Privacy Policy - Distribution IoT

PRIVACY POLICY

General information

UAB Lematics (the “Data Controller” or “we”) is the administrator of this website www.distributioniot.com (the “Website”). The Data Controller respects your privacy and undertakes to protect it in accordance with this Privacy policy (the “Privacy Policy”). We use this Privacy Policy to fully inform you of the processing of your personal data, whether you communicate with us in person, electronically, or in any other manner you choose. The Privacy Policy sets forth and defines the purposes and procedure of processing and collecting personal data, the scope of collected personal data, and informs you about your rights.

The Privacy Policy applies to all persons who visit the Website. The conditions set forth in them apply every time you want to get access to the content we offer, regardless of the device (computer, mobile phone, tablet etc.) you use.

The data of all data subjects is processed legally and transparently, with predetermined goals and only to the extent necessary to achieve them. When processing your personal data, we adhere to 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 (the “GDPR”), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as recommendations and/or requirements of supervisory authorities.

Persons under 14 may not provide any personal data through our Website. If you are under 14, make sure that you obtain permission from your parents or other legal guardians before you provide your personal data to us.

The concepts used in the Privacy Policy are treated as they are described in the GDPR.

For further information please click “Learn More” in every section of this Privacy Policy.

How do we collect your information about you?

Your personal data, i.e. any information about you that allows us to recognize you, is obtained in various ways:

You can provide information (personal data) by your own;
Information about you may be collected automatically;
In certain cases, we may obtain information about you from third parties, we may also collect information about you from publicly available sources.

You can provide information (personal data) by your own. This often happens in the following cases:

When you enter into an agreement with us (e.g. sale and purchase agreement);
When you use our services;
When you subscribe to our newsletters;
When you submit a request, application and/or complaint to us by phone, email, or mail.

Your data may be collected automatically. This often happens in the following cases:

When you submit an application on our websites and profiles on social networks (for example, Facebook, LinkedIn, Instagram, YouTube);
When you make entries on platforms in social networks (for example, Facebook, LinkedIn, Instagram, YouTube) that we manage;
When you use our Website (cookies and similar technologies allow us to collect data. For more information about our cookies, please see below).

We may obtain information about you from third parties as far as the applicable law allows. This may be the data provided by our partners, contractors, service providers, as well as the data from your public profiles or databases.

We may link the information we receive about you from our own, public, and commercial sources to other information we receive from you or about you.

We may also collect information about you in other cases not covered by this Privacy Policy. If this happens, we will inform you additionally.

Which of your information data (personal data) do we process?

While we do our best to collect as little information about you as possible, we collect the following information in order to conduct our business:

The information necessary for the conclusion and execution of transactions, contracts and other agreements;
The information that you provide during telephone conversations with us, in emails or letters, requests or registration forms;
The information contained in the money transfers you make to us;
The information necessary to protect our interests in court or in other institutions;
Information about your device;
Information necessary for direct marketing.

As a rule, the information we collect directly from you consists of the following:

Name, surname, telephone number, email address, date of birth, home address, payment information (including but not limited to payment method and bank account/bank card number),
the method of delivery of the goods and their delivery address, place of employment/job/business, records of the correspondence with you.

As a rule, the information that is collected automatically consists of the following:

Information on how you use the Website (device information: IP address, version of the operating system and the device you use to get access to the content, parameters; login information: session time and duration, as well as any other information that is stored in the cookies that we install on your device (the cookie policy is presented below); location: device GPS signal or information about the nearest Wi-Fi access points and mobile towers (which can be transmitted to us, when you use our websites).

As a rule, we collect the following information from third parties or publicly available sources:

Name, surname, telephone number, email address, place of employment/job/business.

You may opt not to provide us with certain information, however, in such case, we may not be able to provide you with our services (for example, if you do not provide the necessary information required to respond to your request, we will not be able to answer you).

Note: our staff will never ask you to provide your login data, bank card numbers, passwords or any other information, due to the use of which you may suffer financial or any other loss.

Why and on what basis do we process your data?

The above information is processed to achieve the following goals:

Conclusion and execution of transactions, contracts, and other agreements;
Establishment, maintenance and development of business, professional and/or other legal contacts;
Performance of our duties in accordance with applicable legal acts;
Processing of our internal administrative and accounting records;
Verification of the quality of services provided by us on the internet;
Defense of our interests before a court or other authority;
Direct marketing.

We inform you that we strive to keep in touch with our customers and provide them with information about the services offered. To do this, we carry out direct marketing by phone and email, providing notifications and news about our goods. We have the right to send our customers promotional information about our products to the email address that we received during the sales of goods. Our clients have the right to immediately or at any time refuse our marketing notifications by letting us know about this decision in any way convenient for them: by email info@distributioniot.com, by sending a letter to the address JSC Lematics, Lvovo str. 25-702, LT-09320, Vilnius, Lithuania or using the link in the advertising notice in an email. This refusal will in no way affect our processing of customer data that we carried out before.

In all other cases, to carry out direct marketing, we will process your personal data only by receiving your consent to process it for this purpose. You can cancel your consent at any time by notifying us by any of the methods above.

Your personal data is processed in accordance with one or several legal processing principles:

Compliance with legal requirements;
The conclusion and execution of transactions, contracts or other agreements concluded with you;
Our legitimate interests (unless your personal interests prevail);
In some cases – your consent.

The purposes, principles and personal data that we process are shown in the following table.

*Purpose*	*Legal basis*	*Personal data*
Conclusion and execution of transactions, contracts and other agreements	Conclusion and execution of agreements with youCompliance with legal requirements Our legitimate interests	Name, surname, telephone number, email address, date of birth, home address, payment information (including but not limited to payment method and bank account / bank card number), the method of delivery of the goods and their delivery address, place of employment/job/business, records of the correspondence with you
The establishment, maintenance and development of business, professional and/or other legal contacts	Compliance with legal requirementsOur legitimate interests	Name, surname, telephone number, email address, place of employment/ job/ business
Fulfilment of our duties in accordance with applicable legal acts	Compliance with legal requirements	This depends on the requirements of the applicable legal acts, the institution request content or other objective reasons
Processing of our internal administrative and accounting records	Compliance with legal requirementsOur legitimate interests	To do this, we can process all the personal data we have specified in the Privacy Policy
Verification of the quality of services provided by us on the internet (to improve them and create new content)	Our legitimate interests	IP address, version of the operating system and the device you use to get access to the content, parameters, session time and duration, as well as any information that is stored in cookies that we install on your device, device GPS signal or information about the nearest Wi-Fi access points and mobile towers, which can be transmitted to us, when you use our Website
Defense of our interests before a court or other authority	Our legitimate interests	To do this, we can process all the personal data we have specified in the Privacy Policy
Direct marketing (only if we received your consent or did not receive a message from you prohibiting us from doing so)	ConsentOur legitimate interests	Name, surname, email address, telephone number, home address

When we cannot be guided by one of the legal grounds set forth in this table, prior to beginning to process your personal data, we will ask for your consent (such cases will be clear, depending on the circumstances and context).

When we process your personal data for purposes other than those specified in the Privacy Policy, we will notify you in a separate notice.

To whom we may transfer your personal data?

Without your prior written consent, we may transfer your personal data only to:

Our business partners or companies, providing services at our request (that are also selected in a responsible manner);
Law enforcement and government agencies;
Other entities, if this is required by law or in order to protect our legitimate interests.

Your personal data recipients’ (individual data controllers) ability to use your data is limited. They may not use this information for purposes not specified in the contract with us. In order to use your data for their own direct marketing offers, you will be asked for separate consent.

We can also provide your data to data processors who provide services to us (perform our assignments). They are entitled to process your personal data only based on a written contract signed between us and them according to our instructions and only to the extent necessary for the proper fulfillment of contractual obligations. Our data processors help us take all the necessary measures to ensure that they can take appropriate organizational and technical measures to ensure security and maintain the confidentiality of your personal data.

Below is a list of data recipient categories:

Banks; advertising and marketing agencies; companies involved in provision of IT services and/or software creation/development, installation, and support/maintenance; communication companies; companies providing financial accounting; mail delivery companies and courier services; companies providing legal assistance; archiving companies; etc.

Other parties who may be provided with your personal information that we have, when it is necessary to protect our legitimate interests or to comply with the requirements of legal acts: governmental and municipal authorities, persons conducting a pre-trial investigation, courts, etc.

You can get more information about the specific companies listed in this section with whom we can share your personal data, using the contact details, provided in the Privacy Policy or the informational notices provided to you.

Which countries are your personal data transferred to?

We process your personal data in the territory of the European Union. We currently do not have any intention to transfer and do not transfer your personal data to any third countries. However, sometimes we must transfer your personal data to other countries where lower-level data protection policies may be applied. In such cases, we do our best to ensure the security of the transferred personal data.

We hereby inform you that in very rare cases your personal data may be transferred or made available to entities operating both within and outside the European Economic Area (hereinafter – EEA). Please note that personal data outside the EEA may be subject to a lower level of protection than within the EEA; however, we will thoroughly evaluate the conditions under which such your data will be later processed and stored after the transfer to the above entities.

If we will send your personal data to countries outside the EEA, we will notify you and make sure to have one of the following security measures in place:

The agreement that is concluded with the recipient of the data would be based on the Standard Terms and Conditions approved by the European Commission;
The recipient of the data would be based in a country recognized by the European Commission as having adequate data protection standards;
Consent of the Lithuanian State Data Protection Inspectorate;
Use of codes of conduct or certification mechanisms.

If any of the above security measures are applied, we can use the exceptions provided in Article 49 of the GDPR (for example, transfer your data with your consent).

What do we do to protect your personal data?

We have implemented smart and appropriate physical and technical means to protect the information we collect in order to provide content/services. However, please note that, although we take appropriate measures to protect your personal data, not a single website, transaction through the internet, computer system or wireless communications is completely secure.

How long will we store your personal data?

We will keep your personal data for as long as necessary to achieve the stated purpose. Once we have achieved the purpose, your personal data will be deleted unless we are required by law to retain information or the data may be required for pre-trial investigation, but in any event, the retention period will not exceed 10 years. After this time limit expires, the data will be deleted so that it cannot be restored.

As a rule, the following personal data storage terms are established:

*Personal data*	*Storage period*
Data in the applications, statements and/or claims provided to us by phone, email or mail	Up to 2 years from the request/application/claim receipt or their execution
Data related to the conclusion and execution of transactions, contracts and other agreements	10 years after expiration/termination of a transaction, contract or agreement
Payment details	10 years after the transaction
Data related to registration forms	As long as you are registered on the Website, i.e. until you delete your account
Your data is related to the potential or existing protection of our interests in court or another institution	Until the claim limitation or the claim/complaint submission period expires and/or until the court decision comes into force
Personal data processed with your consent	Up to 2 years from receipt of your consent, unless it is revoked before
Records (logs) of IT systems	[please indicate]

Even if you declare your desire to terminate the contract, due to requirements that may arise in the future, we will need to continue to store some of your personal data until the storage period expires. The data will also be stored so that, if necessary, we can provide you with the necessary information/answer your questions related to our communication.

What are your rights?

Depending on the situation and additional conditions approved by GDPR you have the following rights:

The right to be informed;
The right to access;
The right to rectification;
The right to erasure;
The right to restrict;
The right to data portability;
The right to object;
The right to withdraw your consent.

We always strive to properly enforce your rights and respond promptly to any possible violation of them, so, if you have any questions, regarding your personal data that we process, we ask you to contact us first. We also note that, in all cases, you are entitled to file a complaint with the State Data Protection Inspectorate at any time.

We give you the opportunity to exercise your rights in a convenient way. You can do this by phone – +370 650 02277, email – info@distributioniot.com or using links listed at the bottom of the advertising content provided to you.

Your rights will be exercised subject to prior personal confirmation of your identity (subject to the provision of an identification document: an identification card or passport) or via electronic communication (for example, using an electronic signature).

*Your right*	*Some* *restrictions*
The right to be informed	Before the beginning of your personal data processing, you are entitled to receive concise, simple and understandable information about the collection and use of your personal data.There are a few circumstances when we do not need to provide you with privacy information, such as if you already have the information or if it would involve a disproportionate effort to provide it to you.
The right to access	This gives you the right to obtain a copy of your personal data as well as other supplementary information. It helps you to understand how and why we are using your data, and check that we are doing it lawfully. You have the right to obtain the following from us:– confirmation that we are processing your personal data; – a copy of your personal data; and – other supplementary information. We will provide the above information if it does not violate the rights and freedoms of others.
The right to rectification	This gives you the right to have inaccurate personal data rectified, or completed if it is incomplete.We can refuse to comply with your request if it is: – manifestly unfounded; or – excessive.
The right to erasure	You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. This right applies, if:– the personal data is no longer necessary for the purpose which we originally collected or processed it for; – we are relying on consent as our lawful basis for holding the data, and you withdraw your consent; – we are relying on legitimate interests as our basis for processing, however you object to the processing of your data, and there is no overriding legitimate interest to continue this processing; – we are processing the personal data for direct marketing purposes and you object to such processing; – we have processed the personal data unlawfully; – we have to do it to comply with a legal obligation; or – we have processed the personal data to offer information society services to a child.
The right to restrict processing	You have the right to restrict the processing of your personal data where you have a particular reason for wanting the restriction. This may be because you have issues with the content of the information we hold or how we have processed your data. In most cases we will not be required to restrict your personal data indefinitely, but we will need to have the restriction in place for a certain period of time. You have the right to request us restrict the processing of your personal data in the following circumstances:– you contest the accuracy of your personal data and we are verifying the accuracy of the data; – the data has been unlawfully processed and you oppose erasure and request restriction instead; – we no longer need the personal data but you need us to keep it in order to establish, exercise or defend a legal claim; or – you have objected to us processing your data under Article 21(1), and we are considering whether our legitimate grounds override those of yours.
The right to data portability	The right to data portability gives you the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format. It also gives you the right to request that we transmit this data directly to another controller.The right to data portability only applies when: – our lawful basis for processing this information is consent or for the performance of a contract; and – we are carrying out the processing by automated means (i.e. excluding paper files).
The right to object	This effectively allows you to stop or prevent us from processing your personal data.An objection may be in relation to all of the personal data we hold about you or only to certain information. It may also only relate to a particular purpose we are processing the data for. The right to object only applies in certain circumstances. Whether it applies depends on our purposes for processing and our lawful basis for processing. You have the absolute right to object to the processing of your personal data if it is for direct marketing purposes. You can also object if the processing is for: – a task carried out in the public interest; – the exercise of official authority vested in us; or – our legitimate interests (or those of a third party).
The right to withdraw consent	You can cancel your consent to the processing of your personal data at any time, if the processing is based on your consent.
The right to file a complaint with the State Data Protection Inspectorate	You have the right to contact the institution responsible for the supervision and control of legal acts regulating the personal data protection – the State Data Protection Inspectorate (A. Juozapavičiaus str., 6, 09310 Vilnius, email: ada@ada.lt, phone (8 5) 271 2804).More information available at: www.ada.lt

We may not create conditions for you to exercise the above rights when, in cases provided for by law, it is necessary to ensure the prevention of crimes, violations of professional or professional ethics, ensure the investigation progress and the criminal identification, as well as protect the rights and freedoms of the data subject and other persons.

Cookies, signals and similar technologies

Cookies are small informational elements that are stored in your browser. In the Privacy Policy, we use the term “cookies” to describe these elements and other similar technologies, such as Pixel Tags, Web Beacons, Clear GIFs. They help us:

To ensure efficient and safe functioning of the Website;
To understand, improve, and research products, features, and services, including when you access our Website from other websites, applications, or devices;
To recognize the returning visitors of the Website;
To analyse your habits so that the functioning of the Website would be convenient, efficient and would conform to your needs and expectations;
To measure the flows of the information and data being sent to our Website;
To target and advertise.

Cookies, thar are used on our Website:

_gatUpon the first visit to the website/
until the end of the sessionThis cookie is used by Google Analytics to collect statistical information about the website traffic.

*Category*	*Name*	*Duration*	*Purpose*
Strictly necessary cookies
Strictly necessary cookies
Preferences cookies
Preferences cookies
Statistics cookies	_ga	From the time of consent/ 2 years.	This cookie is used by Google Analytics to assess the purpose of the user’s visit, generate reports on the website activity to website operators, and improve user’s experience when browsing on the website.
Statistics cookies	_gat_gid	Upon the first visit to the website/ until the end of the sessionUpon the first visit to the website/ 2 days	This cookie is used by Google Analytics to collect statistical information about the website traffic. This cookie is used by Google Analytics to distinguish you from other users.
Marketing cookies
Marketing cookies

When you use a browser to access content that we provide, you can configure your browser to accept all cookies, reject all cookies, or to notify you when a cookie is downloaded. Each browser is different, therefore, if you don’t know how to change your cookie preferences, check out its Help menu. Your device’s operating system may have additional cookie controls. If you do not want that the information would be collected by cookies, use the simple procedure available in most browsers which allows you to opt out of cookies. In order to learn more about how to manage cookies, please visit http://www.allaboutcookies.org/manage-cookies/. Keep in mind, however, that certain services may be designed to work only with cookies, and if you disable them, you will no longer be able to use those cervices or certain parts of them.

In addition to cookies used by Data controller, our websites allow certain third parties to set and access cookies on your computer. In such case, the use of cookies is subject to third-party privacy rules.

Please note that our social network accounts are subject to the cookie policy of the respective social network.

External websites

The Website may have links to external websites. When using these links, pay attention to the fact that the websites and services accessible should have a separate privacy policy, so we recommend reviewing them in detail before providing any of your personal data.

Contact us

If you notice an inconsistency with this Privacy Policy, a security loophole on our Website, or have other questions regarding the processing of your personal data, please contact us in one of the ways convenient to you:

UAB Lematics

Legal entity code: 304460700

Registered address: Lvovo g. 25-702, LT-09320 Vilnius

Phone: +370 650 02277

Email: info@distributioniot.com

Final provisions

The Privacy Policy is reviewed and updated according to our needs, but at least every two years, or in case of changes in legal acts regulating the processing of personal data. By updating the Privacy Policy, we will notify you of the changes that we consider essential (by posting a notice on the Website or in a similar way).

By continuing to browse our Website, you hereby consent to this Privacy Policy.

The last review of this Privacy Policy was made on 19 August 2020.

UAB Lematics

Website: www.distributioniot.com

E-mail: info@distributioniot.com

Telephone: +370 650 02277

Address: Lvovo str. 25, LT-09320, Vilnius, Lithuania

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