1. While visiting real estate projects developed by RECUS or its affiliates on websites;
2. While visiting RECUS or its affiliated companies or real estate projects on its social network accounts (Facebook, Instagram, LinkedIn);
3. While sending inquiries for RECUS or its affiliates (via email, social networks, on-line inquiry form);
4. By submitting your information to the representatives of RECUS or its affiliates in other ways (during meetings, events, etc.).
1. TERMS USED IN PRIVACY P OLITICS
1.3. Data controller – RECUS group companies: UAB “Recus”, legal entity code 303271807, registered office address Tuskulenu g. 33C-41, Vilnius, e-mail: firstname.lastname@example.org; tel. no. +370 5 250 7471.
1.4. Customer (Data Subject) means a natural person whose personal data are managed by the Data Controller.
1.5. Personal data – means any action performed on personal data: collection, recording, storing, classifying, grouping, merging, modifying (supplementing or correcting), rendering, publishing, using, logical and / or arithmetic operations, searching, dissemination, destruction or other action or set of actions.
1.6. Data Processing – any action on personal data: collection, recording, storage, modification (addition or correction), provision, use, destruction or other action or set of actions.
1.7. Consent is any freely given, specific and unambiguous expression of a well-informed will of the Data Subject in a statement or unambiguous action by which he/she agrees to the processing of the Personal Data relating to him/her.
1.8. Third parties – a natural or legal person, public authority, agency or other body which is not a data subject, controller, processor or authorized to process personal data under the direct authority of the controller or processor;
1.9. Cookies are a small volume of data that is transmitted from a website and stored on a visitor’s computer or other device.
2. GENERAL PROVISIONS
2.2. Purpose of processing personal data:
2.2.1. in order to provide the Clients with relevant information about the Data Controller’s project, when the Customer EXPRESSES THEIR NEED BY COMPLETING A REQUEST OR CONTACTS BY OTHER MEANS WITH THE DATA CONTROLLER;
2.2.2. to ensure a comfortable and smooth use of the Website;
2.3. The Data Controller, through organizational and technical measures, ensures the proper security of Personal Data, including protection from the processing of Personal Data without permission or unlawful processing of Personal Data, and from accidental loss, destruction, or damage.
2.4.1. The Data Subject’s Personal Data shall be collected for specified and legitimate purposes, established by law, and processed in a manner consistent with these purposes;
2.4.2. The Data Subject’s Personal Data are collected and processed in accordance with the principles of expediency and proportionality, and does not require the Data Subject to provide any Personal Data that is not necessary. No excess personal data is collected and processed;
2.4.3. The Data Subject’s Personal Data is processed accurately, fairly and lawfully;
2.4.4. The Data Subject’s Personal Data must be accurate and, if necessary, kept up to date on the processing of Personal Data; inaccurate or incomplete Personal Data are corrected, supplemented, destroyed or suspended;
2.4.5. The Data Subject’s Personal Data shall be kept in a form which permits identification of the Data Subject for no longer than is necessary for the purposes for which the Personal Data were collected and processed.
2.6. The Data Controller collects, uses, and stores Client’s Personal Data on the following legal grounds:
2.6.1. Consent given by the Client;
2.6.2. Execution of a Client Agreement;
2.6.3. Compliance with legal requirements;
To ensure the legitimate interests of the Data Controller and to ensure the quality of the services.
3. WHAT KIND OF DATA THE DATA CONTROLLER (PERSONAL DATA) COLLECTS, USES AND STORES
3.1. When the Client uses the Website:
3.1.1. Internet Protocol address (IP);
3.1.2. information about the device:
3.1.3. login information;
3.1.4. Website browsing features.
3.2. When the Client sends an inquiry to the Data Controller:
3.2.1. Name and surname;
3.2.2. E-mail address;
3.2.3. Telephone number;
3.2.4. The topic of inquiry;
3.2.5. The date of the inquiry;
3.2.6. Content of the inquiry;
3.2.7. Files attached to the inquiry;
3.2.8. Answer to the Client’s inquiry;
3.2.9. Other information provided by the Clients themselves.
3.3. Upon request, the Data Controller may request the Client to provide additional information in order to respond appropriately to the Client’s question.
3.4. All information provided by the Customer via social media – Facebook, Instagram, LinkedIn (including notifications, use of “Like” and “Follow” fields, and other communications) is controlled by the social network manager. The Data Controller recommends that you familiarize yourself with third-party privacy policies and contact your service providers directly if you have any questions.
4. PROCEDURE FOR USING COOKIES
4.1. Website cookies are used for:
4.1.1. for statistical purposes, evaluating site traffic and popularity of individual content;
4.1.2. to ensure proper functionality of the Website;
4.2. The following types of cookies are used on the website:
4.2.1. User session Cookies – created by a user after a browsing session on a website or browser. Deleted when the browser is closed;
4.2.2. Long-term cookies – cookies are stored on the device used by the user. Cookies are not deleted when you close your browser or website. These cookies are valid for a different time depending on the cookie itself;
4.2.3. Primary cookies – cookies used or created by a website visited by a user. These cookies are used to adapt to the needs of the visitor;
4.2.4. Third Party Cookies – Cookies from other websites hosted by the user. This type of cookies are usually used for data analysis purposes. Facebook and Google are the most commonly used third-party cookie domains.
4.3. The Website visitor (Client) can delete cookies from their computer or block them from their web browser, but blocking cookies can stop user access to certain features of the website and their performance, which may result in inefficient or impossible browsing.
5. TO WHOM DATA CONTROLLER TRANSFERS CLIENT’S PERSONAL DATA
5.1. When providing services, the Data Controller uses the services of certain third parties, so the Client’s Personal Data may be provided in certain cases:
5.1.1. for companies that provide services to the Data Controller (IT companies, etc.);
5.1.2. for legal entities associated with the Data Controller
5.2. For third parties the Client’s Personal Data shall be provided only to the extent necessary to ensure the proper provision of such third party services to the Data Controller.
6. TERMS OF STORING THE CLIENT’S PERSONAL DATA
7. CLIENT RIGHTS
7.1. The Client has the following rights:
7.1.1. Make a request for access to information held by the Data Controller about the Client;
7.1.2. Submit a request to correct available information about the Client;
7.1.3. Submit a request to delete the existing information about the Client;
7.1.4. Submit a request to restrict access to or deletion of information held by the Data Controller about the Client;
7.1.5. Submit a request to export Client’s Personal Data or transfer it to another Data Controller;
7.1.6. Submit a complaint to the State Data Protection Inspectorate.
7.2. The Data Controller may not create conditions for the Client to enforce the above-mentioned rights when, in the cases provided for by law, it is necessary to ensure the prevention, investigation and detection of crimes, official or professional ethics violations, as well as the protection of the rights and freedoms of the Client or other persons.
8. PERSONAL DATA PROTECTION RISK FACTORS AND THEIR SOLUTION
8.1. In order to ensure the proper protection of Personal Data, the Data Controller implements the following Organizational and Technical Data Protection Measures:
8.1.1. The Data Controller shall organize the workflow in such a way as to ensure the secure handling and / or transmission of computer data and / or documents and their archives;
8.1.2. Access to the Data Subject’s Personal Data is only provided to those employees who need it to perform the job functions and only those who have signed confidentiality agreements and are familiar with other internal procedures within the scope of Personal Data Processing.
8.1.3. Data Managers (Service Providers) appointed by the Data Controller only act under the authority of the Data Controller.
8.1.4. Personal data is protected against loss, unauthorized use, and changes.
8.1.5. computer hardware protection from malicious software (such as installing, updating antivirus programs) and internal computer network firewall is ensured.
9. FINAL PROVISIONS