We understand the special importance of protecting your personal data, so we only collect and process the data necessary for carrying out our activities. We process personal data lawfully, transparently, and fairly, for predetermined purposes, and only to the extent necessary to achieve the processing objectives. When processing personal data, we strive to ensure that they are accurate, secure, confidential, properly maintained, and stored.
When processing your personal data, we comply with the General Data Protection Regulation (EU) 2016/679, adopted on April 27, 2016 (hereinafter – GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as other personal data processing requirements established by legal acts.
1. WHAT IS THIS DOCUMENT?
1.1. After reading this Privacy Policy (hereinafter – the Privacy Policy), you will find out how and for what purposes we process your personal data, where we obtain them from, to whom we provide them, how we protect them, and what rights you have as a data subject.
1.2. This Privacy Policy sets out the privacy terms for using the main Draugas.lt website www.draugas.lt and its inseparably related projects, as well as all websites under the “draugas.lt” domain (hereinafter all the websites together referred to as the “Websites”) and (or) the Draugas.lt mobile application, which can be downloaded from the Apple App Store, Google Play, and Huawei AppGallery, as well as our accounts on social networks Facebook (https://www.facebook.com/apsilankyk.draugas.lt), Instagram (https://www.instagram.com/draugas.lt), YouTube (https://www.youtube.com/channel/UCNSUicqQkIXySBmoSAsKLGQ, https://www.youtube.com/channel/UCysBLKPIemqFKVb0oXmkX4A) insofar as it relates to our processing of personal data and our privacy rules. Please read this Privacy Policy carefully, as each time you visit any of the Websites and (or) our account(s), you agree to the terms of this Privacy Policy. If you do not agree with these terms, please do not visit any of our Websites and (or) our accounts or use our mobile application.
1.3. In this Privacy Policy, the term “personal data” means any information that can identify you directly or indirectly – for example, your last name, first name, email address, phone number, location data, and internet identifiers, characteristic features of your person, or other personal data as defined by the GDPR.
2. WHO ARE WE?
2.1. We are UAB “Draugas.lt projektai”, legal entity code 304523741, registered address Olimpiečių g. 5-7, Vilnius, contact email pazintys@dr.lt, contact phone number +37066612056.
2.2. Pursuant to the provisions of legal acts, we are the controller of your personal data in the cases specified in this Privacy Policy.
2.3. Personal data are processed and used to properly provide the Services to Visitors, ensure their quality, manage visitor flows, and offer Visitors the opportunity to use new products developed and (or) created by Draugas.lt. The Visitor’s data is also processed for the purpose of his/her registration and for administering the relevant Website database, as well as for direct marketing and promotional activities (direct marketing games, quizzes, contests). Draugas.lt will collect and store Personal Data electronically and, if necessary, provide extracts of such Personal Data in other forms. Anonymous Visitor Personal Data (by which a specific Visitor cannot be identified) is processed and used to assess the quality of the Services, describe the Visitor profile to be able to offer relevant Services, and for Website auditing.
3. WHAT PRINCIPLES DO WE FOLLOW?
3.1. When processing your personal data, we:
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
4.1. We process your personal data obtained in the following ways:
4.2. We may combine the personal data we have received from you when you use all our Websites (or one of them, or several Websites together), the mobile application, our account(s), or all of them together, with data we have collected from other public and (or) available sources (for example, we may combine personal data you have provided with data obtained through the use of Website cookies or lawfully obtained from third parties).
5. FOR WHAT PURPOSES AND HOW DO WE PROCESS YOUR PERSONAL DATA?
5.1. We will process your personal data for the following purposes:
Data categories | IP address, type of internet browser used, age, number of visits, time spent on the Website, the internet source from which you came, information about the device used, language, country, internet provider, etc. |
We obtain data from | Data obtained from you while you use the Website(s), the mobile application, generated and (or) obtained from other persons (including social network operators) |
Data categories | First name, phone number, email address, gender, date of birth, place of residence, last name (if it actually forms part of the email address), data on the ordered services (e.g., date and time of the ordered services, name of the services, quantity, nature of the ordered services), the history of personal offers presented to you and information about their use |
Legal basis for data processing | Your consent |
Data processing period | 2 years from the date you gave us your consent |
We obtain data from | You, including when you use the Website(s), our account(s), mobile application |
We provide or transfer data to | Companies providing newsletter sending services, other related companies and partners |
Data categories | Visitor’s first name, gender, email address, last name (if it actually forms part of the email address), date of birth, search and (or) interest intentions, city, relationship status (married, single, etc.), height, body type (slim, large, etc.), information about having (or not having) children, eye color, hair color, sexual orientation, education, information about smoking and alcohol consumption habits, information about languages spoken, occupation, monthly income, hobbies (music, books, films, sports, hobbies, etc.), personality description, image (in the photos and (or) videos posted by the visitor, as well as in the verification photos used for the photo confirmation process), phone number, the content of posted comments, the content of ads (e.g., ad topic, category, desired action (selling, buying, etc.), city, price, object of the ad, etc.) |
Legal basis for data processing | Contract (Terms of Use), in the case of information about sexual orientation – consent |
Data processing period | 2 years from the date of your last login to your account |
We obtain data from | You |
We provide or transfer data to | Other Website(s) visitors (e.g., when they want to communicate, view your profile, play games with you, view your ad and (or) the comments you have written, or otherwise use our services insofar as such use is inseparable from the data you make public), game operators. |
Data categories | First name, last name, email address, phone number, data on ordering paid services (e.g., service order date, start date, end date, duration, status, etc.), data on the services ordered and used and the fees for them, payment information (e.g., bank account details, ordered and (or) provided paid services, date, payment number, amount due and (or) amount paid, payment method, payment date, payment status, data related to a debt (e.g., the reason for the debt, date, debt amount, type of debt, etc.)) |
Legal basis for data processing | Contract (Terms of Use) |
Data processing period | 2 years from the date of receipt of payment for the service |
We obtain data from | You and third parties, such as your mobile operator, the bank or electronic money institution where you have an account, and the online payment platform |
We provide or transfer data to | Your mobile operator, bank, or electronic money institution where you have an account, the online payment platform – we transfer only the data necessary for payment, in order to identify you as a Website(s) visitor ordering a paid service. Debt collection companies that mediate the debt collection process, but only to the extent necessary to initiate and carry out debt collection |
Data categories | Visitor’s first name, the content of the complaint and (or) inquiry submitted in writing (e.g., date of the document, content, contact address, etc.), by email (e.g., date of the email, content, sender’s email, etc.), by phone (e.g., phone number, date, time, and duration of the call, data provided during the call, etc.), via the live chat function (e.g., date, time, and content of the correspondence, etc.) |
Legal basis for data processing | Contract (Terms of Use), as well as our legitimate interest to evaluate the feedback of our customers in order to improve the quality of our operations and services |
Data processing period | 2 years from the day you submit your inquiry to us, if you submit an inquiry in writing, by email, or via the live chat function. |
We obtain data from | You. While processing an inquiry or analyzing a complaint, we may create the data ourselves (e.g., upon receiving your complaint, we contact our employees about the factual circumstances of the complaint and record them, etc.). |
We provide or transfer data to | An online payment platform or other partners, insofar as is related to the examination of your inquiry or the resolution of the problem. |
Data categories | The data specified in your CV or application form, data collected during communication, such as: first name, last name, visitor nickname, email, phone number, city, gender, date of birth, education, areas of activity, information about professional (including volunteer) experience, foreign languages spoken |
Legal basis for data processing | The aim to conclude an agreement on your joining our team |
Data processing period | 90 calendar days from the day the specific selection was completed and (or) we informed you that there is no possibility of joining our team, unless we have received your separate consent to store the data longer |
We obtain data from | You, from third parties: e.g., current or former employers or acquaintances providing recommendations, social networks, CV portals, the media, etc. |
We provide or transfer data to | No one |
5.2. Please note that data about your sexual orientation are considered special categories of personal data, which we will process in the ways specified in clause 5.1. (c) of this Privacy Policy only after receiving your consent. You can express your consent by providing us with information about your orientation in the description of your individual profile. If you do not agree to our processing of such data, simply do not provide us with that information. You can always withdraw your consent for processing data about your sexual orientation. To do so, you must edit the information in your individual profile, removing the checkbox by which a specific sexual orientation was marked (e.g., by unchecking the “Bisexual” option, etc.).
5.3. We do not ask you to provide special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as health data, genetic data, biometric data (for the purpose of specifically identifying your identity), or information about your sexual life. If you provide us with such data while using our Website(s), our account(s), mobile application, or by other means (writing, email, telephone), it shall be deemed that these data were provided knowingly and with your consent. Accordingly, we will process these data together with other data you provide, for the purposes and in the ways specified in clause 5.1. of this Privacy Policy, if those data cannot be separated from each other or such separation would require disproportionately large effort.
6. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING?
6.1. With your consent, we may use your personal data for direct marketing purposes, so that we can provide you with newsletters, offers (including personalized ones), and information about our services and (or) goods, or those of related persons and partners, which we believe may interest you. Nevertheless, we will only use your personal data for this purpose if you have additionally agreed to it.
6.2. For this purpose, we process your personal data specified in clause 5.1. (b) of this Privacy Policy.
6.3. By giving consent to process data for direct marketing purposes, you also give us permission to contact you via relevant means of communication (e.g., email, phone, SMS, or other communication tools such as Viber, etc.) for this purpose.
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 analyze and improve the effectiveness of our websites, advertising, and market research, as well as for other company marketing and sales purposes. In this case, we will use your anonymized data.
6.6. Even if you have given consent to process your personal data for direct marketing purposes, you can easily withdraw that consent at any time for all or part of the personal data processing actions. To do this, you can:
6.7. If you withdraw your consent, we will make every effort to stop processing your personal data for direct marketing purposes as soon as possible.
6.8. Withdrawing consent does not automatically oblige us to destroy your personal data or provide you with information about the personal data we process about you, so if you want us to perform these actions, you must state it 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, allowing us to recognize you during subsequent visits to the Website(s), social networks, or mobile application, save your browsing history, preferences, customize content, speed up searches, create a convenient and user-friendly environment, and deliver it more efficiently and reliably. Cookies are a common practice to facilitate browsing on websites.
7.2. Through cookies, we may collect the information specified in clause 5.1. (a) of this Privacy Policy, as detailed in clause 7.6.
7.3. We use the information obtained through cookies for:
7.4. We may, without violating legal acts, combine the information obtained by using cookies with the information obtained about the person by other means (e.g., information about using the Website(s), mobile application with other personal data you have provided or obtained from other sources).
7.5. Please note that the Website(s), the mobile application, and social networks may use, for example:
7.6. All information about the cookies used by us on the Website(s), mobile application, their purpose, validity, and the data used is provided here.
7.7. You can give your consent to the use of cookies on our Website by:
7.8. You can withdraw your permission for us to use cookies at any time by changing your internet browser settings so that it does not accept cookies. How to do this depends on the operating system and internet browser you are using. You can find detailed information about cookies, how they are used, and how to opt out at http://AllAboutCookies.org or http://google.com/privacy_ads.html.
7.9. In some cases, especially if you disable technical and functional cookies, refuse cookies, or delete them, your browsing speed may slow down, certain Website functions may be restricted, or access to the Website may be blocked.
7.10. For more detailed information about external sites (such as social networks), please read Section 11 of this Privacy Policy.
8. TO WHOM DO WE PROVIDE YOUR PERSONAL DATA?
8.1. We guarantee that your personal data will not be provided to or otherwise transferred to third parties without a legitimate basis, nor used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy and (or) our Personal Data Processing Rules and legal acts. However, we reserve the right to provide information about you if required by law or if requested by legitimate authorities or criminal prosecution authorities.
8.2. We may transfer your personal data to companies that help us carry out our activities. From such entities, we require that your data be processed only in accordance with our instructions and the applicable laws ensuring the protection of your data. We conclude agreements with these persons that strictly oblige them to comply with personal data protection requirements.
8.3. The possibility of the above-mentioned service providers to use your data is limited – they cannot use these 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 separately for each purpose of data use in clause 5.1. of this Privacy Policy.
9. HOW LONG DO WE STORE YOUR PERSONAL DATA?
9.1. We store your personal data no longer than required by the purposes of data processing or provided by law if a longer data retention period is established by legal acts.
9.2. We aim not to store outdated, irrelevant personal data, so once it is updated (e.g., refined, changed, etc.), only the current information is stored. Historical information is kept if it is required by legal acts or needed for our operations.
9.3. The retention periods of your personal data for each purpose of data use are provided separately in clause 5.1. of this Privacy Policy.
10. HOW DO WE PROTECT YOUR PERSONAL DATA?
10.1. The data we collect from you will be stored within the EU, but may be transferred or stored outside the EU. They may also be processed by our or our suppliers’ staff operating outside the EU. When transferring your data outside the EU, we will take all necessary steps to ensure that your data are processed securely and in accordance with this Privacy Policy.
10.2. Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we cannot guarantee the security of the data when you transmit it to the Website – you assume the risk associated with transmitting data to the Website. Once we receive your data, we will apply strict procedures and security measures to protect your data from unauthorized access.
10.3. In the unlikely event that we become aware of a breach of the security of your personal data that may pose a high risk to your rights or freedoms, we will immediately inform you as soon as we have identified and determined which information was accessed.
11. EXTERNAL WEBSITES
11.1. The Website may contain links to external websites – our business partners’ websites or websites where we have accounts or where our goods and (or) services are advertised. By following such links to any of these websites, please note that these websites and the services accessible through them have their own separate privacy policies, and we assume no responsibility or liability for these policies or the personal data collected on these websites or in the course of providing services, for example, contact or location data. We recommend reviewing these policies before submitting personal data on those 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:
12.2. We will make every effort to guarantee your rights as a data subject and to create all conditions for these rights to be effectively exercised, but we reserve the right not to comply with your requirements when it is necessary to ensure:
12.3. You can submit requirements related to the exercise of your rights to us personally, by mail, or by electronic communications. Once we receive your request, we may ask you to provide identity documents and any other additional information related to the request we may need.
12.4. After receiving your request, we will respond to you no later than 30 calendar days from the day we receive your request and all the documents necessary to provide a response.
12.5. If we consider it necessary, we will suspend the processing of your data (except for storage) until your request is resolved. If you lawfully withdraw your previously given consent, we will stop processing your personal data no later than 30 calendar days after your withdrawal, except in the cases specified in clause 12.2. of this Privacy Policy and in legal acts, i.e., when we are obliged to continue processing your data by applicable legal acts, legal obligations, court decisions, or mandatory instructions from authorities.
12.6. If we refuse to comply with your request, we will clearly state the reason for such refusal.
12.7. If you disagree with our actions or our response to your inquiry, you may appeal our actions and decisions to the competent state authority.
13. HOW TO DELETE YOUR ACCOUNT AND PERSONAL DATA?
If you wish to delete your account and the associated personal data, please follow these steps:
Note: If you registered via Google / Facebook or simply forgot your password, you must create a new password before deleting your account. You can do this by clicking on https://m-eng.draugas.lt/pamirsai.
If you're unable to delete your account using the above steps, please contact us by email at pazintys@dr.lt or send a message.
Once the account is deleted, your personal data will be removed from our systems to the extent possible, in accordance with the terms and requirements outlined in this Privacy Policy. However, certain information (such as payment records) may be retained if required by law or our legitimate interests (for instance, debt collection). For more details, please refer to the other sections of this Privacy Policy.
14. TO WHOM CAN YOU FILE A COMPLAINT?
14.1. If you wish to file a complaint regarding our data processing, please submit it in writing, providing as much information as possible, using the contact details provided at the end of this Policy. We will cooperate with you and strive to resolve any issues promptly.
14.2. If you believe that your rights under the GDPR have been violated, you can file a complaint with our supervisory authority – the State Data Protection Inspectorate of the Republic of Lithuania. More information and contact details can be found on the inspectorate’s website (www.ada.lt). However, we primarily seek to resolve all disputes quickly and amicably together with you.
15. HOW WILL THIS PRIVACY POLICY BE CHANGED?
15.1. All changes to our Privacy Policy will be announced on the Website. If necessary, we will inform you about them. The new terms of the Privacy Policy may also be presented on the Website, and you may need to read and accept them in order to continue using the Website and (or) our services.
16. PROTECTION OF MINORS
16.1. We take care to protect the rights of minors and restrict their ability to use certain services intended for adults only (as set out in the Terms of Use). Therefore, certain Websites or parts thereof may be intended solely for adult audiences. Minors are strictly prohibited from entering such Websites or parts thereof. A visitor is also responsible not only for their own behavior but also for the behavior of their minor children or other dependents on the Websites if they use the Websites in the presence of the visitor, with his/her permission, or by using the visitor’s hardware.
16.2. More information on protecting children and minors from harmful internet content can be found at www.draugiskasinternetas.lt.
17. HOW TO CONTACT US?
17.1. Please send all documents related to this Privacy Policy or contact us using the following details:
Date of publication of the Privacy Policy: September 1, 2018.