1. General provisions

1.1. Personal data manager (hereinafter - "Negotiator") - Ltd „Baltic commerce“, company code 302618347, registered office address Algirdo str. 53, Vilnius, phone no. +370 633 42244. The online store managed by Negotiator

1.2. The following privacy policy and personal data rules target (hereinafter - Rules) - regulate and clearly define the collection, processing and storage of personal data by the Negotiator.

1.3. Purpose of the rules - provide for basic rules for the collection, storage and processing of personal data, technical and organizational measures for the implementation of the rights of the data subject, in order to secure the Republic of Lithuania Law of personal data data protection law, General Data Protection Regulation (ES) 2016/679 (hereinafter – Regulation (ES) 2016/679) and other laws and legislation providing for protection of personal data, compliance and implementation.

1.4. These Rules must be observed by the employees of the Negotiator Company,, who manages personal data acquired by the Negotiator or learns personal data while performing certain functions.

1.5. The data subject is considered to be familiar with these Rules and read them when they express their consent to process their personal data.

2. Personal data processing objectives

2.1. An Negotiator manages personal data for the following purposes:

2.1.1. Negotiator managed e-shops visitors registration on the website and identification of sign-ups of visitors to enable online shopping to purchase gift vouchers online.

2.1.2. For customer service purposes, to enable online shopping to purchase online gift vouchers for registration and identification purposes.

2.1.3. In order to give a discount and in order to prevent the illegal discounts acquisition.

2.1.4. For direct marketing purposes, in order to offer the Negotiator’s customers and online store visitors or inform them of the Negotiator (single or together with its partners) provided services, announcements of shares and discounts, to greet the Negotiator’s and its web page visitors and customers for state and personal occasions for both the Mediator and the client.

2.1.5. Customer loyalty programs development, in order to offer the opportunity for the visitors and customers of the Negotiator’s e-shop to participate in organized lotteries, promotions and games, to offer special offers for regular visitors/customers as well as provide additional discounts.

2.1.6. For customer service purposes, to provide the opportunity to purchase gift vouchers from partners who distribute them on the basis of cooperation agreements.

2.2. Negotiator collects personal data only by the legislation and following these Rules. Negotiator only with the prior consent of the subject's personal data, manages personal data for direct marketing purposes.

2.3. The processing of personal data of workers employed Negotiator company, comply with the principles and conditions set out in this section.

3. Personal data sources

3.1. The Negotiator collects personal data from the following sources:

3.1.1. Personal data, which are indicated in clause 2.1.1 of these Rules, are obtained directly from the personal data subject when the person sign up in the Negotiator’s e-shop and creates an individual user account.

3.1.2.Personal data, which are indicated in clause 2.1.2 of these Rules are obtained directly from the personal data subject when the person makes a purchase in the e-store managed by the Negotiator and, at the time of purchase, provides information and agrees with its further use.

3.1.3 The personal data specified in clause 2.1.6 of these Rules is obtained from gift voucher distributors on the basis of cooperation agreements, when the data subject arrives to official distributor to purchase a gift voucher.

3.1.4. Personal data, which are specified in clauses 2.1.3, 2.1.4 of these Rules. and 2.1.5 received directly from the personal data subject when making a purchase at the Negotiator’s e-shop by registering and entering the relevant information on the Negotiator’s website or by contacting the Negotiator in any other way and providing relevant information at the time of the Negotiator’s service.  

3.1.5. Negotiator has the right to receive personal data from other providers of personal data (including the receipt of personal data from the companies concerned according to concluded contracts for the provision of personal data) in compliance with the Law on the Legal Protection of Personal Data of the Republic of Lithuaniaand other laws and legal acts regulating the processing of personal data.

3.2. The Negotiator does not accumulate or manage excess personal data,  compliance with expediency, fairness and proportionality of the processing of personal data.

3.3. The Negotiator for the purposes of the Rules in 2.1.1. and 2.1.2, 2.1.3, 2.1.4, 2.1.5. and 2.1.6. collect and manages: name, telephone number, e-mail address and IP address. Also collect address information and loyalty card data, according to which the customer can receive a discount.

3.4. Negotiator can additionally collect and manage the following personal data: telephone number, e-mail, address, name, purchase history, and hobbies.

3.5. The Negotiator may also process other personal data without prejudice the Republic of Lithuania Law on Legal Protection of Personal Data and other laws and legal acts regulating the processing of personal data.

3.6. An online store can only be used by people over the age of 16. Persons under 16 years old may only provide personal data with the consent of their parents or guardians. Parents or guardian who found out that their minor children use an online store, and parents or guardians do not agree with it, they can submit an e-mail request and all related data will be deleted.

4. Processing, storage and terms of personal data

4.1. Negotiator handles personal data accurately, fairly and legally. Negotiator handles personal data when they need to keep a legitimate interest, by Negotiator or the third person, which is legally provided with personal data, and if in some cases, the interests of the data subject are not more important.

4.2. Negotiator managing personal data complies with the Law on Legal Protection of Personal Data of the Republic of Lithuania, the General Data Protection Regulation (EU) 2016/679 and these rules and internal legal acts. The customer has the right to believe that his personal data is being processed incorrectly, has the right to submit a complaint to the State Data Protection Inspectorate.

4.3. The personal data are accurate and can be updated if necessary. Personal details are updated and refined after data subject informs about the changes by email or by phone. Registered users can modify personal data in their user account.

4.4. Personal data is stored in such a way as to identify the identity of the subject, when it is necessary for the purposes for which the data were collected and processed.

4.5. The personal data at the Negotiator’s company employees are managed by only those employees to whom the data necessary to perform job functions:

4.5.1. Persons responsible for marketing activities.

4.5.2. Persons responsible for direct communication with customers.

4.5.3. Persons responsible for maintaining information technology.

4.5.4. Individuals responsible for conflict management and handling claims made by clients or visitors to the site.

4.6. The Negotiator’s authorized persons and the manager ensures compliance with the basic data protection principles. When necessary, these individuals take appropriate measures, such as orders and recommendations, to ensure compliance with the employees' existing obligations.

4.7. Data subjects are guaranteed the right to know about the processing of their personal data, get acquainted with personal data stored, for what purposes they are processed, to whom they are given, and implement other rights provided by the Law on Legal Protection of Personal Data in the Republic of Lithuania, the General Data Protection Regulation (EU) 2016/679 and other legal acts.

4.8. The mediator shall take all necessary measures to enable the data subject to exercise their rights with regard to the data stored. The data subject, who has submitted the application and the identity document, has the right to access his personal data which is stored by the Negotiator and how the data is processed. Personal data are submitted to the data subject no later than within 30 calendar days from the date of submission of the request by the data subject. For the preparation of data, in accordance with the Law on the legal protection of personal data in the Republic of Lithuania, the General Data Protection Regulation (EU) 2016/679, may be charged a fee.

4.9. Negotiator shall ensure that all necessary information to the data subject would be provided in a clear and understandable language, normally used in a computer readable format.

4.10 The data subject has the right to demand rectification or destruction and to suspend its processing of personal data. The data subject's right of the Republic of Lithuania is realized Personal Data Protection Act, the General Data Protection Regulation (EU) 2016/679 and other legal acts.

4.11 Individuals, who give incorrect, false or misleading information,are responsible for this in accordance with the law of the Republic of Lithuania. The Negotiator does not check and has no obligation to verify the veracity and accuracy of the data provided by individuals on its own initiative.

4.12. In the cases provided by law, the Intermediary may provide personal data processed to third parties.

4.13 Persons responsible for the processing of data are appointed on the order of the head of the Negotiator’s company. Personal data is stored on an electronic media by the creation of Negotiator customers, managed e-shop visitors or in points 3.1.1-3.1.5. acquired personal data subject's personal data base.

4.14. The Negotiator’s database stores personal data for 5 years from the last visit of the data subject to the e-store managed by the Negotiator, if the client has been identified during the visit.

4.15. The personal data, which is received in points 2.1.3 and 2.1.6, is provided by these Rules is kept for 5 years from the date of submission of data or of the last data updating .

4.16. The main groups of data recipients are delivery companies (UAB Venipak, UAB Omniva, AB Lietuvos paštas and others) and accounting companies.

5.  Personal data security

5.1. The Negotiator ensures the implementation of appropriate administrative and technical measures to protect personal data against unauthorized copying, deletion, modification, disclosure or other unlawful activities with personal data.

5.2. The mediator ensures that all employees who work with personal data are familiar with these Rules. The Negotiator authorized employees who work with personal data are required to keep all personal data information confidential, except where the laws or regulations determine the disclosure of the relevant information. The confidentiality principle is also applied upon termination of the Negotiator’s employment relationship with the employee.

5.3. Employees who work with personal data, as well as employees whose computers have personal data stored or have access to personal data, use passwords. These devices limit access to data, requiring a re-entry of a password after a certain amount of inactivity.

5.4. An Negotiator’s e-shop works in such a way as to limit the access to stored personal data to publicly accessible search engines.

6. Cookies

6.1. In order to provide the complete online store, the Negotiator can install the Cookies on the website of the visitor's computer or other device.

6.2. Cookies are used to identify the visitor / buyer, store information about items stored in a shopping cart, store website statistics, and more.

6.3. Social network cookies are intended to provide potentially interesting products for the visitor. Navigation cookies provide easy browsing on the website and provide access to secure e-shop areas. Promotional cookies are intended to remind visitors about potentially interesting products from visited e-shop, so these cookies allow to see banners on other pages. Functional cookies can store items in the shopping cart so that the next time visitor enter the page, he can continue shopping.

6.4. Negotiator’s e-shop users can review any cookies, that are used, at any time delete some or all of the cookies stored on the device. After deleting cookies some website functions may not be available. It is recommended to leave cookies turned on for full use of the online store. The cookie can be canceled by the user at any time by changing the settings of the used web browser.

7. Final provisions

7.1. These Rules come into force on 17th April 2018. Any changes to the Rules will be notified in 1.5 point prescribed procedure.