We, the group of companies UAB “Logas”, UAB “Logas data”, UAB “Logas line” and UAB “Prokodas” (hereinafter – We, the Company), value and protect our customers’ privacy; therefore, we collect and process only those of Your data that are 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 those purposes. When processing personal data, we strive to ensure that they are accurate, secure, confidential, properly stored and protected.
When processing Your personal data, we comply with the General Data Protection Regulation (hereinafter – GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as the requirements for personal data processing established in other legal acts.
What is this document?
1. In this Privacy Policy (hereinafter – the Policy), we clearly and transparently set out the principles we apply to the collection and use of information. After reading this document, You will learn how We process Your personal data, where we obtain them from, and what rights You have as a personal data subject.
2. This Policy applies to:
a) all persons visiting Our website www.labbis.lt (hereinafter – the Website), taking into account the permissions You have granted regarding the use of cookies,
b) all actions that You may perform on the Website, for example, when sending Us enquiries or orders,
c) all persons applying for vacancies offered by us and submitting information about themselves to Us for this purpose,
d) all persons calling Us when conversations with them are recorded (we will inform You about the recording before the conversation begins),
e) all persons sending Us emails,
f) all persons submitting messages to Us through the HelpDesk support system (https://help.labbis.lt/),
g) all persons using the TRIAL version of the LABBIS BONUS self-service mobile application,
h) all persons participating in Our surveys, interactive games, questionnaires.
This Policy is also intended to inform You about other personal data processing operations carried out by Us and the main provisions designed to ensure Your privacy.
2.1. In this Policy, the term “personal data” means any information by which You can be identified – directly or indirectly. For example, personal data include a person’s surname, first name, date of birth, postal or email address, location data and IP address, as well as characteristics specific to You.
What principles do we follow?
3. When processing Your personal data, we:
a) comply with the requirements of applicable laws and regulations, including the GDPR;
b) process Your personal data lawfully, fairly and transparently;
c) collect Your personal data for specified, clearly defined and lawful purposes and only to the extent permitted by law and/or Your consent;
d) take all reasonable measures to ensure that personal data that are inaccurate or incomplete, taking into account the purposes for which they are processed, are promptly corrected, supplemented, their processing suspended or the data destroyed;
e) store data in a form that allows Your identity to be determined for no longer than is necessary for the purposes for which the personal data are processed;
f) do not disclose personal data to third parties and do not make them public, except in the cases specified in the Policy or as required by law;
g) ensure that Your personal data are processed in a manner that ensures appropriate security of personal data through suitable technical or organisational measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
How do we collect Your personal data?
4.1. We process Your personal data obtained in the following ways:
a) when You provide personal data to us. You provide us with Your personal data when You submit enquiries to us on the Website, through the HelpDesk support system, LinkedIn, Facebook or another social platform, communicate with us by telephone or email, submit Your CV, complete Our surveys or questionnaires, or participate in interactive games. When You contact us in writing, by email or by telephone, we will retain correspondence and conversation data (You will be informed at the beginning of the call if the telephone conversation is being recorded);
b) when You use the Website. When You use the Website, certain information (for example, IP address, type of internet browser used, number of visits to the Website, Website pages viewed, time spent on the Website, demographic data and, if You arrived at the Website from a third-party website, the page URL) is collected in accordance with the permissions You have granted;
c) when You use the TRIAL version of the LABBIS BONUS self-service mobile application.
d) when we receive Your personal data from other persons in accordance with laws and/or this Policy and/or contracts.
4.2. We may combine personal data received from You with data collected by us from other public or accessible sources. For example, we may combine the personal data You provide with data obtained through Website cookies, data collected when providing services to You, or data lawfully received from third parties.
What data of Yours do we process and for what purposes?
5.1. We process Your personal data for the following purposes:
a) for the purpose of ensuring the quality of sales and services. You provide us with Your personal data by submitting enquiries to Us on the Website, by email, by communicating with our team by telephone, or by submitting messages regarding the Website or the services we provide. When You contact us in writing, by email or by telephone, we will retain the correspondence or audio recording (recording of the conversation). Personal data processed for this purpose:
| Data categories | First name, surname, email address, telephone number, data provided when You submit an enquiry regarding our products, solutions or services by email (e.g. message text, etc.) or by telephone (e.g. recording of the telephone conversation, date, time and duration of the telephone conversation, etc.) |
| Legal basis for data processing | Your consent, as well as our legitimate interest in assessing feedback from our customers in order to improve the quality of our activities and services |
| Data processing period | 1 year from the date You submit Your enquiry to us. |
b) in order to respond to Your enquiries submitted to us regarding our products, solutions or services. You provide us with Your personal data by submitting enquiries to Us on the Website, by email, by communicating with our team by telephone, or by submitting messages regarding the Website or the services we provide. When You contact us in writing, by email or by telephone, we will retain the correspondence or audio recording (recording of the conversation). Personal data processed for this purpose:
| Data categories | First name, surname, email address, telephone number, data provided when You submit an enquiry regarding our products, solutions or services by email (e.g. message text, etc.) or by telephone (e.g. recording of the telephone conversation, date, time and duration of the telephone conversation, etc.) |
| Legal basis for data processing | Your consent, as well as our legitimate interest in assessing feedback from our customers in order to improve the quality of our activities and services |
| Data processing period | 1 year from the date You submit Your enquiry to us. |
c) for direct marketing purposes, in order to provide You with offers, newsletters and information about the goods and/or services of us, persons related to us and our partners. Personal data processed for this purpose:
| Data categories | First name, surname, email address, information identifying the act of consent |
| Legal basis for data processing | Your consent |
| Data processing period | 3 years from the date You give us Your consent, or for as long as services are provided to the legal entity whose employee You are, or until You withdraw Your consent in the manner specified in Clause 6.7 of this Policy.
Once consent is withdrawn, the data are no longer processed for marketing purposes. However, information about the granting of consent continues to be stored for the purpose of proving such consent – for 3 years from the date the consent was given. |
d) for recruitment purposes as part of the current and future recruitment process, as well as to assess Your competence and other qualities. By completing the recruitment form or providing us with information about themselves, the user expresses their consent to participate in the current or future recruitment process of the Company. This consent applies to all documents submitted during the recruitment process.
| Data categories | Email address, curriculum vitae, cover letter |
| Legal basis for data processing | Your consent, expressed by the act of providing the information |
| Data processing period | 1 year from the date You give us Your consent or until You withdraw Your consent in the manner specified in Clause 6.7 of this Policy. |
e) for recruitment purposes as part of the current and future recruitment process, as well as to assess Your competence and other qualities.
| Data categories | First name, surname and comments by our employees, which may contain personal information such as: position at the time of application, work experience. |
| Legal basis for data processing | Your consent, expressed by the act of providing the information |
| Data processing period | 10 years from the date You give us Your consent or until You withdraw Your consent in the manner specified in Clause 6.7 of this Policy. |
f) for the purpose of ensuring the functionality of the Website and improving it. When You use the Website, certain data are transmitted to us automatically after Your visit to the Website. These data constitute certain non-personal information used to improve the Website’s content, functionality and attractiveness.
g) for advertising purposes, in order to encourage the purchase of Our services. You provide us with Your personal data by writing a review about the services we provide. By responding to questions sent by us by email regarding the quality of services, You agree that we may share Your answers and Your personal data (first name, surname, position and workplace name) on Our website and social networks and that they will be publicly accessible. Personal data processed for this purpose:
| Data categories | First name, surname, position, workplace name, email address, Your review of our goods or services. |
| Legal basis for data processing | Your consent |
| Data processing period | 3 years from the date You give Your consent or until You withdraw Your consent in the manner specified in Clause 6.7 of this Policy. |
h) for the purpose of ensuring the proper operation of the TRIAL version of the LABBIS BONUS self-service mobile application (hereinafter also – the Application).
| Data categories | Email address, actions performed while using the Application, Your consent to the Terms of Use of the Application |
| Legal basis for data processing | For the purpose of performing the contract concluded with You and for the purpose of protecting Our legal interests. |
| Data processing period | 3 years from the end of the use of the Application. |
j) for the purpose of safeguarding assumed contractual obligations in the event of possible disputes.
5.2. We ask You not to provide Us with, and we do not process, special categories of Your personal data revealing Your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as health data or data concerning Your sex life and sexual orientation. If, while using the Website or by any other means (in writing, by email, by telephone), You provide us with such data, it will be considered that these data were provided with Your consent. Accordingly, we will process such Your data together with other Your data that You have provided in the ways specified in Clause 5.1 of the Policy.
Do we use Your personal data for direct marketing?
6.1. Yes, we may use Your personal data for direct marketing purposes in order to provide You with offers, newsletters and information about the goods and/or services of us, persons related to us and our partners which, in our opinion, may be of interest to You. We will use Your personal data for this purpose only with Your consent.
6.2. For this purpose, we process Your personal data specified in Clause 5.1(c) of the Policy.
6.3. You may choose whether You allow us to use Your personal data for direct marketing purposes. You can do this in an electronic form, by clicking a button or otherwise selecting the option indicating that You agree to Your data being processed for marketing purposes or that You agree to receive news, offers and other information about products and services.
6.4. By granting us the right to process data for direct marketing purposes, You also authorise us to contact You for this purpose via the means of communication provided by You (for example, email, telephone, short (SMS) messages) or other communication channels (for example, Messenger, Viber, etc.).
6.5. We may combine the information we hold about You with information held by third parties in order to provide You with offers and newsletters.
6.6. If You consent to the use of Your personal data for direct marketing purposes, we may use Your personal data to analyse and improve the effectiveness of our websites, advertising and market research, as well as for other marketing and sales purposes of the Company. In such a case, we will use anonymised Your data.
6.7. Even if You have given consent to the processing of Your personal data for direct marketing purposes, You may easily withdraw this consent at any time in respect of all or part of the personal data processing activities. To do so, You may:
a) notify us of Your refusal in the manner specified in electronically received offers or newsletters (e.g. by clicking the “Unsubscribe from newsletters” link or similar in offers or newsletters), or
b) send us a request to the email address specified in this Policy. The request must clearly state Your first name and surname. If You express Your wish to withdraw Your consent in this way, we may ask You to provide identity documents.
6.8. If You withdraw Your consent, we will endeavour to stop processing Your personal data for direct marketing purposes as soon as possible.
6.9. Withdrawal of consent does not automatically oblige us to destroy Your personal data or provide You with information about the personal data we process; therefore, if You want us to take these actions as well, You must specify such a request separately.
How do we use cookies?
7.1. We collect information about You using cookies (cookies) and similar technologies. Cookies are small files that are temporarily stored on the hard drive of Your device and allow us to recognise You during subsequent visits to the Website, save personal browsing history and preferences, customise content, speed up searches performed on the Website, create a convenient and user-friendly Website environment, and provide it more efficiently and reliably. Cookies are a common practice when browsing websites and make websites easier to use.
7.2. Through cookies, we may collect information that You allow us to collect: IP address, type of internet browser used, number of visits to the Website, Website pages viewed, time spent on the Website, demographic data and, if You arrived at the Website from a third-party website, the page URL and similar information.
7.3. We use information obtained through cookies for the following purposes:
a) to ensure the functionality of the Website (for example, so that You can use Website personalisation);
b) so that we can improve and develop the Website to better meet Your needs;
c) for service development and analysis of Website usage;
d) for targeted marketing.
7.4. Without violating applicable laws, we may combine information obtained through cookies with information obtained about You by other means (for example, combine information about Website usage with the personal data You provide).
7.5. The following cookies may be used on the Website:
a) technical cookies – cookies that are necessary for the operation of the Website; even if the use of cookies is rejected, these cookies will still function;
b) functional cookies – cookies that, although not necessary for the operation of the Website, significantly improve its performance, quality and user experience;
c) analytical cookies – cookies used to prepare statistical analyses of Website visitors’ navigation methods; the data collected by these cookies are used anonymously;
d) targeting or advertising cookies – cookies used to display offers or other information that may be of interest to You;
e) social network cookies – cookies necessary to use Website information within Your social profile account.
By allowing the use of cookies, i.e. by clicking the “Allow” button, You agree to the use of all cookies mentioned in points b–e.
“Facebook” advertisements. This feature allows our users to display advertisements on the “Facebook” platform. A “Facebook” tracking pixel is installed in the browser of a visitor to our website. This allows the user to be recognised and shown an individual remarketing advertisement on the “Facebook” platform. This technology facilitates the placement of advertising campaigns on the “Facebook” platform and allows us to view reports on the effectiveness and performance of these advertising campaigns. More information about this technology can be found at: https://www.facebook.com/policies/cookies/. If You wish to opt out of these cookies, follow the instructions provided below in Section 7.8.
7.6. All information about cookies used on the Website, their purpose, validity period and data used is provided here / in the table below:
| Name | Purpose of data processing | Time of creation | Validity period | Data used |
| _gat | Google Analytics cookie used to limit the number of requests sent to the Google service | Upon entering the page | Session | The cookie does not store any information; it is used to limit the number of requests to www.doubleclick.net |
| collect | Used to send information to Google Analytics about the visitor’s device and behaviour. Helps recognise a visitor using different devices. | Upon entering the page | Session | |
| r/collect | Collects information about the effectiveness of advertisements viewed or clicked and helps display advertisements targeted to the visitor. | Upon entering the page | Session | |
| s | Cookie that records the visitor’s clicks on the website | Upon entering the page | Session | |
| u | Cookie that helps recognise a visitor who has previously visited the website | Upon entering the page | Session | |
| NID | Information about the visitor’s preferences is collected | Upon entering the page | 6 months | The NID cookie contains a unique ID that “Google” uses to remember preferences and other information, such as Your preferred language (e.g. Lithuanian), how many search results You want to display per page (e.g. 10 or 20), and whether You want to enable the “Google” SafeSearch filter. |
| october_session | A CMS cookie that enables the collection of information about website traffic | Upon entering the page | Session | IP addresses and unique ID numbers are used for accounting purposes. The result of the accounting is statistical. |
| acceptCookie | Used to store information on whether the user agreed to the cookie collection terms | When agreeing to the terms | 1 year | Value — “true” |
| _ceg.s | These cookies are used to collect statistical information about website traffic. The data obtained are used to prepare reports and improve the page. | Upon entering the page | 3 months | IP address and unique ID numbers are used for accounting purposes. The result of the accounting is statistical. The counter is managed through “Crazy Egg” |
| _ceg.u | These cookies are used to collect statistical information about website traffic. The data obtained are used to prepare reports and improve the page. | Upon entering the page | 3 months | IP address and unique ID numbers are used for accounting purposes. The result of the accounting is statistical. The counter is managed through “Crazy Egg” |
| _gid | These cookies are used to collect statistical information about website traffic. The data obtained are used to prepare reports and improve the page. | Upon entering the page | Session | IP addresses and unique ID numbers are used for accounting purposes. The result of the accounting is statistical. The counter is managed through “Google Analytics” |
| _ga | These cookies are used to collect statistical information about website traffic. The data obtained are used to prepare reports and improve the page. | Upon entering the page | 2 years | IP addresses and unique ID numbers are used for accounting purposes. The result of the accounting is statistical. The counter is managed through “Google Analytics” |
7.7. You can give consent to the use of cookies in the following ways:
a) by clicking the “Reject”, “Save my preferences” or “Accept all” buttons.
7.8. You may withdraw the permission You have given us to use cookies at any time. You can do this by changing Your internet browser settings so that it does not accept cookies. How this is done depends on the operating system and internet browser You use. Detailed information about cookies, their use and opt-out options can be found at http://AllAboutCookies.org or https://policies.google.com/technologies/ads.
To whom do we disclose Your personal data?
8.1. We guarantee that Your personal data will not be sold, disclosed or otherwise transferred to third parties without a lawful basis, nor used for purposes other than those for which they were collected. We will not transfer Your personal data in any manner other than in accordance with this Policy. However, We reserve the right to disclose information about You if we are required to do so by law, if lawfully operating law enforcement authorities require Us to do so, or if this is necessary to ensure our legal defence.
8.2. We may transfer Your personal data to companies that assist Us in carrying out our activities, including direct marketing. We require such partners to process Your data only in accordance with our instructions and applicable laws ensuring the protection of Your data.
8.3. We may disclose the data we have collected about You to the following third parties:
a) third-party service providers (for example, technical service providers in the performance of our contracts with such providers, including services related to sending newsletters or carrying out other marketing activities);
b) third-party service providers whose services we normally use for data storage, telecommunications, website hosting and legal advisory purposes.
c) companies managing debtor records or administering debts;
d) courts, law enforcement authorities or state institutions to the extent such disclosure is required by law;
e) partners, for example, assignees of claims, where, in order to ensure effective debt management, the Company transfers to them the right to claim the amount payable by the customer;
8.4. The ability of the above-mentioned service providers to use Your data is limited – they may not use such data for purposes other than providing services to us.
How long do we store Your personal data?
9.1. We store Your personal data for no longer than required by the purposes of data processing or by law, where a longer data retention period is established.
9.2. We aim not to retain outdated or irrelevant personal data; therefore, once such data are updated, only current information is retained. Historical information is retained if this is required by law or necessary for carrying out our activities.
9.3. Clause 5.1 of the Policy separately specifies the retention periods of Your personal data for each purpose of personal data use.
How do we protect Your personal data?
10.1. The data we collect from You will be stored within the territory of the European Union (EU) and will not be transferred outside the EU.
10.2. We take reasonable organisational, physical and technological measures to ensure data security. These measures include rules and procedures applicable to employees governing data and IT infrastructure, internal and external networks, and protecting all equipment.
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 notify You without undue delay as soon as we become aware of it and determine which information has been accessed.
External websites
11.1. The Website may contain links to external websites – websites of our business partners or websites advertising our goods and/or services. If You follow such links to any of these websites, please note that these websites and the services available through them have their own separate privacy policies, and we accept no responsibility or liability for these policies or for personal data collected on these websites or when providing services, for example, contact or location data. Please review these policies before providing personal data on such websites or using any services.
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 personal data subject, You have the following rights:
a) to know (be informed) about the processing of Your personal data;
b) to access Your personal data that we process;
c) to request the correction, supplementation or clarification of incorrect, inaccurate or incomplete Your personal data;
d) to request the deletion of personal data when they are no longer necessary for the purposes for which they were collected;
e) to request the deletion of personal data if they are processed unlawfully, or when You withdraw Your consent to the processing of personal data, or do not provide such consent where it is necessary;
f) to object to the processing of personal data or withdraw previously given consent;
g) to request the suspension (except for storage) of the processing of Your personal data where disputes are ongoing or the lawfulness of processing or accuracy of the data needs to be verified, as well as in cases where we no longer need Your personal data but You do not want us to delete them;
h) to request, where technically feasible, that Your personal data collected on the basis of Your consent or for the performance of a contract be provided in an easily readable format or transferred to another data controller.
12.2. We will endeavour to guarantee the exercise of Your rights as a personal data subject and to provide all conditions necessary for the effective exercise of these rights; however, we reserve the right not to comply with Your requests where necessary to ensure:
a) compliance with legal obligations imposed on us;
b) national security or defence;
c) public order, prevention, investigation, detection or prosecution of criminal offences;
d) important economic or financial interests of the state;
e) prevention, investigation and detection of breaches of official or professional ethics;
f) protection of Your rights and freedoms or those of other persons.
12.3. You may submit requests related to the exercise of Your rights to us in person, by post or by electronic means of communication. Upon receiving Your request, we may ask You to provide identity documents, as well as other additional information related to the request that we may need.
12.4. Upon receiving Your request, we will respond no later than within 30 calendar days from the date of receipt of Your request and all documents required 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 has been resolved. If You lawfully withdraw Your consent, we will immediately, but no later than within 30 calendar days, cease processing Your personal data, except in the cases specified in Clause 12.2 of this Policy and as required by law, i.e. where applicable laws, legal obligations imposed on us, court decisions or mandatory instructions issued to us by authorities require us to continue processing Your data.
12.6. If we refuse to comply with Your request, we will clearly state the grounds for such refusal.
12.7. If You disagree with our actions or our response to Your request, You may lodge a complaint against our actions and decisions with the competent state authority.
Where can You lodge a complaint?
13.1. If You wish to lodge a complaint regarding data processing carried out by us, please submit it in writing, providing as much information as possible and using the contact details provided at the end of this Policy. We will cooperate with You and endeavour to resolve all issues promptly.
13.2. If You believe that Your rights under the GDPR have been violated, You may lodge a complaint with the supervisory authority – the State Data Protection Inspectorate, although we will first endeavour to resolve all disputes together with You.
How will this Policy be amended?
14.1. All changes to Our Policy will be published on the Website. The terms of the new Policy will also be provided on the Website and You may be required to read and accept them.
How can You contact us?
15.1. Please send all documents related to this Policy using the contact details below:
a) by post – UAB Logas data, address: A. Goštauto g. 40 B, Vilnius
b) by email – [email protected]
