MB “TIKRAS VAIZDAS” PRIVACY RULES
MB “TIKRAS VAIZDAS”, legal entity code 303595392, registered address Savanorių pr. 178F, LT-03154 Vilnius, Lithuania (hereinafter – the Company), is the operator of the online store www.hopro.lt.The Company values the trust of every User of the online store, the online store managed by the Company, and the goods and/or services sold or rented through it. This trust, among other things, is inseparable from the proper handling and protection of the User’s Personal Data. Therefore, in this section of the online store website, you will find the provisions of the Company’s Privacy Rules (hereinafter – Privacy Rules) governing the receipt, use, processing, and other handling of Personal Data of Users by the Company, as well as the related rights of Users and the obligations of the Company. Please note that by using the online store website and the services provided therein, the User agrees to the provisions of the Privacy Rules. If the User does not agree to comply with the provisions of the online store Privacy Rules, the User may not continue to use the Company’s online store website. Please note that the Company has the right to unilaterally change the provisions of the Privacy Rules at any time, by notifying the Users of the online store website in advance. Any changes to the provisions of the Privacy Rules become effective from the day they are published on the online store website, so please read the provisions of these Privacy Rules each time before using the capabilities of the online store. If, after reading the provisions of these Privacy Rules, you decide to continue using the capabilities of the online store, you confirm that you agree with and accept them. If the User has any questions related to the User’s Personal Data, they can contact the Company directly via email: info@hopro.lt More detailed information about the Company and the Company’s contact details can be found in the sections of the online store website, “Contacts,” as well as below in this document. Please note that all actions performed with the User’s Personal Data are carried out in accordance with the applicable provisions of the European Union and the Republic of Lithuania laws, primarily the General Data Protection Regulation and the Law on the Legal Protection of Personal Data of the Republic of Lithuania.
KEY TERMS
Controller: The Company, i.e., MB “TIKRAS VAIZDAS”, legal entity code 303595392, registered address Savanorių pr. 178F, LT-03154, Vilnius, Lithuania, which determines the purposes and means of data processing.
Online Store: The online store accessible at www.hopro.lt
User: A natural person visiting the online store website and/or a natural person seeking to purchase goods sold by the Company and/or receive services provided by the Company, and/or purchasing them.
Personal Data: Any information related to an identified or identifiable natural person – data subject.
Data Recipient: A legal or natural person to whom the Data Controller provides personal data.
Online Store Account: An account for logging into the online store website, which is created by the User’s active actions according to the sequence of actions indicated on the online store website, and where the User’s Personal Data and order history are stored.
Cookie: A small text file sent to each User’s device from which the online store website is accessed and temporarily stored on that device.
Direct Marketing: Activities aimed at offering goods or services to individuals by mail, telephone, or other direct means and/or inquiring about their opinions regarding the offered goods or services.
Company Partner: A person supplying goods or services to the Company with whom joint promotions or projects may be carried out.
METHODS OF RECEIVING PERSONAL DATA
The Company receives Users’ Personal Data in three ways, when: • The User provides information about themselves; • Data related to the User is generated automatically when the User uses the online store website; • Data about the User is obtained from third parties.
The User of the Company’s online store website provides information to the Company in the following cases: • When creating an account on the online store and placing an order; • During any form of communication with the Company.
The second method of receiving Personal Data involves a situation where the Company collects information automatically using Cookies, based on the User’s consent to process their Personal Data, when the User uses the Company’s online store website and its functionalities.
The third method of receiving Personal Data involves a situation where, based on the User’s consent, the Company receives information about the User from third parties such as Facebook, Inc., Google, Inc. The Company receives from Facebook, Inc. such User Personal Data as the User’s image and the name of their profile on www.facebook.com, while from Google, Inc., the Company only receives the User’s image data.
PURPOSES OF PROCESSING USER PERSONAL DATA
The Company processes Users’ Personal Data for the following purposes: • For the execution of electronic commerce on the Company’s online store website; • For the organization and execution of contests, promotions, and games; • For providing services; • For direct marketing; • For evaluating, improving, and ensuring the quality of professional service and resolving potential or actual disputes with Users (recording audio).
The Company does not process User Personal Data for any other purposes that are not compatible with the above purposes.
PROCESSED PERSONAL DATA AND LEGAL BASES FOR PROCESSING
The Company processes the following User Personal Data:
•On the basis of contract conclusion and execution: User’s Personal Data such as name, personal code, surname, email address, phone number, delivery address, IP address, bank account number, payment method for purchased goods, order history, residential address, cookies, income level, passport number, marital status. This Personal Data is processed for the purpose of executing electronic commerce on the Company’s online store website.
• On the basis of User’s consent: User’s Personal Data such as name, surname, phone number, email address, IP address, video recording, image, cookies. This Personal Data is processed for the purpose of organizing and executing contests, promotions, and games.
• On the basis of contract conclusion and execution: User’s Personal Data such as name, surname, personal code, phone number, email address, workplace address, complaints. This Personal Data is processed for the purpose of providing services advertised on the Company’s online store website.
• On the basis of User’s consent: User’s Personal Data such as name, surname, email address, city, purchase category, purchase amount, cookies, image data, social network www.facebook.com profile name, residential address. This Personal Data is processed for the purpose of direct marketing.
• On the basis of the Company’s legitimate interest: User’s Personal Data such as audio recordings (conversation recordings). This Personal Data is processed for the purpose of evaluating, improving, and ensuring the quality of professional service and resolving potential or actual disputes with Users.
The Company notes that it does not collect, process, or perform any other data processing operations related to the User’s sensitive (special) personal information, such as religious or political beliefs, health, etc.
USER RIGHTS AND THEIR IMPLEMENTATION PROCEDURE
The Company ensures, adheres to, and respects the rights of Users of the Company’s online store website:
• The right to information, i.e., the right to be informed about the Company’s processing of the User’s Personal Data;
• The right to receive information related to the Personal Data processed by the Company;
• The right to rectification of the User’s Personal Data if it is inaccurate or incomplete;
• The right to be forgotten when Personal Data is no longer necessary to achieve the purposes for which it was collected or otherwise processed, and/or the User withdraws the consent on which the processing is based and there is no other legal ground for processing Personal Data, and/or the User objects to the processing of Personal Data and there are no overriding legitimate grounds for processing, and/or Personal Data has been unlawfully processed, and/or Personal Data must be erased in compliance with a legal obligation under European Union or Member State law to which
the Company is subject, and/or the User’s Personal Data has been collected in relation to the offer of information society services;
• The right to restrict the processing of the User’s Personal Data when the User contests the accuracy of the Personal Data for a period enabling the Company to verify the accuracy of the Personal Data, and/or the processing is unlawful and the User opposes the erasure of Personal Data and requests the restriction of its use instead, and/or the Company no longer needs the Personal Data for processing purposes, but they are required by the User to establish, exercise, or defend legal claims, and/or the User has objected to processing pending the verification whether the Company’s legitimate grounds override those of the User;
• The right to object to the processing of the User’s Personal Data, i.e., the User has the right to object at any time, on grounds relating to their particular situation, to processing of Personal Data concerning them which is based on performing a task carried out in the public interest or in the exercise of official authority vested in the Company, including profiling, and/or processing necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the User which require protection of Personal Data, especially where the User is a child, including profiling, and/or when Personal Data is processed for direct marketing purposes, including profiling related to direct marketing. The Company hereby states that, considering the implementation of the User’s right to object to the processing of Personal Data, the Company will no longer process Personal Data unless the Company demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the User, or for the establishment, exercise, or defense of legal claims.
• The right to data portability, i.e., the User has the right to receive the Personal Data concerning them, which they have provided to the Company, when the processing is based on consent and/or a contract and the processing is carried out by automated means. The Company hereby states that by exercising the right to data portability, the User has the right to have the Personal Data transmitted directly from the Company to another controller, where technically feasible.
• The right to withdraw consent to the processing of Personal Data, where the processing is based on the User’s consent.
The Company informs that the relevant actions to implement the above-mentioned User rights will be performed as soon as possible, but no later than 1 (one) month from the date of the User’s request. Please note that if necessary, the 1 (one) month period may be extended by two more months considering the complexity and number of requests. In such a case, the Company will inform the User about such an extension within 1 (one) month from receiving the request, providing the reasons for the delay.
The Company points out that without prejudice to other administrative or judicial remedies, every User has the right to lodge a complaint with a supervisory authority, particularly in the Member State of their habitual residence, place of work, or place of the alleged infringement if they consider that the processing of Personal Data related to them infringes applicable data protection laws. In the Republic of Lithuania, such a supervisory authority is the State Data Protection Inspectorate, legal entity code 188607912, address A. Juozapavičiaus g. 6, LT-09310 Vilnius, Lithuania.
If the User wishes the Company to implement the above-mentioned rights or if the User has any questions regarding the exercise of their rights, please contact the Company.
PERSONAL DATA RETENTION PERIODS
The retention periods of Personal Data processed by the Company, depending on the purposes of Personal Data processing, are as follows:
• Personal Data of the User, processed for the purpose of executing electronic commerce on the Company’s online store website, is stored for 5 (five) years from the last use of the Company’s online store by the User;
• Personal Data of the User, processed for the purpose of organizing and conducting contests, promotions, and games, is stored for 5 (five) years from the last participation of the User in a contest, promotion, or game organized by the Company;
• Personal Data of the User, processed for the purpose of providing services, is stored for 5 (five) years from the last use of the services provided by the Company by the User;
• Personal Data of the User, processed for the purpose of direct marketing, is stored for 5 (five) years from the date of receiving the User’s consent to process their Personal Data for direct marketing purposes;
• Personal Data of the User, processed for the purpose of evaluating, improving, and ensuring the quality of professional service and resolving potential or actual disputes with clients, is stored for 3 (three) years from the date of receiving the relevant Personal Data.
The Company makes all reasonable and justified efforts to protect the User’s Personal Data during the above periods. Upon the expiration of the Personal Data retention period, the Company destroys the User’s personal information.
TRANSFER AND DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
The Company uses the services of reliable third parties established in Lithuania and other European Union countries, such as courier services, leasing companies, direct marketing services, and server rental companies.
The Company informs the User that, in order to achieve the purposes of Personal Data processing identified in these Privacy Rules, depending on the specific purpose of Personal Data processing, the Company transfers the User’s Personal Data to the aforementioned third parties.
The User’s Personal Data is transferred to third parties only to the extent necessary to directly fulfill their duties and ensure the legitimate interests of the User.
The Company and the third party to whom the Company has transferred the User’s Personal Data operate under a separate agreement(s), which regulate the actions of processing Personal Data transferred to the third party, the necessary technical and organizational security measures, and other mandatory legal provisions governing Personal Data processing.
The User is obligated to protect their password and login details for the Company’s online store account and other Personal Data. The User undertakes not to disclose Personal Data about
themselves or third parties if such third-party Personal Data becomes available to them, and to immediately inform the Company of any identified violations.
The Company aims to ensure the confidentiality of the User’s personal information and, under normal circumstances of using the Company’s online store website, the Company has no right to disclose the User’s Personal Data to any other Data Recipients unless required by the implementation process of the services provided by the Company.
In case the Company is required by law or other legal acts, the Company must disclose information about the User to competent authorities.
PERSONAL DATA SECURITY
The Company takes care of the security and confidentiality of the User’s Personal Data. To prevent unlawful access to or unlawful disclosure of Personal Data and to protect the information, the Company has implemented appropriate technical and organizational security measures.
The Company notes that while it strives to implement appropriate technical and organizational security measures, these or any other measures cannot guarantee complete security and cannot protect against all potential security breaches at all times.
The User has the right to request the deletion of accumulated Personal Data by informing the Company via email at info@hopro.lt.
CHILDREN’S PERSONAL DATA AND PRIVACY
The Company’s online store and the services provided therein are intended for persons aged 16 and above. Therefore, the Company does not knowingly collect or process Personal Data of children under the age of 16.
However, the Company notes that parents have the right to give the Company their consent if their underage child under the age of 16 wishes to use the Company’s online store and its functionalities, such as purchasing goods or services.
If you learn that your child has provided personal information to the Company without your consent, please contact the Company at the provided address.
DIRECT MARKETING
The Company, with clear consents from the User, has the right to send direct marketing messages to the User via email and/or SMS.
The User has the right to withdraw their consent(s) to process their Personal Data for direct marketing purposes at any time.
After the User withdraws their consent, due to technical reasons, the User may still receive marketing offers from the Company for a reasonable period of time.
If the User no longer wishes for their Personal Data to be used for direct marketing purposes, the User can:
• Send an email to info@hopro.lt or call the Company’s customer service at +370 657 60230 and indicate that they do not wish to receive emails and/or SMS messages;
• Unsubscribe from the newsletter by clicking the “unsubscribe” link at the bottom of the newsletter.
The sending of emails and/or SMS messages will be terminated only for the email addresses and/or phone numbers clearly indicated by the User.
The User has the right to object to their personal data being used for direct marketing purposes by informing the Company via email at info@hopro.lt or customer service phone +370 657 60230.
COOKIES
To provide the User with the full scope of services of the Company’s online store, cookies may be recorded on the User’s device used to connect to the online store, subject to the User’s consent.
If the User agrees to have cookies recorded on their device, the User must click “I agree to the use of cookies,” and if the User does not agree to have cookies recorded, they must click “I do not agree to the use of cookies.”
The cookies used by the Company are intended to transmit information over an electronic communication network. Another type of cookies is used to collect information for calculating visits (collecting statistical information), providing content that matches the User’s interests, and saving browsing history. The Company does not use this type of cookies but notes that some of the Company’s partners may use this type of cookies, so if the User suspects that these types of cookies are being used without their consent, they should contact the specific partner of the Company.
If the User has agreed to have cookies recorded on their device, the User has the right to withdraw their consent at any time by clicking the “Cancel cookie usage” link or changing their browser settings. However, in this case, some functions of the online store may not work for them.
EFFECTIVE DATE OF PRIVACY RULES
These Privacy Rules are effective from January 2, 2025. Any changes to the Privacy Rules will be published and visible on the Company’s online store website.
CONTACT INFORMATION
MB “TIKRAS VAIZDAS” Legal entity code 303595392 Savanorių pr. 178F, LT-03154
Phone: +370 657 60230 Email: info@hopro.lt
Privacy rules editing date: December 15, 2024.
