among other things, the protection of personnel, information, IT infrastructure, internal and public networks, as well as office buildings and technical equipment.

Who do we share your data with?

We may provide your data to:
Data processors (subcontractors) who provide services to us and process your data on behalf of the company as the data controller, and to other companies acting as independent data controllers. Please note that data processors are only permitted to process personal data according to our instructions and only to the extent necessary to properly fulfill the contractual obligations. When engaging subcontractors, we take all necessary measures to ensure that our data processors also implement appropriate organizational and technical security measures and maintain the confidentiality of personal data. Below is a list of our partners who may receive your personal data: Link

Data processors may be located outside the Republic of Lithuania, the European Union, or the European Economic Area. If we transfer your personal data to such processors, we will take all necessary measures required by law to ensure that your right to privacy continues to be properly protected. To obtain information about the additional security measures applied, please contact us using the contact details provided below.
Companies managing joint debtor data files. The company has the right to provide data to data controllers managing joint debtor databases (e.g., UAB Creditinfo Lietuva) regarding data subjects (debtors) who have failed to fulfill their financial and/or property obligations in a timely and proper manner, in order to manage debts. Debtor data is provided only in accordance with the legal requirements, after issuing a written reminder to the data subject and ensuring the proper implementation of data protection requirements as prescribed by law.
Companies acquiring the right to claim a debt. According to the Civil Code of the Republic of Lithuania, the company (creditor) has the right to assign the right to claim a debt to another party by a debt portfolio purchase-sale agreement without the debtor’s consent. Both the former and the new creditor may inform the debtor about the assignment.
Other third parties if such provision is necessary and does not conflict with legal regulations.

We may also provide your data:

In response to court or government authority requests, but only to the extent necessary to properly comply with applicable legal requirements or a court order/warrant.

How long do we retain your data?

We retain your personal data no longer than necessary for the purposes of data processing or as required by legal acts, if a longer retention period is specified therein.
Data collected for direct marketing purposes is stored until you withdraw your consent.
We strive not to retain outdated or unnecessary information and ensure that personal data and other client information is regularly updated and accurate.

How do we use cookies?

In order to improve your experience when visiting the company's websites, we use cookies – small pieces of text information that are automatically created while browsing the website and stored on your computer or other end device. The information collected through cookies allows us to ensure a more convenient browsing experience, provide you with relevant offers, better understand the behavior of our website users, analyze trends, and improve the website, customer service, and the services provided by the company.

What types of cookies do we collect?

The Elesen.lt website uses four main types of cookies. By continuing to browse, you agree to the use of essential cookies. You may also choose to consent to the use of other types of cookies.
Cookies are small text files that websites can use to enhance the user experience.
By law, we are allowed to store cookies on your device only if they are strictly necessary for the operation of this site. For all other types of cookies, we must obtain your permission.
This website uses different types of cookies. Some cookies are placed by third-party services that appear on our pages.
You can change or withdraw your consent at any time in our website's Cookie Declaration.
To learn more about who we are, how you can contact us, and how we process personal data, please see our Privacy Policy.
Please provide your consent ID and the date when contacting us about your consent.
Your consent applies to the following domain: elesen.lt
Your current status: Allow all. Your consent ID: EMP Date of consent:
Change your consent | Withdraw consent
Cookie description last updated on 5/9/24; updated by Cookiebot

How to manage and delete cookies

Necessary cookies will be stored immediately. You can manage the storage of other cookies on your device using the pop-up window that appears when you open our website. All cookies except essential ones will only be stored with your active consent.
When using a browser to access our content, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so if you are unsure how to change your cookie settings, check your browser’s help menu. Your device's operating system may also provide additional cookie controls. If you do not want information to be collected through cookies, use the simple procedure available in most browsers that allows you to refuse the use of cookies. To learn more about managing cookies, visit: AllAboutCookies.org ; https://policies.google.com/technologies/ads.
Please note, however, that in some cases deleting cookies may slow down your browsing experience, limit certain website functionalities, or block access to the website.

What are your rights?

You have the right to:

contact the company to request information about the personal data processed by the company;
contact the company to request the correction of your personal data and/or to request the suspension of processing activities (except storage) if, after reviewing the data, you find that the data is incorrect, incomplete, or inaccurate;
contact the company to request the destruction of your personal data or the suspension of processing activities (except storage) if, after reviewing your personal data, you find that it is being processed unlawfully or unfairly;
contact the company to request the transfer of your personal data to another controller or processor;
object to the processing of your personal data when such data is processed or intended to be processed for direct marketing purposes or on the basis of the legitimate interest pursued by the company or a third party receiving the personal data.

If you have concerns about any actions or inactions by the company that may not comply with this privacy notice or legal requirements, you may contact the company in any way convenient to you.

in writing – by email: info@elesen.lt
orally – by phone: 8 700 38500
in writing – to the address: Taikos pr. 15, Klaipėda
by visiting any company store

If the issue cannot be resolved with the company, you have the right to contact the State Data Protection Inspectorate at www.vdai.lt, which is responsible for supervising and enforcing the legal acts regulating personal data protection.

How can you stay informed about changes to this notice?

As our operations and services expand, we may need to update this privacy notice. For this reason, we recommend that you periodically visit our website, where the latest version of this privacy notice will always be available.
If we make any material changes to this notice, we will inform you in advance by publishing a notice on our website.

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