Cookies and Privacy Policy

1.What Does This Privacy Policy Mean?

1.1 In this Privacy Policy (hereinafter, the “Privacy Policy”), we provide information on how UAB “Sėkmingi” (hereinafter, the “Company”) processes your personal data obtained: when the Company provides services and sells goods to clients or receives services and purchases goods (when the other contractual party is a natural person); in the course of direct marketing activities; in candidate selection; to ensure the protection of confidential information and business continuity; to fulfill contracts established between the Company and corporate partners; to defend legitimate interests in the event of disputes or violations; when you visit the Company’s website or social media accounts; in response to inquiries; and through video surveillance. All individuals whose data is processed by the Company are referred to as “Data Subjects” below.

2. About the Company

2.1 The Company refers to UAB “Sėkmingi,” legal entity code 304754709, with its registered office at Rąžės g. 35-2, Kaunas, Lithuania. Information about the Company is collected and stored in the Register of Legal Entities of the Republic of Lithuania. For data protection inquiries, please contact us at lets@convo.lt.

3. What Are Personal Data?

3.1 Personal data are any information collected by the Company about the Data Subject that can be used to identify the Data Subject and is stored electronically or otherwise.

3.2 Personal data includes any information about the Data Subject such as name, surname, and address collected by the Company for purposes specified in this Privacy Policy or in a separate Data Subject consent or agreement with the Company.

4. Personal Data Processed When Receiving or Providing Services

Processed Personal Data

• Name, surname, phone number, email address.
• Any information about the Data Subject that can be used to identify them.

Basis for Processing

GDPR Article 6(1)(b) (contract)

Data Retention Period

10 years after the expiration of the contract

5. Direct Marketing

5.1 For individuals over 14 who have provided their contact information and expressed interest in receiving information about the Company’s products and/or services, we will send offers, newsletters, and other promotional materials electronically (e.g., by email).

5.2 For direct marketing purposes, the Company will process your email address (a mandatory field without which we cannot send you marketing messages). Your data will be processed for direct marketing purposes for three years from the date of consent.

5.3 If you have purchased services from the Company and have not objected to receiving direct marketing messages (e.g., by checking an opt-out box in the direct marketing consent form or notifying us via the email provided in the Policy), we will send you emails or SMS regarding services similar to those you purchased. In such cases, your data will be processed for direct marketing purposes for three years after the last purchase.

5.4 You have the right to object or withdraw from receiving direct marketing messages by contacting us at the email provided in Section 2.

6. Candidate Selection

6.1 We collect and process your personal data (name, surname, desired position, work experience including previous employers, job titles, references, education, and any other information specified in your CV, application, cover letter, or other provided information) for recruitment purposes based on your consent, which you grant by submitting your CV and/or cover letter to the Company. If you do not provide your CV and/or cover letter, we will be unable to assess your suitability for the advertised position.

6.2 If you do not provide separate consent for processing your personal data, we will delete and/or destroy your personal data within three days after signing a contract with the selected candidate or deciding to close the recruitment process, except when separate consent for data retention is granted for a specified period as outlined in the consent agreement.

6.3 If, under applicable law, we are required to verify your health status before employment, we will process health data to confirm your suitability based on legal obligation.

6.4 With your consent, we will retain your data for the period specified in the consent.

6.5 Based on our legitimate interest, we may process data on individuals referenced by the candidate (name, surname, email, phone number, and information provided by the reference) for recruitment purposes. In this case, our legitimate interest is to select a suitable candidate for the position. This data will be destroyed at the end of the recruitment process.

6.6 We may receive your data directly from you, from online platforms where you apply for our job openings, or from recruitment agencies.

7. Protection of the Company’s Confidential Information and Business Continuity

To ensure the protection of the Company’s confidential information and to maintain business continuity as part of our legitimate interest, the Company may review its employees’ correspondence with contractors. For these purposes, the Company processes personal data, including the email addresses, content of information on electronic work tools, and dates of correspondence, from employees and individuals who send or receive messages from employees. This data is retained for four years.

8. Fulfillment of Contracts with Corporate Partners

To ensure the fulfillment of the Company’s contracts established with corporate partners (legal entities) as part of our legitimate interest, the Company processes personal data of these entities’ employees, such as name, surname, email address, phone number, and correspondence content. Data related to contract fulfillment is retained for ten years after the contract ends.

9. Defense of Legitimate Interests in Cases of Disputes, Theft, and Other Criminal or Administrative Offenses

To defend its rights based on its legitimate interest, the Company processes personal data of individuals involved in or suspected of criminal offenses, civil disputes, thefts, or administrative violations, as well as other parties involved in the case. This data includes names, surnames, personal identification numbers, case details, other case-related information, and publicly available information. Data may be shared with insurance companies, law enforcement agencies, or bailiffs engaged in debt collection. This data is destroyed three years after the case’s final resolution and full satisfaction of the Company’s claims (if any awarded amounts are collected).

10. Contacting Us

10.1 There are several ways to contact the Company: by phone, email, or by filling out an online inquiry form. We receive, review, and respond to all messages directly. If you contact us, we may process the data you provide, including name, company, phone number, email, project description, and any attached project information.

10.2 Such data will be processed based on your consent to respond to your questions and review your suggestions. If you do not provide your contact information, it will not be possible to reach you.

10.3 Correspondence is retained for one year from the receipt of the message, except in cases where other retention periods are specified in this Privacy Policy or required by law.

10.4 All personal data you provide while communicating with us is used solely for the purposes stated above, to review messages, and to manage communication flows. We commit not to use your personal data in any media channels in a way that could identify you without your explicit consent.

10.5 Please note that we may need to contact you by email at lets@convo.lt lets@convo.lt or by phone at +370 687 732 51. Please inform us of any changes to your personal data.

11. Website

11.1 Our website, www.convo.lt, uses cookies.

11.2 A cookie is a small file made up of letters and numbers that, with your consent, we place in your browser or on your computer’s hard drive. We use different cookies for various purposes. Cookies also help us differentiate you from other website users, ensuring a more pleasant browsing experience and allowing us to improve the website.

11.3 Most browsers allow you to reject all cookies, and some provide options to reject only third-party cookies. You may choose these options as needed. However, please note that blocking all cookies may negatively impact your experience on the website, and without cookies, you may not be able to access all services offered on the site. Further information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.

11.4 Third-party cookies may also be placed when visiting the website. The Company does not control these cookies, nor does it have access to the data collected by them. Detailed information on the purposes and collected personal data of third-party cookies (such as those used by Facebook, Google, etc.) can be found in these third parties’ privacy/cookie policies (e.g., Facebook’s or Google’s cookie policies) or by contacting the third party directly.

11.5 We may use the types of cookies described below; however, you can find the detailed and up-to-date list of cookies we use HERE.

12. Social Media Platforms

12.1 The information you provide to us through social media platforms (including messages, use of “Like” and “Follow” buttons, and other communication) is controlled by the social network operator.

12.2 We process the information available on our accounts for account administration purposes based on your consent.

12.3 We recommend reading the privacy notices of third parties and directly contacting the service providers if you have any questions regarding how they use your personal data and what cookies are collected on these sites.

13. Newsletter

13.1 On our website, you may be offered the option to subscribe to our newsletter by providing your email address to receive updates about our latest products and services.

13.2 By consenting to receive our newsletters, you grant us full permission to send them. You may unsubscribe at any time by clicking the “Unsubscribe” button in a received email and confirming the unsubscribe request in the subsequent email.

13.3 Your email address will be processed solely for the purpose of sending newsletters until you choose to unsubscribe. Data may be collected when a newsletter is sent, and you click on a newsletter link.

13.4 Your email address may be shared with third parties providing specialized newsletter delivery services solely to enable us to send you the newsletter through their platform.

13.5 For any questions related to the newsletter, please contact us at lets@convo.lt

14. Data Collection and Disclosure

14.1 We obtain your data from you, your devices, our employees, and from our contractual partners.

14.2 We may disclose information about you to our employees, intermediaries, service providers such as debt management or collection companies, IT service providers, or subcontractors if reasonably necessary for the purposes specified in this Privacy Policy.

14.3 Additionally, we may disclose information about you:

• if required by law;
• to protect our rights or interests (including providing your data to third parties for debt collection);
• if we intend to sell part of the Company’s business or assets, disclosing your personal data to a potential buyer (based on our legitimate interest in finding an investor);
• in the event of a sale of the Company’s business or its substantial assets to third parties.

14.4 Except as outlined in this Privacy Policy, we do not disclose your personal data to any third parties.

14.5 The list of recipients or recipient categories mentioned in this Privacy Policy may change. If you wish to be informed of any changes to the recipients of your personal data, please let us know via the email provided in this Privacy Policy, including the text “I wish to be informed of changes to the recipients of my personal data” along with your name and surname.

15. Security of Your Personal Data

Your personal data will be processed in compliance with the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable legal requirements. In processing your personal data, we implement organizational and technical measures to protect it from accidental or unlawful destruction, alteration, disclosure, and any other unauthorized processing.

16. Your Rights

16.1 This section provides information about your rights regarding our processing of your personal data and the circumstances under which you can exercise these rights. If you wish to obtain more information about your rights or to exercise them, please contact us via the email address provided in this Privacy Policy.

16.2 The Company will provide you with information on actions taken in response to your request regarding your rights without undue delay, and no later than one month from receipt of your request. Depending on the complexity and volume of requests, this period may be extended by two additional months. In such cases, we will inform you within one month of receiving your request about the extension and the reasons for it. The Company will refuse to implement your rights only in cases specified by law.

17. Right to Access Your Personal Data

We aim to ensure that you fully understand how we use your personal data and do not experience any inconvenience as a result. You may contact us at any time to inquire whether we process any of your personal data. If we store or otherwise use your personal data, you have the right to access it. To do so, submit a written request to the email address specified in this Privacy Policy, confirm your identity, and observe the principles of honesty and reasonableness when making such a request.

18. Right to Withdraw Consent

If you have given us explicit consent for processing your data, you may withdraw it at any time.

19. Additional Rights

Below is information on the additional rights you have, which you may exercise according to the procedures described below.

19.1 You have the right to request that we correct any inaccuracies in your data. In such cases, we may ask you to confirm the corrected information.

19.2 You have the right to request the deletion of your personal data, which can be exercised under the conditions specified in Article 17 of the General Data Protection Regulation (EU) 2016/679.

19.3 You have the right to request that we restrict or stop processing your personal data:

• for a period required to verify the accuracy of your data when you submit a claim regarding data accuracy;
• when our collection, storage, or use of your data is unlawful, but you choose not to request data deletion;
• when we no longer need your personal data, but you require it to establish, execute, or defend a legal claim;
• for the period required to determine whether we have a stronger legal basis to continue processing your personal data, should you exercise your right to object to the processing.

19.4 You have the right to data portability for data processed by automated means that we obtained from you with your consent or for the purposes of contract fulfillment. Upon exercising this right, we will, at your request, transfer a copy of the data you provided.

19.5 Under Article 21 of the GDPR, you have the right to object to our use of your personal data. You have the right to object when your personal data is processed based on legitimate interest (the basis for each processing purpose is indicated above) or for direct marketing purposes.

20. Right to Request Additional Information

We understand that it is challenging to cover every possible way personal data may be collected and used. We strive to provide the most clear and detailed information and are committed to updating this Privacy Policy as data usage practices evolve. Nevertheless, if you have any questions about the use of your personal data, we would be happy to answer them or provide any additional information we are able to disclose. If you have specific questions or find any part of this information unclear, please contact us.

21. Complaints

21.1 If you believe that your rights as a Data Subject have been or may be violated, please contact us immediately via the email provided in this Privacy Policy. We ensure that upon receiving your complaint, we will reach out to you within a reasonable timeframe to inform you of the complaint investigation process and, subsequently, the results.

21.2 If you are dissatisfied with the outcome of the investigation, you may submit a complaint to the supervisory authority—the State Data Protection Inspectorate (www.vdai.lrv.lt).

22. Responsibility

You are responsible for maintaining the confidentiality of the data you provide, as well as ensuring that the information you submit to us is accurate, complete, and up-to-date. If there are any changes to the data you have provided, you must inform us promptly via email. We will not be liable for any damage resulting from inaccurate or incomplete data provided by you or for failure to notify us of data changes.

23.Privacy Policy Amendments

We may update or modify this Privacy Policy at any time. If you wish to receive an updated version of the Privacy Policy, please notify us at the email address provided in Section 2.