Privacy Policy

We, UAB „Rebaltic“, through this personal data processing policy (hereinafter – the Data Processing Policy), provide information on how we process your personal data when you use our services and visit our website. With this Data Processing Policy, we establish the main guidelines and provisions that we undertake to observe and implement when processing the personal data of natural persons (data subjects) entrusted to us or otherwise collected.

The Data Processing Policy has been prepared in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter – the General Data Protection Regulation or GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other legal acts applicable to the protection of personal data.

We reserve the right to unilaterally change this Data Processing Policy at our own discretion at any time by publishing a new version on our website.

This Data Processing Policy provides concise answers to the following questions:

What principles do we follow?
How do we collect personal data?
What personal data do we collect, for what purposes, and on what legal basis?
How do we use cookies?
How long do we process (store) personal data?
To whom may the personal data we process be disclosed?
How do we ensure the security of the personal data we process?
What rights do data subjects have?
How to exercise the right to lodge a complaint regarding data processing?

WHAT PRINCIPLES DO WE FOLLOW?

When processing personal data, we undertake to follow the principles related to the processing of personal data established in Article 5 of the General Data Protection Regulation and to make every effort to ensure that personal data is:

processed lawfully, fairly, and in a transparent manner in relation to the data subject;
collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes, except for the exceptions provided for in the General Data Protection Regulation;
adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
accurate and, where necessary, kept up to date;
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (with exceptions provided for in the General Data Protection Regulation);
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

HOW DO WE COLLECT PERSONAL DATA?

Depending on the nature of the data and the purposes of its processing, we collect personal data:

directly from the data subject or their representative (authorized person), when they provide their personal data (for example, when the data subject fills in (on paper or electronically) relevant sections (parts, forms) of contracts, submits copies of documents, sends data by email, or provides it by phone (during a phone conversation, SMS));
when the data subject visits our website (using cookies);
from other data controllers (for example, photographers);
when there is a justified need – from various publicly accessible sources (for example, aruodas.lt, domoplius.lt, SE „Centre of Registers“).

WHAT PERSONAL DATA DO WE COLLECT, FOR WHAT PURPOSES, AND ON WHAT LEGAL BASIS?

Depending on the purposes of data processing, and based on the provisions set out in Article 6(1) of the General Data Protection Regulation, we collect and process the following personal data indicated below.

Data related to the conclusion and execution of a contract

Purpose of data processing: In order for us to conclude, prepare an intermediation, lease, preliminary sales agreement, or other contract with the data subject and execute it (provide services), as well as to carry out financial accounting (issue invoices, collect and store financial reporting information required by law), control payment for services, provide information related to the concluded contract (about changes in contract terms, etc.), and prove the execution of the contract, we need to know the relevant data.
Scope of data processing: We process:
- Name and surname;
- Personal identification number or date of birth;
- Place of residence address;
- Address of the owned property;
- Phone number;
- Email address;
- Personal data of representatives (authorized persons) concluding contracts with us on behalf of legal or natural persons (name, surname, other data indicated in the relevant powers of attorney);
- Address and photos of the real estate (object) being sold/rented;
- Data related to payments for services rendered (payment amount, date, method, number of the payment account from which the payment is made, etc.);
- Other data provided in the relevant contracts.
Legal basis for data processing: The processing of the above-mentioned data is based on Article 6(1)(b) of the General Data Protection Regulation. Furthermore, the processing of other data subjects‘ data provided to us by the data subject (our client’s representatives), as well as personal data received during the execution of the contract, is based on Article 6(1)(f) of the General Data Protection Regulation in order to ensure our and/or our client’s legitimate interests.
Consequences of failure to provide data: If we do not receive the above-mentioned personal data, we will not be able to conclude the relevant contract and/or provide the relevant services.

Data related to various requests and inquiries submitted to us by data subjects

Purpose of data processing: When a data subject submits any request (claim, demand, inquiry) to us, even if they have not concluded a contract with us, we will process the data provided by them in order to resolve such a request, provide an answer to the data subject, and take other necessary actions according to the legitimate request of the data subject.
Scope of data processing: We process:
- Name;
- Surname;
- Communication data (phone no., email);
- Correspondence (when a natural person can be identified from it);
- Other provided data.
Legal basis for data processing: Processing of personal data for the purpose of resolving requests submitted to us is based on the provisions of Article 6(1)(b), (c), and/or (f) of the General Data Protection Regulation.
Data subject’s right to object: The data subject is not obliged to provide their personal data for the above-mentioned purpose. However, if certain data is not provided, the relevant request of the data subject may not be fulfilled.

Data required for direct marketing

Purpose of data processing: With the consent of the data subject (by filling out a separate form), their contact details may be used for direct marketing purposes.
Scope of data processing: We process:
- Name;
- Surname;
- Email address;
- Phone number;
- History of contractual relations (information about previously concluded contracts and services provided).
Legal basis for data processing: Such data processing is based on the provision of Article 6(1)(a) of the General Data Protection Regulation.
Data subject’s right to object or withdraw consent: The data subject may at any time object to or withdraw their consent to use their data for direct marketing purposes. If the data subject does not consent to the use of their personal data for direct marketing purposes or withdraws such consent, their data will no longer be processed for such marketing purposes, but the data subject will not lose the opportunity to use other services provided by us.

HOW DO WE USE COOKIES?

We use cookies on our website.

A cookie (hereinafter – Cookie) is a small set of data stored on the User’s computer or other terminal device when visiting the Company’s Website. The Cookie contains information placed by the Website. When visiting the Website, the information contained in the Cookies is automatically analyzed and adapted to the needs of the Company and the User. The information provided by Cookies may be used to evaluate the User’s behavior on the Website and to provide them with advertising offers and/or other services provided on the Website.

The Website uses temporary and persistent Cookies. Temporary cookies remain on the User’s computer (or other device) while the User is using the Website, which means that when the User leaves the Website, temporary Cookies are removed from the User’s computer (or other device). Persistent cookies are processed on the User’s computer (or other device) for 5 years.

Types of Cookies used:

Essential: Necessary for the proper operation of the Website; allow full navigation of the website and use of all its functions;
Performance: Help understand how the data subject uses the website. They help obtain information about the parts of the website visited, the time spent on the website, and any website operation problems and disruptions encountered by the data subject while browsing the website;
Functional: Help remember what the data subject selected or indicated on the website during a previous session; for example, when the data subject starts typing their username to log in to the system, the username used by the data subject in previous sessions is presented;
Targeting or Advertising: Used to provide the data subject with content that better matches their interests. They also help to know what type of Company advertising the data subject saw and when they last saw it, if any was shown to them at all.

All cookies used by the Company are anonymous; they allow the website user to be recognized but do not allow their personal identity to be determined.

Purposes of using Cookies:

To provide the data subject with the opportunity to use all website functions and services provided on the Company’s Website;
To satisfy the individual interests and needs of each Website User;
To ensure the security and privacy of the Website User;
To save input information in our tools, thus speeding up the User’s actions on the Website;
To save information about information and services of interest to the Website User, in order to provide the User only with targeted information and advertising;
To obtain aggregated data on the basis of which the Company could evaluate how Users use the Website and, based on such data, improve the operation of the Website, its structure, and content.

Cookie Management:

The User expresses their prior voluntary consent to allow cookies to be recorded by checking the appropriate box „I AGREE“ („SUTINKU“) next to the message: „We inform you that cookies are used on this website. By agreeing, check the appropriate box ‚I Agree‘. You can withdraw your choice at any time by changing your internet browser settings and deleting saved cookies.“

Most internet browsers are set to automatically accept Cookies. Therefore, a User who does not agree to Cookies being recorded and processed on their computer (or other device) can block or delete them by changing their internet browser settings (usually found in the browser’s toolbar under „Tools“ – „Internet options“ menu).

If all or part of the Cookies are blocked and/or deleted, the User can still use the Website, but some Website functions and/or services provided on the Company’s Website may become unavailable to the User. Furthermore, such a User will not receive information on the Company’s Website adapted to their needs.

The collection and processing of personal data using Cookies is based on the provisions of Article 6(1)(a) and (b) of the General Data Protection Regulation.

Third-party websites, services, and products on our website

Our website may contain third-party advertising banners, links to their websites, and services that we do not control. We are not responsible for the security and privacy of data collected by third parties. The data subject must inquire about the privacy protection of such data with the relevant third parties whose websites or services they use.

HOW LONG DO WE PROCESS DATA?

We process personal data for the entire duration of the contract concluded with a specific data subject and for another 10 years after its end, except for:

Financial data of contract execution, which is stored for 10 years from the completion of the relevant financial operation;
Personal data provided to us in various requests by data subjects, which are stored for 6 months after the request is resolved, but not for less than one year from the receipt of the request.

If we believe that a dispute may arise in a specific case, we store the data related to such a case for the entire relevant statute of limitations period established by applicable laws (depending on the nature of the potential claim), if it is not shorter than the relevant period indicated above.

Upon expiration of the data processing terms, we delete the data so that it cannot be reproduced, or we alter it so that it cannot be linked to a specific natural person.

TO WHOM MAY THE PERSONAL DATA WE PROCESS BE DISCLOSED?

The personal data we process may be disclosed to persons engaged by us to provide services and/or perform works and/or persons providing relevant services to us (brokers) or performing relevant works, only to the extent necessary to provide specific services and/or perform specific works. The processed data may also be disclosed to insurance companies insuring our civil liability, lawyers representing us, assistant attorneys, auditors, and other independent persons supervising our activities.

Data related to visiting the website may be disclosed to our partners engaged for the maintenance and development of our website and the processing of statistical data.

In accordance with the procedure established by legal acts, we may be obliged to disclose data to competent authorities or institutions (for example, the police, courts, tax inspectorate, labor inspectorate, insurance companies).

HOW DO WE ENSURE THE SECURITY OF THE PERSONAL DATA WE PROCESS?

In order to protect the data we process from loss, unauthorized use, or illegal alteration, we have implemented appropriate organizational and technical measures. However, we would like to point out that no organizational and/or technical measures can ensure complete data security.

WHAT RIGHTS DO DATA SUBJECTS HAVE?

The data subject has the right to contact us regarding issues related to the processing of their personal data, i.e., they have the following rights:

The right to receive information about data processing;
The right to access their data (request our confirmation as to whether your personal data is being processed, and if so – to access your data and see how it is being processed);
The right to request the rectification of data or, taking into account the purposes of personal data processing, to supplement incomplete personal data;
The right to request the erasure of data or the suspension of data processing actions (excluding storage) (right to destruction and right „to be forgotten“);
The right to restrict data processing;
The right to data portability;
The right to object to the processing of personal data;
The right to lodge a complaint with a supervisory authority;
Other rights established by legal acts applicable to personal data processing.

The data subject may submit any request related to the processing of personal data to us by email at info@reb.platina.lt, by sending the request by post, or by arriving at our office at the address indicated below. Taking into account the subject matter of the data subject’s request, in order to ensure the confidentiality of the personal data we process, we may require the person submitting the request to provide additional information necessary to identify the personal data subject and/or to confirm their identity in a specific way (for example, to sign the request with a secure electronic signature, to personally arrive at the location and present a valid identity document, to send a properly certified copy of such a document, or similar). If the person fails to comply with such a request of ours, the requested information may not be provided.

We undertake to respond to all requests related to the processing of personal data within one month from the receipt of the request in accordance with the procedure established by the General Data Protection Regulation.

HOW TO EXERCISE THE RIGHT TO LODGE A COMPLAINT REGARDING DATA PROCESSING?

Regarding the exercise of their rights when we process personal data, the data subject may contact us at any time by email at info@reb.platina.lt.

Every data subject has the right at any time to complain about our processing of their data by submitting a complaint to the State Data Protection Inspectorate (L. Sapiegos g. 17, 10312 Vilnius, tel. (8 5) 271 28 04, (8 5) 279 1445, email ada@ada.lt, www.vdai.lrv.lt). We value your feedback and encourage data subjects to contact us first regarding any questions, doubts, or complaints related to the processing of their data without hesitation.

UAB „REBALTIC“ CONTACTS

Address: Liejyklos g. 3, Vilnius, Republic of Lithuania

Tel: +370 657 42234

Email address: info@reb.platina.lt

More information: www.reb.platina.lt