Privacy Policy

This Privacy Policy is prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and in accordance with data processing practices of the Lithuanian Free Market Institute (hereinafter – LFMI) with regard to cooperation with shareholders, clients and third persons. Any questions relating to this Privacy Policy shall be addressed to LFMI by email LLRI@LLRI.LT

In processing personal data, LFMI complies with the requirements of General Data Protection Regulation (hereinafter – GDPR). LFMI acknowledges the importance of the protection of personal data and is committed to respect and ensure the privacy of every data subject. Data subjects entrust LFMI with their personal data and we are committed to act in a way to justify their confidence.

Definitions

‘Personal data’ means any information relating to a natural person (‘data subject’) who is identified or can be identified directly or indirectly by reference to respective data.

‘Anonymised data’ means any information no longer relating to a natural person because all identifiable information has been removed from the data set.

‘LFMI’ means the Lithuanian Free Market Institute, public institution, company code 110059496, 6 Juozapavičiaus str., LT-09310 Vilnius.

Legal basis for processing personal data

The processing of personal data by LFMI is conditioned upon a sufficient legal basis. The activities of LFMI imply that in most cases personal data will be processed on the basis of the consent of the person concerned.

On the basis of the consent of the person: e.g. LFMI processes personal data provided by the person concerned when no contract is concluded or the personal data provided is not necessary for the execution of the contract, but is relevant for other purposes and the person concerned has given his consent.

For the purposes of carrying out obligations established by law: e.g. LFMI is an employer subject to specific requirements and obligations, including on the provision of personal data, established by employment legislation and other legal acts. LFMI may provide personal data to state authorities, including, but not limited to, the State Tax Inspectorate, the State Social Insurance Board, Statistics Lithuania, etc. The above list should not be considered exhaustive as it may change in accordance with changes in the legislative framework.

For the execution of contracts: in implementing its activities, LFMI concludes contracts with natural and legal persons and processes related personal data to the extent necessary to ensure the execution of those contracts for no longer than the term of those contracts.

For other grounds provided for by GDPR: in each individual case, LFMI will indicate in the consent, contract or any other document to the data subject, to his or her representative or to a third person (who is entitled to receive such information) the legal basis for processing personal data.

Data subjects who find that their personal data is being processed by LFMI on a wrong basis shall immediately inform LFMI. Upon request of the data subject, LFMI shall destroy all personal data collected on a wrong basis. In order to maintain business relationship in such cases, LFMI shall request data subjects to re-submit their personal data or give appropriate consent to further processing of his or her personal data.

Your consent

By accepting this Privacy Policy, you agree (hereinafter – Consent) that:

– we collect, store and process the following data about you: full name, contact details (phone number, email address, employer’s address) and information on the activities of LFMI that are relevant to you;

– we use your data for the following correspondence (hereinafter – Correspondence): in order to inform you about LFMI’s work and share LFMI’s insights on economic policy and/or information on ways to support LFMI and its projects;

– we use your data for profiling in order to analyse the relevance of Correspondence that we sent you (the analysis of newsletter statistics and the registration of relevant economic topics in an internal database);

– in accordance with the decision of LFMI and the Law on the Protection of Personal Data of the Republic of Lithuania, your personal data may be temporarily made available to third persons (hereinafter – Partners) who provide programming, marketing and other related services to LFMI in order to ensure timely and targeted Correspondence with you and secure processing of personal data.

The collection, processing and use of personal data

Data collection methods and data sources

LFMI collects and processes data provided by the data subjects themselves, other data controllers or processors who have the right to transfer personal data under GDPR or other legal acts (including contracts), public sources or data that is made public by the data subjects themselves. LFMI processes data in accordance with its activities and objectives. You may decide not provide your personal data to LFMI; in such cases LFMI will be unable to establish business relations with you or provide services to you.

Guiding principles for processing personal data

  1. Data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness and transparency principle)
  2. Data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those (the purpose limitation principle);
  3. Data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (the principle of data minimisation);
  4. Data shall be accurate and, where necessary, kept up to date (the principle of accuracy);
  5. Data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods (the storage limitation principle);
  6. Data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (the integrity and confidentiality principle)

Data collection methods:

  • From registration forms and statistical information generated by LFMI’s websites and newsletter platforms;
  • From execution of contractual obligations in cases when the provision of personal data is required by law in order to conclude transactions (the provision of support and services);
  • Upon the submission of personal data via email, phone or during events and meetings by the data subjects themselves or upon the consent of the data subjects;
  • Solely from publicly available sources (Creditinfo, media, websites of the data subjects),
  • From employment or service contracts between LFMI and its employees or service providers.

 Aims of data collection, processing, and use:

  • to duly fulfil LFMI’s contractual obligations;
  • to implement targeted Correspondence with regard to your interests and to inform you about LFMI’s work, economic policy environment and ways to support LFMI and its projects;
  • to improve technical capability to send Correspondence to you;
  • to fulfil LFMI’s obligations as an employer to public authorities and employees;
  • to conduct research solely based on anonymised data.

If you are visiting our websites, we also collect information about the use of our services and automatically generated statistics. You may read more about this below – Use of Cookies.

LFMI collects and uses IP addresses in technical and content management and diagnostics of its websites.

LFMI may also use aggregate data (without the possibility of identifying specific users):

  • for the evaluation of customer‘s behavior;
  • in cooperation with marketing partners;
  • in website audit.

LFMI undertakes not to publicize or transfer personal data to any third parties, except in the following cases:

  • upon your consent;
  • when your personal data is temporarily made available to our Partners for the abovementioned purposes;
  • when your personal data is provided to law enforcement authorities according to the procedures established by laws of the Republic of Lithuania.

How long do we keep your personal data for?

Your personal data are kept for no longer than is necessary for the purposes for which the personal data are processed or for longer periods insofar as it is provided for by law.

We seek not to store outdated or unnecessary information and to ensure that your personal data and other information about you are up to date and correct.

Data processors

Personal data are processed in LFMI’s internal databases, website and external newsletter platform.

Personal data may only be processed by specifically authorised staff and Partners who provide marketing, programming and IT maintenance, hosting, data centre and/or server services, and external audit services to LFMI.

Data processors may only process personal data as instructed by LFMI and only to the extent that it is necessary to duly fulfil their contractual obligations to LFMI. LFMI seeks to ensure that Partners have taken the necessary organizational and technical measures to guarantee the security and secrecy of personal data.

Data security

LFMI uses security systems and technical and physical measures that restrict access to and use of personal data stored in LFMI’s servers in order to secure and defend personal data entrusted by the data subjects.

Only specifically authorised staff and Partners have the right to process personal data of the data subjects solely for purposes established by LFMI and in accordance with GDPR.

Staff members of LFMI are made aware of the internal data processing regulations and relevant laws of the Republic of Lithuania. Partners shall sign data processing and provision and/or confidentiality agreement.

Rights of the data subject

Data subjects have the right:

  • to request LFMI to provide all information about the processing of their personal data;
  • to request LFMI to correct their personal data and/or stop the processing of personal data, except for data retention, when the data subject becomes aware that the data are incorrect, incomplete or inaccurate;
  • to request LFMI to destroy personal data or stop the processing of personal data when the data subject becomes aware that the data are processed illegally or unfairly or expresses his or her will to withdraw his or her consent to processing of personal data;
  • not to agree to the processing of personal data when personal data are processed or intended to be processed for direct marketing purposes or other legitimate needs of LFMI or third persons;
  • to request LFMI to stop sending Correspondence.

Any request or requirement relating to the processing of personal data shall be submitted to LFMI in writing by:

  • serving the request or requirement at LFMI’s office (6 Juozapavičiaus str., 09312 Vilnius, Lithuania);
  • sending the request or requirement by email LLRI@LLRI.LT from an email address previously provided to LFMI;
  • clicking on specific links in LFMI’s Correspondence, including ‘stop receiving newsletters’, ‘manage my subscriptions’, or ‘delete my data’.

LFMI will respond to your request or requirement and take necessary actions within 30 calendar days from the receipt of your submission. Upon your request, LFMI will provide a response in writing via email.

In case of a failure to solve any issues pertaining to collection, processing and use of personal data, the data subjects shall have the right to apply to the State Data Protection Inspectorate.

Use of cookies

We use cookies in our websites to improve user experience and ensure certain the functioning of certain features of our websites. The information collected through the use of cookies is used for the following purposes:

  • To ensure the functioning of our website. Functional cookies are essential to the work of certain features of our websites and the way users are able to enjoy our services. For example, these cookies allow our websites to remember choices you make and information you enter to give you better functionality by pre-filling your data such as your name or password.
  • To improve our services. The use of cookies helps us to improve the functioning of our website and electronic services. Cookies allow us to collect information on the most popular pages of our websites, get information about referrals to our websites, and record how much time users spend browsing our websites.
  • To collect statistical data. We use cookies to collect statistical data about the number of users of our websites and the use of our online services. We may use cookies to collect marketing information about our emails and newsletters, for example, cookies allow us to track if the recipient has opened our emails and newsletters and if he or she has clicked on any hyperlink provided in those emails or newsletters.
  • To implement targeted campaigns. We use cookies to collect information about the users of our website, divide them into groups and show personalized ads and content to those groups.

Cookies are small pieces of data sent from a website and stored on the user’s computer or mobile device. Cookies are used to ensure the effective functioning of our websites and to collect information needed to improve our services and user experience in the future.

We use cookies on LFMI’s websites in order to track the number of visitors and identify their interests. Our goal is to better understand which information is relevant to the visitors of our websites and to minimise the amount of irrelevant information on our websites.

Cookies may also collect anonymous information about the websites you visit. This helps us to identify the information that is most relevant to the visitors of our websites.

Cookies are also used to make sure you do not see the same ads too often and help to track the effectiveness of informational and promotional campaigns.

Most browsers are set to accept cookies automatically. You may choose not to accept cookies by changing your cookie settings, but some essential features of our websites may not work without cookies.

For more information about the use of cookies, please visit http://www.allaboutcookies.org or http://www.aboutcookies.org, where you will find detailed independent information about how to deactivate cookies in your browser and delete the existing cookies from your system. Please refer to your user manual to remove cookies from your mobile phone.

To opt-out from the processing of information by Google Analytics please visit http://tools.google.com/dlpage/gaoptout.