If the Buyer does not agree with this Policy or its separate terms, this may mean that the buyer will not be able to use the services of the Company Modulit Solutions PJSC (hereinafter - the Services).
Please note that the Policy may be reviewed annually or as necessary.
Personal data means any information that can be used to identify a person, as well as any information about a person who has already been identified.
The Company collects and processes the personal data listed in this Policy on the following legal bases:
- acceptance of the terms provided for in this Policy;
- legitimate interest of the Company;
- fulfillment of the legal obligation arising for and applicable to the Company.
To the extent and under the conditions provided for by the applicable legislation, the processing of the same personal data may be subject to one or more of the above legal bases.
1. Buyer’s data and purposes of its processing
1. 1. Inspection and administration
Purpose and method of using the buyer’s personal details: The Company identifies the buyer according to the provided personal details. The Company uses the personal details (name, last name, e-mail, telephone number) provided in the Buyer’s query form to communicate with him/her, including responses to queries and comments, provision of the important information about the Services, their provision and/or changes to this Policy.
The buyer is responsible for the correctness and accuracy of the data provided. If the buyer provides incorrect (false) data, forgets or does not update the changed data, the Company cannot exercise the buyer’s rights. The Company shall not be liable for any damages incurred by the Buyer because the Buyer provided incorrect or incomplete personal data.
The Company does not have the possibility to verify the correctness and accuracy of the data provided by the buyer. By accepting the buyer’s query form, we believe that the buyer’s details are accurate and correct, and all consents are given voluntarily after a thorough reading of this Policy.
1.2. Service of buyer’s queries, complaints, requests and responses
The Company uses personal data to respond to queries, complaints, and requests. The following identification and contact information provided by the buyer is used for this purpose: name, last name, telephone number, e-mail address. We process the data in fulfillment of our obligation to respond to the buyer’s query. Duration of the data processing – 5 years. We only use buyer’s data to properly respond to queries.
2. Data processing and storage time
The Company shall process and store the query submitted by the Buyer and related data until the examination of the query and submission of the response, as well as for up to 5 (five) years after the resolution of the Query, but not less than:
- Email queries - 5 years
- Complaints - 5 years
If a legal dispute is initiated or there is a possibility of such a dispute, the Company may store the buyer’s data for a longer period of time until the statute of limitations for filing a complaint or lawsuit expires and/or the final decision enters into force.
Upon expiration of the term of processing and storage of data set forth in this Policy, the Buyer’s data shall be destroyed as soon as possible, within a reasonable and substantiated time required to perform such action.
3. Sources for personal data collection
The Company receives buyer’s data directly from submitted queries, submitted by e-mail, written query, call, etc.
If in order to qualitatively and objectively examine the buyer’s query, the Company needs to collect additional information or conduct an investigation of significant circumstances, the Company may link the query data with the data available and / or data collected during the examination of the query.
4. Cases of disclosure of personal data and third parties to whom it may be disclosed
The Company may transfer the buyer’s data to third parties for processing. Such individuals may include database software providers, database administration service providers, providers of data center, hosting and cloud services, direct marketing service providers, market research or business analytics service providers, etc. In each case, the Company provides the data processor with the data necessary for the performance of a specific order or for the provision of a specific service. Data processors undertake to process the buyer’s personal data only in accordance with the instructions of the Company Modulit Solutions PJSC and may not use it for other purposes or transfer it to other persons without the consent of the Company. In addition, they must ensure the security of buyer’s data in accordance with applicable legislation and written agreements signed with the Company.
Data may also be provided to competent authorities or law enforcement agencies, such as police or supervisory authorities, but only upon request and only when required by applicable law or in the cases and procedures specified in the legislation; in order to ensure our rights, safety of buyers, employees and resources, and to file, present, and defend legal claims.
If the Company uses a website analytics service (such as Google Analytics), the Buyer’s anonymised data may be exchanged with third parties.
5. Territories and jurisdictions for the processing of the buyer’s personal data
The Company Modulit Solutions PJSC processes personal data only in the territory of the European Union. The Company does not intend to transfer nor transfers the Buyer’s personal data to third countries.
6. Data protection legislation and recourse to it
Information on the specific rights of the buyer and how to exercise them is provided in this Policy.
6.1. Right of access to the buyer’s personal data that we process
The Buyer has the right to receive confirmation regarding the processing of his/her personal data, access to his/her processed personal data and information on the purposes of data processing, categories of processed data, categories of data recipients, data processing period, and sources of data receipt.
This information is provided in this Policy.
6.2. Right to the correction of personal data
If the buyer’s data provided to the Company has changed or the buyer considers that the information processed by the Company about him/her is inaccurate or incorrect, the buyer has the right to demand that this information be changed, revised or corrected in the ways specified in this Policy.
6.3. Right to withdraw the consent
In cases where the Company processes the data of the buyer on the basis of his/her consent, the buyer has the right to withdraw his/her consent at any time and the processing of data based on the consent will be ceased. This may mean that the buyer will not be able to use the services of the Company Modulit Solutions PJSC.
Upon expiration, withdrawal or cancellation of the buyer’s consent, the Company shall destroy the data processed with the buyer’s consent.
The Company may keep the consent given by the buyer and the proof thereof for a longer period of time, if this is necessary for the Company to be able to defend itself against the demands, claims or lawsuits brought against it.
6.4. Right to appeal
If the buyer believes that the Company processes his/her data in violation of the requirements of data protection legislation, the Company asks that the buyer would contact it directly.
If the buyer is not satisfied with the solution proposed by the Company, the buyer has the right to file a complaint with the supervisory authority, i.e. the State Data Protection Inspectorate.
6.5. The right to object to the processing of data, where the processing is justified by legitimate interests
The Buyer has the right to object to the processing of personal data when personal data is processed on the basis of the legitimate interests of the Company. This may mean that the buyer will not be able to use the services of the Company Modulit Solutions PJSC.
In order to exercise this right, the buyer submits a written request.
6.6. Right to delete data (right to be forgotten)
The buyer has the right to request the deletion of personal data. In order to exercise this right, the buyer submits a written request.
The Buyer’s personal details are deleted without a separate request upon termination of the use of services provided by the Company Modulit Solutions PJSC.
6.7. Right to restrict data processing
The buyer has the right to restrict the processing of his/her data. This may mean that the buyer will not be able to use the services of the Company Modulit Solutions PJSC.
In order to exercise this right, the buyer submits a written request.
6.8. Right to data portability
The buyer has the right to request the transfer of his/her data to another data controller. In order to exercise this right, the buyer submits a written request.
6.9. Procedure for examination of requests
In order to protect the buyer’s data from unlawful disclosure, the Company must establish the buyer’s identity upon receipt of the buyer’s request to provide data or exercise other rights. The company may request the buyer to provide his/her relevant personal details (e.g. name, e-mail address or telephone number).
Upon receipt of a request for the exercise of any right of the buyer, the Company undertakes to provide the buyer with information on the action taken in response to his/her request without undue delay, but in any case no later than within one month after the receipt of the request and completion of the verification procedure. Taking into account the complexity and number of requests, the Company has the right to extend the one-month period, informing about it before the end of the first month and stating the reasons for such extension.
The Company shall provide the buyer with a response by the same means as the request, complaint or query.
7. Contacts of Modulit Solutions PJSC
You can contact us with any data processing questions in the following ways:
- by email: email@example.com;
- by post:
Modulit Solutions PJSC
Vytauto pr. 29, Kaunas,
Legal entity code 304460974
Registered office address:
Modulit Solutions PJSC
Vytauto pr. 29, Kaunas,
8. Buyer’s data security
The Company uses a variety of security technologies and procedures to protect the buyer’s personal information from unauthorized access, use, or disclosure. The Company’s suppliers undertake to use appropriate measures that can protect the buyer’s confidentiality and ensure the security of personal information.
9. Longer storage of data
Upon expiration of the term of processing and storage of buyer’s data set forth in this Policy, the Company destroys his/her data as soon as possible, within a reasonable and substantiated time required to perform such action.
The storage of the buyer’s personal data for a longer period than specifically specified in this Policy may be carried out only when:
- it is necessary for the Company to be able to defend itself against demands, claims or lawsuits and to exercise its rights;
- there are reasonable grounds for suspecting that an illegal act, which is under investigation;
- the buyer’s data is necessary for the proper resolution of the dispute or complaint;
- it is needed for backups and other similar purposes;
- it is needed based on other grounds provided for by legislation.
The session cookie is used every time the buyer visits the Company’s website. The Company uses this type of cookie to link the buyer’s actions on the Company’s website, and each session cookie lasts only as long as the browser session, after which the cookie is no longer used. Each browser session begins when the buyer opens a browser window and ends when the browser window is closed. After the buyer visits our website, all session cookies are deleted.
A permanent cookie allows to remember buyer’s wishes or actions on the website. This type of cookie is not deleted after the browser window is closed and will be saved on the buyer’s device. It will be activated each time the buyer visits the website.
11. Validity and amendments of the Policy
This Policy is valid from 24 March 2021.