When processing your personal data, we comply with the provisions of the General Data Protection Regulation (GDPR), the provisions of the Law on Legal Protection of Personal Data of the Republic of Lithuania, and the applicable requirements provided for in other legal acts.
1. General provisions
1.5. The controller of your personal data is UAB "FrontIT", legal entity code 300579778, Lvovo str. 101, LT-08104, Vilnius, e-mail firstname.lastname@example.org (hereinafter referred to as "the Company" or "we")
1.7. If you have any questions about our personal privacy protection, you can contact us by e-mail email@example.com
2. On what grounds do we process your personal data?
2.1. The Company collects and processes personal data in accordance with EU and Republic of Lithuania legislation governing the protection of personal data.
2.2. The scope of the personal data processed depend on the services used and the information provided by the person who uses the services or browses our Website.
2.3. The Company processes the personal data of visitors on the following grounds:
2.3.1. consent, which is expressed by your active actions, i.e. referrals to us and the provision of personal data, or other active actions;
2.3.2. the exercise of our legitimate interests (e.g. management and administration of the Website, etc.);
2.3.3. to fulfill the obligations imposed by law.
2.4. The Company seeks to ensure that personal data is processed accurately, fairly and lawfully, that it is processed only for the purposes for which data was collected, so that it is processed in accordance with the clear and transparent principles and requirements of the processing of personal data laid down in legal acts.
3. What personal data do we process and why?
3.1. Processing of personal data in cases of requests you have made
3.1.1. The Company also processes your data in cases where you contact us by e-mail, request, ask questions and provide any other information on our Website or social networks.
3.1.2. The Company processes your data in these cases in order to administer requests and complaints, to ensure the quality of the services it provides, and to protect your rights and legitimate interests. You provide your data to us based on consent, which is expressed by your active actions, i.e. by contacting us.
3.2. Data processed for recruitment purposes.
3.2.1. We process the following data: name, surname, place of residence or address of residence, e-mail address, telephone number, information on the candidate's work experience (workplace, period of work, duties, responsibilities, achievements), information about the candidate's education (educational institution, learning period, education and/or qualifications acquired), information on training (training received, certificates obtained), information on language skills, information technology, driving skills, other competencies, other information you provide in the CV, cover letter or other candidate documents, recommendations or feedbacks, contact details, content of recommendations or feedbacks, summary of interview with candidate, notes and opinions of the candidate, candidate’s test results.
3.2.2. We process your data with your consent and ensure Company’s legitimate interest in selecting the most suitable employee, as well as for performance of the contract when the selection of employees is made public.
3.2.3. While we perform the selection to the workplace and 3 months after the end of the selection (as long as it is technically optimal to perform periodic data deletion).
3.2.4. After the deadline for processing and storing your data has expired, we will destroy your data.
3.2.5. We may also retain your consent and proof of it for a longer period, if necessary, to defend ourselves against claims, or any other legal actions initiated against us.
3.2.6. We may transfer your data to third parties who assist us in the selection of candidates or who provide us services related to selection, evaluation of candidates and internal administration: personnel selection and evaluation service providers, software providers, database providers, data centers, cloud service providers, etc.
3.2.7. In each case, we provide the processor only as much data as is necessary for the execution of a specific order or for providing a specific service.
3.2.8. We will collect the information from you, when you respond to our job advertisement and provide us your CV, candidate profile and other candidate documents (resume, cover letter, etc.).
3.2.9. We will collect the information from job search and recruitment agencies, e.g. from employment agencies, job search portals, specialized career social networks (e.g. Linkedin).
3.2.10. We will collect the information from your previous employers or persons giving recommendation only if you give us your consent to contact your named employer and/or other person to receive a recommendation or feedback about you.
3.3. Processing shareholders, members of management bodies, beneficiaries, customers, business partners, other persons data
3.3.1. We process personal data of our shareholders, members and beneficiaries of our management bodies, their representatives, authorized persons. This data is obtained from legitimate sources (including public registers) and is used only for the fulfillment of the legal obligations applicable to it in relation to the activities of the Company, the registration and processing of data, the implementation of the rights of shareholders, the enforcement of the requirements of the laws, financial accounting and the fulfillment of tax obligations, as well as other obligations and obligations applicable to the Company.
3.3.2. We also process the personal data of different categories of data subjects (customers, business partners, suppliers, other counterparties, as well as their employees, managers, shareholders, representatives and agents).
3.3.3. This data shall be collected and processed for the following purposes and on the basis corresponding to them:
18.104.22.168. when the persons establish, maintain and develop business, professional and other legitimate relationships with us;
22.214.171.124. the concluding, execution, management of transactions, contracts and agreements;
126.96.36.199. developing and guaranteeing the legitimate interests of us and our affiliates;
188.8.131.52. defending against claims, and other legal actions initiated against us;
184.108.40.206. obligations under the legislation in force.
3.3.4. In addition, this information and personal data are collected and processed by the Company based on the consent of the person himself, when such person himself submits his/her data to the Company or its representatives during various meetings, conferences, trainings or other events.
3.3.6. The Company shall retain such data to the extent necessary to achieve the purposes for which it is processed, also in accordance with the data retention requirements, limitation periods for bringing or defending legal claims and, if so, to the extent necessary for that purpose.
3.4. Data processing in social accounts
3.4.1. We process your data in our social accounts: username, comments on the posts, record sharing, "like" and "follow" on our social network accounts, information about reactions to posts, photo, message, message receipt time, message content, message attachments, reply to message, time of reply to message.
3.4.2. Information you provide to us through social media (including messages, “Like”, “Follow” and other communication) is controlled by the manager of the social network concerned. We have and manage accounts on the social media listed below.
3.4.3. We recommend that you read the privacy policies of the following third parties and contact social networking providers directly when you have questions about the processing of personal data:
4. From what sources do we collect your personal data?
4.1. We process personal data provided by you when you use the Company's services or Website.
4.2. Data can be generated when you use services such as making phone calls, sending an instant message, e-mail, or visit the Website.
5. How long do we process and store your personal data?
5.2. If you contact/email us, we usually store e-mail in active e-mail for 24 months and up to 5 years in the inactive e-mail archive.
5.3. Longer storage of your personal information can only be carried out when:
5.3.1. there are reasonable suspicions of an unlawful act which is the subject of an investigation;
5.3.2. your data is necessary for the proper resolution of the dispute or the complaint;
5.3.3. if we have received complaints about a visitor to the Website, or if we have noticed any violations committed by the relevant visitor of the Website;
5.3.4. other specific grounds, conditions or cases provided for in the legislation.
6. In what cases and for which third parties do we disclose your personal data?
6.1. The Company shall not transfer your personal data to any third parties without your prior consent, except in the cases described below.
6.2. We may transfer your data to third parties who assist us in the execution and administration of the service. Such persons may include database software providers, database administration service providers, data centers, cloud service providers, etc. In each case, we provide the processor with only as much data as is necessary for the execution of a specific order or for the purpose of providing a specific service.
6.3. Data processors that are cooperating with us may process your personal data only in accordance with our instructions. They must also ensure the security of your data in accordance with the applicable legislation and the agreements concluded with us.
6.4. Data may also be made available to competent authorities or law enforcement agencies, such as the police or supervisory authorities, but only at their request and only when required by applicable legislation or in cases and procedures provided for by law.
6.5. If we use the Website analytics service (e.g. Google Analytics), to determine how you use the information provided on our Website, we may exchange your anonymised data with third parties who rely on this information to evaluate the use of the Website.
7. In which territories and jurisdictions do we carry out data processing activities?
7.1. We process your personal data only within the territory of the European Union. We have no intention of transferring your personal data to third countries currently.
7.2. Please be informed that certain technical data of your visit (IP address, cookies, technical information of the browser you use, other information related to browser activity and Website browsing) when browsing Website may be transferred or made available to entities operating both within and outside the European Economic Area for statistical, analytical and related purposes (e.g. through our use of the Google Analytics Service, such entity is operating in the United States). Please note that non-EEA Countries may provide less protection for personal data than in EEA Countries, but we will carefully assess the conditions under which such data will be processed and stored later after the transfer to the above-mentioned entities.
8. How do we protect your personal data?
8.1. The Company shall implement and keep up to date appropriate organisational and technical security measures to protect personal data against accidental or unlawful destruction, alteration, disclosure, as well as any other unlawful processing.
8.2. Any personal data you provide may be processed by the Company or the contracting party, e-mail owner, data centre, repository and other IT infrastructure service providers for the purposes of maintaining the security of the Company's IT systems, ensuring business with customers, suppliers and other business partners, ensuring that the data is adequately protected and is not lost in breach of security.
9. Submission of requests and complaints
9.1. If you wish to file a complaint about data processing, please provide it in writing with as much information as possible using the contact details provided at the end of this Policy. We will cooperate with you and will endeavour to resolve all issues without delay.
9.2. If you believe that your rights have been violated in accordance with the GDPR, you can file a complaint with the State Data Protection Inspectorate at L. Sapiegos st. 17, Vilnius, or by e-mail firstname.lastname@example.org
10. What rights do you have?
10.1. Right of access. You have the right to receive our confirmation of whether we process your personal data, as well as the right to access your personal data and information about the purposes of the processing, the categories of data processed, categories of recipients, the period of processing, the sources of data acquisition.
10.2. Right to erasure. You have the right to request that we delete your personal data when personal data is processed unlawfully, the basis for processing has disappeared, etc.
10.3. Right to rectify personal data. If the data you provide to us has changed, or you believe that the information we process about you is inaccurate or incorrect, you have the right to request changing, clarifying, correcting this information.
10.4. Right to withdraw consent. You have the right to withdraw your consent at any time and to request the termination of further processing of personal data, which is carried out on the basis of consent.
10.5. Right to restrict of processing. You have the right to restrict the processing of your data when personal data is processed unlawfully, you dispute the accuracy of the data, you have objected to the processing on the basis of our legitimate interest, etc.
10.6. Right to data portability. You have the right to request transferring your personal data that we process by automated means to another data controller.
10.7. Right to complaint. If you believe that we are processing your data in breach of data protection law, please contact us directly and If you are not satisfied with the way in which we can resolve the problem, you have the right to file a complaint to the supervisory authority.
11. How to contact us?