PRIVACY POLICY OF
Private Limited Liability Company “MIDA LT”
Wording of 04.05.2023
- What does this Privacy Policy mean?
This Privacy Policy (hereinafter referred to as the Privacy Policy) provides information, how Private Limited
Liability Company “MIDA LT” (hereinafter referred to as the Company) processes your personal data received in the
following manner: when the Company is engaged in direct marketing; when candidates are selected; in order to assure
protection of confidential information and continuity of performance; in order to assure protection of persons and
property (video surveillance); in order to carry out the contracts entered by and between the Company and its
counterparties – legal entities; when the Company is examining the received requests, complaints, also in relation
with judicial and extrajudicial proceedings; when you visit the Company’s website or the Company’s accounts in
social media, and when the Company is contacted. Hereinafter all the persons, whose data are processed by the
Company shall be referred to as Data Subjects.
- About the Company
The Company means Private Limited Liability Company “MIDA LT”, code of legal entity 110433047, registered address at
Gamyklos str. 19, Gargždai, LT-96155 Klaipėda district; the data about the Company are collected and stored in the
Register of Legal Entities of the Republic of Lithuania. Contact e-mail address for the issues of data protection
legal@mida.lt.
- What are personal data?
Personal data shall mean any information collected about the Data Subject that could be used to identify the Data
Subject and that is stored in an electronical or other manner.
Personal data shall include any information, including the Data Subject’s name, surname, and address, collected by
the Company about the Data Subjects for the purpose specified in this Privacy Policy or a separate consent of the
Data Subject or an agreement with the Company.
- Performance of the Company’s contracts with its counterparties legal entities (including organisation of
carriage, granting of access to self-service platforms)
In implementation of the contracts with its counterparties legal entities, the Company unavoidably processes
personal data of employees of such legal entities or other natural persons engaged in contract performance. The
information about personal data processing is provided in the table below:
|
Purpose of data processing
|
Processed personal data
|
Ground for data processing
|
Term of data processing
|
| Making and performance of contracts with customers/ suppliers – legal entities |
Name, surname, e-mail address, phone number, communication content, course of order’s execution,
date |
GDPR Article 6(1)(f) (legitimate interest)
|
4 years for communication, 10 years after the contract’s expiry, information related to the
contract’s performance or contained in the contract |
| Execution of carriages |
Driver’s (counterparty’s employee): job title, name, surname, numberplate of the driven vehicle
and other information about the vehicle (loading and unloading places and dates), in individual
cases – a copy of a personal identity document (passport) |
GDPR Article 6(1)(f) (legitimate interest)
|
10 years after the order’s execution (except for the copy of a personal identity document that
is destroyed immediately after the order has been executed) |
| Granting of access to the corporation’s self-service portals |
Name, surname, represented company, job title, e-mail address, phone number, information about
actions performed in the portal |
GDPR Article 6(1)(f) (legitimate interest)
|
Logging-in data – while the user’s account is active, information about entered data - 10 years
after execution of the particular order |
| Accounting management |
Name, surname, information about received / provided services and sold goods, other personal
data provided in invoices and other accounting documents |
GDPR Article 6(1)(c) (legal obligation)
|
The data shall be stored for the terms set out in the legal acts governing accounting
management, and in accordance with the Index of General Storage Terms of Documents |
- Direct marketing
We can make offers for the Company’s goods or services, send newsletters and other advertising materials, and notify
about the Company’s news to the persons, who have given their contact data and expressed the desire to receive
information about the Company’s goods and/or services by phone or electronic communication means (e-mail).
The Company shall process the following personal data for the purpose of direct marketing: name, surname, phone
number, information about made offers (sent e-mails, calls). Your personal data shall be processed for the purpose
of direct marketing for 3 years after the consent is given.
If you have purchased the Company’s goods and have not expressed an objection to receive the Company’s direct
marketing messages (e.g., by ticking a disagreement box in the form of consent with direct marketing), we will
e-mail you notices about the goods and services similar to the ones sold or provided to you on the ground of
legitimate interest. In such a case, your data will be processed for the purpose of direct marketing for 1 year
after purchase of the last item or service.
You have the right to object or decline to receive direct marketing notices at any time by contacting us by e-mail
address provided in Section 2 or by clicking on the cancellation link sent in each notice.
6. Selection of candidates
We collect and process your personal data (name, surname, desired position, work experience (employer, job title,
person who could give reference), education, other data provided in CV, questionnaire or cover letter and/or other
information you have provided) in the course of your participation in the selection procedure for the purpose of
employee screening on the ground of your consent that you express by sending your curriculum vitae and/or cover
letter to the Company. If you do not submit a curriculum vitae and/or cover letter, we will not be able to assess
your suitability for the offered job.
Upon your consent, we will address your current or former employer on the ground of legitimate interest (to select a
suitable candidate). You may withdraw your consent at any time or express your disagreement with our referral to
your former employer by contacting us by e-mail address provided in Section 2 above.
If you do not express your disagreement with your personal data processing by us individually, after the employee
selection is over, we oblige to delete and/or destroy your personal data within 3 days after entering into a
contract with the selected candidate or making the decision to end the selection, unless an individual consent for
storage of the candidate’s personal data for the period specified in the consent is given.
We will store your personal data for the period specified in the consent.
We will process the data about the person indicated by the candidate (name, surname, e-mail address, phone number,
information provided by the person) (current or former employer or person giving recommendation) on the ground of
legitimate interest – selection of the candidate. In this case, our legitimate interest means selection of a
candidate suitable for the position in question. We will destroy these data after the selection is over.
- Protection of the Company’s confidential information and continuity of activities
Aiming at the legitimate interest to ensure protection of the Company’s confidential information and continuity of
its performance, the Company may review communication of its employees with counterparties. For these purposes, the
Company is processing personal data of its employees and the persons receiving or sending e-mails from/to the
employees: e-mail address, name and surname of sender and receiver, date, and content of information contained in
the electronic work tools. Such data shall be stored for 4 years.
- Protection of property and persons
In order to ensure safety of customers, visitors, employees and other persons within the surveillance field, as well
as property of such persons and the Company, to collect evidence about violations, and to defend its rights, the
Company is performing video surveillance. Video surveillance is performed on the ground of legitimate interest of
these persons and the Company. For the purpose of video surveillance, the Company processes the following personal
data: image, movement trajectory, belongings of persons. The data are stored for 14 days after being recorded.
- Examination of requests and complaints, settlement of disputes in judicial and extrajudicial proceedings
The Company shall process the following data for the purpose of examination of requests and complaints, and
settlement of disputes in judicial and extrajudicial proceedings (in implementation of the legitimate interest to
protect its rights and legitimate interests):
|
Categories of data subjects
|
Processed personal data
|
Ground for data processing
|
Term of data processing
|
| 1. Natural persons who file requests, complaints or initiate disputes otherwise, as well as
natural persons related to disputes of data controller (in case of a legal entity, employees and
other representatives);2. Representatives and employees of state and local authorities,
pre-trial investigation institutions and other law enforcement institutions, etc. |
Name, surname, job title, employer, e-mail address, phone number, content of a claim, complaint
or other dispute-related document, provided personal data, and other personal data received
during examination of a claim, complaint or another statement. |
GDPR Article 6(1)(f) (legitimate interest)
|
1 year after final court judgment or dispute resolution in extrajudicial proceedings |
- Internal administration of the Company (implementation of shareholders’ rights)
The Company may transmit any personal data (recorded in the documents submitted to the shareholder) for the purpose
of internal administration (upon request of the shareholder to implement the right to access). Transmission shall be
performed in implementation of the legal obligation imposed on the Company (GDPR Article 6(1)(c)). The transmission shall be performed under the standard conditions of contracts approved by the
decision of the European Commission, with which or with main provisions whereof you may get acquainted by contacting
us using the Company’s contacts provided herein.
- Contact us
There are several methods, how to contact the Company: by phone, e-mail, via the Company’s accounts in social media.
We receive, review and reply to all the messages ourselves. If you contact us, we will be able to process the data
you have provided to us, i.e., e-mail address, phone number, name and surname (if indicated), user name (if an
inquiry is sent via the accounts in social media), employer (if stated in the e-mail), dates, time and content of
the sent and received messages.
Such data will be processed in order to answer to the questions you are interested in and to analyse your proposals.
If you do not provide your contact data, it will be impossible to contact you.
It is also possible to contact the Company using the inquiry form available on its website. Here you will be asked
to give your name, surname, phone number, e-mail address, and an employer (only when the inquiry is made in the name
and for the interests of the employer) and to state your question (the text of your message to the Company). In
addition to this information, we will also process date and time of your inquiries.
We shall process your personal data on the ground of your consent (GDPR Article 6(1)(d)(a)).
The communication shall be store for 1 year after receipt of the message, save for the information, for storage of
which other terms are set out in the Privacy Policy or legal acts.
All the personal data provided in the course of communication with us shall be used only for the above purposes, as
well as to review the messages, to administer and manage communication flows, and to answer to your inquiries. We
oblige not to use your personal data without your explicit consent in any publications in such a manner as to make
it possible to identify you.
We would like to note that we may need to reach you by phone, e-mail or mail. You are requested to notify us about
changes in your personal data.
We may transmit your personal data received through the inquiries on our website to our partners (distributors) if
you give such consent at the time of inquiry (GDPR Article 6(1)(d)(a)). The Company is oriented to the wholesale
customers, so in the cases when the inquiry is related to small quantity of the needed goods, we would like to
transmit your inquiry to our partners, who would contact you in response to your inquiry. We provide the list of our
partners, to whom your personal data may be transmitted:
- Website and cookies
It is possible to download personal data on the website in an electronic manner. We would like to note that the
downloaded data cannot violate rights or interests of third persons. The person who has downloaded the data shall be
held liable for such violations.
We use cookies on the website. Cookies are small files made from letters and digits saved in the browser of your
device (e.g., computer, mobile phone, tablets) (e.g., Google Chrome, Microsoft Edge, Firefox, etc.) or in the hard
disk of your computer. Other similar technologies, for example, pixel tags are also called cookies in this Privacy
Policy.
We use different cookies for different purposes. The cookies help us to distinguish you from other website’s users,
hence, assuring more pleasant experience of website’s use and allowing to make improvements on the website.
You may choose whether to accept the cookies. If you do not agree with saving of the cookies into a browser of your
computer or another device or into a hard disk of your computer, you may mark this on the cookie bar, change
settings of the used browser, or turn the cookies off (all together or in groups).
The majority of browsers allow declining all the cookies, while other browsers provide the possibility to decline
only cookies of third parties. Thus, you may use these options. However, you should remember that blockage of all
cookies will have negative impact on the website’s use, and you will not be able to use all the services provided on
the website. More detailed information is available at
AllAboutCookies.org
or
www.google.com/privacy_ads.html.
We may use the types of cookies described below; however, the detailed and updated list of used cookies is available
HERE :
Strictly necessary cookies
These cookies are essential for our website’s operation. The ground for use of these cookies is Article 73(4) of the
Law on Electronic Communications of the Republic of Lithuania. These cookies are necessary for operation of the
website and cannot be turned off. These could be cookies that allow you to log in and access protected zones of our
website, for example.
Analytical and/or performance cookies
These cookies allow us to recognise and count the website’s users and to observe their movements within the website.
It helps us to improve the website’s operation, for example, to ensure that the users could find easily what they
are looking for. The ground for processing of data collected by these cookies is your consent.
Functional cookies
These cookies are used to recognise you on return to our website so that we would be able to adjust the presented
content to your needs and to memorise the information relevant for you. The ground for processing of data collected
by these cookies is your consent.
Commercial cookies
We use own and third-party cookies so that we would demonstrate personalised advertising on own and other websites.
This is called “repeated marketing” that is based on the browsing actions, for example, the goods you were looking
for or the goods you viewed.
- Social media means
The information provided by social media means (including notifications, use of like and follow and other
communication) is controlled by the social network’s manager.
There are references to our accounts in social media (hereinafter referred to as the Social Accounts) on our
website. At present we are administering the following accounts in social networks:
- account midalietuva in social network Facebook;
- account midalatvija in social network Facebook;
- account ą midaeesti in social network Facebook;
- account (channel) midalt in social
network LinkedIn.
We are processing the information provided in our accounts for the purpose of account administration on the ground
of your consent.
When you visit the Social Accounts, the administrators of social networks save cookies in your device, and they
collect personal data. The cookies are saved if you are a registered user of social networks and also when you do
not have an account in the respective social network. We do not have access to the collected data and can receive
only statistical information on attendance on the Social Accounts from administrators of social networks.
In order to receive more comprehensive information about your personal data processed for the purpose of
administration of the Social Accounts, you should get familiar with privacy/cookie policies of
Facebook and
Google (regarding personal data used by
Youtube).
- Receiving and disclosure of the data
We receive your data from you, your devices, our employees and counterparties of the contracts.
We may disclose your information to our employees, agents, and service providers (such as companies carrying out
debt administration or recovery, persons or subcontractors providing marketing services), if it is
reasonably needed for the purposes specified in this Privacy Policy.
We inform that certain data about your visits to the website collected by the cookies, as described in the section
“Website and cookies” of this Privacy Policy for the purpose of analysis and repeated marketing may be transmitted
or made available for the entities operating in the European Economic Area and beyond (e.g., when we are using
Google Analytics service, such entity is a company operating in the United States of America). We remind that
smaller protection could be applied on personal data in the non-EU and/or non-EEA states than in the EU and/or EEA
states. In such a case, contractual safeguards shall be applied (based on the standard conditions of contracts for
transmission of personal data beyond the EEA approved by the decisions of the European Commission). If you need more
information about the measures used to protect the personal data transmitted beyond the EEA (including the
information, how to get a copy or to view these safeguards), you should contact the Company using the contacts
provided herein.
Besides, we can disclose information about you:
- if required so by laws;
- in order to protect our rights and interests (including presentation of your data to third persons for the
purpose of recovery of your debts to us);
- if it is intended to sell a part of the Company’s business or assets, your personal data could be disclosed
to the potential purchaser of the business or its part;
- when the Company’s business or a substantial part of its assets is sold to third persons.
Unless provided so in this Privacy Policy, we do not transmit your personal data to any third parties.
The list of recipients or categories of recipients provided in the Privacy Policy may differ, so, if you want to be
informed about any changes of recipients of your personal data, you should inform us thereof by writing to the
e-mail address given in this Privacy Policy, stating the following in the text of the letter “I want to receive
information about changes of recipients of my personal data, name, surname .”
- Safety of your personal data
Your personal data shall be processed in accordance with the requirements of the General Data Protection Regulation,
Law on the Legal Protection of Personal Data of the Republic of Lithuania, and other legal acts. When processing
your personal data, we implement the organisational and technical measures that ensure protection of personal data
from accidental or unlawful destruction, modification, disclosure, and any unlawful processing.
- Your rights
In this section, we provide information about your rights related to personal data processing we are performing and
about the cases when you can use these rights. If you need more information about your rights or want to use them,
contact us by the e-mail address provided in this Privacy Policy.
The Company will inform you about the actions undertaken after receipt of your request to implement the rights
without unreasonable delay and, in any case, not later than within 1 (one) month after receipt of the request.
Depending on the request’s complexity and number of received requests, the aforementioned term could be extended for
2 (two) more months. In such a case, we will inform you about extension of the term and its reasons within 1 (one)
month after receipt of the respective request. The Company can refuse to implement your rights only in the cases
defined in the legal acts.
-
- The right to access own personal data
We want you to understand completely how we are using your personal data and not to cause any inconveniences to you
thereby. You may contact us at any time and ask whether we are processing certain personal data. If we store or use
your personal data in any other manner, you have the right to access them. If you want to access the data, you have
to submit a written application to the e-mail address provided herein, confirm your identity and comply with the
principles of reasonability and fairness when submitting such an application.
-
- Right to withdraw the consent
If you have given an explicit consent to process your personal data, you can withdraw it at any time.
-
- Additional rights
Below, we provide information about your additional rights that you may implement in accordance with the procedure
described below.
- you have the right to ask to rectify any inaccuracies of your personal data. In such a case, we may ask you
to verify the rectified information;
- you have the right to ask to erase your personal data. This right is implemented in the cases described in
Article 17 of the General Data Protection Regulation (EU) 2016/679;
- you have the right to ask to restrict processing of your personal data or not to process them:
- during the period necessary to make sure about accuracy of your personal data when you file claims regarding
accuracy of the data;
- when collection, storage and use of your personal data by us is unlawful, but you decide not to ask to erase
the data;
- when we do not need your personal data ant more, but you need them to establish, execute or defend some
legal demand;
- during the period necessary to determine that our legitimate grounds to process your personal data override
those of yours, if you have used the right to object to personal data processing.;
- you have the right to portability of the data processed by automated measures and received after you had
given a consent or for the purpose of the contract’s conclusion. If you use this right, we will transmit the
copy of the data you have provided upon your request;
- you have the right to object to use of your personal data by us in the procedure set out in Article 21 of
GDPR. You have the right not to agree with processing of your personal data on the ground of legitimate
interest (the ground of processing is stated by each purpose of personal data processing provided above) or
for the purpose of direct marketing.
-
- The right to request more information
We hope that you will understand that it is very difficult to discuss all the possible methods of personal data
collection and use. We endeavour at presenting as clear and thorough information as possible and we oblige to update
this Privacy Policy when the process of use of personal data changes. However, if you have any questions about use
of your personal data, we will be happy to answer them or we will provide all the additional information that we are
entitled to disclose. If you have any specific questions or you have not understood the provided information, you
are welcome to contact us.
- Complaints
If you believe that your rights of the Data Subject have been and/or could be violated, you should contact us
immediately using the e-mail address provided herein. We guarantee that upon receipt of your complaint, we will
contact you within the reasonable period and inform you about the course and later, about the outcome of the
complaint’s examination.
If you are not satisfied with the investigation’s outcomes, you may appeal to the supervisory authority – the State
Data Protection Inspectorate (
www.vdai.lrv.lt).
- Responsibility
You are responsible for confidentiality of the provided data, their accuracy, correctness and completeness. If the
provided data change, you should notify us thereof by e-mail without delay. We shall never be liable for any damage
caused to you because you have provided incorrect or incomplete personal data or because you have not notified us
about their changes.
- Amendments of the Privacy Policy
We can update or amend this Privacy Policy at any time. If you want to receive an updated Privacy Policy, you should
notify us in writing to the e-mail address provided in Section 2 above.
Cookie’s name
| Purpose/aim of data processing |
Creation moment |
Expiry term |
Character of the cookie (necessary, analytical, functional, commercial) |
Used data |
Reference to the third party’s privacy policy |
|
| ga - Google Analytics |
To collect information about the website’s attendance |
Immediately after the website is opened |
2 years |
Analytical |
Persistent identity data, such as customer’s personal ID, user’s personal ID and IP address |
link
|
| _gat - Google Analytics |
To regulate number of inquiries |
Immediately after the website is opened |
10 min. |
Analytical |
Persistent identity data, such as customer’s personal ID, user’s personal ID and IP address |
link
|
| gid_Google Analytics |
For observation, in order to distinguish users |
Immediately after the website is opened |
24 months |
Analytical |
Persistent identity data, such as customer’s personal ID, user’s personal ID and IP address |
link
|
| _utma - Google analytics |
To collect statistical information about the website’s attendance |
Immediately after the website is opened |
2 years |
Analytical |
Persistent identity data, such as customer’s personal ID, user’s personal ID and IP address |
link
|
| _utmz - Google analytics |
To collect statistical information about the website’s attendance |
Immediately after the website is opened |
6 months |
Analytical |
Persistent identity data, such as customer’s personal ID, user’s personal ID and IP address |
link
|
| _hjSession{site_id} |
To recognise a user and to make sure that the later inquiries in the session window would be
attributed to the same session |
Immediately after the website is opened |
30 min. |
Analytical |
Device’s IP address, size of the device’s screen, type of device, browser’s information,
geographical location (only country), priority language of the website |
link
|
| PHPSESSID |
To realise website’s functionality (to identify the user’s session on the website and to recognise
the user) |
Immediately after the website is opened |
Until the browser’s window is closed |
Functional |
Unique session ID |
|
| BX_USER_ID |
To identify a unique user not signed in to the website |
Immediately after the website is opened |
10 years |
Functional |
Unique session ID |
link |
| _GRECAPTCHA |
This cookie is used to distinguish humans from automatic systems |
Immediately after the website is opened |
Until the browser’s window is closed |
Functional |
IP address. Downloaded resources, including styles and images. Information about the user’s Google
account. Behaviour, e.g., browsing on the website, mouse’s movement, clicking of links, time spent
on completion of forms and writing of templates. |
link
|
| Other used tools/services |
| Google Tag manager |
When this tool is used, no cookies are used, and no personal data are saved. Google Tag
Manager activates other tags that collect data, if necessary. More information at link.
|
| Meta Pixel |
Used for repeated marketing, i.e., in order to be able to contact you again in 180 days
and show advertisements according to your hobbies when you re-visit social network Facebook or other
websites that are also using this tool. This tool uses the HTTP headers, specific points, button
clicking, optional values and names of form’s fields and these data are saved for 180 days. More
information on functioning of Meta Pixel is available at link ir link.
|
| Linkedin Insight Tag |
LinkedIn Insight Tag allows collecting data about visits of LinkedIn members on the
website, including URL, transmission URL, IP address, characteristics of the device and browser, and
time tag. IP addresses are shortened or mixed (when used to access LinkedIn members in all devices),
while the direct identifiers of persons are removed within seven days so that the data would be
named by a pseudonym. The remaining pseudonymised data are deleted within 180 days. This tool is
used for reports and warnings (that do not identify LinkedIn members) about the website’s audience
and productivity of ads. Besides, this tool allows demonstrating personalised LinkedIn ads on the
website, using these data, but without identification of the member in question. LinkedIn uses the
data that do not identify the members to improve the ad’s conformity and access the members in
various devices. LinkedIn members can control the use of their personal data for advertising in
LinkedIn settings. More information on functioning of Linkedin Insight Tag is available at link.
|
