1. What does this Privacy Policy mean?
In this privacy policy (hereinafter - Privacy Policy) we provide you with information on how UAB Naujienų agentūra ELTA (hereinafter - Company, we) processes your personal data for the purposes set out in the Privacy Policy, as well as information on your rights and their exercise. Hereinafter, any person whose personal data is processed by the Company is referred to as the Data Subject.
This Privacy Policy does not cover cases where the Company acts as a data processor (if any), i.e. this Privacy Policy only provides information about how the Company processes personal data in its capacity as a data controller. If you believe that the Company is also acting as a processor of your data, please contact us to enter into a data processing agreement.
2. About the Company
Company means UAB Naujienų agentūra ELTA, legal entity code 306091052, registered office at Gynėjų g. 16, LT-01109, Vilnius, Republic of Lithuania, data about the Company shall be collected and stored in the Register of Legal Entities of the Republic of Lithuania. The contact e-mail address for personal data protection issues is info@elta.lt.
3. What is personal data?
Personal data is any information collected by the Company about an individual that can be used to identify the individual and is stored electronically or otherwise.
Personal data includes any information, including name, address, IP address, which the Company collects about individuals for the purposes set out in this Privacy Policy or in a separate consent or agreement with the Company.
This data also includes personal information in the public domain that the Company has access to when you contact the Company via social media or through active actions on the Company's social media accounts.
In processing personal data, the Company is guided by Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "General Data Protection Regulation" (the "GDPR")), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, as well as by the other legal acts regulating personal data protection.
Below you can find out how we process your personal data: what personal data we process, the purposes for which we process it, how long we keep it and what rights you have. You can do this by clicking on the option that interests you.
4. What rights do you have and how do you exercise them?
In this section, we provide information about your rights in relation to our processing of your personal data and when you can exercise these rights. If you would like more information about your rights or to exercise them, please contact us at the email address set out in this Privacy Policy.
The company will provide you with information on the action taken following your request for the exercise of your rights without undue delay, but at the latest within one (1) month of receipt of the request. Depending on the complexity of the request and the number of requests received, the aforementioned time limit may be extended for a further 2 (two) months. In this case, we will inform you within 1 (one) month of receipt of the request of such extension and the reasons for it. The company will only refuse to exercise your rights in cases provided for by law.
4.1. Right of access to your personal data
We want you to fully understand how we use your personal data so that you do not experience any inconvenience. We first provide information about how we process your personal data in this Privacy Policy (right to be informed). You can contact us at any time to enquire whether we are processing any of your personal data. If we store or use your personal data in any way, you have the right to access it. To do so, please submit a written request to us at the email address set out in this Privacy Policy, and provide us with proof of your identity (if such proof is required in your particular case).
We expect you to respect the principles of fairness and reasonableness when making such requests.
4.2. Right to withdraw consent
If you have given us your explicit consent to the processing of your data, you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of consent-based processing carried out before the withdrawal of consent.
4.3. Additional rights
The following information sets out the additional rights you may have, which you can exercise by following the procedures described below.
You have the right to ask us to correct any inaccuracies in the data we hold. In this case, we may ask you to confirm the corrected information.
You have the right to ask us to erase your personal data. This right shall be exercised in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679.
You have the right to ask us to restrict or not to process your personal data:
the period necessary to verify the accuracy of your personal data when you make a complaint about the accuracy of the data;
where our collection, storage or use of your personal data is unlawful, but you choose not to request erasure;
where we no longer need your personal data but you need it to establish, exercise or defend a legal claim;
the period necessary to determine whether we have an overriding legal basis to continue processing your personal data if you have exercised your right to object to the processing of personal data.
d. You have the right to the transfer of data processed by automated means and which we have received from you in a structured, commonly used and computer-readable format with your consent or for the purposes of concluding a contract. If you exercise this right, we will, at your request, transfer a copy of the data you have provided to you or to a data controller of your choice.
e. You have the right to object to our use of your personal data in accordance with Article 21 of the GDPR. You have the right to object when your personal data is processed on the basis of legitimate interest (the basis for processing is indicated next to each purpose of processing set out in the Privacy Policy) or for direct marketing purposes.
4.4. Right to request more information
We hope that you will understand that it is very difficult to discuss all possible ways of collecting and using personal data. We endeavour to provide as clear and comprehensive information as possible and we undertake to update this Privacy Policy as and when our use of personal data changes. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or do not understand the information provided, please contact us.
5. Information about the processing of personal data for the purposes of creating and using an account on the elta.lt website
Purpose of the management | Data Subject | Personal data | Legal basis | Storage period |
| Creating an account | Client natural person | Email address, password, name, surname, phone number, date and time of account creation and activation | Article 6(b) GDPR (contract) | Once the form has been filled in, the data will be stored for 7 days, and if the account is not validated within that time, the submitted data will be destroyed. Once an account has been created, the personal data is stored until the account is cancelled. The account shall be archived within 3 working days of the end of the contract and cancelled 2 years after the end of the contract. |
| An employee of the client's legal entity | Email address, password, name, surname, employer's name, job title, telephone number, date and time of account creation and activation | Article 6(f) GDPR (legitimate interest) | ||
| Client natural person, employees of the client's legal entity | Employer and its address (JA), information in the remarks field | Article 6(1)(a) GDPR (consent) | ||
| Administration of the free trial period (ensuring that the free trial period is used only 1 time) | Client natural person, employees of the client's legal entity | Email address, name, expiry date of probationary period | Article 6(1)(f) GDPR (legitimate interest) | 10 years after the end of the probationary period |
Account administration/ support | Client natural person | Personal data processed for the purpose of creating an account, the date and time of logins, and information about the actions performed using the account | Article 6(b) GDPR (contract) | Personal data is stored until the account is terminated. The account shall be archived within 3 working days of the end of the contract and deleted 2 years after the end of the contract. |
| An employee of the client's legal entity | Article 6(f) GDPR (legitimate interest) | |||
| Client natural person, employees of the client's legal entity | ELTA news, photo areas of interest | Article 6(1)(a) GDPR (consent) | Until the data subject changes his/her preferences (retained to the same extent as other account data upon termination of the contract) | |
| Sending newsletters (provision of services) | Client natural person | Selected method of receiving the news feed, if you choose to receive the news feed by email - email address | Article 6(b) GDPR (contract) | Before account cancellation |
| An employee of the client's legal entity | Article 6(f) GDPR (legitimate interest) | Before account cancellation | ||
| Opportunities to publish reports | The customer's employee or representative who posted the notice
| Data that is not publicly available but is stored in your account: email, name, job title, published press release (date, time, content) | Article 6(f) GDPR (legitimate interest in the performance of the contract with the client JA) | Before account cancellation |
| Publicly available data (where stated in the press release): name, surname, place of work, job title, contact details (email address, phone number). | Article 6(1)(a) GDPR (consent) | Until the press release is published |
6. Processing of personal data in connection with the conclusion and performance of contracts with customers, suppliers, partners, etc. (to the extent that this does not include the creation and use of elta.lt accounts as discussed above)
Management objective | Personal data | Legal basis | Storage period | Other remarks |
| Establishing and executing contracts with suppliers, partners, etc. (natural persons) | Name, surname, date of birth, address, business license/individual activity certificate number (of the service provider), details of the services provided, bank account number of the natural person providing or receiving the service or goods | Article 6(1)(b) GDPR (contract) | During the term of the Agreement
| The data is transferred to data processors that provide server rental and other administration services. |
| Establishing and executing contracts with clients, suppliers, partners, etc. (legal entities) | Name, surname, title, basis of representation, email address, telephone number, content of correspondence | Article 6(1)(b) GDPR (contract) | During the term of the Agreement | The data is transferred to data processors that provide server rental and other administration services. |
| Bookkeeping | Name, surname, details of services received/provided and goods sold, and other personal data in invoices and other accounting documents | Article 6(1)(c) GDPR (legal obligation) | The data shall be kept within the time limits laid down by the legislation governing the keeping of accounting records and in accordance with the General Document Retention Periods Index | The data is transferred to data processors that provide server rental and other administration services. |
| Archiving | Data processed for the purposes of concluding and performing contracts with customers, suppliers, partners, etc. (both natural and legal persons) | Article 6(1)(c) of the GDPR, the legal obligation is provided for in point 10.37 of the General Index of Document Retention Periods, approved by Order of the Archivist of the Republic of Lithuania No V-100 of 9 March 2011. | 10 years (after contract expiry) | Data is transferred to data processors providing server rental and other administration services |
| Defending legal claims | Data processed for the purposes of concluding and performing contracts with customers, suppliers, partners, etc. (both natural and legal persons) | Article 6(1)(f) GDPR (legitimate interest - defence of legal claims) | 10 years (after contract expiry) | Data transmission to courts, public dispute resolution bodies, litigants, lawyers and other legal service providers. It is also transferred to data processors providing server rental and other administrative services. |
7. Direct marketing
We may carry out direct marketing to individuals who have provided their contact details and who have expressed an interest in receiving direct marketing communications, such as sending commercial offers, other commercial information about our services, surveys about satisfaction with our services, etc. For the purpose of direct marketing, we process the following personal data: the name of the organisation represented, position, email address, telephone number, content and dates of communications sent. Your data will be processed for the purpose of direct marketing for a period of 3 years from the date of your consent. Direct marketing communications are carried out (your contact details are processed) on the basis of consent.
If you are our customer and you did not object to direct marketing of our services similar to the services you have purchased at the time of ordering the services (by entering into a contract), we may send direct marketing communications to the email address specified in the contract on the basis of legitimate interest. In this case, direct marketing communications will be sent to the email address specified in the contract for the duration of the contract and for 1 year after its termination, unless you object to the further processing of the data for the purpose of direct marketing before that time. In this case, we will immediately stop sending you direct marketing communications
Personal data processed for the purpose of direct marketing shall be transferred to the processors necessary to carry out direct marketing.
You have the right to opt-out of receiving direct marketing communications at any time by contacting us at the email address set out in Section 2.
8. Selection of candidates
We collect and process your personal data: your workplace, email address, date of birth, address, education, surname, telephone number, first name, preferred job, date of receipt of your CV, information about your personal qualities, your work experience (last workplace, length of service with the workplace, your last job title, other work experience), information on your knowledge of foreign languages (language, reading, writing, speaking levels), your ability to work with computer programmes, and any other information contained in your CV, letter of recommendation and/or cover letter; your preferred salary, for the purpose of participation in the selection process, on the basis of your consent, which you express to the Company by sending your CV and/or cover letter. If you do not submit your CV and/or cover letter, we will not be able to assess your suitability for the position offered.
With your consent, we will contact your current employer, and we may contact your former employer on the basis of our legitimate interest (to select a suitable candidate) and on the basis of Article 5(2) of the Law on the Legal Protection of Personal Data of the Republic of Lithuania, in order to verify information about your qualifications, professional abilities and business qualities (such as your work performance, relations with clients and/or colleagues, your performance evaluation, etc.). You may withdraw your consent or, as the case may be, object to us contacting your former employer at any time by notifying us at the email address set out in paragraph 2 of the Policy.
In the event that you do not express your individual consent to the processing of your personal data for a longer period of time after the end of the specific job selection, we undertake to delete and/or destroy your personal data within 3 working days after the signing of the contract with the successful candidate or the decision to close the selection. If you are not selected but have given your consent to the processing of your personal data for the purpose of offering you a job in the future, we will keep your data for 1 year after the end of the selection on the basis of your consent.
On the basis of our legitimate interest, we will process data about the person (name, surname, email, telephone number, information provided by the person) indicated by the candidate - a former or current employer or a person providing a reference, and the information provided by the person - for the purpose of selecting the candidate. In this case, our legitimate interest is to select the right candidate for the position we are seeking. We will delete this data within 3 days after the contract with the selected candidate has been signed or the decision to close the selection has been taken.
9. Protecting confidential company information and business continuity
In order to ensure its legitimate interest in the protection of the Company's confidential information, the continuity of the Company's business, the protection of the Company's information systems against hacking and data theft, viruses, dangerous websites, malware, copyright infringement through technical and internet access and the protection of the computer network against heavy loads, the Company may review the correspondence of its employees with contractors and the information stored in the Company's electronic equipment. For these purposes, the Company processes the following personal data of its employees and of the persons who send or receive the employees' correspondence: e-mail address, name of the sender or recipient, date, content of the information contained in the electronic work tools.
Data collected for the purpose of protection of confidential information and protection of the Company's information systems against hacking and data theft, viruses, dangerous websites, malware, copyright infringement through technical and internet access and computer network against heavy loads, shall be stored for the purpose of defence of legal claims for a period of 4 years in accordance with the provision set out in Article 1.125 (9) of the Civil Code of the Republic of Lithuania. For the purpose of defending legal claims, the data may be made available to recipients (data controllers) such as courts, law enforcement authorities, public authorities settling disputes, litigants, lawyers and other entities providing legal services.
10. Protecting legitimate interests
The company shall, on the basis of its legitimate interest to defend its rights, including in the event of civil disputes, process the names, surnames, personal identification numbers, case circumstances, other information related to the case, and information available in the public domain of the persons involved in the case or their employees. The data may be communicated to law enforcement authorities, lawyers or bailiffs for the purpose of debt collection. The data shall be destroyed 1 year after the final settlement of the case and the full satisfaction of the Company's claims (if satisfied).
11. Internal company administration (exercising shareholders' rights)
The company may, for internal administration purposes (upon a shareholder's request for the exercise of the right to information), transfer to the shareholder any personal data (as recorded in the documents provided to the shareholder). The transfer is made in fulfilment of a legal obligation imposed on the Company (Article 6(1)(c) GDPR), and the personal data shall be processed only until they are transferred to the shareholder.
12. Contact us
There are several ways you can contact the Company: by phone, email, social media accounts or by sending a letter to the Company's registered office. We receive, review and respond to all communications ourselves. If you contact us, we may process the data you provide to us, i.e. email address, name (if provided), username (if the request is sent via a social networking account), workplace (if provided), the date, time, recipient, sender (if the message is addressed to you), and the content of the messages sent and received.
Such data will be processed in order to answer your questions and process your suggestions. If you do not provide your contact details, it will not be possible to contact you.
Correspondence is stored for 1 year from the date of receipt of the message, except for information for which other time limits are specified in the Privacy Policy or in legal acts. If you have communicated a news item to us and we have published it, the data of the communication with you will be stored until we publish the publication based on your communication.
Any personal data you provide when you interact with us is only used for the purposes set out above and to view messages and administer and manage communication flows. We undertake not to use your personal data in any publications in a way that could identify you without your explicit consent.
Please note that we may need to contact you by post, email or telephone. Please notify us of any changes to your personal data.
13. Website, cookies
Our website uses cookies and other tracking technologies. A cookie is a small file made up of letters and numbers that we place on your browser or on the hard drive of your computer with your consent. We use different cookies for different purposes. Cookies also help us to distinguish you from other users of the Website, thus ensuring a more pleasant experience and enabling us to improve the Website.
Most browsers allow you to reject all cookies, and some browsers only allow you to reject third party cookies. You can therefore take advantage of these options. However, please note that blocking all cookies will have a negative impact on the use of the Website and without cookies you will not be able to use all the services provided on the Website. For more information, please visit AllAboutCookies.org or www.google.com/privacy_ads.html
A detailed and up-to-date list of the cookies we use:
Category | Provider | Purpose | Expiry | Type |
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies. | ||||
CookieConsent | Elta.lt | Stores the user's cookie consent state for the current domain. | 1 year | HTTP cookie |
laravel_session | Elta.lt | This cookie is used internally by the website’s owners, when uploading or renewing website content. | 1 day | HTTP cookie |
XSRF-TOKEN | Elta.lt | Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor. | 1 day | HTTP cookie |
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. | ||||
_ga | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. | 2 years | HTTP cookie | |
_ga_# | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. | 2 years | HTTP cookie | |
_gat | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. | 1 day | HTTP cookie | |
_gid | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. | 1 day | HTTP cookie | |
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies. | ||||
| phpdebugbar-height | Elta.lt | Unclassified | Persistent | HTML Local Storage |
| viewedItems_pressreleases | Elta.lt | Unclassified | Persistent | HTML Local Storage |
Cookies are absolutely essential.
These cookies are essential for our website to work. The basis for the use of such cookies is Article 73(4) of the Law on Electronic Communications of the Republic of Lithuania. These cookies are necessary for the operation of the website and cannot be disabled on our systems. They are usually used in response to what you do on the website, such as starting to browse or selecting your privacy settings. These cookies do not store any personally identifiable information about you and are deleted as soon as you turn off the website.
Analytical and/or performance cookies.
These cookies allow us to count the number of visits to the website and to monitor the flow of visitors to the website so that we can improve the website. They allow us to know which pages of the website are the most or least visited and to monitor how visitors navigate through the website. We use Google Analytics for this purpose. The data collected is not accessible to any other party. The information collected by cookies is anonymous and is not intended to identify you or to influence your browsing experience while you are on the website. If you do not consent to the use of these cookies, you will not be recorded in the visit statistics. The processing of data collected by these cookies is based on your consent.
Commercial cookies.
These cookies, used by us and third parties, are designed to show you offers or other promotional information that may be of interest to you. We use cookies that collect data about your browsing history and identify your areas of interest so that we can show you relevant marketing information. The processing of data collected by these cookies is based on your consent.
14. Social media
The information you provide to us via social media (including messages, the use of the "Like" and "Follow" fields, and other communications) is controlled by the operator of the social network.
Our Website provides links to our social media accounts ("Social Accounts"). We currently administer the following Social Accounts:
Facebook account for Naujienų agentūra ELTA;
Account Naujienų agentūra ELTA, UAB on YouTube;
Account Naujienų agentūra ELTA on LinkedIn;
We process the information contained in social accounts for the purpose of administering the accounts on the basis of your consent. We do not separately store the information contained in the Social Accounts (where the data is processed for the purpose of administering the Social Accounts, but the data may be stored if it is necessary to process the data for another purpose, such as for the purpose of enforcing rights).
When you visit Social Accounts, social network administrators place cookies on your device that collect personal data. Cookies are stored both if you are a registered user of a social network and if you do not have an account with the relevant social network. We do not have access to the personal data collected about you and can only obtain statistical information from the administrators of the Social Networks about the traffic of the Social Accounts.
We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions about how they use your personal data.
15. Provision of data to third countries
The data controllers of social media networks (Facebook, Youtube) are established in a third country), but both companies participate in the EU-US Data Privacy Framework (EU-US Data Privacy Framework).
The data of European Union residents published on Facebook is processed by the data controller Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). You can find information on how you can exercise your rights as a data subject at: https://lt-lt.facebook.com/privacy/explanation/.Turėdami. If you have any complaints about the processing of your personal data by Meta Platforms Ireland Limited or the exercise (non-exercise) of your rights as a data subject, you have the right to lodge a complaint with the supervisory authority in charge of Meta Platforms Ireland Limited, namely the Irish Data Protection Commission or the State Data Protection Supervisor.
The data of YouTube social network users residing in the European Union are processed by the data controller Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Information on how you can exercise your rights as a data subject is available at: https://policies.google.com/privacy?hl=lt. If you have any complaints regarding the processing of your personal data by Google Ireland Limited or the exercise/non-exercise of your rights as a data subject, you have the right to lodge a complaint with Google Ireland Limited's supervisory authority, the Irish Data Protection Commission or the National Data Protection Inspectorate.
16. Receipt and disclosure of data
We receive your data from you, your devices, job applicants, our employees and our contractors.
We disclose information about you to the data processors we use (the company from which we rent servers, software providers, IT maintenance providers, recruitment companies, etc.). In order to ensure the security of personal data, we do not make public the specific processors we use, but you can find out about them by exercising your right of access to the personal data we process.
In addition, we may disclose information about you:
if we have to do so by law;
when you intend to sell the Company's business or part of its assets by disclosing your personal data to a potential buyer of the business or part of it;
the sale of the Company's business or a substantial part of its assets to a third party.
Except as provided in this Privacy Policy, we do not provide your personal data to any third parties.
The list of recipients or categories of recipients specified in the Privacy Policy is subject to change, therefore, if you wish to be informed about changes in the recipients of your personal data, please notify us by sending us an e-mail to the e-mail address specified in this Privacy Policy, indicating in the body of the e-mail "I wish to receive information about changes in the recipients of my personal data, name, surname".
17. Security of your personal data
Your personal data will be processed in accordance with the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal requirements. When processing your personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.
18. Complaints
If you believe that your rights as a data subject have been and/or may be violated, please contact us immediately at the email address specified in this Privacy Policy. We ensure that only upon receipt of your complaint will we contact you within a reasonable period of time to inform you of the progress of the investigation of the complaint and, subsequently, of the outcome.
If you are not satisfied with the results of the investigation, you can lodge a complaint with the supervisory authority, the State Data Protection Inspectorate: https://vdai.lrv.lt/.
19. Responsibility
You are responsible for maintaining the confidentiality of the data you provide to us and for ensuring that the data you provide to us is accurate, correct and complete. If there is any change in the data you have provided, you must inform us immediately by e-mail. In no event shall we be liable for any damage caused to you as a result of your providing incorrect or incomplete personal data or your failure to inform us of any change in the data.
20. Changes to the Privacy Policy
We may update or change this Privacy Policy at any time. Registered users will be notified of any changes to this Privacy Policy by a notice sent to their account and the email address provided in their account. Other, non-registered, visitors can find the current version of the Privacy Policy by clicking on the link to the Privacy Policy on each page of the website. When we make more significant changes to the Privacy Policy, we will take additional steps to bring the changes to your attention (we will post a news item discussing the changes to the Privacy Policy, we will post a separate information bar on the website to inform you of the fact of the changes, etc.). If you would like to receive the updated Privacy Policy personally, please notify us at the email address set out in Section 2.
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