When processing personal data, LTD SULINKIAI, registration code 271383880 (hereinafter referred to as SULINKIAI, Data Controller or we) seeks to protect the privacy of all persons in a clear and transparent manner.
When processing the personal data, we follow the European Union General Data Protection Regulation No 2016/679, Law on Legal Protection of Personal Data of the Republic of Lithuania, Law on Electronic Communications of the Republic of Lithuania, other related legal acts and instructions of controlling institutions. During the data processing, we implement appropriate technical and organizational measures in respect of data protection established in the legal acts to protect personal data processed from accidental or unlawful destruction, damage, alteration, loss, disclosure, as well as any other unlawful processing thereof. The appropriate measures are determined considering the risks arising in relation to the processing of personal data.
When processing your data, we may collect, record, store, modify, transfer and destroy them as defined in this policy and legal acts.
Your personal data will be processed in accordance with the requirements of the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts. Depending on our relationship with you, we process the following data:
- Identification data: name, surname, date of birth, taxpayer code, country of birth, photo.
- Contact details: address of the place of residence or address for correspondence, postal address, telephone number (fixed and/or mobile phone number), e-mail address, the language of communication.
- Digital identification data: name on social networks, Skype, transport exchanges or other programs and systems.
- Professional (job) data: education, foreign language proficiency, desired work, desired salary, personal characteristics, work experience, workplaces, length of service, positions, other work experience, other information provided in CV, recommendation and/or motivation letter.
- Other data:
- Data about the representatives of the companies that use or intend to use our services or otherwise cooperate or intend to cooperate with us, and the contact details thereof.
- Records about correspondence (nature, date, registration No).
- Video surveillance data: video records made in our territory and premises.
We do not process sensitive data related to your health, ethnic origin, religious or political beliefs except for the cases required by law or in special cases when, for example, you disclose such data yourself.
We receive your data from you upon your submission thereof, by contacting us by phone or e-mail, by letter or by contacting us by any other means of remote communication means and upon arrival at our offices. We may also retrieve and process your personal data after you have completed the application online, by submitting your data through third-party platforms (such as job search pages), after signing a contract with us, after making payments to us, visiting our website. In some cases, your data may also be provided by third parties at your own request and/or consent or on other grounds (such as representatives, lawyers, brokers, your employer when you, as an employee, represent the employer in the relationship between us and your employer, etc.).
SULINKIAI is able to gain access to the personal data disclosed if it is necessary for administrative purposes or for our legitimate interest.
In cases where we have a legitimate interest (which is related to risk reduction depending on the service you receive from us, the risk assessment, etc.), we also collect your personal data from other external sources such as credit bureaus, public and private registers or other companies or state institutions, including information from databases of third-party service providers and publicly available sources such as media sources, search engines.
We can transfer your personal data to companies that help us to implement our activities, as well as direct marketing. From such partners, we require that your data would be processed only in accordance with the instructions we provide and the applicable legal acts that ensure the protection of your data.
We collect your data for the following purposes:
- Data processing and administration purposes, we process identification, contact, digital identification and other data. We process this data on the basis of performance of the contractual duties and/or statutory obligations, and/or the legitimate interest in the need to perform the contract.
- For the purpose of administration of the database of candidates to the job places proposed by us, we handle the identification; contact and professional (work) data of the candidates. Failure to provide all or part of the data will not allow us to assess the suitability of the candidate for the proposed position. If you do not agree that your data will be processed at the end of the recruitment process where you provided your data, we undertake to destroy the data within ten days of the date of employment of the candidate you have selected.
- In order to ensure the safety of people and property when accessing the territory of SULINKIAI, video surveillance is carried out; therefore we are processing video surveillance data that may contain your image. These data are processed on a legitimate interest basis and stored for one month.
Access to your personal data shall have the right only authorized persons inside the Data Controller or the third parties employed by the Data Controller with whom the Data Controller cooperates when providing the services or other persons when required or permitted by laws. If the processing of personal data is performed by a third party on our behalf, we only hire third parties that provide reasonable assurance on the implementation of appropriate technical and organizational measures to ensure that the processing complies with requirements of applicable legislation and ensures the protection of your rights.
We may disclose your Personal Data to:
- SULINKIAI related companies (for administrative purposes).
- State institutions and other entities which carry out the functions assigned to them the law.
- Authorized auditors, legal and financial advisers and other third parties, including certain service providers, such as IT service providers, translators, couriers and other service providers.
- Employed personal data controllers and their sub-controllers who manage your personal data on our behalf.
- Any entity involved in the provision of services or the supply of goods to you, including entities participating in performance of your operations (such as banks, financial institutions, insurance companies, customs brokers, etc.).
- Credit and financial institutions, credit bureaus, intermediaries of financial services and insurance service providers.
- Managers of public registers;
- Debt recovery companies, credit bureaus, and other third parties to whom we can transfer, pledge or hand over our rights and obligations.
In cases where we transfer your data to a third party, we follow at least one of the following conditions:
- The data are transferred to the state for which the decision on the adequacy has been taken.
- The transfer of data is performed through the application of appropriate safeguards as specified in the legislation.
- The provisions provided for in the legislation are complied with if it is not possible to transfer the data under the clauses (a) and (b) mentioned above.
You have the right to:
- Know whether the Data Controller processes your personal data and, if they are processed, with your personal data processed by the Data Controller and the purpose of processing the data; categories of relevant personal data; data recipients to whom your personal data have been disclosed or will be disclosed; where possible, the planned storage period of the personal data or, if not possible, the criteria applied for determining that period.
- Require the correction of inaccurate personal data.
- Require that we delete your personal data. Nevertheless, this right is not absolute and can be justified if there are at least one of the following reasons: personal data are no longer needed to achieve the purposes for which they were collected or otherwise processed; You have decided to revoke your consent to the processing of your personal data when your personal data are processed solely on the basis of consent and there are no other grounds for processing your personal data; You do not consent to the processing of your personal data in the cases provided for by law and there are no overriding legitimate reasons for processing your data; Your personal data have been processed illegally; Your data should be deleted when we have an obligation to do so.
- Require that the processing of your personal data would be restricted where one of the following cases is applied: You dispute the accuracy of the data for the period during which we can verify the accuracy of your personal data; The processing of your personal data is unlawful and you do not agree to the deletion of your data and instead request the restriction of the use thereof; We no longer need your data for the purposes of their processing, but they are required for you to bring, execute or defend legal claims. When the processing of your personal data is restricted, we may process such data except for storage thereof only with your consent or for the purpose of claiming, performing or defending legal requirements and/or protecting your or other person’s rights, or for reasons of public interest.
- Revoke consent to processing your personal data when personal data are processed solely on the basis of your consent.
- Request that we transfer your personal data being processed to another data controller when technically possible.
- Submit a complaint to us or to the State Data Protection Inspectorate if you believe that your rights as a personal data subject are and/or may be violated.
Personal data shall be stored in accordance with applicable laws and for the period not longer than is needed. Periods for storage of personal data shall be determined by SULINKIAI and they shall depend on the specific terms and conditions of the contract and the basis for the processing of personal data.
In order to implement own rights, please submit applications, complaints or requirements in writing at:
- Email address firstname.lastname@example.org;
- Send by postal address Durpiu str. 2, Radviliskis, the Republic of Lithuania;
- Arrive at the address Durpiu str. 2, Radviliskis, the Republic of Lithuania.
We will respond to the requests, complaints or claims received in writing in accordance with the procedure and within the time limits set by legal acts and we will endeavour to submit the information to you as soon as possible, but not later than within 30 days of receipt of your request. This period may be extended, if necessary, by a further 30 days, depending on the complexity and number of requests. The Data Controller will inform you of such an extension within one month of receiving the request together with the reasons for the delay.
If, upon reception of an application, complaint or claim, we have suspicions about the identity of the applicant, we shall have the right to request confirmation of your identity of the person by means of the identification document and/or in accordance with the procedure set out in legal acts and/or electronic means of communication that allow the identification of the person.
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Cookies are commonly used on the Sulinkiai.lt website for the following purposes:
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Commercial cookies: we use our own cookies and third party cookies to display personalized advertising on our own website and other websites while limiting the amount of advertising you receive.
Our cookies are installed with the help of the “Google Analytics” tool. These cookies are intended for collecting statistical data on website traffic, collecting information about the browser, the computer or other device used, visits, time spent, where the visitor came to the website from, and what search led them to the website to evaluate the visitor’s visit goals, prepare reports on website activity for the site operators and improve visitor’s experience when visiting the site.
Who can access the data collected with the help of cookies?
The collected data can be accessed by UAB SULINKIAI employees who analyze these data and improve the website. Technical data may also be held by UAB SULINKIAI partners providing the website management tools.
The “Google Analytics” tool is provided by Google Inc. (U.S. company), so it also has access to the statistical data collected by this tool. “Google Inc.” is committed to the principles of the EU-U.S. Privacy Shield that ensure that the service provider complies with EU privacy standards. This provider is also subject to contractual privacy obligations. You can read about it here
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