Effective Date: 20-Nov-2023
Last Updated: 20-Nov-2023

In this Privacy and Cookie Policy (hereinafter referred to as the “Privacy Policy”), we present the practices of the website www.tubegreen.lt (hereinafter referred to as the “Site”) regarding the processing of personal data of visitors to the Site (hereinafter referred to as “Visitors” or “You”), the terms of processing personal data, and the rights related to the collection and use of personal data that Visitors have.

Carefully read this document because each time you visit the website www.tubegreen.lt, you agree to the conditions described in this Privacy Policy. If you do not agree with these conditions, we regretfully ask you not to visit our Site and not to use our content and/or services.

IDENTITY OF THE DATA CONTROLLER

The owner and controller of the Site is “Headline Agency,” legal entity code 301163601, registered address Mėsinių g. 5, LT-01133 Vilnius (hereinafter referred to as the “Company” or “we”).

PURPOSES OF DATA PROCESSING AND LEGAL BASIS FOR DATA PROCESSING

The Company collects and processes personal data in accordance with the laws of the European Union and the Republic of Lithuania regulating the protection of personal data.

The Company processes the personal data of Visitors on the following grounds:

  1. On the basis of consent, expressed through your active actions, i.e., by contacting us and providing personal data, or other active actions.
  2. For the purpose of implementing our legitimate interests (e.g., administering the Site and ensuring its proper functioning; conducting the Company’s economic-commercial activities, etc.).
  3. To fulfill the obligations imposed on us by legal acts.

The Company seeks, by applying all reasonable technical and administrative measures, to ensure the security of Visitors’ personal information and the protection of their rights when using the Site and its content.

WHAT DATA DO WE PROCESS AND WHY?

When you visit and browse our website, for the purposes of collecting browsing statistics, improving service quality, and enhancing visitor experience, the Company processes the following anonymized data: IP address, MAC address, visit date, duration, pages visited, devices and programs used for internet browsing, etc. In addition, cookies are used on our website. We use the Google Analytics website analysis service, which allows us to record and analyze statistical data on website usage. More information about Google Analytics and the information these tools allow collecting can be found here – Google Analytics. If you wish to prevent Google Analytics tools from recording information about your internet browsing, you can use the “Google Analytics” browser add-on. More information about cookies can be found in later sections of this document.

PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES

The Company processes your personal data for direct marketing purposes after obtaining your clear consent for such data processing, for example, when you subscribe to our newsletters, etc. (the legal basis for data processing is your consent).

For direct marketing purposes, we may process your name and email address. Your personal data for direct marketing purposes may be processed in the following ways:

  1. You can receive a newsletter with updates from our website via email.
  2. You can receive invitations to events, offers, and similar information via email.

You can unsubscribe from our newsletters at any time. You can do this by clicking the link provided at the bottom of the newsletters we send.

We also use the services of Facebook, Google, and other online advertising providers.

You can read about the privacy policy of these service providers, the data they collect, and the personal data protection measures they apply in the privacy policies of these service providers. More information about how they operate, as well as information on how you can refuse the display of such ads or the use of such data, can be found in the information provided by these service providers – Facebook; Google.

FROM WHICH SOURCES DO WE COLLECT YOUR PERSONAL DATA?

The Company processes:

  1. Data provided by you when you interact with the Company, subscribe to newsletters, contact us requesting information, etc.
  2. Data generated when you use our services (e.g., when you call by phone, send an email, or visit our websites), etc.

HOW LONG WE PROCESS AND RETAIN YOUR DATA?

We will process and retain your personal data no longer than necessary to achieve the purposes for which the data were collected or for the period stipulated by applicable laws.

The duration of personal data storage is determined based on the following principles:

  1. The length of time such information is needed for the purposes for which it was collected and processed.
  2. The length of time such information is needed for us to fulfill legal requirements applicable to us.
  3. The length of time you have allowed us (by your consent or otherwise) to use such information about you.

The specific terms of personal data storage are detailed in this Policy or in the privacy notices or policies of the respective categories of personal data. Personal data storage longer than specified in the Policy may occur only when:

  • There are reasonable suspicions of illegal activity under investigation.
  • Your data is necessary for the proper resolution of a dispute or complaint.
  • We have received complaints related to the Visitor, or we have observed violations committed by the respective Visitor.
  • Backup and other activities related to the operation and maintenance of information systems.
  • Other special legal grounds, conditions, or cases as provided by applicable laws.
UNDER WHAT CIRCUMSTANCES AND TO WHICH THIRD PARTIES DO WE DISCLOSE YOUR DATA?

Without your prior consent, the Company does not transfer your personal data to any third parties, except in the cases described below.

We may transfer your data to be processed by third parties who assist us in conducting activities and administering the provision of Services. These may include data centers and related service providers, advertising and marketing service providers, companies that create, provide, support, and develop software, companies providing information technology infrastructure services, companies providing internet browsing or online activity analysis and services, security service providers, and more. In each case, we provide data processors with only the amount of data necessary to fulfill a specific task or provide a specific service.

Our appointed data processors may process your personal data only according to our instructions. Additionally, they are required to ensure the security of your data in accordance with applicable laws and the written agreements concluded with us.

Data may also be disclosed to competent authorities or law enforcement agencies, such as the police or supervisory authorities, but only upon their request and only when required by applicable laws or in cases and procedures specified by laws to safeguard our rights, the security of our customers, employees, and resources, and to assert, present, and defend legal claims.

IN WHICH TERRITORIES AND JURISDICTIONS DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data in the territory of the European Union. We currently have no intention to transfer and do not transfer your personal data to third countries.

Please note that certain technical data of your website visits (IP address, cookies, technical information about the browser you use, and other information related to browsing activity on the website) for statistical, analytical, and related purposes may be transferred or made available both to entities operating within and outside the European Economic Area (EEA). For example, when using services such as Google Analytics and Facebook Ads, a subject located in the United States may be involved. We remind you that in non-EEA countries, personal data may be subject to lower protection standards than in EEA countries. However, we will carefully assess the conditions under which such data will be processed and stored after being transferred to the mentioned entities.

DATA SECURITY

The Company implements and continuously updates appropriate organizational and technical security measures to protect personal data from accidental or unlawful destruction, alteration, disclosure, as well as any other unlawful processing.

Any personal data you provide, including your name, surname, email address, and any other information contained in emails, may be processed by the Company or the email owner who signed the agreement, data center, storage, and other IT infrastructure service providers for the maintenance of the company’s IT system security, business with customers, suppliers, and other business partners, ensuring that the data is properly protected and not lost in the event of a security breach.

WHAT RIGHTS DO DATA PROTECTION LAWS GIVE YOU?

Data protection laws provide you with various rights that you can freely exercise, and we must ensure that you have the opportunity to do so.

RIGHT TO ACCESS YOUR PERSONAL DATA

You have the right to obtain confirmation from us as to whether or not we are processing your personal data, as well as the right to access your personal data processed by us and information about the purposes of data processing, the categories of data processed, the categories of recipients of the data, and the duration of data processing.

Most of this information is provided to you in this Privacy and Cookie Policy, and we believe it is beneficial to you.

RIGHT TO RECTIFY PERSONAL DATA

If your data provided to us has changed or if you believe that the information we process about you is inaccurate or incorrect, you have the right to request that this information be changed, corrected, or amended.

RIGHT TO WITHDRAW CONSENT

In cases where we process your data based on your consent, you have the right to withdraw your consent at any time, and the processing based on your consent will be terminated.

RIGHT TO LODGE A COMPLAINT

If you believe that we process your data in violation of data protection laws, we always first ask you to contact us directly. We believe that with goodwill, we can resolve any doubts, satisfy requests, and correct any mistakes we may have made.

If our proposed solution to resolving the issue or your opinion about our lack of necessary actions is unsatisfactory, you have the right to lodge a complaint with the supervisory authority, which in the Republic of Lithuania is the State Data Protection Inspectorate (more information: www.ada.lt).

RIGHT TO OBJECT TO DATA PROCESSING BASED ON LEGITIMATE INTERESTS

You have the right to object to the processing of personal data when personal data is processed based on our legitimate interests.

To exercise the right mentioned in this section, please submit a written request to our Company.

RIGHT TO ERASURE OF DATA (RIGHT TO BE FORGOTTEN)

Under certain circumstances specified in data protection laws (when personal data is processed unlawfully, the legal basis for data processing has disappeared, etc.), you have the right to request that we erase your personal data. To exercise this right, please submit a written request to our Company.

RIGHT TO RESTRICT DATA PROCESSING

Under certain circumstances specified in data protection laws (when personal data is processed unlawfully, you dispute the accuracy of the data, you object to the processing of data based on our legitimate interest, etc.), you also have the right to restrict the processing of your data.

To exercise the right mentioned in this section, please submit a written request to our Company.

RIGHT TO DATA PORTABILITY

Data that we process with your consent and which is processed using automated means can be transferred to another data controller. We will provide you with the data you wish to transfer in the usual format used in our systems, and if you wish and if technically feasible, we will transfer the data directly to another data controller specified by you.

To exercise the right to data portability, please submit a written request to our Company.

PROCEDURE FOR HANDLING REQUESTS

To protect your and other people’s data from unlawful disclosure, upon receiving your request to provide data or to implement other of your rights, we must verify your identity. For this purpose, we may ask you to provide your name, surname, email address, or phone number and compare whether the data you provided matches the relevant data we have. In conducting this check, we may also send a control message to the specified contact (SMS or email) asking for an authorization action. If the verification procedure is unsuccessful (e.g., your provided data does not match our data or you do not authorize yourself by responding to the received SMS or email message), we will have to establish that you are not the Visitor of the requested services and will have to reject your request.

Upon receiving your request for the implementation of any of your rights and successfully completing the verification procedure, we undertake to provide you with information about the actions taken on your request no later than one month from the receipt of your request and the completion of the verification procedure. Taking into account the complexity and number of requests, we reserve the right to extend this period by two months, informing you before the end of the first month and indicating the reasons for such an extension.

If your request is made electronically, we will also provide you with a response electronically, unless it is impossible (e.g., due to a very large amount of information) or if you request a different way of responding.

We will refuse to satisfy your request with a motivated response when circumstances specified in the legal acts are identified, informing you in writing about it.

GENERAL INFORMATION ABOUT COOKIES

On the website, we use cookies. They allow us to tailor the website’s operation to your needs, as well as facilitate navigation and usage of our website.

Cookies are small text files (taking up to a few KB) that your web browser places on your computer, tablet, or other smart device when you visit our website. They allow the website to store data such as:

  • Login data (IP address of the connecting device, login time, city of connection).
  • Browser type.
  • Demographic data (age group, gender).
  • Data on how you browse the website (which sections you visit, which products you are interested in).

Through cookies, we aim to:

  • Ensure efficient and secure website operation: We use cookies to support our security features, which help detect and identify cases of inappropriate behavior on our website.
  • Improve website performance: By monitoring cookie usage, we can enhance the operation of the website and electronic services, develop existing services, improve functionality, and analyze performance when you visit our website from other sites, devices, or devices.
  • Recognize returning website visitors: Cookies help display relevant information to visitors and also prevent repeated registration and form completion for frequent visitors.
  • Analyze your habits to make the website convenient, efficient, and meet your needs and expectations. For example, ensuring that you easily find everything you are looking for.
  • Measure the flow of information and data sent to our website: We use cookies to accumulate statistical data on the number of users visiting the website and using electronic services.
  • Targeted marketing and advertising: Using cookies, we can collect information to provide targeted advertising or content for a specific browser by creating different target groups. We may use cookies to display relevant ads both on our website and beyond.

We may, without violating legislation, combine information obtained through cookies with information obtained about you through other means, such as information about service usage, our loyalty program, and so on.

USE OF COOKIES ON THE WEBSITE

Every time you visit our website, long-term cookies may be created, which remain on your computer after you log out and will be used when you visit our website again; they are valid and are not deleted when you finish browsing the website, and/or short-term (session) cookies that expire and are deleted when you finish browsing the website.

You can find the cookies used by the company in the cookie settings window.

ESSENTIAL COOKIES

These cookies on the website are essential for you to browse and use the website’s features, such as remembering information entered in forms during the session, accessing protected areas of our website. Without these cookies, it would be impossible to provide certain website services, and it would not operate as smoothly as it should.

FUNCTIONAL COOKIES

By using these cookies, visitors can avoid changes to settings each time they visit the website. These cookies help remember your choices and settings (e.g., language or time zone). With these cookies, visitors avoid changes to settings every time they visit the website. Functional cookies also remember changes you make, as well as in other cases, such as when you leave a comment on the website. Functional cookies do not track your actions on other websites.

ANALYTICAL COOKIES

Analytical cookies show us whether a visitor has already visited the website. These anonymous cookies help us track the number of users and their visit frequency. These cookies collect information about the use of the website and help improve its performance. For example, analytical cookies can show which pages are visited most frequently, help record issues on the website, and so on.

ADVERTISING, TARGETING COOKIES

These cookies allow us to record your visit to our website, the pages you visited before, and the links you followed. We will then use this information to ensure that the advertising displayed is relevant to your interests. Advertising and targeting cookies allow us to know if you have already seen specific advertising or a specific type of advertising, and how much time has passed since you saw it. We may use cookies set by another entity to provide more accurately targeted advertising. They are also used to ensure that you see certain ads only a certain number of times and help measure the effectiveness of advertising.

HOW ARE COOKIES USED FOR ADVERTISING PURPOSES?

Cookies and other advertising technologies, such as pixels and tags, help us deliver more relevant ads. They also help us provide research and reporting to advertisers, understand and improve our services, and know when content was shown to you.

REFUSAL AND BLOCKING OF COOKIES

Many web browsers are set to automatically accept cookies. Visitors can block or delete cookies and similar unique identifiers at their discretion if their browser or device settings allow it.

However, please note that essential cookies and analytical cookies are a condition for using the website. If you refuse these cookies, we cannot be sure if or how our website will function.

You can control the use of other cookies by changing your browser settings. More information on how to remove cookies, as well as other useful information related to the use of cookies, can be found at these internet links:

However, if you refuse or block cookies or similar technologies, some website features may be unavailable or may not work as smoothly.

WAYS AND CONTACTS TO REACH US

You can contact us regarding any data processing issues in the following ways:

By email: info[at]tubegreen.lt

By phone: +370 652 18785

OTHER PROVISIONS

This Privacy and Cookies Policy may be updated by the company at any time. The company will inform visitors about updates by providing a new version of the privacy policy on the website.

If any provision of the Privacy Policy is deemed invalid or inapplicable, this provision does not affect the legality and validity of the remaining provisions of the Privacy Policy.

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