Privacy Policy

We understand the special importance of protecting Your personal data, therefore, we collect and process only those data that are necessary for our activity. We process personal data lawfully, transparently and honestly, for predefined purposes and only to the extent that is necessary for the achievement of those purposes. When processing personal data, we seek to make them accurate, safe, confidential, properly stored and protected.

When processing Your personal data, we comply with the requirements of the General Data Protection Regulation (hereinafter referred to as GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as other legislation governing the protection of personal data.

1. What is this document?

1.1. After reading this privacy policy (hereinafter referred to as Privacy Policy), You will learn how and for what purposes we process Your personal data, where we receive them from, whom we provide them to, how we protect them, and what rights You hold as a subject of personal data.

1.2. The term “personal data” used in this Privacy Policy includes any information, which allows to identify You, i. e. to directly or indirectly determine Your identity. Personal data incudes a surname, a name, the date of birth, the postal or e-mail address, location and the Internet identifier, Your specific features, etc.

1.3.The Privacy Policy applies to all individuals whose data we process.

2. Who are we?

2.1. We are JSC Master Class LT, company code 302309920, address Ž. Liauksmino g. 3, LT-01101 Vilnius. According to legal provisions, we constitute a controller of Your personal data.

2.2. For more information on matters dealt with in this Privacy Policy, please contact our administration by e-mail address info@masterclass.lt.

3. Our principles

3.1. Your personal data are:

a) processed in compliance with the existing and applicable legislation including GDPR;

b) processed lawfully, fairly and in a transparent manner in relation to individuals;

c) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes, except and to the extent permitted by law;

d) we will take every reasonable step to ensure that personal data that are not accurate or comprehensive, having regard to the purposes for which they are processed, are corrected, supplemented, stopped being processed or erased without delay;

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

f) neither distributed to third parties, not made publicly available, except for cases specified in the Privacy Policy or in legal acts;

g) 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.

4. How we collect your personal data?

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

a) when You provide them to us. You give us Your personal data when you send us Your CV and cover letters, register on our websites, communicate with us by phone, email or during meetings, fill in our questionnaires, perform tasks or tests. After You contact us via e-mail, we will keep the correspondence data.

b) when You use websites that we control. When You use websites that we control certain information (such as the Internet address (IP), the type of the web browser used, the number of visits, web page views, time spent on the website, etc.) is collected automatically.

c) when we receive Your personal data from other individuals in accordance with legal acts and/or this Privacy Policy.

4.2. We may combine personal data received from You with the data collected on our own from other public or accessible sources. For example, we may combine Your personal data with the data obtained through the use of website cookies, the data collected by providing our services to You, or the data legally obtained from third parties. By enforcing Your rights, You will always be able to correct the inaccurate personal data of Yours.

5. For what purposes do we process your personal data

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

a) For the purpose of providing services to our customers. We process Your personal data in order to provide our services to You and to other customers: to find and to select candidates meeting our customers’ needs, to assess whether the candidates are suitable for the proposed job, and to introduce candidates to the employers.

For this purpose, we process Your personal data received from Yourself (e. g., Your CV, data collected as a result of communicating with You, etc.), data obtained from Your visits in our website and other websites and/or received from other persons (e. g., recommendations of current or former employers or acquaintances, social networks, media, etc.).

For this purpose, we provide or transfer Your data to our customers – employers who are looking for employees. Together with us, they will be controllers of Your personal data. We will provide our customers with not more information than we process on the basis of this Privacy Policy. We have entered into agreements with our customers, by which both parties undertake to protect Your personal data.

For this purpose, we keep Your data for 10 years from the date You last submitted or updated Your data, unless we have received Your explicit consent to keep the data longer.

b) For the purpose of administration of the database of candidates.At the end of a specific selection to which You submit Your data, we process Your personal data so that we can offer You the job and career opportunities in the future, find and select candidates meeting our customers’ needs, evaluate candidates’ suitability for the proposed job, and introduce candidates to employers.

For this purpose, we process the same personal data as for the purpose of the provision of services, we provide them to the same individuals and keep them for the same period of time as defined in paragraph 5.1 (a).

c) For the purpose of security of property and persons (feedback form). When you participate in our selections or provide you with our other services, our satisfaction with our services is important to us.

For this purpose, we process the following personal data of Yours:

      • e-mail address, name, surname, telephone number.

For this purpose, we receive Your personal data:

      • from Yourself as a result of the use of our services by You.

For this purpose, we keep Your data until the end of your contract with you, unless Your consent is obtained to keep Your personal data longer.

d) For the purpose of administration of the work and activities of the company’s employees.To the extent that we are obliged or authorized by law, we process personal data of our employees. The personal data of our employees is processed in accordance with the procedure set out in the Description of the Processing of Personal Data of Employees.

e) For direct marketing purposes. With Your consent and in order to offer you job offers or other services of our own, the persons associated with us and our partners, to improve our services, we process your personal data.

For this purpose, we process the following personal data of Yours:

      • workplace, e-mail address, position, surname, telephone number, name, date of birth, personal identification number (personal identity number of a resident of the Republic of Lithuania or foreign national’s personal identification number or other identification number), age, address of residence.

For this purpose, we receive Your personal data:

      • from Yourself.

For this purpose, we keep Your data until the expiry of Your contract with us, unless Your consent is obtained to keep Your personal data longer.

f) For the purpose of implementation of contracts.We process the personal data in order to identify the customer or the supplier, to carry out the sale of products and solutions as well as the provision of services, to process and administer orders of the customer or the supplier, to issue to the customer or to accept from the supplier accounting documents, to deal with issues related to the product installed, the volume of the solution or the services provided, to carry out other obligations of the Company as a seller or a buyer, or a provider or a buyer of services.

For this purpose, we process the following personal data of Yours:

      • name, surname, date of birth, personal identification number (personal identification number of the citizen of the Republic of Lithuania or the citizen of a foreign state or other identification number), age, place of residence, telephone number, e-mail address.

For this purpose, we receive Your personal data directly from data subjects when the potential customer or supplier, represented by that data subject, seeks to conclude a contract with the Company or during the execution of the contract concluded between the Company and the customer or the supplier represented by that data subject.

For the purpose of selection of candidates to vacancies in the Company. We process Your personal data in order to find candidates meeting our needs to work with us, to select them and to assess whether the candidates are suitable for the proposed work.

For this purpose, we process Your personal data received from Yourself (e. g., Your CV, data collected as a result of communicating with You, etc.), data obtained from Your visits in our website and other websites and/or received from other persons (e. g., recommendations of current or former employers or acquaintances, social networks, media, etc.).

For this purpose, we keep Your data for 3 years from the date You last submitted or updated Your data, unless we have received Your explicit consent to keep the data longer.

g) For the purpose of administration of the database of candidates to work in the Company. At the end of a specific selection to which You submit Your data, we process Your personal data so that we can offer You the job and career opportunities in the future, find and select candidates meeting our Company’s needs, and evaluate candidates’ suitability for the proposed job.

For this purpose, we process the same personal data as for the purpose of the provision of services, we provide them to the same individuals and keep them for the same period of time as defined in paragraph 5.1 (f).

h) For the purpose of administration of debts.
For this purpose, we process Your name, surname, telephone number, e-mail address.

For this purpose, we receive Your personal data directly from Yourself, from publicly available sources (e. g., 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 collection companies.

For this purpose, we keep Your data until the end of the debt administration (debt liquidation) taking into account the limitation periods set by the legal acts (Civil Code of the Republic of Lithuania and others).

i) For the purpose of improvement of websites that we control and in order to offer You better and more personalized services.We use Your personal data, including any personal data that we receive from the use of our websites by You, to improve and develop these websites and to offer You better and more personalized services. For this purpose, we use Your personal data received from Yourself, from the use of our websites by You and from other persons.

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

5.2. We do not process Your personal data for any other purpose incompatible with the above purposes.

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

6.1. Upon receipt of 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, our affiliates and partners that we believe may be of interest to You.

6.2. For this purpose, we process the following personal data of Yours: name, surname, date of birth, telephone number, e-mail address.

6.3. By granting the right to process Your data for direct marketing purposes, You also authorize us for this purpose to contact You by communication means (e. g., e-mail, telephone, short messages (SMS)) or other means of communication (such as Skype, Viber, etc.).

6.4. We may combine our information about You with the information possessed by third parties.

6.5. If You give Your consent to use 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 other marketing and sales purposes. In this case, we will use depersonalized data of Yours.

6.6. Even if You have given Your consent to the processing of Your personal data for direct marketing purposes, You may easily withdraw this consent any time for all or some of the personal data processing activities. You may do this by:

a) communicating Your withdrawal following the instructions given in e-messages and/or offers (e. g., by clicking the link “Do not subscribe” in the newsletter, etc.);

b) arriving at us and submitting a relevant application. The application must clearly indicate Your full name. If You express Your willingness to withdraw Your consent in this manner, You may be asked for a proof of identity;

c) sending us an application at the e-mail address referred to in the present Privacy Policy. The application must clearly indicate Your full name and other registration details (if any). If You express Your willingness to withdraw Your consent in this manner, You may be asked for a proof of identity.

6.7. If You withdraw Your consent, we will endeavour to terminate the processing of Your personal data for direct marketing purposes as soon as possible.

6.8. The withdrawal of Your consent does not automatically oblige us to destroy Your personal data or to provide You with information about the personal data we process, therefore, if You want us to perform these actions, You have to express such a request separately.

7. How do we use cookies?

7.1. We collect information about You using cookies and similar technologies. Cookies are small files that are temporarily stored on Your device’s hard drive and enable to recognize You during other visits to websites, to save Your personal browsing history, options, to customize content, to accelerate website searches, to create a comfortable and friendly website environment, to present it in a more efficient and reliable way. Cookies are commonly used in web browsing, facilitating the enjoyment of websites.

7.2. By means of cookies we may collect the following information: IP address, browser type, demographic data.

7.3. We use the information obtained by means of cookies for the following purposes:

a) to ensure the functionality of websites (e. g., to enable You to personalize websites);

b) to analyse the use of websites;

c) to improve and develop our websites to better meet Your needs;

d) to develop services; and

e) for targeted focus of marketing.

7.4. Without prejudice to the legislation, we may combine the information obtained by means of cookies with the information obtained by other means (e. g., information on the use of websites, personal data provided by Yourself, etc.).

7.5. Websites may use the following types of cookies:

a) technical cookiesare cookies that are essential for the functioning of websites;

b) functional cookiesare cookies that although not essential for the functioning of websites significantly improve their performance, quality and user experience;

c) analytical cookiesare cookies that are used to develop the statistical analysis of navigation methods of website visitors; the data collected by these cookies is used anonymously;

d) target or promotional cookiesare cookies that are used to show offers or other information that may be of interest to Your;

e) cookies of social networksare cookies that are essential for the use of information from websites in one’s social profile account.

7.6. All information about cookies used on websites, their purpose, expiry, and used data are available below:

The title Purpose Expiry date
_ga Used by Google Analytics to evaluate user visit goals, report web site activity to site operators, and improve user experience when visiting a site 2 years
_gat Used by Google Analytics to collect website traffic statistics (collects information about your browser, computer, visits, time spent at the website) Until your browser window closes
_gid
collect Information collected by the Google Analytics service about the visitor’s device Until your browser window closes

7.7. You may give Your consent to use cookies in the following ways:

a) by not deleting them and/or not changing Your Internet browser settings so that it would stop accepting cookies;

b) by clicking the tag “I accept” on the link (bar) appearing on websites;

c) expressing Your consent at the time of signing up in websites.

7.8. You may at any time withdraw Your consent given to us to use cookies. You can do this by changing Your Internet browser settings so that it would stop accepting cookies. How to do this depends on Your operating system and the Internet browser. Detailed information on cookies, their use and refusal options are available on http://AllAboutCookies.orgor http://google.com/privacy_ads.html.

7.9. In some cases, in particular the deactivation of technical and functional cookies, the rejection or deletion of cookies, may slow down browsing, restrict the functionality of certain websites or even block access to websites.

8. Who we provide your personal data to?

8.1. We guarantee that Your personal data will not be sold, provided or otherwise illegally transferred to third parties, and used for purposes other than those they were collected for. We will not transfer Your personal data in any other way but only in compliance with this Privacy Policy and legal acts. However, we reserve the right to provide information about You if we are required to do so in accordance with the law or if we are required to do so by legally operating institutions or prosecution authorities.

8.2. We may transfer Your personal data to companies assisting us to carry out our business as well as direct marketing. We demand our partners to process Your personal data only in accordance with our instructions and applicable legislation governing the protection of Your data. We enter into agreements with these individuals, which oblige both parties to strictly comply with the requirements of data protection.

8.3. The ability of the abovementioned service providers to use Your data is limited, i. e. they cannot use these data for any purposes other than providing services to us.

8.4. An incomplete list of individuals and their categories to whom we transfer Your personal data is provided in paragraph 5.1. above distinguishing each purpose of the use of personal data.

9. How long do we keep your personal data?

9.1. We keep Your personal data for not longer than it is required for the purposes of data processing or by the legislation provided that they allow longer terms of keeping personal data.

9.2. We intend not to keep out-of-date, non-relevant personal data, which is why after updating them (e. g., adjusting Your account, changing Your information, etc.), only the relevant information is stored. Historical information is stored if it is required by the legal acts or for the performance of our activities.

9.3. The terms of storage of Your personal data are provided in paragraph 5.1. above distinguishing each purpose of the use of personal data.

10. How we protect your personal data?

10.1. The data that we collect from You will be in the territory of the European Union, however, may also be transferred or stored outside the EU. They may also be processed by the personnel of ours or our suppliers operating outside the EU. Before transferring Your data outside the EU, we will take all steps necessary to ensure that Your data are processed safely and in compliance with the present Privacy Policy.

10.2. Unfortunately, the online transfer of information is not completely secure. Although we do our best to protect Your personal data, we cannot guarantee the security of data when You transfer Your data to websites, i. e. You assume the risks associated with the transfer of data to websites. When we receive Your data, we will apply strict procedures and security measures to protect Your data against unauthorized access.

10.3. In the event of unlikely circumstances and if we find out a breach in the security of Your personal data that may seriously jeopardize Your rights or freedoms, we will immediately inform You as soon as we learn about it and determine which information has been accessed.

11. External sites

11.1. Websites may contain links to external sites – websites of our business partners or websites that promote our goods and/or services. By following such links to any of such websites, please note that these websites and the services available through them have their own separate privacy policies and we do not accept any liability or obligations for these policies or for the collection of personal data through these websites or through the provision of services, such as contact or location data. Please, review these policies before submitting Your personal information to these websites or before using any of their services.

12. What rights do you have?

12.1. In processing personal data, we guarantee Your rights under the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a subject of personal data, You have the following rights:

a) to be aware of (to be informed about) the processing of Your personal data;

b) to access Your personal data that we process;

c) to demand the correction, supplementation or adjustment of incorrect, inaccurate, incomplete personal data of Yours;

d) to demand the destruction of personal data when they are no longer needed for the purposes for which they were collected;

e) to demand the destruction of personal data if they are processed illegally or when you cancel Your consent to the processing of personal data or do not provide such consent, which is obligatory;

f) to disagree with the processing of personal data or to cancel the previously given consent;

g) to demand the suspension (except for storage) of the processing of Your personal data, in the event of disputes or the need to verify the legitimacy of the processing, the accuracy of data, as well as in cases where we no longer need Your personal data, but You do not want us to destroy them;

h) to demand, if technically feasible, the provision of Your personal data collected with Your consent or for the purpose of performing the contract in an easily readable format, or to request their transfer to another data controller.

12.2. We seek to ensure the exercise of Your rights as a subject of the personal data and to create all conditions for the effective exercise of these rights, however, we reserve the right not to comply with Your requirements when it is necessary to ensure the following:

a) the fulfilment of legal obligations imposed on us;

b) the state security and defence;

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

d) important economic or financial interests of the state;

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

f) the protection of rights or freedoms of Yours or other individuals.

12.3. You may express Your requirements related to the implementation of Your rights in person, by post or by electronic means of communication. Upon receipt of Your request, we may ask You to provide a proof of identity, as well as any additional information necessary for the request.

12.4. Upon receipt of Your request, we will respond to You within 30 calendar days following the receipt of Your application and the date of submission of all documents necessary for the response.

12.5. If we consider it necessary, we will stop processing Your data, except storage, until Your application is resolved. If You legally withdraw Your previously given consent, we will immediately but not later than within 30 calendar days terminate the processing of Your personal data, except in cases specified in clause 12.2 above and in cases provided for by law, i. e. when we are obliged to continue to process Your data by the applicable legislation, the legal obligations imposed on us, court judgements or binding instructions from the authorities.

12.6. In case of refusal to satisfy Your request, we will clearly indicate the grounds for such a refusal.

12.7. If You disagree with our actions or the response to Your application, You may complain about our actions and decisions to a competent state authority.

13. Who can you complain to?

13.1. To file a complaint regarding our processing of data, please provide it in writing, with as much information as possible, using the contact details provided at the end of this Policy. We will cooperate with You and will attempt to resolve all issues immediately.

13.2. If You think that Your rights have been violated under GDPR, You may file a complaint to our supervisor – the State Data Protection Inspectorate, although, above all, we will seek to resolve all disputes along with You.

14. How will this privacy policy be amended?

14.1. All amendments to our Privacy Policy will be published on our websites. If needed, You will be notified about them. The terms and conditions of the new Privacy Policy may also be published on websites and You may be requested to read and accept them in order to continue using websites and/or our services.

15. How to contact us?

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

    • by post – Master Class LT, UAB, Ž. Liauksmino g. 3, LT-01101 Vilnius;
    • by e-mail – info@masterclass.lt.

Privacy Policy Release Date – September 30, 2019.