Privacy Policy
Current edition (v.1). Effective from 2021-03-01.
Non-profit Advertising School PRIVACY POLICY
GENERAL PROVISIONS
The data controller is VšĮ Reklamos mokykla, legal entity code 303372553, registered office address Savanorių pr. 4, Vilnius, Republic of Lithuania, respects the privacy of the visitors of the Website and other individuals who provide Personal data to the School or who the School, having a legitimate basis for receiving and processing Personal data, obtains such data, including from third parties, (hereinafter – You or you, or your) privacy.
In this regard, the School collects, stores, uses, and discloses or otherwise processes Your Personal data only as described in this Privacy Policy and/or applicable laws, including GDPR, ADTAĮ, as well as other information provided to you. Please note that additional and/or more detailed information about how we process Your Personal data may be provided in contracts and other information and documents provided to you by the School.
This Privacy Policy describes the principles of information collection, use, or other processing applied on our managed Website as well as other information about the Personal data processed in the School's activities, policies, and principles applied to ensure the protection of Personal data.
By using the Website and/or providing us with Personal data (except in cases where we are required by applicable laws to obtain your explicit consent), you agree that the Personal data you provide to the School will be processed in accordance with this Privacy Policy.
Your provision of Personal data on the Website indicated or other cases requested by the School is generally voluntary, but necessary for us to provide you, for example, the ability to submit a query on the Website regarding the training of interest, receive news, etc.
The data controller has the right to process Personal data in other cases and for purposes not discussed in this Privacy Policy; however, in any case, you will be informed about the processing of Your Personal data in accordance with the procedures provided by law.
Please familiarize other existing or future representatives of yours or the individuals represented by you (persons representing you in relations with us and/or persons you represent in relations with us), as well as other persons for whom this notification may be relevant, as you provide us with their Personal data.
TERMS
In the Privacy Policy, concepts and phrases written in capital letters have the meanings defined below:
ADTAĮ – Law on Legal Protection of Personal Data of the Republic of Lithuania;
Personal data – any information relating to you as a natural person whose identity is determined or whose identity can be determined (Data subject); a natural person, whose identity can be determined directly (by identifier, such as name and surname, internet identifier) or indirectly (by one or more physical, physiological, genetic, mental, economic, cultural, or social identity traits of that natural person);
GDPR – 2016 April 27 Regulation (EU) 2016/679 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC;
Data controller or the School or we, or us, or our – VšĮ Reklamos mokykla, legal entity code 303372553, registered office address Savanorių pr. 4, Vilnius, Republic of Lithuania;
You or you, or your – any person who visits the Website and uses its functionalities (e.g., submits a query, subscribes to newsletters) or is, for example, a client of the Company, a representative of the Company’s client (when the Company’s client is a legal entity), or a person represented by the Company’s client;
Privacy policy – these are principles, rules, and requirements provided by the School that establish the procedure for collecting, storing, using and otherwise processing information related to the use of the Website and its functionalities, as well as other relevant provisions related to information processed in the Company’s activities, including Personal data;
Cookies (English: "Cookies") – small files sent to your browser and stored on your computer, phone, or other device you use to connect to the Website, as well as other technologies, including pixels;
Direct marketing – activities aimed at offering individuals goods or services by mail, telephone, or other direct means and/or soliciting their opinions on the offered goods or services;
Website – the website accessible at the internet address atomicgarden.lt, whose administrator is the School.
ACCESSING THE WEBSITE
Whenever you visit the Website, the servers of the Website temporarily store information about the connecting device in the login file. In this procedure, regardless of your actions, the following information is automatically collected and stored until it is deleted either automatically and/or manually, i.e., the IP address of the connecting computer, the date and time of connection, information about the browser you use and its version, device type, as well as other technical data. This information is collected and processed so that you can use our Website, ensure the continuous security and stability of the system, enable technical administration of the network infrastructure, and for internal statistical purposes. Additionally, the IP address may be investigated and used in cases of Privacy Policy violations, attacks against the infrastructure of the Website, statistical purposes, and other cases where this is provided for in this Privacy Policy or applicable laws.
PERSONAL DATA PROCESSING PURPOSES, DATA SOURCES, CATEGORIES OF SUBJECTS, OTHER INFORMATION RELATED TO YOUR PERSONAL DATA PROCESSING
In order to ensure transparency and responsible processing of Personal data, we inform you that the School may process your Personal data for the following purposes under the conditions defined below:
Administration of queries submitted through functionalities available on the Website (e.g., using registration forms) or School contact points (including e-mail)
In order to enable you to submit queries regarding our services or courses using functionalities available on the Website (e.g., registration or inquiry form), we may process your Personal data as the person submitting the inquiry.
For this purpose, we process the data so that we can provide you with answers to your inquiries and related offers, including responding to your inquiries regarding interesting training courses, their terms, and providing you with relevant course offers and information about other conditions related to the services you are interested in.
For this purpose, Personal data is also processed when you submit inquiries via the School contact points indicated on the Website (e.g., via the email specified on the Website or this Privacy Policy).
Processed Personal data
Name, surname, email address, phone number, the training course of interest, or any other Personal data provided in the inquiry.
Legal basis for processing Personal data
Personal data is processed based on the consent of the Data subject expressed by checking the appropriate checkbox next to the relevant registration or inquiry form or when contacting by email by submitting an appropriate inquiry to the School.
Retention period for Personal data
1 (one) year from the date of submission of the relevant inquiry.
Source of Personal data
Personal data is obtained from the Data subject himself or a person representing the Data subject.
Implementation of direct marketing, including sending newsletters
In cases where we receive your separate consent for direct marketing, we may process your Personal data to offer you School services, including sending information about special training offers, new courses, and other information related to the School's services.
You are provided with an option at any time to disagree with the processing of Personal data for direct marketing purposes and to withdraw the provided consent for the processing of Personal data for this purpose. Additional information regarding the processing of Personal data for this purpose is provided in the section of the Privacy Policy titled "Direct marketing".
Processed Personal data
Email address, name.
Legal basis for processing Personal data
Personal data is processed based on the consent of the Data subject.
Retention period for Personal data
2 (two) years from the receipt of consent or another term provided for in the Data subject's consent (only if specified).
When you provide us with your data to order direct marketing messages, you will receive an email asking you to confirm your consent and the accuracy of the data by clicking on the active link in the email. If you do not do this within 48 hours, we will consider that consent has not been given and we will delete your data.
Source of Personal data
Personal data is obtained from the Data subject himself.
Management of available material and financial resources
In order to ensure our independent functioning and manage the financial and material resources we have, including processing the School's accounting, issuing invoices to clients, we may process clients' Personal data.
Processed Personal data
Client's name, surname, email address, address, phone number, information about payable/receivable amounts.
Legal basis for processing Personal data
Clients’ Personal data is processed to fulfill a contract of which he is a party, as well as to comply with the legal obligation applicable to the School to properly manage accounting.
Retention period for Personal data
10 (ten) years from the relevant accounting operation.
Source of Personal data
Client's Personal data is obtained from the Data subject himself.
Conclusion and execution of contracts
To conclude and properly execute contracts concluded with clients, including accounting concluded transactions, controlling their execution and settlements, recovering debts, we may process Personal data of clients and/or individuals/students represented by clients.
Processed Personal data
Name, surname, date of birth, address, phone number, email address, payment terms, amount of debts/installments, dates of occurrence and grounds, date of birth, other information related to the execution of contractual obligations.
Legal basis for processing Personal data
Personal data is processed to fulfill a contract of which the person is a party.
Retention period for Personal data
10 (ten) years from the proper execution of the contract.
Source of Personal data
Personal data of clients and/or individuals/students represented by clients is obtained from the Data subject himself and/or a person representing him.
COOKIES
General provisions related to Cookies and their use on the Website
We use Cookies on the Website to ensure the proper functioning of the Website, smooth usage of the Website, as well as for the purposes of visitor statistics, improving user experience, advertising, and other purposes specified below.
Cookies may be "session cookies" which are used only while you browse the internet and are automatically deleted when you close the browser, "persistent cookies," which are stored on your end device (computer, tablet, smartphone, etc.) until the set Cookie usage time expires or you refuse the Cookie using one of the methods described in this Privacy Policy, or "third-party cookies," which are used by entities not controlled by the Website administrator.
When you visit the Website, a pop-up notification is presented with a link to this Privacy Policy which informs about the use of Cookies on the Website. By making the appropriate choices in the pop-up notification, you express your consent to the School recording the selected Cookies on your end device (computer, tablet, smartphone, etc.) which are described in more detail below in the Privacy Policy. You have the right to choose and consent to the use of all or certain types of Cookies.
Regardless of your choice, i.e., while you continue to browse the Website, strictly necessary (essential) Cookies will be recorded in any case.
Please note that Cookies may also be used by the School's partners or other third parties, which are not controlled by the Website administrator. The School cannot be and is not responsible for the actions of such entities. If you suspect that School's partners or other third parties not controlled by the Website administrator are using Cookies without your consent, you should contact the specific partner or other third party.
Refusal of Cookies
If you do not wish or consent that Cookies be recorded on your computer or other end device, you can refuse to take the appropriate actions to express your consent, and you can also at any time refuse the respective or all Cookies using the instructions provided below.
You can uninstall Cookies in the following ways:
at any time you can refuse or withdraw your expressed consent regarding the use of respective or all Cookies here.
you can view Cookies already installed on your computer in your browser and delete them one by one or all at once. The actions to take vary (instructions for the most popular browsers regarding Cookies can be found by clicking on the browser name Opera, Firefox, Chrome, Safari, Internet Explorer), therefore the specific actions to be taken should be determined according to your browser;
also, you can configure your internet browser to block Cookies or to obtain a warning about any Cookie being installed. The actions to take differ in each browser, so the specific actions to be taken should be based on your browser.
Types and list of Cookies used on the Website
We use the Cookies listed in the table below on the Website, which are categorized into the four types specified below. All Cookies except strictly necessary Cookies will only be used once we have received your separate consent.
– Strictly necessary Cookies
These Cookies are needed for the visitor to be able to use the opportunities offered by the Website and to be identified, and are essential to ensure the functioning of our Website and electronic services. These Cookies are always active and do not require your consent.
– Functional Cookies
These Cookies allow the Website to remember the choices made by the visitor (e.g., username, language used, etc.) and improve and personalize the Website and its functionalities.
– Analytical Cookies
These Cookies are used to monitor, collect, and analyze statistical (anonymous) data about the number of users visiting our Website and using electronic services, and help to improve the functioning of the Website.
– Advertising Cookies
These Cookies allow us to contact the visitor of the Website with advertising offers on other websites (e.g., "YouTube," "Facebook," etc.) and provide more interesting and relevant advertising that meets your interests.
Name, purpose, and data used, duration, user
Strictly necessary cookies
wc_cart_hash
Necessary for the functionality of the shopping cart.
Session
wc_fragments
Necessary for the functionality of the shopping cart.
Session
Analytical
_ga
Used to distinguish users.
2 years
_gat
Used to throttle the request rate in "Google Analytics."
1 day
_gid
Records a unique ID used to generate statistical data about how the visitor uses the website.
1 day
Functional
easy_cookies_policy_warning
Used for confirming cookie consent.
Session
Advertising
IDE
Used by "Google DoubleClick" to register and report the user's actions on the website after viewing or clicking on one of the advertiser's ads, in order to measure ad effectiveness and provide targeted ads to the user.
1 year
test_cookie
Used to check if the user's browser supports cookies.
1 day
VISITOR_INFO1_LIVE
Attempts to estimate users' internet speed on pages with embedded "YouTube" videos.
179 days
YSC
Records a unique ID to collect statistical data about which "YouTube" videos the user has seen.
Session
yt.innertube::nextId
Sends information to the Youtube platform about which video you chose to watch after the last one you watched.
Persistent
yt.innertube::requests
Collects information about the user's selected 'watch later' videos or search terms entered on YouTube.com.
Persistent
yt-remote-cast-installed
Stores the user's video player settings using the embedded "YouTube" video.
Session
yt-remote-connected-devices
Stores the user's video player settings using the embedded "YouTube" video.
Persistent
yt-remote-device-id
Stores the user's video player settings using the embedded "YouTube" video.
Persistent
yt-remote-fast-check-period
Stores the user's video player settings using the embedded "YouTube" video.
Session
yt-remote-session-app
Stores the user's video player settings using the embedded "YouTube" video.
Session
yt-remote-session-name
Stores the user's video player settings using the embedded "YouTube" video.
Session
Using the above-mentioned analytical Cookies, which collect anonymous information and provide reports, and the "Google Analytics" tool, the School can find out how visitors interact with the Website. Please note that the "Google Analytics" tool is provided by "Google," under the terms of service. "Google" has access to the statistical data collected by this tool and may process it on servers in the USA, but is committed to applying the EU-U.S. Privacy Shield principles, which ensure that the service provider conforms to EU privacy standards. Given that the EU Court of Justice has ruled the EU-U.S. Privacy Shield is invalid, we expect Google to take appropriate measures according to applicable laws. In any case, "Google Analytics" complies with an independent security standard and holds an ISO 27001 certificate. ISO 27001 is one of the most widely recognized certificates globally, demonstrating that "Google Analytics" and the provided systems meet the standards.
An alternative way to disable "Google Analytics" is to install a small plugin offered by "Google" which you can find here.
For more information about "Google Analytics", please click here.
STORAGE OF PERSONAL DATA
The School will process your Personal data as long as stipulated above in this Privacy Policy.
Please note that in certain cases, a longer retention period for Personal data or our right to store Personal data longer may be stipulated by law, for example, when processing Personal data is necessary to comply with legal requirements applicable to the School that require the processing of Personal data, or when processing Personal data is necessary to assert, exercise, or defend legal claims.
In such cases, we may process your Personal data for a longer period, but only as necessary for these purposes of Personal data processing. Such Personal data will be destroyed immediately when it becomes unnecessary.
DIRECT MARKETING
Your consent for processing Personal data for Direct marketing purposes is obtained in advance, i.e., prior to the commencement of processing Personal data for Direct marketing purposes.
The School will use Personal data for Direct marketing purposes to provide information and/or advertising material about the School, training offers, other School services, and other related news (including, but not limited to, newsletters) as well as invitations to participate in related School events, etc.
Information about Personal data processed for Direct marketing purposes, retention periods, legal basis, and source is provided in the section of this Privacy Policy titled "Personal data processing purposes, data source, categories of subjects, other information related to your personal data processing".
The right to object
You are provided with the right at any time to object to the processing of Personal data for Direct marketing purposes and to withdraw the given consent for the processing of Personal data for this purpose (the withdrawal of consent will not affect the legality of the processing of Personal data based on consent prior to the withdrawal of consent). Your refusal or objection will not prevent you from using the services provided by the School and the Website, but the School will no longer be able to provide beneficial offers, information, news, etc.
You may withdraw your consent by using functionalities offered in the emails sent, allowing you to unsubscribe from notifications, as well as contacting the School at the email address specified below in this Privacy Policy.
DISCLOSURE OF PERSONAL DATA
We may disclose your Personal data only on a legitimate basis (e.g., as required by law or as required by the contract entered into with you, or if we have your separate consent) and in compliance with applicable legal requirements.
In addition to the cases already specified in this Privacy Policy, you are informed that we may provide your Personal data to:
service providers acting as the School's Personal data processors and providing the School services related to IT, Website support and maintenance, maintenance of the programs used by the School, providing and maintaining servers, providing a platform for sending newsletters (e.g., UAB "MailerLite"), payment system services (e.g., UAB OPAY solutions), etc.;
law enforcement and supervising authorities in cases specified by law, as well as other state and local authorities, fulfilling legal requirements, including the State Tax Inspectorate;
persons providing services related to the performance of the contract concluded with you, including organizing the training you requested, including postal and parcel service providers;
bailiffs, courts, and other dispute adjudicating authorities;
other third parties when you submit a respective request to provide your Personal data or to third parties about which you are clearly informed in another way and/or your consent is obtained, and information provision is agreed upon using a specific service;
companies providing auditing and related services to the School, legal and financial consulting service providers;
other business entities in the case of the Company merging with another legal entity or acquisition, including individuals performing due diligence.
YOUR RIGHTS AS DATA SUBJECTS AND THEIR IMPLEMENTATION
As a Data subject, you have all rights provided for in applicable laws, including the rights listed below:
The right to withdraw consent
If you have given us consent for the processing of your Personal data, you may withdraw it at any time (the withdrawal of consent will not affect the legality of processing of Personal data based on consent prior to the withdrawal of consent) by contacting us using the contacts specified in this Privacy Policy or other functionalities provided by the School (e.g., by clicking the link in the newsletter that allows you to unsubscribe from direct marketing messages).
The right to access your Personal data
You may access your Personal data processed by the School. You can receive information about how they are collected, how long your data is stored, and who and to what extent receives data about you. However, the right to access may be restricted by law.
The right to request correction of Personal data
You may request the School to correct Personal data processed that relate to you if they are inaccurate, incorrect, or incomplete.
The right to object
Under certain circumstances, you have the right to object to the processing of your Personal data, including when your Personal data is processed based on legitimate interests. You also have the right to object to our use of your Personal data for Direct marketing purposes (only when and if we process data for these purposes).
The right to request the restriction of Personal data processing
If you believe that your Personal data processed by the School is incorrect or objected to the use of data, you may request the School to restrict the use of such data to storage only. The use will be limited to storage only until the accuracy of the data is established or it is verified whether the School's legitimate interests outweigh your interests.
The right to request the deletion of Personal data.
If your Personal data is being processed unlawfully, you object to such processing of your Personal data or there are other grounds stipulated by law, you have the right to request that the data be deleted, subject to the restrictions stipulated by law.
The right to data portability
You have the right to receive Personal data related to you that you provided to the School in a structured, commonly used, and machine-readable format and to request that this data be transferred to another data controller, in accordance with the procedure established by law.
The right to lodge a complaint
You also have the right to lodge a complaint with the State Data Protection Inspectorate if you believe that the processing of your Personal data relating to you is being carried out in violation of legal requirements. However, we always ask you to first contact us using the contacts indicated in this Privacy Policy.
Procedure for implementing data subject rights
If you have additional questions or wish to exercise your rights regarding Personal data processing indicated in this Privacy Policy, you should contact us using the contacts indicated in this Privacy Policy (by email, by post (sending to the specified address), or by physically visiting the School's premises during working hours (09:00 – 18:00), with prior notification).
When submitting requests regarding rights related to Personal data processing, you will be required to confirm your identity (e.g., when submitting a request electronically, you must sign it with an electronic signature; when contacting the School physically or sending a request by post, you must submit a document confirming your identity or a copy of it duly certified in accordance with the law).
We will only accept those requests for exercising Data subject rights that are filled/submitted in coherent and understandable official language (Lithuanian), in legible writing, using no offensive or disrespectful phrases, clearly and specifically indicating which right(s) you seek to exercise and providing circumstances related to the exercise of the right.
A request to exercise a Data subject right(s) will be deemed unreasonable and may not be granted in cases where it does not specify the right(s) to be exercised, as well as other necessary information required in the Privacy Policy or GDPR. We may also not grant your request if we do not process your Personal data, or if the appropriate documents to determine your (or your representative's) identity are not provided together with the request, or if the person submitting the request is not properly authorized or has no right to submit the request (no authorization or other document proving the authority to represent you presented), or if the law does not provide the possibility to grant your request.
Please note that in cases where you abuse your right to submit a request, we have the right to charge a fee for fulfilling the request.
We will respond to all your requests related to your rights as a Data subject without unreasonable delay, but no later than within 1 (one) month from the date of receipt of the request. This term may be extended by an additional 2 (two) months, with prior notice to you regarding this.
THIRD PARTIES
The School does not control the privacy policies and/or other rules applicable to you in relation to third parties. You are responsible and obligated to comply with them at your own discretion and risk in cases where they apply to you (e.g., when links to websites not controlled by the School are provided on the Website). The School is not responsible for the privacy policies of other websites or any other content when a link is provided to other sites in the Website or other functionalities or a link is provided from those sites to the Website. By clicking on any of the mentioned elements, you may leave the Website or other functionalities.
The School does not collect information about you from third parties, except in the cases provided in the Privacy Policy, nor when legal requirements are not followed or third parties’ rights are violated.
CHANGES TO THE PRIVACY POLICY
The School has the right to adjust (including change, edit, supplement, cancel, revoke) this Privacy Policy or any part of it and any related information at its discretion.
The updated Privacy Policy will be published on the Website and will take effect from the date of its publication (the "Effective from" link at the top of the Privacy Policy indicates when the Privacy Policy was last updated).
We recommend that you check the Privacy Policy and its updates when visiting the Website or other functionalities and make sure that the current version of the Privacy Policy meets your requirements. If you use the Website or other functions after the updated Privacy Policy has been published, you agree with the current Privacy Policy.
FINAL PROVISIONS AND CONTACT DETAILS
This Privacy Policy is governed by the laws of the Republic of Lithuania.
All disputes arising from this Privacy Policy shall be resolved through negotiations. If an agreement cannot be reached, disputes will be resolved in accordance with the laws of the Republic of Lithuania.
If you have any questions, claims, or need our assistance regarding the interpretation or application of the Privacy Policy, or if you want to exercise your rights as a Data subject, please contact the School at:
Email: info@atomicgarden.lt
Phone: +370 666 11 233
Address: Gedimino pr. 27, Vilnius, Republic of Lithuania
We will strive to respond to all your inquiries regarding this Privacy Policy and submitted in writing without delay (we will respond to all your requests related to your rights as a Data subject no later than 1 (one) month from the date of receipt of the request, except for the exceptions indicated by legal acts or in this Policy).