Privacy Policy
I. Basic concepts
1. The Data Controller (hereinafter referred to as the "Seller") is LNT, a private limited liability company, which owns the SmartGo.lt e-shop, a company incorporated under the laws of the Republic of Lithuania, with its registered office at 12 Savanorių a., Panevėžys, the Republic of Lithuania, with the legal entity code 148332230, the details of which are collected and stored in the Register of Legal Entities of the Republic of Lithuania.
2. Data Subject - a natural person whose personal data is processed by the Seller.
3. "E-shop" means the Company's online shop at www.SmartGo.lt.
4. Services - all services provided by the company.
5. Personal data means any information relating to a natural person - a Data Subject - whose identity is known or can be identified, directly or indirectly, by reference to data such as a personal identification number, one or more factors specific to the person, such as his or her physical, physiological, psychological, economic, cultural or social characteristics.
6. Processing of personal data shall mean any operation or set of operations which is performed upon personal data, such as collection, recording, accumulation, storage, classification, grouping, aggregation, alteration (addition or rectification), communication, disclosure, use, logging and/or arithmetical operations, retrieval, dissemination, destruction, or any other operation or set of operations.
7. A cookie is a corresponding file with a unique identification number that is transferred from the E-shop website to the hard drive of the E-shop visitor's computer in order to allow the E-shop administrator to distinguish the visitor's computer and to see his/her activity in the E-shop, as well as to maintain the proper functionality of the E-shop.
8. Direct marketing means the activity of offering goods or services to persons by post, telephone or other direct means and/or seeking their opinion on the goods or services offered.
9. Privacy Policy - means this document setting out the principles and rules for the processing of Personal Data when using the services of the Online Shop.
10. Account - the Customer's basic login details to the Online Shop, consisting of a single email address and Password.
11. Password means a unique combination of numbers, letters, or numbers and letters or other symbols created by the Customer, which can be used to log in to the Online Shop.
II. General provisions
12. By making a purchase in the Online Shop or registering an Account, the Customer authorises the Company to carry out all Personal Data processing activities within the scope and for the purposes set out in this Privacy Policy.
13. Personal data are processed in accordance with the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts regulating the processing and protection of personal data, as well as this Privacy Policy.
14. The Company processes Personal Data in accordance with the following principles:
14.1 Personal data are collected for specified and legitimate purposes;
14.2 Personal data shall be processed accurately, fairly and lawfully;
14.3.Personal data are adequate and only to the extent necessary for their collection and further processing;
14.4.Personal data is kept up to date;
14.5.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 data were collected and processed.
14.6.All information about Personal Data is confidential;
14.7.The Customer's Personal Data and Personal Information will not be used for any unlawful purpose.
15. By making a purchase in the online shop, the customer shall be deemed to have read and accepted the Privacy Policy in its current version. If the Customer disagrees with any part of the Privacy Policy or the Privacy Policy, in such case the Customer shall not place an order and shall not purchase the product in the Online Shop.
16. The Privacy Policy is available in the Online Shop and can be printed at any time. The Privacy Policy may be amended, supplemented or updated at the discretion of the Company. The new version of the Privacy Policy is published in the Online Shop.
17. The Customer can place an order through his Account by signing in to the Online Shop.
18. During the initial registration to the Online Shop through the Account, the Customer must provide his/her email address and create a secure Password and provide accurate Personal Data to the Online Shop. The Customer is responsible for their correctness.
19. When using the Services, as well as when making purchases in the Online Shop, the Customer must always provide accurate Personal Data to the Online Shop and is responsible for its accuracy.
20. The Client has the right to change and update the Personal Data in the Account or cancel the Account at any time.
21. The Customer shall not disclose the Password to third parties and shall keep it secure, otherwise the Customer shall bear all the liability related thereto.
III. Collection, use, correction and storage of personal data
22. The Company respects the right to privacy of every customer. Customer Personal Data is collected and processed for the following purposes:
22.1. For the purpose of e-commerce. The following Personal Data is processed: name, surname, place of residence (address), e-mail address, telephone number.
22.2. For direct marketing purposes. The following Personal Data is processed: name, surname, place of residence (address), e-mail address, mobile phone number; date of birth, gender.
22.3. for the purpose of administering electronic enquiries. The following Personal Data is processed: name, surname, e-mail address, telephone number.
23. Both when registering for the first time in the Online Shop and when placing each order, the Customer may consent to the processing of his/her Personal Data (name, surname, date of birth, place of residence (address), gender, telephone number, e-mail address) for the purpose of direct marketing. If, after consenting to the processing of his/her Personal Data for the purpose of Direct Marketing, including the receipt of Direct Marketing communications (e.g. newsletters with offers and articles, SMS messages), the Customer subsequently ceases to do so and informs the Company in accordance with the procedure set out below, the Company will cease to process the Customer's Personal Data for the purpose of Direct Marketing, and will no longer send the Customer any electronic newsletters, except for the information relating to the Customer's order.
24. The Company confirms that the Personal Data provided by the Customer will only be processed for the purpose of properly providing the Customer with the services provided in the online store https://smartgo.lt/en/ (including the right to participate in promotions, projects). The Company also confirms that the Personal Data provided by the Customer will be processed for the purposes of analysis of the Company's activities and for Direct Marketing purposes, provided that such consent is given by the Customer and not withdrawn. The retention period of Personal Data to be used for Direct Marketing purposes is set at three calendar years from the moment of providing such data.
25. The Customer shall have the right to withdraw his/her consent to the Company's processing of the Customer's Personal Data for the purpose of Direct Marketing at any time as set out in Clause 23 by sending a notice to the Company at info@smartgo.lt clearly stating that he/she withdraws his/her consent to the use of the Customer's Personal Data for the purpose of Direct Marketing and that he/she does not wish to receive any Direct Marketing communications (e.g. newsletters with offers, articles, SMS messages).
26. The Customer shall also have the possibility to refuse to exercise his/her right to object to the processing of the Customer's Personal Data for the purpose of Direct Marketing by clicking on the relevant link contained in each email sent.
27. The Client, as a Data Subject, has the following rights in relation to the Client's Personal Data processing procedures:
27.1. to receive information from the Company about the processing of the Customer's Personal Data, to have access to his/her Personal Data and how they are processed (right of access);
27.2. to obtain from the Company information on the sources and nature of the Customer's personal data collected, the purposes for which it is processed, the recipients to whom it is provided and has been provided for at least the last 1 (one) year (right to know);
27.3. to request rectification, destruction of the Client's Personal Data or to suspend, with the exception of storage, the processing of his/her Personal Data where the Personal Data is processed in breach of the provisions of the Law on the Legal Protection of Personal Data of the Republic of Lithuania and other laws (the right of rectification, the right of destruction and the right to be forgotten).
27.4. to request the restriction of the processing of the Customer's personal data on one of the legitimate grounds (right to restrict).
27.5. to receive, in a structured, commonly used and computer-readable format, the personal data concerning him or her which he or she has provided to the Company and to transmit such data to another controller, or to require the Company to transmit such personal data directly to another controller where this is technically feasible (the right to data portability).
28. In order to exercise his/her rights under Clause 27, the Customer must present his/her passport, identity card or driving licence. The Customer may exercise his/her rights under Clause 27 by contacting info@smartgo.lt. The Company shall have the right to rectify or delete Personal Data or to suspend the processing of Personal Data only after the identity of the Customer who made the request has been identified.
29. Complaints of persons regarding improper or unlawful processing of Personal Data shall be examined by the State Data Protection Inspectorate, registered office address A. Juozapavičiaus g. 6, LT-09310 Vilnius, www.ada.lt.
30. The Client's Personal Data is not disclosed to third parties, except in the following cases:
28.1. when the Customer's consent is obtained as set out in this Privacy Policy;
28.2. Personal data for e-commerce purposes is provided to Partners who provide services to the Company in connection with the Company's activities;
28.3. for partners belonging to the same group of companies located in a European Union country, for IT solutions, financial/accounting;
28.4. in cases provided for by the laws and legal acts of the Republic of Lithuania, to the competent authorities.
31. The Customer is aware of his/her right to object to the processing of his/her Personal Data for the purposes of Direct Marketing, i.e. the Customer has the right to object immediately or at a later stage.
32. The Customer consents to the transfer of its Personal Data to the Partners for the purpose of fulfilling the Customer's order placed on the Online Shop, as well as for the Company's provision of the Services to the Customer, as well as for the Company to the Partners as set out in Clause 28.
33. If the Customer does not agree to the Privacy Policy, the Customer shall not be able to use the services of the Online Shop. The Customer may express his/her disagreement with this Privacy Policy in accordance with the procedure set out in Clause 24.
34. The Company shall implement organisational and technical measures to protect Personal Data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing. The measures taken by the Company to protect Personal Data comply with the legal requirements of the Republic of Lithuania.
35. Personal data is protected against loss, unauthorised use and alteration. All Customer Passwords are encrypted, the servers that deal with Personal Data can only be accessed by persons authorised by the Data Controller and only through a secure certificate with additional password protection, and all pages of https://smartgo.lt/en/ that require the entry of Personal Data are executed through the https:// protocol.
36. The Customer agrees that in cases where it is necessary to do so pursuant to the instructions of the competent authorities and/or the Customer's Personal Data may have been used in the course of an illegal activity, or where there are reasonable suspicions of identity theft for which a pre-trial investigation is being conducted by the competent law enforcement authorities, or where there are other legitimate grounds or purposes, the Customer's Personal Data shall be retained on the Company's servers for a longer period of time than that specified in this Privacy Policy.
37. Upon receipt of an instruction or enquiry from a Data Subject in relation to the processing of Personal Data, the Company shall provide the Client with a response, either granting the request/instruction or reasoned refusal to do so, no later than 30 (thirty) calendar days from the date of the Data Subject's request. If the Data Subject so requests, the response shall be in writing.
38. In order for the Company to be able to offer the Customer a full range of services in the Online Shop, information (Cookies) is stored on the Customer's computer (device), which is used to identify the Customer as a previous user of the Online Shop, to collect statistics on the number of visits to the Online Shop, and to collect information about the shopping cart. The Customer has the possibility to view what information (Cookies) the Company saves and can delete some or all of the saved Cookies. By accepting the Privacy Policy, the Customer agrees to the storage of Cookies on his/her computer (device) as provided for in this Privacy Policy. The Customer may revoke this consent at any time by changing the settings of his/her web browser, but in such case certain functions of the online shop https://smartgo.lt/en/ may not work for him/her.
IV. Final provisions
1. The Company has the right to amend, supplement the Privacy Policy in whole or in part. Amendments or changes to the Privacy Policy shall come into force from the date of their publication, i.e. from the date on which they are published in the Online Shop.
