PRIVACY POLICY
The Privacy Policy (hereinafter the ‘Policy’) regulates the principles of collection, processing and storage of personal data of visitors to the UAB LIMO TRADING COMPANY (hereinafter ‘ROYAL DENTA’) website www.royaldenta.com and social network accounts and recipients of its newsletters and determines the purposes and means of processing their personal data.
This Policy was drawn up pursuant to the provisions of 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 (General Data Protection Regulation) (hereinafter the ‘Regulation’).
This Policy informs visitors to the ROYAL DENTA website and social media accounts and its newsletter recipients about the processing of their personal data.
DEFINITIONS
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘Data subject’ means a natural person who is a visitor to the ROYAL DENTA website or social media accounts and/or is a recipient of its newsletters, and whose personal data is collected and processed by ROYAL DENTA.
‘Consent of the data subject’ means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
‘Rights of the data subject’ means the ability of the data subject to participate in and control the activities of the controller and/or processor when his or her personal data are processed: to know, to be informed about the processing of his or her personal data; to have access to his or her personal data processed and find out how they are processed; to request the rectification, destruction of his or her personal data, except for storage, or suspension of the processing of his or her personal data if the data are processed in breach of the provisions of legislation; to object to the processing of his or her personal data; to request the erasure of his or her personal data; to receive data related to him or her which he or she has submitted to the controller; to lodge a complaint with the supervisory authority (the State Data Protection Inspectorate).
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘Automated processing’ means any processing operations carried out in whole or in part by automatic means. Those include any information and communication technologies which enable the processing of personal data, such as computers, communication networks, etc.
‘Data Controller’ means UAB LIMO TRADING COMPANY, legal entity number: 133114845, registered office address: Ievos Kalno g. 6-10, 93103 Neringa, phone No +370 684 19699, e-mail address: info@royaldenta.com.
‘Data Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
‘Data Recipient’ means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether they be a third party or not. However, public authorities which, under the European Union or Member State law, may receive personal data in the course of a specific investigation, shall not be regarded as recipients of the data.
‘Cookie’ means a small text file saved by a website on your computer or mobile device when you visit that website.
‘Personal data security breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Other terms used in this Policy shall be understood as defined in the Regulation and other legal acts regulating the processing of personal data.
SECTION I
PERSONAL DATA PROCESSING PRINCIPLES
1. When processing your personal data, ROYAL DENTA adheres to the following principles:
1.1. ROYAL DENTA processes personal data exclusively for the legitimate purposes defined in this Policy and does not further process them in any manner incompatible with those purposes (purpose limitation principle);
1.2. Personal data are processed in an accurate, fair and lawful manner in accordance with the requirements of legislation (lawfulness, fairness and transparency principle);
1.3. ROYAL DENTA processes personal data in such a way that the personal data are accurate and constantly updated in case of any changes thereto (accuracy principle);
1.4. ROYAL DENTA carries out the processing of personal data only to the extent necessary to achieve the purposes of the processing of personal data (data quantity minimisation principle);
1.5. Personal data are stored in a form that permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data were collected and processed (storage period limitation principle);
1.6. In the course of processing of the personal data, ROYAL DENTA ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures (integrity and confidentiality principle);
1.7. ROYAL DENTA is responsible for compliance with the principles set forth in this Privacy Policy and must be able to demonstrate compliance with them (accountability principle).
SECTION II
PURPOSES OF PERSONAL DATA PROCESSING
2. ROYAL DENTA processes your personal data:
2.1. For the purpose of pursuing the legitimate interests of ROYAL DENTA, as well as for the proper management and administration of the website, for monitoring its traffic, ensuring its security, improving its functioning, facilitating the search for information and ensuring the submission of data subject inquiries, as well as for marketing purposes (sending newsletters with the consent of the data subject).
3. For the purpose specified in Paragraph 2 of this Policy, ROYAL DENTA collects and processes the following data about you:
3.1. Personal data: name and surname (if provided by you);
3.2. Contact details: e-mail address (if provided by you);
3.3. Other personal data/information provided to ROYAL DENTA in your inquiry/order;
3.4. Other personal data of newsletter recipients: specialisation (pharmacist, dentist, dental hygienist, etc.), city (if provided by you).
SECTION III
COLLECTION AND PROCESSING OF PERSONAL DATA
4. Personal data is obtained from you if such data are required by legislation or if you provide such data voluntarily.
5. ROYAL DENTA also processes your personal data in cases where you contact it by e-mail by submitting an inquiry on the ROYAL DENTA website, subscribe to newsletters, or send information to the contacts indicated on the ROYAL DENTA website or in ROYAL DENTA social network accounts. In such cases, ROYAL DENTA processes your data for the purpose of managing inquiries and/or sending newsletters and ensuring the quality of the provided services, while protecting and safeguarding its legitimate interests.
6. Regardless of how the data have been collected, they are stored only to the extent and only for as long as it is necessary to achieve the established purposes, but no longer than for the period provided for in the current version of the Index of Terms for Storage of General Documents approved by Order No V-100 of 9 March 2011 of the Chief Archivist of Lithuania and other legislation. The data contained in the inquiries submitted via the website are stored for a maximum period of three years after the reply to the inquiry has been submitted and they are subsequently destroyed.
SECTION IV
RIGHTS OF THE DATA SUBJECT
7. As a data subject, you have the right:
7.1. To be aware/to be notified about the processing of your personal data;
7.2. To access your personal data and to find out how they are processed. You have the right to contact ROYAL DENTA with a request to provide information on which of your personal data are processed and for what purpose;
7.3. To demand the rectification of your personal data. Where you have established that your personal data processed by ROYAL DENTA are inaccurate or incomplete, you have the right to contact the Company with a request for rectification or supplementation of such personal data;
7.4. For erasure of your personal data (‘the right to be forgotten’). You have the right to contact ROYAL DENTA with a request to erase your personal data on one of the following grounds:
– the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
– you have withdrawn the consent used as the basis for processing and there are no other legal bases for the processing of your personal data;
– you object to the processing and there are no overriding legitimate reasons for the processing;
– the personal data have been unlawfully processed;
7.5. To demand the restriction of processing of your personal data. You have the right to contact ROYAL DENTA with a request to restrict the processing of your personal data on one of the following grounds:
– you contest the accuracy of the personal data for a period enabling ROYAL DENTA to verify the accuracy of the personal data;
– the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
– ROYAL DENTA no longer needs the personal data for the established purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
– you have objected to processing pending verification of whether the legitimate grounds of ROYAL DENTA override those of the data subject;
7.6. To object to the processing of your personal data. You have the right to object to the processing of certain optional personal data concerning you. This objection may be expressed by not filling in certain sections of the documents, as well as by submitting a request for the termination of processing of your optional personal data at a later stage. Upon your request, ROYAL DENTA will provide you with information about which of your data are processed on an optional basis. Having received a request to terminate the processing of optional personal data, ROYAL DENTA will immediately terminate such processing, unless this is contrary to the requirements of the legislation, and will notify you thereof;
7.7. To move data, i.e. you have the right to receive the personal data related to you that you have provided to ROYAL DENTA in a structured, common and machine-readable format, and also you have the right to transfer that data to another controller, and ROYAL DENTA must not impede that.
SECTION V
MEASURES TO ENSURE THE SECURITY OF PERSONAL DATA
8. When storing your personal data, ROYAL DENTA implements and ensures appropriate organisational and technical measures to protect personal data against accidental or unlawful destruction, alteration, or disclosure, as well as against any other unlawful processing.
9. Your personal data collected and processed by ROYAL DENTA may be accessed only by persons who have the right of access to such data and only when it is necessary for the purposes provided for in this Policy.
10. ROYAL DENTA ensures proper network management, maintenance of information systems and implementation of other technical measures necessary to ensure the protection of your personal data.
SECTION VI
TRANSFER OF PERSONAL DATA TO THIRD PARTIES
11. Your personal data may be disclosed to third parties providing services to ROYAL DENTA that ensure the operation and maintenance of the information systems used by ROYAL DENTA. In such cases, your personal data will only be disclosed to third parties to the extent necessary for the proper provision of their services.
12. Your personal data may be disclosed to law enforcement authorities in accordance with the procedure provided for in the statutes of the Republic of Lithuania.
13. In all other cases, your personal data may be disclosed to third parties only with your consent.
SECTION VII
USE OF COOKIES
14. Information collected with the help of cookies enables ROYAL DENTA to improve the functioning of its website, ensuring you a comfortable and efficient search for information.
15. The main cookies used on the ROYAL DENTA website are as follows:
16. Consent to store cookies is expressed by clicking ‘I ACCEPT’ when a message with the following text appears on the website: “In order to improve the quality of your browsing, this website uses cookies for statistical and marketing purposes. You can block them at any time by changing your browser settings and deleting stored cookies.”
17. The consent can be withdrawn at any time by changing your web browser settings and deleting stored cookies. How you can do this depends on your operating system and web browser.
18. After deleting the stored cookies, some features of the ROYAL DENTA website may not work as intended.
SECTION VIII
SENDING NEWSLETTERS
19. Having obtained the consent of the data subject, ROYAL DENTA may send newsletters to the data subject for marketing purposes, which contain information about goods being sold, services being provided, training sessions or seminars being organised, and other direct marketing content.
20. ROYAL DENTA sends newsletters to the data subject only with the prior consent of the data subject expressed in electronic form and through an active motion, i.e. if the relevant form is filled on the ROYAL DENTA website, indicating the e-mail address at which they wish to receive newsletters.
21. ROYAL DENTA sends newsletters to the data subject until he/she withdraws the consent.
22. The data subject is provided an easy opportunity to refuse to receive newsletters and to object to further sending of such direct marketing content. The data subject can use this opportunity by clicking on the link provided in the e-mail.
23. In the event where the data subject refuses to receive further ROYAL DENTA newsletters with direct marketing content, such newsletters shall no longer be sent.
SECTION IX
CHANGES TO THE PRIVACY POLICY
24. This Policy is reviewed and updated on a regular basis and its amendments are posted on the website www.royaldenta.com.
SECTION X
CONTACT DETAILS
25. If you have any questions, comments or complaints regarding your personal data that is collected, used and stored by ROYAL DENTA, please contact us by e-mail info@royaldenta.com.