Privacy Policy

We recognise the importance of protecting your personal data and therefore collect and process only the personal data that is necessary for the performance of our activities. We process personal data lawfully, fairly and transparently, for specified purposes and only to the extent necessary to achieve those purposes. When processing personal data, we ensure that it is accurate, secure, confidential, properly stored and adequately protected.

When processing personal data, we comply with the requirements of the General Data Protection Regulation (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as other applicable legal acts regulating the processing of personal data.

1. What is this document?

1.1. By reading this privacy policy (hereinafter – the Privacy Policy), you will learn how and for what purposes we process your personal data, where we obtain it from, to whom we provide and disclose it, how we store it, and what your rights are as a data subject.

1.2. In this Privacy Policy, the term “personal data” means any information by which you may be identified, directly or indirectly. Personal data includes your name, surname, date of birth, postal or email address, location data and internet identifier, characteristics specific to you, etc.

1.3. This Privacy Policy applies to all persons whose personal data we process.

2. Who are we?

2.1. We are Master Class LT, UAB, legal entity code 302309920, registered office address Jogailos g. 4, LT-01402 Vilnius. In accordance with applicable legislation, we are the controller of your personal data.

2.2. For more information on any matters covered by this Privacy Policy, please contact the Company’s administration by email at info@masterclass.lt.

3. What principles do we follow?

3.1. When processing your personal data, we:

a) shall comply with the requirements of applicable legislation, including the GDPR;

b) shall process your personal data in a lawful, fair and transparent manner;

c) shall collect your personal data for specified, explicit and legitimate purposes and shall not further process it in a manner incompatible with those purposes, except to the extent permitted by law;

d) shall take all reasonable steps to ensure that personal data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified or completed without delay, and where appropriate, that processing is restricted or the data are erased;

e) shall keep personal data in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;

f) shall not disclose personal data to third parties or make it publicly available, except as provided in this Privacy Policy or as required by law; and

g) shall ensure that your personal data are processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical and organisational measures.

4. How do we collect your personal data?

4.1. We process your personal data obtained in the following ways:

a) when you provide it to us. You provide your personal data when you send us your CV, cover letters, register on our websites, communicate with us by telephone, email or during meetings, respond to questionnaires, complete tasks or tests. If you contact us in writing or by email, we will retain the correspondence data.

b) when you use websites operated by us. When you use the websites we operate, certain information (e.g., Internet Protocol (IP) address, type of web browser used, number of visits, pages viewed, time spent on the website, etc.) is collected automatically.

c) when we obtain your personal data from other persons in accordance with the procedure established by law and/or this Privacy Policy.

4.2. We may combine personal data received from you with data collected by us from other public or accessible sources. For example, we may combine the personal data you provide with data obtained through the use of cookies on websites, data collected in the course of providing our services to you, or data lawfully obtained from third parties. When exercising your rights, you may at any time request the rectification of inaccurate personal data.

5. PURPOSES OF PERSONAL DATA PROCESSING

5.1. We process your personal data for the following purposes:

a) For the purpose of providing services to our clients. We process your personal data in order to provide our services to you and to other persons: to identify and select candidates that meet our clients’ needs, to assess whether candidates are suitable for the offered position, and to introduce candidates to employers.

For this purpose, we process personal data obtained from you (e.g., information provided in your CV, data collected during communication, etc.), collected through your use of our and other websites, and/or obtained from other persons (e.g., recommendations from current or former employers or acquaintances, social networks, mass media, etc.).

For this purpose, we provide or transfer your data to our clients – employers seeking employees. Together with us, they will act as controllers of your personal data. We will not transfer to clients more of your personal data than we process under this Privacy Policy. We have entered into agreements with our clients under which both parties undertake to protect your personal data.

For this purpose, we retain your data for 10 years from the date you last provided us with your data or updated it, unless we have obtained your separate consent to retain your data for a longer period.

b) For the purpose of administering the candidate database. After the end of the specific recruitment process to which you submitted your data, we process your personal data in order to offer you future employment and career opportunities, to identify and select candidates that meet our clients’ needs, to assess whether you are suitable for the offered position, and to introduce candidates to employers.

For this purpose, we process the same personal data as for the purpose of providing services, disclose it to the same persons and retain it for the same period as specified in Clause 5.1(a).

c) For direct marketing purposes. With your consent, and in order to offer you goods and services of ours, related persons and partners, as well as to improve our services, we process your personal data.

For this purpose, we process the following personal data:

name, surname, email address.

For this purpose, we obtain your personal data from:

you.

For this purpose, we retain your data until the end of the term of the contract with you, unless we have obtained your consent to retain your personal data for a longer period.

d) For the purpose of administering the work and activities of the Company’s employees. To the extent that we are obliged or permitted to do so by law, we process the personal data of our employees. We process employees’ personal data in accordance with the procedure set out in the Employee Personal Data Processing Policy.

e) For the purpose of contract performance. In order to identify a client or supplier, carry out activities related to the sale of products and solutions and provision of services, process and administer orders, issue invoices to clients or accept suppliers’ accounting documents, resolve issues related to the scope of products, solutions or services provided to a client, and fulfil the Company’s other obligations as a seller or buyer, or as a service provider or recipient, we process personal data.

For this purpose, we process the following personal data:

name, surname, date of birth, personal identification number (personal code of a resident of the Republic of Lithuania or personal identification number of a foreign country citizen or other identification number), age, residential address, telephone number, email address.

For this purpose, we obtain your personal data directly from data subjects when a potential client or supplier represented by the data subject seeks to enter into a contract with the Company, or during the performance of a contract concluded between the client or supplier represented by the data subject and the Company.

f) For the purpose of selecting candidates for positions offered by the Company. We process your personal data in order to identify and select candidates that meet our needs for employment, and to assess whether candidates are suitable for the offered position.

For this purpose, we process personal data obtained from you (e.g., data provided in your CV, data collected during communication, etc.), collected through your use of our and other websites, and/or obtained from other persons (e.g., recommendations from current or former employers or acquaintances, social networks, mass media, etc.).

For this purpose, we retain your data for 3 years from the date you last provided us with your data or updated it, unless we have obtained your separate consent to retain your data for a longer period.

g) For the purpose of administering the database of candidates for employment with the Company. After the end of a specific recruitment process in our Company to which you submitted your data, we process your personal data in order to offer you future employment and career opportunities, identify and select candidates that meet the Company’s needs, and assess whether you are suitable for the offered position.

For this purpose, we process the same personal data as for the purpose of providing services, disclose it to the same persons and retain it for the same period as specified in Clause 5.1(f).

h) For the purpose of debt administration.

For this purpose, we process your name, surname, telephone number, email address and residential address.

For this purpose, we obtain your personal data directly from you, from publicly accessible sources (e.g., the Population Register, data provided by third parties, etc.) and from third parties.

For this purpose, we provide or transfer your data to debt administration and/or debt collection companies.

For this purpose, we retain your data until the end of debt administration (settlement) and taking into account statutory limitation periods established by legal acts (the Civil Code of the Republic of Lithuania and others).

i) For the purpose of improving the websites we manage and providing you with better and more tailored services. We use your personal data, including the personal data we obtain when you use our websites, to improve and develop these websites and to offer you better and more tailored services. For this purpose, we use personal data obtained from you, obtained through your use of our websites, and obtained from other persons.

For information on how we use cookies and similar technologies, please refer to Section 7 of this Privacy Policy.

5.2. We do not process your personal data for any other purposes that are incompatible with the purposes listed above.

6. Do we use your personal data for direct marketing?

6.1. With your additional consent, we may use your personal data for direct marketing purposes in order to provide you with offers and information about goods and/or services of ours, related persons and partners that, in our opinion, may be of interest to you.

6.2. For this purpose, we process the following personal data: name, surname and email address.

6.3. By granting us the right to process your data for direct marketing purposes, you also authorise us to contact you for this purpose via communication means (e.g., email, telephone, short message service (SMS)) or other communication platforms (e.g., Skype, Viber, etc.).

6.4. We may combine the information we hold about you with information held by third parties.

6.5. If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyse and improve the effectiveness of our websites, advertising and market research, and for other marketing and sales purposes of the Company. In such case, we will use anonymised data.

6.6. Even if you have given your consent to the processing of your personal data for direct marketing purposes, you may withdraw such consent at any time in respect of all direct marketing processing activities. You may do so in the following ways:

a) by notifying your opt-out in the manner specified in electronic notifications and/or offers (e.g., by clicking the “unsubscribe” link in the newsletter, etc.); or

b) by visiting us and submitting a relevant request. The request must clearly indicate your name and surname. If you wish to withdraw your consent in this manner, we may ask you to provide proof of identity; or

c) by sending us a request to the email address specified in this Privacy Policy. The request must clearly indicate your name and surname and other registration details (if any). If you wish to withdraw your consent in this manner, we may ask you to provide proof of identity.

6.7. If you withdraw your consent, we will endeavour to cease processing your personal data for direct marketing purposes as soon as possible.

6.8. Withdrawal of consent does not automatically oblige us to erase your personal data or to provide you with information about our processing of your personal data. If you wish us to take such actions, you must submit a separate request.

7. How do we use cookies?

7.1. We collect information about you using cookies and similar technologies. Cookies are small files temporarily stored on your device’s hard drive which enable us to recognise you during subsequent visits to websites, save browsing history and preferences, tailor content, accelerate searches, create a convenient and user-friendly website environment, and make the website more efficient and reliable. Cookies are a common web browsing practice that facilitates the use of a website.

7.2. We may collect the following information through cookies: IP address, browser type, demographic data.

7.3. We use the information obtained through cookies for the following purposes:

a) to ensure the functionality of the websites (e.g., to enable website personalisation);

b) to analyse the use of the websites;

c) to improve and develop the websites to better meet your needs;

d) service development; and

e) targeted marketing.

7.4. Without prejudice to applicable law, we may combine information obtained through cookies with information obtained about you by other means (e.g., information about your use of websites, personal data you provide, etc.).

7.5. The following types of cookies may be used on the websites:

a) technical cookies – cookies necessary for the operation of the websites;

b) functional cookies – cookies which are not essential for the operation of the websites but significantly improve performance, quality and user experience;

c) analytical cookies – cookies used to compile statistical analyses of website visitors’ navigation methods; data collected by these cookies is used anonymously;

d) targeting or advertising cookies – cookies used to display offers or other information that may be of interest to you; and

e) social network cookies – cookies necessary to use website information within your social profile account.

7.6. Full information about cookies used on the websites, their purpose, validity period and the data used is provided in the table below:

Name Purpose Validity period

_ga Used by Google Analytics to evaluate the user’s visit objectives, prepare reports on website activity for website operators and improve user experience when visiting the website 2 years
_gat Used by Google Analytics to collect statistical information about website traffic (information about the browser used, device, visits, time spent) Until the browser window is closed
_gid
collect Information collected by Google Analytics about the visitor’s device Until the browser window is closed

7.7. You may provide your consent to the use of cookies in the following ways:

a) by not deleting cookies and/or not changing your browser settings so that it does not accept cookies;

b) by clicking “I agree” in the cookie notice (banner) on the websites; or

c) by expressing consent during registration on the websites.

7.8. You may withdraw your consent to the use of cookies at any time by changing your browser settings so that it does not accept cookies. The method depends on the operating system and browser you use. More information about cookies, their use and opt-out options is available at http://AllAboutCookies.org or http://google.com/privacy_ads.html.

7.9. In some cases, in particular in relation to technical and functional cookies, disabling, refusing or deleting cookies may slow down browsing, restrict certain functions of websites, or even block access to websites.

8. To whom do we disclose your personal data?

8.1. We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without a lawful basis, nor used for purposes other than those for which it was collected. We will not transfer your personal data in any manner other than in accordance with this Privacy Policy and applicable law. However, we reserve the right to disclose information about you if we are required to do so by law or if requested by lawfully acting authorities or criminal prosecution authorities.

8.2. We may transfer your personal data to companies that assist us in carrying out our activities, including direct marketing. We require such partners to process your data only in accordance with our instructions and applicable data protection legislation. We conclude agreements with such parties obliging them to strictly comply with personal data protection requirements.

8.3. The ability of the service providers referred to above to use your data is limited – they may not use such data for purposes other than providing services to us.

8.4. A non-exhaustive list of persons and categories of persons to whom we transfer your personal data is provided in Clause 1 of this Privacy Policy separately for each purpose of personal data processing.

9. How long do we retain your personal data?

9.1. We retain your personal data no longer than required by the purposes of processing or by law, where a longer retention period is established by law.

9.2. We seek not to retain outdated or irrelevant personal data, therefore, once data is updated (e.g., corrected or changed in an account), only the актуal information is retained. Historical information is retained where necessary under applicable law or for the performance of our activities.

9.3. Clause 5.1 of the Privacy Policy specifies retention periods for each purpose of personal data processing.

10. How do we protect your personal data?

10.1. The data we collect from you will be stored within the European Union; however, it may also be transferred to, or stored outside, the European Union. It may also be processed by our or our suppliers’ staff working outside the European Union. When transferring your data outside the European Union, we will take all necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy.

10.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we make every effort to protect your personal data, we cannot guarantee the security of data transmitted by you to websites; you assume the risks associated with such transmission. Once we receive your data, we will apply strict procedures and security measures to protect it against unauthorised access.

10.3. In the unlikely event that we become aware of a personal data security breach that may pose a high risk to your rights and freedoms, we will notify you without undue delay once we become aware of it and determine what information was accessed.

11. External websites

11.1. Websites may contain links to external websites, such as websites of our business partners or websites advertising our goods and/or services. If you follow such links, please note that these websites and the services available through them have their own privacy policies and we do not accept any responsibility or liability for those policies or for any personal data collected through such websites or services, such as contact or location data. Please review such policies before submitting personal data to such websites or using any services.

12. What rights do you have?

12.1. When processing personal data, we ensure your rights under the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a data subject, you have the following rights:

a) to know (be informed) about the processing of your personal data;

b) to access your personal data that we process;

c) to request rectification, completion and clarification of inaccurate, incomplete or incorrect personal data;

d) to request erasure of personal data when it is no longer necessary for the purposes for which it was collected;

e) to request erasure of personal data where processing is unlawful, or where you withdraw your consent (or do not provide consent) and such consent is necessary for processing;

f) to object to the processing of personal data or to withdraw previously given consent;

g) to request restriction of processing (other than storage) of your personal data where there are disputes or where it is necessary to verify the lawfulness of processing, the accuracy of the data, or where we no longer need your personal data but you do not want it erased; and

h) to request, where technically feasible, provision of your personal data collected pursuant to your consent or for the purposes of performance of a contract in a structured, commonly used and machine-readable format, or request that it be transmitted to another controller.

12.2. We will endeavour to ensure the exercise of your rights as a data subject and to facilitate their effective exercise; however, we reserve the right to refuse to comply with your requests where it is necessary to ensure:

a) compliance with our legal obligations;

b) national security or defence;

c) public order, the prevention, investigation, detection or prosecution of criminal offences;

d) important economic or financial interests of the State;

e) the prevention, investigation and detection of breaches of official or professional ethics; and

f) protection of your rights and freedoms or the rights and freedoms of other persons.

12.3. You may submit requests relating to the exercise of your rights to us in person, by post or by electronic means of communication. Upon receipt of your request, we may ask you to provide proof of identity and any additional information necessary in connection with your request.

12.4. Upon receipt of your request, we will respond no later than within 30 calendar days from the date of receipt of your request and the submission of all documents necessary to provide a response.

12.5. If we deem it necessary, we will restrict processing of your data (except for storage) until your request is resolved. Where you lawfully withdraw your consent, we will cease processing your personal data without undue delay, but no later than within 30 calendar days, except in the cases specified in Clause 12.2 of this Privacy Policy and cases provided by law, i.e., where we are obliged to continue processing your personal data under applicable law, a legal obligation incumbent on us, a court decision, or binding orders of competent authorities.

12.6. If we refuse to comply with your request, we will clearly indicate the grounds for such refusal.

12.7. If you disagree with our actions or our response to your request, you may lodge a complaint regarding our actions and decisions with a competent public authority.

13. To whom can you submit a complaint?

13.1. If you wish to submit a complaint about our processing, please submit it in writing, providing as much information as possible, using the contact details provided at the end of this Privacy Policy. We will cooperate with you and endeavour to resolve any issues without undue delay.

13.2. If you believe that your rights under the GDPR have been infringed, you may lodge a complaint with our supervisory authority – the State Data Protection Inspectorate – although we will first endeavour to resolve any disputes with you directly.

14. How will this Privacy Policy be amended?

14.1. Any changes to this Privacy Policy will be published on the websites. Where necessary, we will notify you. New terms of the Privacy Policy may also be posted on the websites and you may need to read and agree to them in order to continue using the websites and/or our services.

15. How to contact us?

15.1. Please send all documents related to this Privacy Policy to the contacts below:

by post – Master Class LT, UAB, Jogailos g. 4, LT-01402, Vilnius;
by email – info@masterclass.lt.

Privacy Policy publication date: 29 October 2025