UAB Tipro (hereinafter referred to as "we" or "Data Controller") is the controller of this promo24.com website (hereinafter referred to as the "Website"). Through these Privacy Policies (hereinafter referred to as "Privacy Policies"), we establish and explain how we collect and process the personal data of visitors to the Website. The Privacy Policies also provide information on the processing of data of all other data subjects (e.g., contractors or their representatives/employees) carried out in the course of our activities.
The Privacy Policies apply to all individuals visiting the Website, and the conditions set forth are applicable each time you wish to access our content and/or service, regardless of the device (computer, mobile phone, tablet, etc.) you use.
We process the data of all data subjects lawfully, transparently, and fairly, for pre-determined purposes and only to the extent necessary to achieve those purposes. In processing your personal data, we adhere to the General Data Protection Regulation No. 2016/679 (hereinafter referred to as "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 and recommendations and/or instructions of supervisory authorities.
Individuals under the age of 14 are not allowed to provide any personal data through our managed internet websites and/or social network accounts. If you are under the age of 14, you must obtain the consent of your legal representatives (parents, adoptive parents, guardians, caretakers) before providing any personal information.
Terms used in the Privacy Policies are understood as they are defined in the GDPR and other legal acts regulating personal data protection.
Click the "Learn More" box in each section to find detailed information about how we process your personal data and specifics of our activities.
How do we collect information about you?
Your personal data, i.e., any information about you that allows us to identify you, is obtained in various ways:
You may provide information (personal data) yourself;
Information about you may be collected automatically;
In some cases, we receive information about you from third parties and may collect information about you from publicly accessible sources.
You may directly provide us with your personal data. This usually occurs in situations such as:
Using our services (e.g., writing comments under articles/recipes, filling out a recipe submission form);
Subscribing to our newsletters or seeking to receive personalised content;
Using our social media accounts;
Submitting an inquiry, request, and/or complaint to us via phone, email, or regular mail;
Participating in contests, where personal data are provided for the receipt of a prize in case of winning.
Information about you may be collected automatically. This typically happens when:
You make a query through our Website or social media accounts (such as Facebook, Instagram, YouTube);
You make public posts on social media platforms (such as Facebook, Instagram, YouTube) that we manage;
You use our managed internet websites (data is collected via cookies and similar technologies. More information about the cookies we use can be found below).
Where permitted under applicable laws, we may receive information about you from third parties. This could be information provided by our partners, contractors, service providers, or information from your publicly accessible profiles or databases (e.g., if you log into the Website through your Facebook or Google account, you grant Facebook or Google permission to share your account information with us – hence, the source of the received data is accordingly Facebook or Google).
We may combine the information we receive about you from yourselves, public, and commercial sources with other information we receive from or about you.
We may collect information about you in other cases not discussed in the Privacy Policies, but if that were to happen – we will inform you additionally.
While we strive to collect as little information about you as possible, we do collect the following information to conduct our operations:
Your contact details;
Information necessary for submitting recipes, conducting transactions, contracts, and any other agreements, their execution and administration;
Information you provide when calling, writing to us, or submitting inquiries;
Public information from your social media profiles if you use our Website by connecting through them;
Information necessary for the defence of our company’s interests in court or other institutions;
Information about the device you use;
Information necessary for direct marketing (if we have the right to provide it to you in a specific case).
The information we directly collect from you most commonly includes:
Your name;
Your email address.
The information we automatically collect typically includes:
Information on how you use this Website and/or our other websites (device information: IP address, operating system version, and settings of the device you use to access content; login information: the duration and timing of your session use and any information stored in cookies that we have set on your device (cookie policy is provided below); location information: device GPS signal or information about nearby Wi-Fi access points and cell towers, which may be transmitted to us when you use our site content).
The information we receive from third parties or publicly accessible sources typically includes:
Information from service providers, your publicly accessible profiles, or databases (e.g., if you log into our social networks through your Facebook or Google account, you grant Facebook or Google permission to share your account information with us – thus, the source of the received data is accordingly Facebook or Google).
You may choose not to provide us with certain information, but in that case, we may not be able to offer you our service (for example, if you do not provide the necessary information requested in order to respond to your inquiry, we will not be able to respond).
Important: We do not request and do not process your special category 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. Our staff does not ask for your login details, credit card numbers, passwords, or any other information that could cause you financial or any other harm via written, telephone, or any other means.
The information provided above is processed for the following purposes:
Registration, transactions, contracts, and any other agreements' formation, execution, and administration;
Service provision – allowing access to Website functionalities (e.g., writing comments, submitting information, participating in forum discussions);
The enforcement of our or our group of companies' rights and interests;
The establishment, maintenance, and development of business, professional, and/or other legitimate relationships;
The fulfilment of our obligations under applicable laws;
The management of our company's internal administration and accounting;
The assessment of the quality of our online services and ensuring the functionality of mobile applications;
The conduct of direct marketing.
We have the right to send promotional information about our services to our clients via the email address we obtained in the course of providing services to them, and our clients have the right now or at any time later to opt-out of receiving such direct marketing content by notifying us of their decision in any convenient way: by email at [email protected] or by using the unsubscribe link in the email with promotional information. Such withdrawal will not affect the processing of your personal data carried out by us prior to it.
In all other cases, we will process your personal data for direct marketing purposes only with your explicit consent for such processing. You may withdraw this consent at any time later by notifying us in the ways mentioned above.
Your personal data is processed based on one or more lawful processing grounds:
Compliance with legal obligations;
The formation or execution of a contract or other similar agreements with you;
Our legitimate interests (unless your private interests prevail);
In certain cases – your consent.
The purposes, legal grounds, and personal data that we process are detailed in the table below:
|
Purpose |
Legal Basis |
Personal Data |
|
Formation, execution, and administration of registrations, transactions, contracts, and any other agreements |
Contract formation or execution with you Compliance with legal requirements Our company's legitimate interests |
Name, surname, residential information, phone number, email address. Also, any other information necessary for fulfilling our obligations |
|
Providing services – enabling the use of Website functionalities (e.g., commenting, submitting information) |
Contract formation or execution with you Our company's legitimate interests |
Name, surname, residential information, email address, professional activity/business, position, education, any public data from social media profiles, and information you provide (e.g., in comments). Also, any other information necessary for acquiring/providing services |
|
Enforcement of our or our group of companies' rights and interests |
Compliance with legal requirements Our company's legitimate interests |
All personal data we possess, as outlined in these Privacy Policies |
|
Establishing, maintaining, and developing business, professional, and/or other legitimate relationships |
Our company's legitimate interests Compliance with legal requirements |
Name, surname, phone number, email address or other contact information |
|
Fulfilment of our obligations under applicable laws |
Compliance with legal requirements |
Depends on the requirements of applicable laws, content of requests from institutions, or other objective circumstances |
|
Management of our company's internal administration and accounting |
Compliance with legal requirements Our company's legitimate interests |
All personal data we possess, as outlined in these Privacy Policies |
|
Assessing the quality of our online services and ensuring the functionality of mobile applications |
Our company's legitimate interests |
IP address, operating system version, and device settings, session usage time and duration, any information stored in cookies on your device, device GPS signal or information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use our website content |
|
Conducting direct marketing (only if we have received your consent, or correspondingly, have not received your objection) |
Consent Our company's legitimate interests |
Name, surname, email address, phone number, residential address, age |
In cases where we cannot rely on one of the legal grounds listed in the table, we will request your consent before processing your personal data. Such cases will be evident from the circumstances and context.
Should we process your personal data for purposes other than those specified in these Privacy Policies, we will inform you by providing a separate notification.
Without your prior written consent, we may only share your personal data in the following cases:
To carefully selected business partners or companies that provide services at our request;
To companies within our group;
To law enforcement and state institutions;
To other entities when required by law or necessary to protect our legitimate interests.
The ability of the recipients of your personal data (separate data controllers) to use your information is limited; they cannot use this information for purposes other than those stipulated in the contract with us or as provided by law. You will be asked for separate consent to receive direct marketing offers from them.
We may also provide your data to data processors who provide services to us (perform tasks). Data processors are authorised to process your personal data only on the basis of a written contract between us and them, according to our instructions, and only to the extent necessary to properly fulfil the obligations set out in the contract. By employing processors, we take all necessary measures to ensure that our data processors have implemented appropriate organisational and technical security measures and maintain the confidentiality of your personal data.
Here is a list of categories of data recipients:
banks; companies developing, implementing, and supporting software; companies providing communication services; security services; postal and courier services; legal service providers; archiving services; bloggers and representatives of various other media; companies involved in accommodation, catering, leisure activities, event organisation, or similar activities.
Other parties to whom our information about you may be disclosed, when necessary to protect our legitimate interests or to comply with legal requirements imposed on us, include state and law enforcement institutions, among others.
For more detailed information about specific companies mentioned in this section to whom your personal data may be provided, you can contact us using the contact details provided in these Privacy Policies.
UAB Tipro currently does not transfer any of your personal data to third countries (i.e., countries outside the European Economic Area (EEA)). Should there be an exceptional need for such a transfer, we will do everything within our power to ensure the security of the transferred personal data.
In exceptional and necessary cases of data provision outside the EEA, we ensure that one of the following security measures is applied:
The contract signed with the data recipient is based on Standard Contractual Clauses approved by the European Commission;
Binding Corporate Rules are applied;
The data recipient is located in a country recognized by the European Commission as having adequate data protection standards;
Codes of conduct, certification mechanisms;
Authorization obtained from the National Data Protection Authority.
In the absence of any of the aforementioned appropriate safeguards, we may resort to exceptions outlined in Article 49 of the GDPR (e.g., transferring your data based on your consent), but these can only be applied in strictly defined cases by the GDPR.
What do we do to protect your personal data?
We have implemented reasonable and appropriate physical and technical measures to protect the information we collect for service provision purposes. However, keep in mind that while we take proper actions to protect your personal data, no website, internet transaction, computer system, or wireless connection is completely secure.
How long do we store your personal data?
The retention periods for personal data are determined based on legal, regulatory requirements, and instructions from supervisory and/or other competent authorities. If these requirements or instructions are not specified, we set the data retention periods based on our legitimate interests.
Please note that, given the scope of personal data we process, we specify the retention periods for certain specific categories of data subjects' personal data in the respective privacy policies of other websites we manage or in informational notices provided to you at the time of data collection.
After the data retention periods have expired, your data will be deleted in a manner that makes it impossible to reproduce or anonymize so that you can no longer be identified.
Typically, personal data are stored for the following periods:
|
Personal Data |
Retention Period |
|
Data related to transactions, contracts, and any other agreements |
10 years after the transaction, contract, or agreement has ended/terminated |
|
Payment data |
10 years after the date of the payment operation |
|
Data related to registration forms on our Website |
As long as you are registered on the Website, i.e., until you delete your account |
|
Data contained in inquiries, requests, and/or complaints submitted to us via phone, email, or regular mail |
Up to 2 years from the receipt of the inquiry/request/complaint or its fulfilment |
|
Your data related to potential or existing enforcement of our interests in court or other institutions |
Until the expiration of statutory periods for claims/complaints or litigation and/or until a final court decision becomes effective |
|
Personal data processed based on your consent |
Up to 3 years from the moment of obtaining consent, unless consent is withdrawn earlier |
Even if you express a desire to terminate the contract and opt out of our services, due to potential future claims, we will continue to store certain personal data until the expiration of specific data retention periods. This information will also be kept to provide you with necessary information when needed, to have a properly recorded history of our relationship with you, and to answer any questions related to your cooperation with us.
Depending on the situation and additional conditions set by the GDPR, you have the following rights:
The right to be informed about the processing of your data;
The right to access your data and how it is processed;
The right to request the correction or, depending on the purposes of processing, the completion of incomplete personal data;
The right to request the deletion of your personal data (the right to be forgotten);
The right to request a restriction on the processing of your personal data;
The right to data portability;
The right to object to the processing of your personal data when it is done for public interest, the pursuit of our or a third party's legitimate interests, or for direct marketing purposes, including profiling;
The right to withdraw your consent for processing personal data, if the processing is based on consent.
We always aim to ensure your rights are fully respected and promptly address any potential violations. Therefore, for any concerns regarding the processing of your personal data by us, we encourage you to contact us first. You also have the right to lodge a complaint with the State Data Protection Inspectorate at any time.
We provide convenient ways for you to exercise these rights. You can do so by writing to us at [email protected] or by using specific links provided at the bottom of our promotional content if such content is sent to you.
Your rights will be implemented after confirming your identity in person (by presenting an identity document: ID card or passport) or through electronic means (e.g., electronic signature).
|
Your Right |
Certain Restrictions |
|
The Right to Know |
You have the right to be informed about the processing of your data in clear, simple, and understandable language before the processing of your personal data begins. |
|
The Right to Access |
This right means you can request from us: Confirmation whether we are processing your personal data; A list of your personal data being processed; A list of purposes and legal grounds for processing your data; Confirmation whether we send data to third parties and, if so, what security measures were taken; The source of your personal data; Information on whether profiling is applied; The data retention period. This information will be provided as long as it does not infringe on other individuals' rights and freedoms. |
|
The Right to Rectify |
Applicable if the information we have related to your personal data is incomplete or inaccurate. |
|
The Right “to be Forgotten” |
Applicable if: The information we have is no longer necessary for the purposes for which it was collected; We process data based on your consent, and you withdraw that consent; We process data based on legitimate interests, and after your request, it is determined that your private interests are overriding; The information was obtained unlawfully. |
|
The Right to Restrict |
This right can be exercised while we assess the situation, i.e., If you dispute the accuracy of the information; If you object to the processing of your personal data based on legitimate interests; We use the information unlawfully, but you oppose its deletion; The information is no longer needed by us, but you require its retention for legal disputes. |
|
The Right to Data Portability |
This right can be exercised if you have provided data and we process it automatically based on your consent or a contract made with you. |
|
The Right to Object |
This right can be exercised when data processing is conducted for the public interest or is necessary for the legitimate interests of the Data Controller or a third party. In processing your personal data on such grounds, we have the obligation to demonstrate compelling legitimate reasons for the processing that override your interests. You may also object to the processing of your personal data for direct marketing purposes at any time, including profiling to the extent that it is related to such direct marketing. |
|
The Right to Withdraw Consent |
Withdraw your consent to process personal data at any time if the processing is based on consent. |
|
The Right to Complain to the State Data Protection Inspectorate |
You have the right to address the institution responsible for the supervision and control of personal data protection laws – the State Data Protection Inspectorate (A. Juozapavičiaus g. 6, 09310 Vilnius, email [email protected], phone (8 5) 271 2804). More information: www.ada.lt |
We may not be able to facilitate the exercise of the above rights in cases prescribed by law, when it's necessary to ensure the prevention, investigation, and detection of crimes, breaches of professional ethics, as well as to protect the rights and freedoms of the data subject or other individuals.
In these Privacy Policies, the term "cookies" is used to describe cookies and other similar technologies, such as Pixel Tags, Web Beacons, and clear GIFs.
Cookies are small pieces of information stored in your internet browser. They help us:
Recognize you as a previous visitor to a particular website;
Save your visit history on the website and customise content accordingly;
Ensure smooth operation of the Website;
Monitor visit duration, frequency, and gather statistical information about the number of visitors to the Website.
By analysing this data, we can improve our Website and make it more user-friendly.
When using a browser to access our content, you can configure your browser to accept all cookies, reject all cookies, or be notified when a cookie is sent. Each browser is different, so if you do not know how to change your cookie settings, look in its help menu. Your device's operating system may have additional cookie controls. If you do not want information to be collected via cookies, you can use a simple procedure available in many browsers that allows you to refuse the use of cookies. To learn more about managing cookies, visit: http://www.allaboutcookies.org/manage-cookies/.
Remember, some services may be designed to work only with cookies, and disabling them or part of them may prevent you from using those services.
Please note that, in addition to our cookies, the Website allows certain third parties (e.g., social network operators) to set and access cookies on your device. Third parties who have installed such cookies apply their privacy policies, and we cannot be responsible for them (our Website does not have access to the information they transmit), so we strongly recommend you to familiarise yourself with these policies posted on the websites of these third parties. Our social media accounts are subject to their operators' privacy policies.
The Website may contain links to external websites, e.g., the websites of our advertised products and/or service providers. Following such links, note that these websites and the services accessible through them have their separate privacy policies (rules) for which we cannot take responsibility, so we recommend you review them thoroughly before providing any personal data.
If you notice any non-compliance with the Privacy Policies, a security gap on any of our managed Websites, or have other questions related to the processing of your personal data, please contact us in any way convenient for you:
Email: [email protected]
The Privacy Policies are reviewed and updated according to our needs, but not less frequently than once every two years or upon changes in the laws regulating personal data processing. Upon updating the Privacy Policies, we will inform you about what we consider to be significant changes by posting a notice on the Website or by a similar method. If you use our content and/or services after such notification is published, we will consider that you agree with the new requirements set out in the updated Privacy Policies.
By continuing to browse the Website, you confirm that you have read these Privacy Policies and understand their provisions.
The Privacy Policies were last reviewed on October 19, 2020.