Privacy policy

Privacy policy

This Privacy Policy is intended for persons visiting this website owned by Klaipeda FEZ (www.fez.lt), using website information and services provided on the website. The Privacy Policy also provides information on the processing of personal data of Klaipeda FEZ customers, suppliers and other persons in the course of Klaipeda FEZ activities, acquisition of goods and/or services.

The personal data controller specified in this Privacy Policy is KLAIPEDA FREE ECONOMIC ZONE MANAGEMENT COMPANY, Private Limited Liability Company, Legal Entity Reg. No. 110707092, address: Pramones Str. 8, LT-94102 Klaipeda, phone: +37069808144; e-mail: [email protected] (hereinafter referred to as “the Klaipeda FEZ” or “We”).

By using the services, continuing browsing the website you confirm that you are familiar with the present Privacy Policy and understand its provisions.

The purposes, basis of your personal data processing, storage term, data categories

Your personal data is processed in accordance with the following conditions:

Purpose Base Data categories Storage term Necessity to provide data
Assurance of the functionality of the website, gathering of the statistics and improving of the website, direct marketing Our website uses cookies.  See our Cookie Policy (further in this document).
Direct marketing Your consent Contact details During the validity term of the consent, but not longer than 2 years Is not necessary
The purpose of providing services; provision of services Our legitimate interest to conclude a service contract, to ensure the provision of services, the performance of the contract, to offer similar services
or
Contract
Contact and identification data 3 years after the end of the contract Is not necessary
Informal communication (to greet you on the occasion of personal holidays) Your consent Contact and identification data During the validity term of the consent, but not longer than 2 years Is not necessary
Purchase of goods/services Our legitimate interest to administer the purchases of goods/services
or
Contract
Contact and identification data 3 years after the end of the contract Is not necessary
Accounting, auditing; storage of necessary documents Legislation;
or
Our legitimate interest of accounting of the economic transactions
Data in the documentation 10 years after the end of the economic transaction;
or
The personal data contained in the documents are stored according to the time limits laid down in the Index for Time Limits for Storage of General Documents, approved by Order No. V-100 of 9 March 2011 of the Chief Archivist of Lithuania 
We process your existing data
Protection of legitimate interests of Klaipeda FEZ It is in our legitimate interest to make claims and defend against the claims made Contact/identification data; contract performance data; financial and payment data 10 years We process your existing data

If you do not provide your personal data necessary for the provision of services or the purchase of goods/services (for the conclusion of contracts), we will not be able to provide you with the services or purchase goods/services from you.

The storage of your personal data for a longer period than the one specified in the Privacy Policy is only possible under the following circumstances:

  • There are reasonable grounds for suspecting an illegal activity, which is under the investigation;
  • Your data is necessary for the proper resolution of a dispute or complaint;
  • For archiving purposes;
  • In the case of other special grounds, conditions or cases provided for in the legislation.

Sources from which your personal data is collected

We process your data received from:

  • Data provided by you when communicating with the Klaipeda FEZ, applying to us for information, conclusion of a contract, etc.;
  • Data generated while you are using our services and network (e.g., calling by phone, sending an email or visiting our website), etc.;
  • Data received from the third parties (e.g., state information systems, other persons).

Cases and third parties to whom your data is disclosed

We can transfer your data for the procession of third parties, who help us in carrying out our activities, i.e. data processors. Such persons may include website developers and administrators, suppliers and administrators of database software, providers of data centre, hosting and cloud services, companies creating, providing, supporting and developing software, companies providing information technology infrastructure services, companies providing communications or mail services, companies providing accounting, law, asset management services, etc. In every case, the data provided to a data processor is limited to the extent needed for the fulfilment of a specific assignment or provision of a specific service. Our contracted data processors can process your personal data exclusively according to our instructions. Besides, they must ensure your data security according to the effective legal acts and written agreements concluded with us.

We may transfer your personal data to auditors, banks, tax administrations, archives, dispute resolution bodies, public authorities when this is necessary for the performance of their functions, etc.

Our website uses Google Analytics service to collect data about how our visitors use our website.

The data collected by Google Analytics may include your Internet access IP address, the MAC address of your device, the date and time, duration of your visit to the website, the web pages you visit, the devices used to surf the web, applications, etc., site or application data, which has been granted access (proxy URL).

To protect from misuse, we may use the Google Invisible reCAPTCHA service, which collects information about hardware and software, for example, device and application data and the results of integrity checks, as well as unique web-based identifiers, for example, IP address, and then sends the collected data to Google for analysis.

By using this service, you agree to provide Google Analytics with your personal data for the purpose of integrity checks and implementation of the measures necessary for the safe use of the website.

Information controlled by GOOGLE IRELAND LIMITED (legal entity code: 477441, registered office address: GORDON HOUSE BARROW STREET, DUBLIN 4, Ireland) may be transferred or transmitted to the United States or other countries outside your country of residence or stored or processed for the purposes specified in the Privacy Policy of the Google Analytics.

To the best of our knowledge, Google has the standard terms and conditions for the transmission of data, as approved by the European Commission in its decisions on the transfer of data from the EEA to the United States and other countries.

Please find more information on Google Analytics and the information that these tools enable to collect here: https://support.google.com/analytics/answer/6004245?hl=lt.

If you don’t want Google Analytics tools to record information about your browsing, you can use the Google Analytics Opt-out Browser Add-on.

Territories and jurisdictions, in which we process your personal data

We process your personal data within the territory of the European Union.

Please be advised that certain technical details of your visit to the website (IP address, cookies, technical information on your browser, other information related to browser activity and website navigation) may be transferred or made available for statistical, analytical and related purposes both to the entities operating inside the European Economic Area and the ones operating outside. Please note that the personal data may be less protected in non-EEA countries than it is protected in EEA countries, though we will carefully evaluate the conditions under which such personal data will be subsequently processed and stored upon transfer to the above entities.

Data security

We process personal data in accordance with the requirements of data protection legislation, including the General Data Protection Regulation. We use various security assuring organisation and technical means to protect your personal information against unlawful access, use, destruction, disclosure or any other unlawful processing. Our chosen data processors are diligently selected, we demand application of adequate measures by them, which can protect your confidentiality and ensure security of your personal information. However, security of information disclosed on internet or by mobile communication cannot be ensured; any communication of information to us by above-mentioned modes is carried out at your own risk.

External websites

This website can contain links to external websites. When following such links to any website, please keep in mind that those websites and services accessible there have their own privacy policies and we do not take responsibility or obligations for their policies or for personal data collected in those websites or during the provision of services available there. Review privacy policies of those websites before providing personal data or using any services.

We use the Bentley tool for you to view the representative 3D model of the Klaipeda FEZ. In this case, the controller of your personal data is Bentley Systems International, address: Charlemont Exchange, 05 – 101, Charlemont Exchange, 42 Charlemont Street, Dublin 2, D02VN88, Ireland. You can read the Bentley’s Privacy Policy here: https://www.bentley.com/en/privacy-policy.

Social media

Klaipeda FEZ owns and administrates Facebook and LinkedIn social media accounts. Certain relationships with social media managers are covered by Article 26 (1) of the GDPR (Joint Controllers).

All information you provide to us through social media channels (including messages, use of the Like and Follow boxes, and other communications) is controlled by the social network manager.

We, as the administrators of Klaipeda FEZ Facebook and LinkedIn accounts, choose the relevant settings based on our target audience, our performance management and promotion goals. The manager of the social network, while providing the Klaipeda FEZ with the ability to create and manage an account on a social network, may limit the ability to change certain key settings and, thus, we have no influence on what information the social network manager will collect upon creation of Klaipeda FEZ account on the social network.

All such settings, whether selected by the Klaipeda FEZ or by the social network manager, may affect the processing of your personal data when using social media, visiting the account of Klaipeda FEZ or reading Klaipeda FEZ posts on the social media network. Even if you only look at our posts on social media, the social network manager may receive certain personal information, for example, information on what device you use and what your IP address is.

Usually, your personal data (even if it is collected through our additionally selected account settings) will be processed by the social network manager for the purposes set by the social network manager in accordance with the social network manager’s privacy policy. However, when you use the social network, communicate with Klaipeda FEZ through the social network, visit the account of Klaipeda FEZ on the social network or follow the posts on its social network, the Klaipeda FEZ receives information about you. The amount of data we receive depends on the account settings we choose, the agreements we have with the social network manager for the additional services, and the cookies set by the social network manager.

We note that the data collected by Facebook and LinkedIn are shared globally between Facebook companies and partners, as well as LinkedIn companies and partners.

Information controlled by Facebook Ireland Limited (legal entity code: 462932, registered office address: 4 Grand Canal Square Grand Canal Harbour Dublin 2, Ireland) may be transferred or transmitted to the United States or other countries outside your country of residence or stored or processed for the purposes specified in the Privacy Policy of the Facebook.

To the best of our knowledge, Facebook has the standard terms and conditions for the transmission of data, as approved by the European Commission in its decisions on the transfer of data from the EEA to the United States and other countries.

The Facebook social network manager collects information about the types of content you see, what you do on Facebook, who you interact with, how often and for how long you interact with them, social network activity and other information, including information about the device you use. For more information on the Facebook manager’s social security policy, click here https://www.facebook.com/policy.php.

Information controlled by LinkedIn Ireland Unlimited Company (legal entity code: 477441, registered office address: 70 Sir John Rogerson’s Quay, Dublin 2, Ireland) may be transferred or transmitted to the United States or other countries outside your country of residence or stored or processed for the purposes specified in the Privacy Policy of the Facebook.

To the best of our knowledge, LinkedIn has the standard terms and conditions for the transmission of data, as approved by the European Commission in its decisions on the transfer of data from the EEA to the United States and other countries.

The LinkedIn social network manager collects information about what type of content you see, what you do on LinkedIn, information about your education, who you interact with and other information. For more information on the LinkedIn manager’s social security policy, click here https://www.linkedin.com/legal/privacy-policy.

We recommend to read third-party privacy notices and contact service providers directly if you have any questions about how they use your personal data.

Rights granted to you by the data protection legislation

Personal data protection legislation grants many rights to you which you can freely exercise while we have to ensure such possibility for you. Information about specific your rights and how they can be exercised is provided in this section of the Privacy Policy, therefore, please read it carefully.

The right to access your personal data that we process

You have the right to receive our confirmation whether we process your personal data and the right to access your personal data processed by us and information about the purposes of data processing, categories of processed data, categories of data recipients, period of data processing.

The major part of this information is provided to you in this Privacy Policy and we believe you will find it useful.

The right to rectify your personal data

If there are changes in the personal data that you have provided to us or you believe that our processed information about you is inaccurate or false, you have the right to request for modification, specification or rectification of the information.

The right to revoke the consent

When we process your data on the basis of your consent, you have the right to revoke your consent at any time and the data processing on the basis of your consent will be terminated.

The right to disagree to data processing, when processing is based on the legitimate interests

You have the right to disagree to personal data processing, when personal data is processed on the basis of our legitimate interests.

The right to make a complaint

If you believe that we process your data in breach of the requirements established by data protection legislation, you are kindly requested to apply directly to us, first. We believe that we will manage to dispel all your doubts with our well-intentioned efforts, to satisfy your requests and to correct our mistakes, if any.

If you are not satisfied with our proposed settlement of an issue or you think we failed to take necessary actions under your request, you have the right to submit a complaint to the supervising institution, which in the Republic of Lithuania is the State Data Protection Inspectorate (for more information visit: www.ada.lt).

The right to erasure (‘the right to be forgotten’)

Under certain circumstances named in the data processing legislation (when personal data is processed unlawfully, basis for data processing ceased to exist, etc.), you have the right to request for erasure of your personal data. In order to exercise this right, you are kindly requested to submit a written request.

The right to restrict the processing

Under certain circumstances named in the data processing legislation (when personal data is processed unlawfully, you contested accuracy of data, you submitted an objection to data processing on the basis of our legitimate interest, etc.), you also have the right to restrict your personal data processing.

The right to data portability

You have the right to move to the other data controller the data that we process on the basis of your consent or agreement concluded with you and processing of which is carried out by applying automated means. The data that you have requested to be moved will be provided to you in the format that is usually used in our systems and readable by computer and, upon your request and if technical possibilities permit, we will forward the data directly to the other data controller named by you.

To exercise the rights specified in this section of the Privacy Policy, you are kindly requested to submit a written request.

Request examination procedure

To protect your and other persons’ data from unlawful disclosure, upon your request to provide data or exercise your other rights, we will have to verify your identity. For this purpose, you may be requested to give your name, surname, email address, phone number or other data and we will check if your provided data is identical to the respective data held by us. If this verification procedure fails, (e.g., your provided data differs from the data held by us), we will have to declare that you are not a proper data subject and will have to reject your request. In such event, you may visit the office of the Klaipeda FEZ and, upon presentation of an identification document, submit your request in writing.

Upon receipt of your request to exercise any of your rights and if the above-mentioned verification procedure has been successful, we assume an obligation, without any unreasonably delay, but in no event later than within one month from the day of receipt of your request and completion of verification procedure, to provide you with the information about the actions taken by us under your request. Giving the complexity and number of requests, we have the right to extend one month’s period for two additional months by giving you a notice before the end of the first month and specifying the reasons for such extension.

If your request is submitted via electronic means, our reply will be sent also by electronic means, unless it is impossible (e.g., because of too big volume of information) or if you request for reply by any other means.

We will reject your request with a reasoned reply once the circumstances set forth in legal acts are established, by informing you in writing.

Other provisions

This Privacy Policy can be updated at any time. The date of the last amendment: 28 June 2021.

Information notice regarding the processing of your personal data (for customers)

To ensure the protection of your personal data that we process under Article 13 of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation), we hereby inform that:

1. Your personal data is processed according to the following conditions:

Purpose Base Categories of personal data Storage term Necessity to provide data
Provision/administration of services – Legitimate interest of the Company to ensure the provision of services, performance of the contract, to offer similar services;
– Contract
Contact and identification data, position 3 years after the end of the contract Is not necessary
Informal communication Consent Contact and identification data, position, date of birth During the validity term of the consent Is not necessary
Publicity of the Company’s activities/marketing Consent Contact and identification data, image During the validity term of the consent Is not necessary
Accounting, auditing; storage of necessary documents – Legislation;
– Legitimate interest of the Company in accounting of the transactions
Data in the documentation 10 years after the economic transaction;
or for the time limits laid down in the Index for Time Limits for Storage of General Documents, approved by Order No. V-100 of 9 March 2011 of the Chief Archivist of Lithuania 
We process your existing data
Protection of the Company’s legitimate interests Legitimate interest of the Company (to make claims and defend against the claims made) Contact and identification data, data related to the dispute 10 years We process your existing data

2. If you do not provide your personal data, we will not be able to enter into/execute a contract with you.
3. Your personal data may be transferred to the following recipients: banks, the State Tax Inspectorate, dispute resolution bodies, bailiffs, auditors, lawyers, tax administrations, experts, information system owners/administrators, accounting service providers, legal service providers, courier/postal service providers, archives, asset management service providers, information systems owners/administrators.
4. We do not use the automated decision-making for processing of your personal data.
5. We do not intend to transfer your personal data to any third country or international organisation.

The controller of your personal data is Joint Stock Company Klaipeda Free Economic Zone Management Company, legal entity code: 110707092, registered office: Pramones Str. 8, Klaipeda, telephone: +370 46 31 21 63, email: [email protected], [email protected].

YOUR RIGHTS:

You have the right to make a reasoned request to us regarding:

  • Information and access to your personal data that we process;
  • Rectification of your personal data;
  • Erasure of your personal data;
  • Restriction of processing of your personal data;
  • Submission of your personal data in a structured, computer-readable format;
  • Your refusal to process your personal data (if the processing is based on a legitimate interest).

If the legal basis for our processing of your personal data is your consent, you have the right to withdraw that consent and our right to process your personal data for the purpose specified in the consent at any time by informing us at the following email addresses: [email protected], [email protected].

Your requests must include: information that would allow us to identify you as a data subject; actions requested; personal data in respect of which such actions are requested. We will process your request within 30 (thirty) days of receiving it and inform you of the actions taken in response to the request received. Only reasonable requests will be executed. You will be informed in the same form in which the request was made.

If you believe that your rights in relation to the processing of your personal data by us have been violated, you have the right to apply to the supervisory authority: the State Data Protection Inspectorate; company code: 188607912, address: A. Juozapaviciaus Str. 6, 09310 Vilnius; tel.: +370 5 271 2804, +370 5 279 1445; fax.: +370 5 261 9494; email: [email protected]

Information notice regarding the processing of your personal data (for suppliers)

To ensure the protection of your personal data that we process under Article 13 of the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation), we hereby inform that:

1. Your personal data is processed according to the following conditions:

Purpose Base Categories of personal data Storage term Necessity to provide data
Purchase of goods/services administration – Legitimate interest of the Company to administer the purchases of goods/services;
– Contract
Contact and identification data, position 3 years after the end of the contract Is not necessary
Accounting, auditing; storage of necessary documents – Legislation;
– Legitimate interest of the Company in accounting of the transactions
Data in the documentation 10 years after the economic transaction
or for the time limits laid down in the Index for Time Limits for Storage of General Documents, approved by the Order No. V-100 of 9 March 2011 of the Chief Archivist of Lithuania 
We process your existing data
Protection of the Company’s legitimate interests Legitimate interest of the Company (to make claims and defend against the claims made) Contact and identification data, data related to the dispute 10 years We process your existing data

2. If you do not provide your personal data, we will not be able to enter into/execute a contract with you.
3. Your personal data may be transferred to the following recipients: banks, the State Tax Inspectorate, dispute resolution bodies, bailiffs, auditors, lawyers, tax administrations, experts, information system owners/administrators, accounting service providers, legal service providers, courier/postal service providers, archives, asset management service providers, information systems owners/administrators.
4. We do not use the automated decision-making for processing of your personal data.
5. We do not intend to transfer your personal data to any third country or international organisation.

The controller of your personal data is Joint Stock Company Klaipeda Free Economic Zone Management Company, legal entity code: 110707092, registered office: Pramones Str. 8, Klaipeda, telephone: +370 46 31 21 63, email: [email protected], [email protected].

YOUR RIGHTS:

You have the right to make a reasoned request to us regarding:

  • Information and access to your personal data that we process;
  • Rectification of your personal data;
  • Erasure of your personal data;
  • Restriction of processing of your personal data;
  • Submission of your personal data in a structured, computer-readable format;
  • Your refusal to process your personal data (if the processing is based on a legitimate interest).

If the legal basis for our processing of your personal data is your consent, you have the right to withdraw that consent and our right to process your personal data for the purpose specified in the consent at any time by informing us at the following email addresses: [email protected], [email protected].

Your requests must include: information that would allow us to identify you as a data subject; actions requested; personal data in respect of which such actions are requested. We will process your request within 30 (thirty) days of receiving it and inform you of the actions taken in response to the request received. Only reasonable requests will be executed. You will be informed in the same form in which the request was made.

If you believe that your rights in relation to the processing of your personal data by us have been violated, you have the right to apply to the supervisory authority: the State Data Protection Inspectorate; legal entity code: 188607912; address: A. Juozapaviciaus Str. 6, 09310 Vilnius; tel.: +370 5 271 2804, +370 5 279 1445; fax.: +370 5 261 9494; email: [email protected]

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