Privacy
policy

Privacy and cookie policy

The purpose of this Privacy Policy is to describe how personal data of data subjects are collected and processed, explain how long the data is stored for, who are the recipients of these data, what rights data subjects have and whom to contact to exercise these rights, and other matters related to the processing of personal data.

Personal data is processed in accordance with the European Union’s General Data Protection Regulation (EU) 2016/679 (the “Regulation”), the Law on Legal Protection of Personal Data and other legislation governing the protection of personal data.

UAB RE Excellence follows the following main principles of data processing:

• Personal data are collected for clearly defined and legitimate purposes only
• Personal data are processed lawfully and fairly
• Personal data are kept up to date
• Personal data are stored securely and no longer than needed for the defined purposes of processing or required by law
• Personal data are processed by those employees of the Organisation only who are authorised to do so because of their job functions, or duly authorised data processors.

1. Definitions

• Data controller means UAB RE Excellence (the “Organisation”), business registration number 306306811, registered office at Paupio g. 50-136, Vilnius.
• Data subject means any natural person whose data are processed by the Organisation. The data controller collects only those data of the data subject that are needed to perform the Organisation’s activities and/or when visiting, using or browsing the Organisation’s sites, Facebook account, etc. (the “Website”). The Organisation ensures that any personal data collected and stored are kept securely and used for defined purposes only.
• Personal data means any information relating, either directly or indirectly, to a data subject who is identified or can be identified directly or indirectly by reference to the relevant data. Personal data processing means any operation which is performed on personal data (including collection, recording, storage, editing, alteration, access, inquiries, transmission, retention, etc.).
• Consent means any freely and consciously given indication whereby the data subject consents to the processing of his/her personal data for a specific purpose.

2. Sources of personal data

• Personal data are provided by the data subject himself/herself. The data subject contacts the Organisation, buys real estate from the Organisation, leaves comments, asks questions, subscribes to newsletters, contacts the Organisation with a request for information, etc.
• Personal data are obtained when the data subject visits the Website. The data subject fills out forms on the Website, or leaves his/her contact information for whatever reason, etc.
• Personal data are obtained from other sources. Personal data are received from other institutions or organisations, public registries, etc.

3. Personal data processing

• By providing personal data to the Organisation, the data subject consents to the use by the Organisation of the data collected for the purpose of performing the Organisation’s obligations to the data subject, providing services that the data subject expects to receive.
• The Organisation processes personal data for the following purposes:

• Real estate selling, administration of debtors. For this purpose, the Organisation processes:

• For the purpose of selling real estate to customers, the following personal data of customers (natural persons) may be processed: name(s), surname(s), personal identification number, date of birth, e-mail address, telephone number, residence address, details of a power of attorney, bank account details, bank, identity card/passport details, such as number, date and place of issue, and other information related to the sale of real estate.
• For the purpose of managing debtors of the Organisation and collecting debts, the following personal data of customers (debtors, natural persons) may be processed: name(s), surname(s), personal identification number or date of birth, residence address, e-mail address, debt amount, other information related to the debt.
• Contracts, VAT invoices and other related documents are stored for such periods of time as specified in the General Document Storage Index approved by the order of the Chief Archivist of Lithuania.
• Information relating to the administration of debtors is kept no longer than is necessary for the purposes for which the personal data are processed.
• The legal basis for processing is the need to perform a contract to which the customer as a data subject is party of or in order to take steps at the request of the customer prior to entering into a contract (Article 6(1)(b) of the GDPR), the processing of certain personal data is necessary for compliance with legal obligations (Article 6(1)(c) of the GDPR), or processing is necessary for legitimate interests of the Organisation of improving its performance and business success rates (Article 6(1)(f) of the GDPR).

• Ensuring business performance and continuity of business. For this purpose, the Organisation processes:

• For the purpose of entering into and performing contracts, the following personal data of suppliers (natural persons) may be processed: name(s), surname(s), personal identification number or date of birth, place of residence (address), telephone number, e-mail address, place of work, position, signature, business licence details (type of activity, group, code, name, periods of activity, date of issue, amount), number of self-employment certificate, information whether the data subject is a VAT payer, bank account number and bank, amount for the service/goods, currency and other details provided by the person himself/herself, that the Organisation obtains itself by law while performing its activities, and/or that the Organisation is required to process by law and/or other legislation.
• For the purpose of entering into and performing contracts, the following personal data of supplier representatives may be processed: name(s), surname(s), telephone number, e-mail address, business name, address, position, power of attorney details (number, date, agent’s date of birth, signature).
• Contracts, VAT invoices and other related documents are stored for such periods of time as specified in the General Document Storage Index approved by the order of the Chief Archivist of Lithuania.
• The legal basis for processing is the need to perform a contract to which the customer as a data subject is party of or in order to take steps at the request of the customer prior to entering into a contract (Article 6(1)(b) of the GDPR), the processing of certain personal data is necessary for compliance with legal obligations (Article 6(1)(c) of the GDPR).

• Handling of inquiries, comments and complaints. For this purpose, the Organisation processes:

• Name(s), surname(s) and/or user name, e-mail address, telephone number, address, subject of the inquiry, comment or complaint, text of the inquiry, comment or complaint.
• Details of requests and comments are kept no longer than is necessary to examine the inquiry, comment or complaint and/or produce a reply to the data subject.
• The legal basis for processing is the necessity to process personal data for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Article 6(1)(f) of the GDPR) and consent of the data subject (Article 6(1)(a) of the GDPR).

• Direct marketing. For this purpose, the Organisation processes:

• Name(s), surname(s), e-mail address, telephone number.
• Data are stored for 5 years after the date of consent. This period may be extended if personal data are used or may be used as evidence or source of information in a pre-trial or some other investigation, including in an investigation by the State Data Protection Inspectorate, in civil, administrative or criminal proceedings, and in other cases provided for by law. Should this be the case, personal data may be stored for as long as necessary for these purposes of processing and destroyed promptly when they become no longer necessary.
• The legal basis for processing is consent of the data subject (Article 6(1)(a) of the GDPR) and the necessity to pursue the legitimate interests of the Organisation of improving its performance and business success rates (Article 6(1)(f) of the GDPR).
• Other purposes for which the Organisation may process personal data of a data subject when the data subject has given consent, when processing is necessary for legitimate interests of the Organisation or when processing of personal data by the Organisation is required by relevant law.

4. Use of social networks

• All information that you provide on social media (including posts, use of Like and Follow buttons, and other communication) is controlled by the operator of the relevant social network.
• The Organisation currently has an account on the social network Facebook. Facebook privacy policy is available at https://www.facebook.com/privacy/explanation.
• The Organisation currently has an account on the social network Instagram. Instagram privacy policy is available at https://help.instagram.com/519522125107875.
• The Organisation currently has an account on the social network LinkedIn. LinkedIn privacy policy is available at https://www.linkedin.com/legal/privacy-policy.
• We recommend that you read third party privacy statements and contact service providers directly if you have any questions about their use of your personal data.

5. Newsletters

For the purpose of sending newsletters, the Organisation uses third party services, such as MailChimp, Moosend, SendInBlue, GetResponse. The third party, i.e., MailChimp, Moosend, SendInBlue, GetResponse, uses only the e-mail address of the newsletter recipient to ensure successful delivery of the newsletter. MailChimp, Moosend, SendInBlue, GetResponse privacy policies are available at:

• MailChimp privacy policy: https://mailchimp.com/legal/privacy/.
• Moosend privacy policy: https://moosend.com/privacy-policy/.
• SendInBlue privacy policy: https://www.sendinblue.com/legal/privacypolicy/.
• GetResponse privacy policy: https://www.getresponse.com/legal/privacy.

You can unsubscribe from the newsletter service simply by clicking the “Unsubscribe” button at the bottom of every newsletter, by replying to the e-mail you’ve received, or by contacting the Organisation directly by e-mail with a request to be removed from the Organisation’s newsletter mailing list.

6. Transfers of personal data

• The Organisation agrees to respect the duty of confidentiality towards the data subjects. Personal data may be disclosed to third parties only if necessary for the conclusion and performance of a contract for the benefit of the data subject, or for other legitimate reasons.
• The Organisation may transfer personal data to its data processors who provide services to the Organisation and process personal data on behalf of the Organisation. Data processors shall have the right to process personal data only as instructed by the Organisation and only to the extent necessary for the proper performance of contractual obligations. The Organisation shall only use data processors that are able to adequately ensure the implementation of the appropriate technical and organisational measures in a manner that data processing complies with the requirements of the Regulation and ensures the protection of the rights of data subjects.
• The Organisation may provide personal data in response to requests from courts and public authorities to the extent necessary for the proper compliance with applicable laws and instructions from public authorities.
• The Organisation guarantees that personal data will not be sold or leased to third parties.

7. Processing of personal data of minors

• Individuals under the age of 14 cannot submit any personal data using the Organisation’s website. If an individual wishes to use the Organisation’s services and is younger than 14 years of age, he/she needs to provide a written consent for personal data processing signed by one of their representatives (father, mother, guardian(s)) before submitting any personal information.

8. Personal data retention periods

• Personal data collected by the Organisation shall be kept in printed documents and/or in the Organisation’s information systems. The processing of personal data shall not be extended beyond what is necessary for the achievement of the purposes of processing and no longer than requested by the data subjects and/or required by law.
• Although the data subject may terminate the contract and refuse the Organisation’s services, the Organisation has the obligation to retain personal data of the data subject in case of any complaints or legal claims in the future until the retention periods expire.

9. Rights of the data subject

• Right to obtain information about personal data processing.
• Right to access personal data about the data subject being processed.
• Right to the rectification of personal data.
• Right to the erasure of personal data (‘right to be forgotten’). This right shall not apply to the extent where personal data the erasure of which has been requested are processed on other legal basis, such as processing is necessary for the performance of a contract or performance of an obligation laid down in applicable laws.
• Right to restriction of processing.
• Right to object to processing.
• Right to data portability. Right to data portability cannot adversely affect the rights and freedoms of others. The data subject shall have no right to data portability with respect to those personal data that are being processed by nonautomated means in structured media, for example, in paper files.
• Right not to be subject to a decision based solely on automated processing, including profiling.
• Right to lodge a complaint regarding personal data processing with the State Data Protection Inspectorate.

10. The Organisation shall provide the data subject with an opportunity to exercise his/her rights described above, except in cases provided for by law, where it is necessary to ensure national security or defence, public order, prevention, investigation, detection or prosecution of criminal offences, important economic and financial interests of the state, prevention, investigation and detection of breaches of official or professional ethics, protection of the rights and freedoms of the data subject or other individuals.

11. Exercising the rights of a data subject

• To exercise any of his/her rights, the data subject may contact the Organisation as follows:
• By submitting a written request in person, by mail, through a representative or by electronic means of communication at info@reexcellence.lt.
• Orally – by phone: +370 610 13655.
• In writing – mailing address: Paupio g. 50-136, Vilnius.
• For the purpose of protecting data from unauthorised disclosure, on receipt of a request from the data subject to provide the data or exercise other rights, the Organisation must verify the identity of the requesting data subject.
• The Organisation shall provide a reply to the data subject no later than one month from the day of receipt of the data subject’s request depending on the specific circumstances of personal data processing. This period may be extended by two more months depending on the complexity and number of requests.

12. Responsibility of the data subject

• The data subject shall:
• Notify the Organisation of any changes to the information and data submitted. It is important for the Organisation to have accurate and up to date information about the data subject.
• Provide the necessary information so that the Organisation is able to verify the identity of the data subject on receipt of his/her request and ensure that the Organisation is in contact with or cooperates with the specific data subject (provide an identification document or proof of identity as laid down in law or by means of electronic means of communication to enable proper identification of the data subject). This is necessary for the protection of the personal data of the data subject and other individuals so that the data subject’s information is disclosed to the data subject only without prejudice to the rights of other individuals.

13. Final provisions

• By providing personal data to the Organisation, the data subject accepts this Privacy Policy, understands its provisions and agrees to comply with this policy.
• For the purpose of developing and improving its operations, the Organisation may make unilateral changes to this Privacy Policy. The Organisation may amend this Privacy Policy, in full or in part, by announcing changes on its website at reexcellence.lt.
• Any additions and amendments to this Privacy Policy shall come into effect on the day when published, i.e., on the day when published on the website at www.reexcellence.lt.

Cookie policy

UAB RE Excellence (the “Organisation”) cares about the security of your personal information. We are committed to the protection and responsible processing of your personal data. This document describes how we process your personal data using cookies.

Personal data are processed in accordance with the General Data Protection Regulation of the European Union (EU) 2016/679 (the “Regulation”), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other legislation governing the protection of personal data.

1. Use of cookies

• The Organisation’s website uses cookies, which are small pieces of text information placed automatically on your personal computer or some other device you may be using to browse the website. Cookies are used to improve visitor browsing experience, analyse visitor traffic information and visitor behaviour on the website.
• The Organisation uses cookies on the website for the purpose of improving visitor browsing experience on the website.
• The Organisation may use the following types of cookies on the website:
• Technical cookies help to display the website and its contents to visitors, ensure the functionality of the website. Technical cookies are essential for the proper functioning of the website.
• Functionality cookies are used to facilitate use of the website by the visitor, remember the choices and preferences made while browsing. Functionality cookies are not essential for the website to function fully, but they do add to the functionality of the website and improve user experience on the website.
• Analytical cookies are used to obtain information how visitors use the website. This is necessary so that the Organisation can optimise and improve the website. With the help of analytical cookies, the Organisation can collect information about the pages you navigate, pages you came from, what e-mails you open and what e-mails you respond to as well as information about the date and time. This also means that we can use information about you and how you use the website, for example, how often you visit the website, number of clicks per page, search keywords, etc.
• Commercial cookies (targeting and advertising cookies) are used for the purpose of displaying advertisements on the website that are tailored to visitors. This practice is called retargeting and it is based on the browsing actions, for example, products and/or services you had previously searched for.
• Access to statistical information about visitors to the Organisation’s website shall be given to employees of the Organisation responsible for analysing this information and improving the website.
• Access to technical records may also be given to partners of the Organisation who provide content management tools to the Organisation.
• Google Analytics tool is provided by the U.S. company Google Inc., meaning that it also has access to the statistical data collected using this tool. This provider has a contractual and statutory obligation to ensure privacy.
• Data collected using cookies shall be stored at the Organisation for no longer than necessary to achieve the purposes of processing, or no longer than requested by the data subjects and/or required by law.
• More detailed information about cookies is available at http://allaboutcookies.org/.
• If you disagree with the use of cookies by us, you have the option of changing settings on your browser and controlling the number of cookies used. Here are some useful links how to disable cookies:

• Chrome browser: https://support.google.com/;
• Firefox browser: https://support.mozilla.org/;
• Safari browser: https://support.apple.com/;
• Edge browser: https://support.microsoft.com/.

2. Description of cookies used on the website