PERSONAL DATA PROCESSING POLICY

PRIVACY POLICY

This Privacy Policy intends to inform you how we („Mokesčių srautas“) collect, use and share your personal data, provided by you or otherwise collected by us. Therefore we want to ensure the fair and transparent collection and use of information about you.

We aim to provide you with detailed information about the processing of your personal data and your  rights as the data subject, whether you provide personal data by contacting us by phone, in person, during events or by electronic means (e.g. using the website), or in any other way you choose, including when we receive your personal data from third parties.

Your personal data is processed in accordance with Regulation (EU) 2016/679, the Law on the Legal Protection of Personal Data of the Republic of Lithuania, as well as other legal acts.

KEY TERMS USED IN THE PRIVACY POLICY

Personal data – any information relating to an individual whose identity is known or can be directly or indirectly established through the use of personal data, such as name, surname, personal identification number, address, e-mail address, internet identifier and other.

Data subject – training attendee, lecturer, individual who submitted the request, individual or a representative (or an employee) of a legal entity who signed the agreement with „Mokesčių Srautas“ and (or) executes this agreement, an individual using the website, or any other individual whose identity is known or can be determined either directly or indirectly through the use of personal data.

Data subject consent – any voluntary, specific and unambiguous expression of a will of a duly informed data subject, in the form of a statement or unequivocal act by which the subject gives consent to the processing of their personal data.

Processing – any action or set of actions taken on personal data (including collection, recording, use, access, storage, disclosure and other).

Data controller – „Mokesčių Srautas“, a private limited liability company established and operating in accordance with the legal acts of the Republic of Lithuania. Company code – 124388313, registered office address – Sėlių st. 33, Vilnius. E-mail address for questions about personal data protection and this Privacy Policy – ada@countline.lt.

FOR WHAT PURPOSES AND LEGAL grounds DOES „MOKESČIŲ SRAUTAS“ COLLECT AND PROCESS YOUR PERSONAL DATA?

„Mokesčių srautas“ collects and processes your personal data for the following purposes:

In order to ensure communication with our potential and existing service providers, business partners, to conclude and execute contracts we process personal data of said service providers, business partners (legal entities) employees and representatives (name, surname, name of the legal entity, position, address, telephone number, e-mail address, correspondence content, other necessary data), and service providers, business partners (legal entities) personal data (name, surname, individual activity certificate data, address, telephone number, e-mail address, contract terms, other necessary data). Personal data is processed for the legitimate interests of ours to carry out economic/commercial activities and for the conclusion and execution of a contract to which the data subject is a party.

For the intention of providing training services (organization of training; registration to a training and confirmation of the registration; creating terms for participation in a training; providing information about the date, time, location change or cancellation of the training; issuing training certificates and other) we process personal data of the attendees (including name, surname, workplace (if the data subject is sent to the training by an employer, or indicates it himself), information about the training (topic, date, time, duration, location, lecturer leading the training), telephone number, e-mail address, IP address and login details (when services are ordered through the website), video and audio data of lecturers and training attendees (when training is remote), other necessary data. When training attendee (individual (person) purchasing training services individually) chooses to pay after training has taken place, date of birth and address data is processed. Personal data is processed on the basis of consent or the conclusion and execution of a contract.

For the purpose of conclusion and execution of a training services contract, issue of invoice, for accounting purposes we process name, surname, address, telephone number, e-mail address, contract terms, information about execution of the contract, information about the training (topic, date, duration, lecturer), invoice details, information about payment, other necessary data. This personal data is processed for the purpose of the contract conclusion and execution, and in order to fullfil legal obligations.

With the aim of administering inquires we receive through the website and (or) e-mail, we process personal data of the contact person, including  e-mail address, telephone number, IP address, message content, any other provided data, response content, other information related to the response. Personal data is processed with the consent of the individual.

For the purpose of direct marketing (so that we can inform you about the services we provide, products and services we offer, promotions and special offers, to request your feedback about organized events and other, both electronically and by registered and standard mail) we process your name, surname, address, telephone number , e-mail address, workplace. After receiving your consent, we will also provide you with notifications via pop-ups on the device you are using (e.g. computer, telephone and other). By giving consent to use your personal data for direct marketing purposes, you agree to receive offers from „Mokesčių srautas“ and our partners („Buhalterių mokymai“, „Profesionalams“). You can withdraw your consent for the processing of your personal data any time by contacting us by e-mail ada@countline.lt, as well as by clicking the appropriate link in every e-mail you receive or following the link regarding consent withdrawal on our website www.countline.lt The withdrawal of consent does not affect the processing of data prior to the withdrawal.

Please be informed that in the case you are our client (if you previously participated in events organized by „Mokesčių srautas“, registered to attend events, you have concluded a contract to receive training services, etc.) we will process your e-mail address for direct marketing purposes without separate consent, in accordance with Article 81 (2) of the Republic of Lithuania Law on Electronic Communications.

In an effort of legitimate interest to implement the mentioned provision of the said law, we will process and analyze the data about the services and products you purchase, but this will not have legal consequences or a similarly significant impact on you.

If you do not consent to such processing of your personal data, you can object at any time by contactacting us by using contacts details provided in this Privacy Policy.

In order to ensure the quality of our customer service, we record telephone conversations and process voice data. Personal data is processed with the consent of the data subject (the person who calls the general „Mokesčių srautas“ telephone number (8 5) 263 99 22, every day from 9 am to 9 pm; and the person whom our employees call).

For the purpose of „Mokesčių srautas“ and informing the public about its activities, we process the personal data of lecturers (name; surname; workplace; position; titles of trainings, seminars and other data relating to them; education, job experience, publications and other data relating to professional experience; photo data; video data). Personal data is processed with the person‘s consent or in an effort of a legitimate interest of „Mokesčių srautas“ to inform the public about its activities, considering the processed personal data is necessary to achieve the mentioned interest and is relating to the data subject‘s (professional) work or economic/commercial activities, or data subject is a public figure, therefore the rights and interests of data subject are not more imporatant than „Mokesčių srautas“ interests.

In order to ensure the security of property and people, at the entrance to our premises and the premises themselves, we use video surveillance to monitor and process the video data of the individuals entering the area of video surveillance. Personal video data is processed in order to ensure the legitimate interests of „Mokesčių srautas“ – the security of the company’s property and the security of individuals, considering that the processed personal data is necessary to achieve the mentioned interests, and the interests of data subjects are not more important.

In an effort to ensure the functionality and efficiency, ease of use, speed and security of the website and other purposes, we process personal data collected with the help of cookies. Detailed information about the use of cookies is provided in the section „Why and what cookies we use“ below. Personal data is processed on the basis of consent and in accordance with the Republic of Lithuania Law on Electronic Communications.

„Mokesčių srautas“ may also process personal data for other purposes to the extent necessary to carry out its activities lawfully, complying with legal requirements, to defend against claims, lawsuits and to protect our legitimate interests. Personal data is processed in accordance with the requirements of the Regulation and other legal act requirements.

When collecting personal data, we provide you with information about which data is mandatory, i.e. without which we will not be able to provide your chosen services or achieve other established personal data processing purposes. In some cases, we provide you with the opportunity to provide optional personal data, which contribute to a better quality of services for you (e.g. data on the current job positions of seminar attendees will help the lecturer to better adapt the content of the seminar, etc.).

IMPORTANT: By providing us with personal data of other individuals (e.g. your employees attending our organized trainings, etc.), you commit to ensure the lawfulness of the data provision (obtain the consent from these individuals, etc.) and provide these individuals with information on where and how they can access with this Privacy Policy.

TO WHOM CAN YOUR PERSONAL INFORMATION BE PROVIDED?

“Mokesčių srautas“ is obliged to comply with confidentiality requirements when processing personal data. Personal data shall be provided to third parties only in accordance with the legal basis for the provision of personal data and after assessing the purpose of the provision of personal data, and the scope of the personal data provided. We may disclose your personal information to the following data recipients:

  • The State Tax Inspectorate, other state institutions, when we are obliged to disclose the data in accordance to legal acts or at your request.
  • „Mokesčių srautas“ service providers (data processors), who provide accounting, document archiving, audit, consulting, training organization, property maintenance and servicing, hardware and software development, maintenance and upkeep, direct marketing messaging, data centers, cloud, communication, website administration and other services, to whom personal data or access to it is given.
  • Personal data may be provided to courts, law enforcement authorities, state institutions conducting inspections of the company’s activities, other third parties in connection with the sale, merger, purchase or reorganization of all or part of the business, or to protect the rights and legitimate interests of „Mokesčių srautas“.

Personal data may be disclosed to other third parties in accordance with Regulation (EU) 2016/679 and other legal acts, to whom we are obliged to provide personal data by law or other legal acts.

We may transfer personal data to third countries on the basis of the decision of the European Commission on the adequate level of protection, with standard data protection conditions approved by the European Commission or data protection supervisory authorities, or following at least one of the conditions set out in Article 49 (1) of the Regulation, if it is not possible to rely on the above mentioned decisions of the European Commission or data protection supervisory authorities. We may provide personal information to data recipients established in the United States who are required to comply with the requirements of the Privacy Shield.

HOW LONG AND HOW WILL YOUR PERSONAL DATA BE STORED?

The collected personal data is stored in printed documents and in our information systems. Personal data shall be stored for as long as it is necessary for the established purposes or within the time limits established in the legal acts of the Republic of Lithuania regulating the terms and procedures of data storage.

We store your personal data:

  • for the purpose of conclution and execution of contracts – during the term of the contract and 10 years after the end of the contract;
  • for the purpose of provision of training services– up to 6 months after the end of the training;
  • for the purpose of direct marketing – 1 year from the last attendence of a seminar, until you withdraw consent or object to data processing;
  • for the purpose of informing the public – until the individual (lecturer) works with „Mokesčių srautas“ or until he withdraws his consent;
  • for the purpose of administering inquiries, received through the website and (or) e-mail – 1 year after the response;
  • for accounting purposes – 10 years after the end of the calendar year, in which the financial transaction took place;
  • for the purpose of ensuring the functionality and efficiency of the operation of the website, ease of use, speed of operation and security of the website, personal data is processed during the validity of the cookie.

At the end of the specified time limits, the data is deleted in such way that it cannot be restored or transferred to the state archives, if such obligation is set by law.

The organizational and technical security measures necessary for the implementation of the processing of personal data are taken to protect the data against accidental or unlawful disclosure or other independent processing.

RIGHTS OF THE DATA SUBJECT

In accordance with the procedures established by legal acts, data subjects have:

  • the right to know about their personal data processing;
  • the right to access and obtain a copy of their personal data;
  • the right to have inaccurate personal data rectified;
  • the right to request a restriction on the processing of personal data;
  • the right to demand personal data erasure (‘right to be forgotten’);
  • the right to withdraw consent given to process personal data. The withdrawal of consent does not affect the processing of data prior to the withdrawal;
  • the right to object to the processing of personal data when such data is processed or is intended to be processed for the purposes of direct marketing or due to a legitimate interest pursued by „Mokesčių srautas“ or a third party to whom the data is provided;
  • the right to personal data portability.

Data subjects can exercise their rights by contacting „Mokesčių srautas“ at Sėlių st. 33, Vilnius, or by e-mail ada@countline.lt

Please find the detailed description how to exercise your data subject rights below.

If the data subject considers that their rights have been violated, they have the right to submit a complaint to the State Data Protection Inspectorate (L.Sapiegos St. 17, Vilnius, www.ada.lt). In all cases, please contact us before you file a complaint, so that we can find a suitable solution together.

If you have any questions related to the processing of personal data or have any suggestions, please contact „Mokesčių srautas“ via the contacts provided above.

HOW TO APPLY FOR THE EXERCISE OF YOUR RIGHTS

In order to exercise your rights as a data subject, you must submit a written request and verify your identity (one of the following documents must be provided to confirm your identity: a passport of a citizen of the Republic of Lithuania, an identity card, a driving license).

The request must specify which of the above mentioned rights is to be exercised and to what extent.

The data subject may verify their identity in the following ways:

  • by providing an identification document, when the written request is presented in person;
  • by submitting a copy of the identification document certified by notary, or a copy of the identification document certified in accordance with procedures established by other legal acts, when the written request is submitted by post;
  • by signing it with a qualified electronic signature, when the application is submitted electronically.

The requirement for the data subject to verify their identity does not apply if the data subject requests information on the processing of personal data in accordance with Articles 13 and 14 of Regulation (EU) 2016/679.

If we have doubts about the identity of the data subject or if we cannot determine the identity of the data subject according to the information provided in the written request, „Mokesčių srautas“ may request additional information necessary to unambiguously verify the identity of the data subject.

When submitting a request for the exercise of rights, you may submit the request written in free-form or the request written in accordance with a form approved by „Mokesčių srautas“.

No later than within one month from the date of receipt of the request, „Mokesčių srautas“ will provide you with information on the actions taken upon receipt of the request. In the event of a complex or multiple applications are submitted, this time limit may, if necessary, be extended by a additional two months, taking into account the complexity and the quantity of these applications. In any case, we will inform you of such an extension and give the reasons for it within one month of receiving your request.

If „Mokesčių srautas“ decides to refrain from implementing the received request, we will inform you immediately, but not later than within one month from the date of the receipt of your request. This decision may be appealed to the State Data Protection Inspectorate and other legal remedies may be used.

WHY AND WHAT COOKIES WE USE

Cookies are small pieces of text stored in the browser (e.g. Internet Explorer, Firefox) of your device (e.g. computer, mobile phone, tablet) when you browse our website www.countline.lt and contain your browsing information. Cookies allow the website to „remember” your actions and preferences (such as registration name, language, font size and other display options) for a period of time, and you do not have to re-enter them each time you visit the site or browse its various pages. The first time you visit the website, cookies are transferred to your device and later used to identify the device.

This is a common practice for browsing websites, making it easier to navigate a website you have already visited and simplifying access to the information we publish. We do not use cookie-related information to identify you.

This website uses cookies:

  • to ensure the functionality and efficiency of the website;
  • to ensure that the website is easy to use;
  • to increase the speed and security of the website.

We use technical cookies on the website, which are necessary for us to provide certain services of the website and to be able to browse and use the features of the website.

Cookies are used to process the IP address, browsing information, such as areas of the website you have visited or the time you spent on the website, and so on.