Last modified 01.10.2025
1. GENERAL
1.1. What is this privacy policy and who is your data controller?
In this Privacy Policy (the “Privacy Policy”) we, Diabetes Solutions, UAB, company code 305571148 (“Company”, “we”, “us” or “our”), explain how we, as a data controller, handle your Personal data (the “Personal data”) when you visit our website/websites (the “Website”), use our mobile app/apps (the “Mobile App”), contact us through our official social media pages or email, and/or use our services.
If you purchase multiple products through our Website, please note that the privacy policies of all such products will apply. In the event of any discrepancy or conflict between this Privacy Policy and the privacy policy of any specific product, the terms of the product-specific privacy policy shall take precedence with respect to that product.
1.2. What are personal data?
We care about the safety and security of your Personal data and make every effort to ensure it. Personal data refer to any information relating to an identified or identifiable natural person (e.g. your name, email address, etc.).
When processing your Personal data, the Company is guided by and complies with the General Data Protection Regulation 2016/679 (the “GDPR”), the California Consumer Privacy Act, and any other applicable statutory regulations governing the protection of your Personal data.
All the definitions used in this Privacy Policy have the same meaning as prescribed in the Company’s General Terms and Conditions unless expressly provided otherwise in this Privacy Policy.
1.3. Do you have any questions or inquiries related to privacy?
In case of any questions or inquiries, or in case you would like to exercise any of your rights provided in this Privacy Policy, you may submit such inquiries and requests by means provided in the Contacts section of this Privacy Policy. You may also contact our Data Protection Officer regarding all privacy-related issues by email: [email protected].
2. WHAT INFORMATION WILL YOU FIND BELOW IN THIS PRIVACY POLICY?
2.1. In this Privacy Policy you will find information about:
a) Personal data processing principles we follow (Section 3);
b) Personal data we collect, processing purposes, legal grounds and retention periods (Section 4);
c) Personal data retention periods (Section 5);
d) to whom we provide your Personal data (Section 6);
e) direct marketing and other marketing operations (Sections 7 and 8);
f) AI tools (Section 9);
g) security of your Personal data (Section 10);
h) your rights related to Personal data you possess (Section 11);
i) other privacy matters that you should take into account (Sections 12-18).
3. WHAT DATA PROCESSING PRINCIPLES DO WE FOLLOW?
3.1. We adhere to the general data processing principles established in the relevant privacy legal acts, including, but not limited to, the following principles:
3.1.1. Lawfulness, fairness and transparency – we process Personal data in a lawful, fair and transparent manner.
3.1.2. Purpose limitation – we process Personal data for specified, explicit and legitimate purposes and do not further process them in a manner incompatible with those purposes.
3.1.3. Personal data minimization – we process Personal data that are appropriate, relevant and only necessary for the purposes for which they are processed.
3.1.4. Accuracy – we process accurate and updated Personal data.
3.1.5. Limitation of storage period – we keep Personal data in a form that permits identification of you for no longer than is necessary for the purposes for which the Personal data are processed.
3.1.6. Integrity and confidentiality – we process Personal data in such a way as to ensure, through appropriate technical or organisational measures, adequate security of Personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
4. PERSONAL DATA WE COLLECT, PURPOSES, LEGAL GROUNDS AND RETENTION PERIODS
4.1. We process the following Personal data for the purposes specified below:
4.1.1. Offering a personalized plan for you, we may process test quiz data (such may include sensitive Personal data related to your health, your age, height, weight, target weight). We obtain such data directly from you. The legal basis for this data processing is your consent (Art. 6 (1) (a) of the GDPR). You have a right to withdraw your consent at any time. Your Personal data processed for this purpose will be retained for no longer than 2 (two) years following your last update on the account or until you withdraw your consent.
4.1.2. Subscribing to our services and provision of our services to you, we may process your name, surname, email address, phone number, certain bank account details and transaction details, purchase history, and other data you provide while registering. We obtain such data directly from you. Such data is processed to provide services as well as to keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract (Art. 6 (1) (b) of the GDPR). Your Personal data processed for this purpose will be retained for no longer than 5 (five) years following the end of provision of the respective services, unless the law requires retention for a longer period (e.g., for accounting purposes).
4.1.3. Subscribing to our email messages and newsletters, we may process your email address and your purchase history. These Personal data are processed to send you relevant messages and newsletters. The legal basis for this data processing is your consent (Art. 6 (1) (a) of the GDPR). You have a right to withdraw your consent at any time.
If we have already sold goods or provided services to you via our Website and/or App, and you do not object, we may also process your email address on the basis of our legitimate interest, namely seeking to offer you similar goods or services to those you have purchased. You have a right to object to such processing at any time (Art. 21 (2) (b) of the GDPR), (Art. 81 of the Republic of Lithuania on Electronic Communications).
Your Personal data processed for this purpose will be retained for no longer than 2 (two) years following the provision of consent or, in cases where the messaging data is sent to existing clients to maintain and improve customer relations, for no longer than 2 (two) years following the end of provision of the respective services, unless you withdraw your consent earlier or object to such processing.
4.1.4. customer service (i.e. managing your requests, enquiries, complaints or other communications with the Company), we (and through our service providers when applicable) may process your email address, content of the request, metadata associated with your communication, other account information that is necessary to fulfill your request or answer your questions. The legal basis for this data processing is your consent (Art. 6 (1) (a) of the GDPR). You have a right to withdraw your consent at any time. Please note that in some cases we may process Personal data indicated in this paragraph to fulfill our legitimate interest, for example, to ensure uniform and high-quality consultation practice and for investigating disputes between you and the Company (Art. 6 (1) (f) of the GDPR). Your Personal data processed for this purpose will be retained for no longer than 3 (three) years following the provision of consent or until you withdraw your consent, unless the data is processed on legitimate interest basis or it might be needed for purposes stated in clause 4.1.8., then data shall be processed as long as it is necessary to fulfil our legitimate interest, or as long as court proceedings continue, or to defend our rights, to respond to the claims and so.
4.1.4.1. We may utilize third-party Artificial Intelligence (“AI”) tools to automate and optimize the processing of customer requests (with respect to customer support inquiries) submitted through email or a customer support chatbot.
4.1.4.2. These tools may analyze and interpret the information provided by customers to better understand their needs and preferences, categorize customer support requests or inquiries, and generate and provide answers to customers.
4.1.4.3. The AI tools may process both personal and non-personal data provided by customers.
4.1.4.4. By contacting our customer support (via email or through a customer support chatbot), you acknowledge and agree to the processing of health-related information through the use of AI tools for the purpose of providing effective and efficient customer support. This information may include, but is not limited to, details about your health condition, symptoms, or any other relevant health-related data you choose to disclose during your interaction with our customer support. The processing of health-related information through AI tools is solely for the purpose of enhancing the quality and efficiency of our customer support services. We are committed to maintaining the confidentiality and security of your health-related information.
4.1.4.5. Your decision to contact our customer support and provide health-related information implies your informed consent for the processing of such information using AI tools. Health-related information processed through AI tools (for customer support purposes) will only be used for the specific purpose of addressing your customer support inquiries.
4.1.4.6. We may employ automated decision-making processes (including refund requests) for your customer support requests. You have the right to request human intervention in the decision-making process. We are committed to providing a timely response to your appeal. The outcome of the appeal, including any adjustments made to the initial decision, will be communicated to you in a clear and comprehensible manner.
4.1.4.7. Data provided to us may be shared with the third-party providers powering the AI functionality. We ensure that these third-party providers adhere to data protection laws and maintain the confidentiality and security of the shared information. We employ industry-standard security measures to protect the data processed by AI tools. In case of any transfer of, or provision of access to, Personal Data outside the EEA to a third party that is located in a non-adequate country, such transfer shall be governed by the terms of Standard Contractual Clauses that are approved by the European Commission.
4.1.5. managing and administering our social media accounts (e.g. Facebook, Instagram, TikTok, LinkedIn), we may process user’s who interact with us through our social media pages profile name, photo, reactions to the content generated or shared by us (likes, comments, shares). The legal basis for this data processing is your consent (Art. 6 (1) (a) of the GDPR). You have a right to withdraw your consent at any time. In some cases, we may process in this paragraph indicated information on the basis of our legitimate interest, for example, for investigating disputes between you and us Art. 6 (1) (f) of the GDPR). Your Personal data processed for this purpose will be retained for as long as the Company's or your social network account is valid, unless you express your wish to delete their data contained in the Company's social network accounts earlier.
4.1.6. administrating and securing the Website and the Mobile App, ensuring the functionalities of the Website and the Mobile App, performing statistical analysis to find out how you use our Website and the App, we may process your device data that may include IP address, geographical location, browser type and version, operating system, device type, screen resolution and (in case you agree to share such) your location data as well as information on the motion activity, use of our website and apps (i.e. referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use). We obtain such data using cookies and similar technologies. The legal basis for this data processing is your consent (Art. 6 (1) (b) of the GDPR) or our legitimate interest Art. 6 (1) (f) of the GDPR). You have a right to withdraw your consent at any time. Your Personal data processed for this purpose will be retained for no longer than 2 (two) years following the provision of your consent or, in case, processing of device data is based on our legitimate interest (e.g. for proper management of our website, app and business), such device data will be processed as long as it is necessary to fulfil our legitimate interest.
4.1.6.1. By using our app and making in-app purchases, you consent to our sharing of data regarding your usage and consumption of purchased content with Apple, as part of our efforts to resolve refund requests. This information may include details about how you have accessed and interacted with the purchased content. The purpose of sharing this data is to help Apple make an informed decision regarding refund requests. We ensure that such data sharing is done in compliance with Apple's policies and only as necessary to process your requests. You may submit request to access or deletion of your personal data related to consumption information, directly to Apple by visiting privacy.apple.com.
4.1.7. the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, we may process your Personal data that is necessary for the specific purpose. The legal basis for this processing is legal obligation and / or our legitimate interests (Art. 6 (1) (e), Art. 6 (1) (f) of the GDPR), namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. Your Personal data processed for this purpose will be retained for as long as it is necessary to fulfill our legitimate interest and legal obligation (e.g., for as long as court proceedings continue, or to defend our rights, to respond to the claims, and so on).
4.1.8. obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice, we may process your Personal data that is necessary for the specific purpose. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks (Art. 6 (1) (f) of the GDPR) and / or legal obligation (Art. 6 (1) (e) of the GDPR). Your Personal data processed for this purpose will be retained for as long as it is required by the applicable legal acts and / or as long as it is necessary to fulfill our legitimate interest and you do not object to such processing.
4.1.9. compliance with legal obligations to which we are subject, we may process your Personal data that is necessary to comply with a specific legal obligation (Art. 6 (1) (e) of the GDPR). Your Personal data processed for this purpose will be retained for as long as it is required by the applicable legal acts.
4.2. Should the purpose or legal basis of data processing activities indicated in this paragraph change, we will inform you.
5. HOW LONG DO WE STORE YOUR PERSONAL DATA?
5.1. Your Personal data that we process for any specific purpose shall not be kept longer than is necessary for that specific purpose. Specific Personal data retention terms are specified in Section 4 of this Privacy Policy.
5.2. After the end of the applicable retention period, or upon your request, Personal data are destructed using overwriting or physical destruction (when applicable) methods.
5.3. Sometimes we may aggregate, anonymize or de-identify your Personal data in such a way that it cannot reasonably be used to identify you. Such data is no longer personal. We may use such data without restriction in any way allowed by law, including, but not limited to sharing such data with our partners or research institutions, sharing in articles, blog posts, and scientific publications, aggregating statistics about certain activities or symptoms from data collected to help identify patterns across users and evaluate or modify our services.
5.4. Notwithstanding the other provisions of this Section, we may retain your Personal data to the necessary extent where such retention is necessary for compliance with a legal obligation to which we are subject (e.g. accounting purpose, tax purpose etc.) or, in case, we need to protect our interest (e.g. exercise or defense of legal claims, etc.).
6. TO WHOM DO WE PROVIDE YOUR PERSONAL DATA?
6.1. We may disclose your Personal data to any member of our group of companies (including our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this Privacy Policy and we have a legal ground to do that. Such may include internal administration purposes as well as provision/sharing of IT, payment or marketing services or data centers in the group.
6.1.1. Subject to your consent or on the basis of the performance of a contract concluded with you, we may share your account data across different products within our Group of companies when you purchase multiple products. Sharing data within our Group of companies' products will help us optimize your experience while using our products and services, as well as ensure easy integration of new products into your account. Should you choose not to consent (when consent is needed) to such automatic data sharing between products purchased by you, you will have the option to enter the required data manually for each product you purchase.
6.2. We may disclose your Personal data to our insurers, bailiffs, auditors, attorneys, notaries and/or other professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.3. We may disclose your Personal data to our anti-fraud, risk and compliance providers insofar as reasonably necessary for the purposes of protecting your Personal data and fulfilling our legal obligations.
6.4. We may disclose your Personal data to AI service providers, insofar as reasonably necessary for the provision of AI chatbot or customer support functionalities. Our partners adhere to strict data protection regulations, and we ensure that any data transfers comply with privacy regulations requirements.
6.5. To order our services, you will be required to provide certain financial information (e.g. cardholder name, surname, card number, data, CVV) in order to facilitate the processing of payments. Please note that we use third-party payment processor services, thus, we do not collect and store card information. Your card information will be directly received by the specific payment service provider as a data controller. We will only receive information about the payment status and store only the last 4 digits of your card.
6.6. Depending on the payment method chosen by you, your Personal data may be received and processed directly by our group companies, insofar as reasonably necessary for the purposes of collecting, processing, and administrating payments for the services. Such companies acts as a separate data controller.
6.7. We may disclose your Personal data to other service providers insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers, service providers used for data analysis or marketing, call centers, customer satisfaction surveys or market research and others). We will conclude necessary agreements (e.g., data processing agreements) with those third parties and we make sure that those third-party providers would be bound by specific contractual clauses regarding the processing of Personal data as well as by the confidentiality obligations. Also, we require third-party service providers to take all the necessary measures to ensure that they would implement proper organizational and technical measures to ensure the security and privacy of your Personal data.
6.8. In addition to the specific disclosures of Personal data set out in this Section, we may disclose your Personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject (e.g., by the lawful request of law enforcement authorities, other public authorities).
6.9. Persons indicated in this Section may be established outside the Republic of Lithuania, the European Union (EU) and the European Economic Area (EEA). In case we will transfer your Personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured, including where appropriate, signing European Commission approved Standard Contractual Clauses for transfer of data. More information about Standard Contractual Clause could be found here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
6.10. Also, your Personal data may be transferred to Personal data recipients established outside the EU or EEA on other legal grounds compatible with the requirements of Articles 45-49 of the GDPR.
6.11. To find out more information regarding appropriate safeguards, you may contact us.
7. DIRECT MARKETING COMMUNICATION
7.1. We may contact you via email or phone to inform on what we are up to (we may send newsletters, the latest information about our products and services, special offers, marketing campaigns). Also, we may inform you about our similar products and services that might interest you via email. You have a right to object to such your Personal data processing at any time.
7.1.1. We may share your contact information with our group companies for direct marketing purposes.
7.2. When contacting you by phone (if you agreed to receive marketing communications via phone), SMS/text messages or phone calls from us will be received through your wireless provider to the mobile number you provided. SMS/text messages may be sent using an automatic telephone dialing system or other technology. Message frequency varies. Message and data rates may apply.
7.3. We may use your Personal data used to create your account and related to your use of our services to personalize marketing messages and advertisements presented to you. The legal basis for this processing is our legitimate interest to present you with marketing messages that we consider relevant to you (Art. 6(1)(f) of the GDPR).
7.4. You may opt out of receiving marketing communications at any time. You may do so by choosing the relevant link in our marketing messages or contacting us via means provided on our website, or you can contact us via email. If you are receiving both email and phone marketing communications and you wish to opt out of receiving them, you will need to opt out separately by following the relevant link in any of our marketing messages or contacting us via means provided in our Website or this Policy.
7.5. Upon you having fulfilled any of the provided actions, we will update your profile to ensure that you will not receive our marketing communication in the future.
7.6. In case you opt out of receiving marketing communications, we will immediately stop sending marketing communications to you. Nevertheless, please be informed that as our business activities consist of a network of closely related services, in certain cases, it may take a few days until all the systems are updated, thus you may continue to receive marketing communication while we are still processing your request.
7.7. In any case, the opt-out of the marketing communications will not stop you from receiving communication directly related to the provision of services.
8. OTHER MARKETING OPERATIONS AND COOKIES
8.1. We may use marketing tools of social media platform operators (e.g. Google LLC, Meta Platforms Inc.) or other third parties and, therefore, share your Personal data relevant for marketing operations to such social media platform operators or other third parties for marketing purposes.
8.1.1. For EU residents: Please note that social media platform operators may be established not in the EU and EEA, thus your Personal data may be transferred outside the EU and EEA. In this case, your Personal data will be protected by concluding Standard Contractual Clauses approved by the European Commission. More information about Standard Contractual Clause could be found here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
8.2. We also use cookies. More information about cookies can be found in our Cookie Policy.
9. AI TOOLS
9.1. In case you consent, we will use your Personal data to enhance your experience with our AI assistant, Dia. This includes tracking your logged meals to provide personalized nutrition summaries and coaching. By analyzing your meal data, medical conditions, allergies, and dietary preferences, Dia can offer tailored nutrition tips and recommendations to help you achieve your health goals.
9.1.1. The in-app chat assistant utilized by us is powered by third-party service providers, whose technologies enhance the functionality of our application. These third-party providers adhere to strict data protection regulations and contractual obligations to ensure the confidentiality and security of your Personal data. We have implemented appropriate safeguards to protect your data during these processing activities.
9.1.2. In the course of using the in-app chat assistant, certain data may be collected or used from your profile, including profile information, user queries, interactions, and any information shared during the conversation or necessary for query solution. This data may include details about your logged meals, nutritional information (such as calories, macronutrients, and micronutrients), medical conditions, allergies, dietary preferences, and any other health-related data from your profile or data which you choose to disclose during your interaction with the chat assistant. This data may be processed to provide tailored suggestions and responses to user inquiries.
9.1.3. The scope of information processed by AI tools will also depend on the nature of your request or inquiry, as well as any information you provide in the request itself, so both personal and non-personal data provided by customers may be processed. This information may include details about your health condition, symptoms, profile information, or any other relevant health-related data you choose to disclose during your interaction with the chatbot or is necessary to process in the course of your interaction.
9.1.4. By using our in-app chat assistant, you acknowledge and consent to the processing of any Personal Data contained in your inquiry, including health-related Personal Data, through the use of AI tools. The purposes for processing this data are:
The information processed is not used for unrelated purposes without your consent. We are committed to maintaining the confidentiality and security of your Personal Data.
9.1.5. Data collected by the in-app chat assistant may be shared with the third-party providers powering the chat assistant functionality, including, but not limited to, OpenAI. We ensure that these third-party providers adhere to data protection laws and maintain the confidentiality and security of the shared information.
9.1.6. The in-app chat assistant does not operate with and does not provide final answers regarding refund or subscription management requests, as well as data subject rights requests described in this Privacy Policy. If you have these kind of requests, please contact our customer support.
9.1.7. The data processed in the context of chat assistant conversations will be retained by us for up to 12 months from your last consent renewal to ensure the functionality and personalization of your experience with the chatbot.
10. SECURITY OF YOUR PERSONAL DATA
10.1. We are using a number of an appropriate level of technical and organisational measures to protect your Personal data. Organisational security measures include restricting access solely to authorised persons with a legitimate need to access Personal data, signing confidentiality agreements, arranging training, creating and implementing relevant policies and procedures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, implementing access control and authentication tools, ensuring physical security, etc.
10.2. Personal data is stored either on the servers of the Company or of our contractors, who are bound by specific contractual clauses regarding the processing of Personal data as well as by the confidentiality obligations.
10.3. Regardless of technical and organizational measures taken by us to protect your Personal data, we cannot objectively guarantee the full security of it.
11. YOUR RIGHTS
11.1. In this Section, we have summarized the rights that you have under data protection laws. Some of the rights are complex, thus we only provide the main aspects of such rights. Accordingly, you should read the relevant laws (first and foremost the GDPR) and guidance from the regulatory authorities for a full explanation of these rights.
11.2. Your principal rights under data protection law are the following:
11.2.1. The right to be informed about processing of Personal data. You have the right to obtain information about the Personal data processed by us, the sources of the Personal data, the purposes of the processing, the legal grounds, the retention period, data recipients or data processors, your rights, etc.
11.2.2. The right to access data. You have the right to confirmation as to whether or not we process your Personal data and, where we do, access to the Personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal data concerned and the recipients of the Personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your Personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
11.2.3. The right to rectification. You have the right to have any inaccurate Personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal data about you completed.
11.2.4. In some circumstances, you have the right to erasure of your Personal data. Those circumstances include when: (i) the Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the Personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defence of legal claims.
11.2.5. In some circumstances, you have the right to restrict the processing of your Personal data. Those circumstances are when: (i) you contest the accuracy of the Personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the Personal data for the purposes of our processing, but you require Personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Personal data, however we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.
11.2.6. You have the right to object to our processing of your Personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
11.2.7. You have the right to object to our processing of your Personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal data for this purpose.
11.2.8. You have the right to object to our processing of your Personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
11.2.9. The right to data portability. To the extent that the legal basis for our processing of your Personal data is: a) consent; or b) performance of a contract or steps to be taken at your request prior to entering into a contract, necessary to enter into such, you have the right to receive your Personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11.2.10. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of Lithuania, registered office at L. Sapiegos St. 17, LT-10312 Vilnius, email address [email protected], www.vdai.lrv.lt.
11.2.11. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11.2.12. You have the right to request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. However, there are exclusions of this right. Such exclusions include when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorised by EU or EU member state law to which we are subject to and which also lays down suitable measures to safeguard the your rights and freedoms and legitimate interests; (iii) is based on your explicit consent.
11.3. In addition to specific measures provided in this Section or the website you may also exercise any of the rights indicated herein by contacting us by email. Please note that we have a legal obligation to verify your identity before exercising your rights. We undertake to respond to your inquiry within 1 month after it is received. This response time may be extended by 2 months for complex or multiple requests. In case of such an extension, we will inform you additionally.
12. THIRD PARTY WEBSITES
On the website you may find links to and from partner sites, information sources and related party websites. Please take note that such third-party websites that you will visit by clicking on links have their own privacy policies and we take no responsibility regarding such privacy policies. We recommend familiarising yourself with privacy policies of such websites before providing any Personal data to such.
13. CHILDREN PERSONAL DATA
13.1. Our Website and Mobile app are targeted only at people over the age of 18.
13.2. If we have reason to believe that we hold Personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that Personal data. If you become aware that your child has provided us with Personal data without your consent, please contact us via email.
14. CALIFORNIA PRIVACY ADDENDUM
14.1. If you are a California consumer or resident, in addition to the information provided in this Privacy Policy, you may have the additional rights and information provided to you under the California Consumer Privacy Act:
We do not knowingly sell personal information nor share it with third parties for direct marketing purposes. However, if we do so in the future, you will be notified and have the right to opt out of the “sale” of personal information.
We will retain, use, or disclose personal information we collect or processes on your behalf, only for the purposes described in this Privacy Policy, and will notify you if this changes.
You have the right not to be subject to discrimination if you exercise any of your rights.
14.2. We do not currently recognize or respond to browser-initiated Do Not Track signals. Instructions to enable for the following browsers are here: Chrome, Firefox, IE, Edge, Safari, Opera.
15. RIGHT TO COMPLAINT
If you believe that your rights have been violated, you may always contact us by email. Also, you may file a complaint with the supervisory authority in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by the State Data Protection Inspectorate of the Republic of Lithuania, registered office at L. Sapiegos St. 17, LT-10312 Vilnius, email address [email protected], www.vdai.lrv.lt.
16. DATA SCRAPPING
Please note that the automated data collection, also known as data scraping, from our Website is strictly prohibited without explicit written consent from us. This includes, but is not limited to, the use of software, bots, scripts, or any other automated methods to collect, extract, or replicate content, data, or information from our Website.
17. UPDATING YOUR DATA
Please let us know if the personal information that we hold about you needs to be corrected or updated.