Principles of processing personal data
In these Principles of Processing Personal Data (hereinafter also – Principles) the information on how ‘Linas Agro’ processes personal data has been presented.
These Principles are applied for the mutual relations of ‘Linas Agro’ and the Customers which are using, were using, have expressed the intention to use or are in any other ways related with the services rendered by ‘Linas Agro’, including the relations with the Customers which had appeared before these Principles coming into effec
A Customer – any natural person which is using, was using, has expressed the intention to use or is in any other ways related with the services rendered by ‘Linas Agro’.
Personal data – any information directly or indirectly related with the Customer.
Processing – any operation performed with the Personal data (including gathering, entering, saving, changing, granting an access, presentation, transfer of queries and others).
‘Linas Agro’ – any legal entity or a branch of a legal entity belonging to the parent company AB Linas Agro Group, the registered office of which is in Lithuania and which acts as the Manager of the Personal data. The list of subsidiaries is announced in website www.linasagrogroup.lt.
2. General Provisions
2.1 In these Principles general provisions on how ‘Linas Agro’ processes Personal data have been presented. Additional information on the processing of Personal data can be presented in the Services Agreements and other documents related with services, also in the website of AB Linas Agro Group and the websites of its subsidiaries.
2.2 ‘Linas Agro’ ensures the confidentiality of Personal data according to the requirements of the legal acts in effect and the implementation of suitable technical and organizational measures intended for the protection of the Personal data from illegitimate access, revelation, accidental loss, changing or destruction or other illegitimate processing.
2.3 For the processing of personal data ‘Linas Agro’ can invoke the help of data processers. In such cases ‘Linas Agro’ takes the necessary measures aiming to secure that such data processers processed the Personal data following the instructions of ‘Linas Agro’ and the valid legal acts and demands to carry out proper Personal data protection measures.
2.4 The policy of the cookies used by ‘Linas Agro’ is announced in AB Linas Agro Group website www.linasagrogroup.lt.
3. Categories of Personal Data
Personal data can be obtained directly from the Customer, from the activities of the Customer when he uses services and from external sources, such as the registers managed by the state and private persons and other third parties. The principal categories of the Personal data which ‘Linas Agro’ gathers, however, it does not limit to them, are as follows:
Personal identity data, as – name, surname, personal number, birthdate, data of the document of personal identity (a passport, a personal identity card).
Data for contacts, as – address, telephone number, e-mail address.
Data on the family, as – information on the family of the Customer, other related persons.
Data on the ties with legal entities, as – data which the Customer presents or which are obtained from public registers or the third persons for the purposes of conducting a transaction on behalf of a corresponding legal entity.
Data related with profession, as – data on the educational background and professional activity.
Financial data as – data on accounts, owned property, transactions, loans, income, liabilities, the financial situation of the Customer which are obtained when the Customer chooses and services are rendered/goods are supplied with deferred payment related with crediting risk of which the Company must be aware.
Data on the origin of the wealth and property, as – data on the parties of the transactions of the Customer and performed activity.
Data related with the reliability of the Customer and evaluation of the activity, as – data on the financial operations, harm done to ‘Linas Agro’ or any third party.
Data obtained and (or) created while fulfilling the requirements of the legal acts, as – data obtained according to the queries of the law enforcement institutions, Notaries, Tax Administrator, courts and bailiffs, data on the income, financial liabilities, owned property and outstanding debts.
Data gathered using communication and other technical means, as – data which were gathered when the Customer came to the subdivisions of ‘Linas Agro’ and visited other places rendering ‘Linas Agro’ services (data of video monitoring) or while communicating with ‘Linas Agro’ by telephone, means of video and/or audio recording, e-mail, notifications and other communication means, such as social networks; data related with the visits of the Customer in ‘Linas Agro’ websites or using other channels of ‘Linas Agro’ communication.
Data related with rendering of services/selling of goods, as – data on the carrying out or failure to carry out agreements, conducted transactions, valid or expired agreements, presented applications, requests or complaints, applied interest and payments for services.
Data on behaviour habits, priorities and satisfaction with services, as – data on the activeness in using the services, services rendered to the Customer, personal evaluations, the response of the Customer about the services, data on the mode of life, interests and if the Customer is satisfied with the services.
Data on participation in the games and promotional actions organized by ‘Linas Agro’, as – data on the prizes won during games or promotional actions.
4. Purposes and Basis of Processing Personal Data
The principal purposes which ‘Linas Agro’ strives to achieve during processing Personal data:
4.1 Maintenance of relations with the Customers and offering of opportunities to use the products and services proposed by ‘Linas Agro’ and their administering
Concluding an agreement with the Customer and its carrying out, renewal of the data on the Customer aiming to secure their correctness employing external and internal registers, when that is necessary while carrying out an agreement or aiming to take actions before concluding an agreement at the request of the Customer or when performing a legal obligation.
4.2 Evaluation of credit and risk
Aiming to establish what services and products and under what conditions can be offered to the Customer, when giving commodity credits, loans and rendering other financial services, to perform the duties provided for in the legal acts related with the evaluation of the risk of solvency and fulfilling of obligations, to manage the indebtedness of the Customer, to fulfil the requirements related with the management of the activity risk and sufficiency of capital, to do internal calculations and make internal analysis when that is necessary for the carrying out of an agreement, aiming to take actions before concluding an agreement at the request of the Customer or when performing a legal obligation or striving to the legitimate interest of ‘Linas Agro’ to ensure a reliable management of risk.
4.3 Defence of interests of the Customer and (or) ‘Linas Agro’
Aiming to defend the interests of the Customer and (or) ‘Linas Agro’, exercise the services rendered by ‘Linas Agro’ quality control, present the evidence of a commercial transaction or other business communication (recording of conversations), when that is necessary during carrying out of agreement, aiming to take actions before concluding an agreement at the request of the Customer or when performing a legal obligation, striving for the legitimate interest of ‘Linas Agro’ to prevent any improper or illegitimate use of the services of ‘Linas Agro’ and products offered by it, to impose restriction on such use and to conduct its investigation, to provide training of the employees and security of services quality.
To assure the safety of ‘Linas Agro’ and (or) the Customer, to protect the life and health of the Customer and (or) its representative and other rights of ‘Linas Agro’ and the Customer (video and (or) audio recording), striving for the legitimate interest of ‘Linas Agro’ to protect its customers, employees, visitors and their and ‘Linas Agro’ wealth.
4.4 Rendering of additional services, inquiry about the opinion of the Customers, market research and gathering of statistical data
For the aim of offering of services to a Customer chosen by ‘Linas Agro’ or partners responsibly selected by ‘Linas Agro’, including personal offers, having got the consent of the Customer or striving for legitimate interest of ‘Linas Agro’ related with the offer of additional services.
For the aims of organization of opinion polls, market research and gathering of statistical data, organization of games and promotion actions for the Customers, having got the consent of the Customer or striving for legitimate interest of ‘Linas Agro’ to improve the quality of ‘Linas Agro’ services, experience of the Customers as the recipients of the services and create new products and services.
4.5 Fulfilling legal obligations and establishment of identity
During fulfilment of requirements of legal acts and international agreements, related, for example, with the putting into practice of the principles of responsible borrowing/commodity credits with deferred payment, putting into practice of the principles “know your customer”, striving to take actions at the request of the Customer before concluding an agreement, performing a legal duty or striving for legitimate interest of ‘Linas Agro’ to secure proper management of risk and organization.
4.6 Preventing services abuse and securing proper rendering of services
Aiming to offer an opportunity to use electronic channels and provide the control of their use and operation, to prevent illegitimate access and their illegitimate use for the purposes of ensuring information security, when that is necessary while carrying out an agreement, striving to take actions at the request of the Customer before concluding an agreement or when performing a legal duty or striving for legitimate interests of ‘Linas Agro’ related with opening up an opportunity to use the e-services of ‘Linas Agro’, control of their use and their action.
Aiming to improve the technical means, infrastructure of informational technologies, to secure the application of the rendered service to the used equipment, to create new ‘Linas Agro’ services by testing and improving technical means and IT infrastructure, striving for legitimate interest of ‘Linas Agro’ related with the improvement of technical means and IT infrastructure.
4.7 Advancing, meeting and defending of lawful demands
For the aims of advancing, meeting, transfer and defence of lawful demands, when that is necessary while carrying out an agreement, striving to take actions at the request of the Customer before concluding an agreement or when performing a legal duty or striving for legitimate interest of ‘Linas Agro’ related with meeting of lawful demands.
4.8 Conducting transactions via payment system
When meeting liabilities related with conducting of international transactions via credit institutions and making local payments via national, European and international payment systems and securing the abidance by rules and obligations related with the use and safety of payment cards established in the European and international standards and certification systems when that is necessary while carrying out an agreement, striving to take actions at the request of the Customer before concluding an agreement or when performing a legal duty.
5. Profiling, Making Personal Offers and Automated Decision-taking
5.1 The profiling carried out by ‘Linas Agro’ is related with the automated Personal data processing aiming to evaluate certain personal features of a Customer and thus to analyse or forecast, for example, the economic situation, personal choices, interests, to establish the place of residence of such person. Profiling is used for making the analysis related with the consultation provided to the Customer, for the purposes of direct marketing, for automated decision-taking related, for example, with the evaluation of credit solvency, risk management, evaluation of insurance risk and transactions monitoring, aiming to prevent fraud; such carried out profiling is based on legitimate interests of ‘Linas Agro’, performing legal duty, carrying out an agreement or by the consent of the Customer.
5.2 ‘Linas Agro’ can process Personal data aiming to improve the quality of the e-services rendered to the Customer, for example, by applying the offered services for the used device, also aiming to prepare personal offers to the Customer. If the Customer did not contradict to the processing of Personal data for the purpose of direct marketing, ‘Linas Agro’ can process Personal data to make general and personal offers of the services rendered by ‘Linas Agro’. Such marketing activity can be based on the services used by the Customer and the way the Customer uses them and manages ‘Linas Agro’ digital channels.
5.3 Profiling activity for the purpose of preparation of personal offers and marketing is based on the legitimate interest of ‘Linas Agro’. ‘Linas Agro’ allows for the Customer’s management of his privacy settings using a convenient tool.
5.4 ‘Linas Agro’ can also gather statistical data on the Customer, such as typical behaviour and mode of life. Statistical data for the development of segments/profiles are gathered from external sources and can be used together with the data owned by ‘Linas Agro’.
6. Personal Data Recipients
The Personal data are communicated to recipients, such as:
6.1 State institutions, other persons/entities performing the functions assigned to them by laws (for example, law enforcement institutions, bailiffs, Notaries, institutions performing the activities of tax administration, investigation of financial crimes).
6.2 The legal entities belonging to AB Linas Agro Group.
6.3 Auditors, legal and financial consultants, data processers authorized by ‘Linas Agro’.
6.4 The third parties managing registers (including, loan registers, Residents’ Register, Register of Legal Entities, securities registers or other registers in which personal data are processed) or which mediate in furnishing with Personal data from such registers.
6.5 Legal entities and natural persons to which claims for the Customer’s indebtedness are assigned, courts, non-judicial institutions of adjudgement and bankruptcy administrators.
6.6 Entities/persons which secure proper fulfilment of the obligations of the Customer to ‘Linas Agro’, such as sponsors, guarantees, pledgers.
6.7 Other entities/persons related with the provision of ‘Linas Agro’ services, such as providers, sellers of archiving, mail services.
7. Geographical Processing Territory
7.1 Usually Personal data are processed within the territory of the European Union / European Economic Space (EU/EES), however, in certain cases they can be transferred and processed beyond the borders of EU /EES.
7.2 Personal data can be transferred and processed beyond the borders of EU / EES, when the transfer is necessary for concluding and carrying out an agreement or the Customer has given a consent; also if proper precautionary measures have been taken. Proper precautionary measures are as follows:
• an agreement in which standard conditions or other confirmed clauses, behaviour codes, certificates and others enacted by the European Commission confirmed according to the General Data Protection Regulation have been included;
• the country do not belonging to EU / EES in which the recipient of Personal data is according to the resolution of European Commission secures the protection of Personal data of sufficient level;
7.3 The Customer having presented a request can acquire more information about the transfer of Personal data beyond the borders of EU / EES.
8. Period of Protection
8.1 Personal data are processed not longer than it is necessary. The period of protection of Personal data is defined taking into consideration the character of the agreements concluded with the Customer, by legitimate interest of ‘Linas Agro’ or the requirements of legal acts (e.g., regulating the term of record, limitation of action and others).
9. The Rights of a Customer as a Data Subject
The rights of a Customer (Data Subject) secured to him by legal acts related with the processing of his Personal data include the following right:
9.1 To demand to correct his Personal data, if they are incorrect, non – exhaustive or imprecise.
9.2 To object to the processing of his Personal data, if the basis of processing of Personal data are legitimate interests including profiling for the purposes of direct marketing (e.g., getting marketing offers or participation in polls).
9.3 To demand to delete his Personal data which are processed only with his consent, if the Customer cancels the corresponding consent. This right is not applied, if the Personal data the deletion of which is requested are processed on another legal basis as well such as the processing necessary for carrying out an agreement or performing of a duty according to the applicable legal acts.
9.4 To limit the processing of his Personal data according to the applicable legal acts, e.g., for a period during which ‘Linas Agro’ will evaluate if the Customer is entitled to request his Personal data to be deleted.
9.5 To acquire information about whether ‘Linas Agro’ is processing his Personal data and, if yes, to familiarize with them.
9.6 To get the Personal data furnished with by himself which are processed on the basis of his consent or carrying out an agreement in writing or in commonly used electronic form and, if possible, to transfer such data to another services provider (transferability of data).
9.7 To cancel his consent to process Personal data.
9.8 To object to completely automated decision-making applied to him, including profiling, if such decision-making has a legal or similar significant effect on the Customer. This right is not applied in the case when such decision-making is necessary for the purposes of concluding or carrying out an agreement with the Customer, is permitted according to the applicable legal acts or the Customer has given a definite consent to it.
9.9 To lodge a complaint regarding the processing of Personal data to the State Data Protection Inspectorate the address of the website of which is www.ada.lt, if the Customer thinks that his Personal data are processed violating his rights and legitimate interests according to the applicable legal acts.
10. Contact information
10.1 The Customer is entitled to address ‘Linas Agro’ aiming to submit queries, to cancel the given consents, to file requests regarding the exercising of the rights of the data subject and complaints regarding the processing of Personal data. You can do it by sending an e-mail to email@example.com.
11. Validity and Amending of the Principles
11.1 The Customers can familiarize with these Principles in website www.linasagrogroup.lt.
11.2 ‘Linas Agro’ is entitled to amend these Principles ex-parte any time informing the Customer about the amendments by announcing it in AB Linas Agro Group website, informing the Customer by post, an e-mail, an SMS or in a different way (e.g., by publishing) not later than before 30 (thirty) calendar days till the coming into effect of such amendments.