Privacy Policy

General information 

This Privacy and Cookie Policy (“PP”) establishes conditions for the processing of personal data through the website www.sanguskuparkas.lt (“Website”). 

By using the Website or providing your personal data in the contact section of the Website, you, as the Website user, agree to the terms of the PP and confirm that you have read and understood all the terms provided by the PP. 

When processing your personal data, we shall comply with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), the Law on Legal Protection of Personal Data of the Republic of Lithuania and other directly applicable legal acts regulating the protection of personal data, as well as instructions of competent authorities. 

Who is the data controller? 

The data controller of those persons who use the Website or submit their personal data in the contacts section of the Website is Investment company for closed-end informed investors KŪB “Subačiaus projektas”, legal entity code 304829421, registered address Jogailos str. 4, LT-01116 Vilnius. 

What personal data and for what purposes do we collect and how long do we store your data? 

 

Purpose of data collection 

Description of categories of personal data 

Legal basis for data collection 

Data retention deadlines 

Purpose of collecting the customer database 

Email address 

Your consent expressed by giving your email address  

3 years 

For communication purposes 

Name, surname, email address, phone number 

Your consent expressed by giving your name, surname, email address and phone number in the contact section 

3 years 

 

What principles do we follow when processing your personal data? 

 

The data controller shall process the personal data of data subjects in accordance with the following principles: 

  • personal data shall be processed in a lawful, fair and transparent manner (principle of lawfulness, fairness and transparency); 
  • personal data are collected for specified, explicit and legitimate purposes and are not further processed in a manner incompatible with those purposes (purpose limitation principle); 
  • personal data are limited to what is necessary for the purposes for which they are processed (principle of data minimisation);  
  • personal data are accurate and, where necessary, kept up to date (principle of accuracy); 
  • personal data are kept in a form which permits identification of the individual for no longer than is necessary for the purposes for which the personal data are processed (principle of limitation of storage period); 
  • personal data shall be processed in such a way as to ensure, through appropriate technical or organisational measures, adequate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage (principle of integrity and confidentiality). 

 

Can I withdraw my consent? 

 

If your personal data is processed on the basis of your consent, you are entitled to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing your personal data prior to withdrawal. Please contact us by email info@releven.lt to withdraw your consent. 

 

How will we protect your data? 

 

We pay special attention to data security, therefore we responsibly implement organizational and technical data security measures that help protect personal data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing. 

 

To whom does your data become available? 

 

Your personal data may only be accessed by a limited number of our employees and our company’s IT entities, and only to the extent necessary to implement proper processing of your personal data. All of these persons are subject to strict confidentiality protection requirements. 

 

What rights are guaranteed to you? 

 

We guarantee the exercise of the following rights of yours and the provision of any relevant information upon your request or inquiry: 

  • know (be informed) about the processing of your personal data; 
  • access to your personal data and how it is processed; 
  • request the rectification, destruction of your personal data or the suspension, except for storage, of the processing of your personal data; 
  • not consent to the processing of your personal data; 
  • request the deletion of your personal data (“the right to be forgotten”); 
  • request the transfer of your personal data, i. e. allow you to access your personal data in the form when you will be provided with personal data in a commonly used and computer-readable format; 
  • the right to submit a complaint to the State Data Protection Inspectorate of the Republic of Lithuania L. Sapiegos str. 17, Vilnius, email: ada@ada.lt. 

 

How can you enforce these rights? 

 

In the event of any request from you regarding the processing of your data or any related question, please write to us at the e-mail address info@releven.lt. 

 

COOKIE POLICY 

Like other websites, we use cookies to provide the best possible experience with our Website. 

A cookie is a small text file that a website saves on your computer or mobile device when you visit that website. Cookies are widely used to make websites work or work more efficiently, and to provide information to a website owners. Cookies used on our Website can be grouped into the following types: 

  • Necessary cookies are strictly necessary to enable the Website to perform basic functions. These cookies allow you to browse the Website and use the desired features, such as providing access to secure areas of the Website. Without these cookies, we would not be able to provide services that allow this Website to operate; 
  • Activity cookies collect anonymous information about how visitors use the website. By providing information about the areas visited, the time spent on the website, and any problems encountered, such as error messages, these cookies help us understand how visitors behave on the Website. This information helps us improve the way our Website works. 

How to manage and delete cookies? 

When you use a browser to access the content we provide, you can configure your browser to accept all cookies, reject all cookies, or be notified when the cookie is downloaded. Each browser is different, so if you do not know how to change cookie preferences, see its Help menu. Your device operating system may have additional cookie controller. If you do not want information to be collected through cookies, take advantage of the simple procedure available in many browsers that allows you to opt out of cookies. For more information on how to manage cookies, visit http://www.allaboutcookies.org/manage-cookies/. 

However, please note that some services may be designed to work only with cookies, and you will no longer be able to use them or certain parts of them when they are turned off. 

APPROVAL AND AMENDMENT OF PRIVACY AND COOKIE POLICY 

 

This Privacy and Cookie Policy shall be reviewed at least every two years. Any changes to this Privacy and Cookie Policy will be published on the Website and, in case of material changes, we will inform you by email. 

 

Privacy and Cookie Policy was drafted on 17 August 2023.