We understand the special importance of the protection of your personal data, therefore we collect and process only those data of yours that are necessary for the performance of our activities. We process personal data lawfully, transparently and fairly, for predetermined purposes and only to the extent necessary to achieve the purposes. When processing personal data, we strive to keep it accurate, secure, confidential, properly stored and protected.

When processing your personal data, we comply with the General Personal Data Protection Regulation (hereinafter – GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as the personal data processing requirements set forth in other legal acts.

  1. WHAT IS THIS DOCUMENT?

1.1. This privacy policy (hereinafter – the Privacy Policy) sets out the privacy conditions for your use of the Website. In this Privacy Policy, the website www.holdsocks.com is referred to as “Website”.

1.2. Read this Privacy Policy to find out how we process your personal data, where we get it from and what your rights are as a subject of personal data.

1.3. If you use the Website, it means that you have read and familiarized yourself with this Privacy Policy and the purposes, methods and procedures for processing your personal data specified in it.

1.4. The term “personal data” used in this Privacy Policy is any information that can be used to identify you – directly or indirectly identify you. Personal data includes surname, first name, date of birth, postal or e-mail address. e-mail address, location data and Internet identifier, characteristics specific to you, etc.

1.5. The Privacy Policy applies to all persons who visit the Website, as well as to actions that you can perform on the Website.

  1. ABOUT US

2.1. The website is managed and administered by MB Inlista, company code 306153810, address Mainų st. 6, Klaipėda. If you have any questions, please contact us by e-mail. by mail hello@holdsocks.com

2.2. Based on the provisions of legal acts, we are the controller of your personal data.

  1. WHAT PRINCIPLES WE FOLLOW

3.1. When processing your personal data, we:

a) we will comply with the requirements of valid and applicable legal acts, including GDPR;

b) we will process your personal data in a legal, fair and transparent manner;

c) we will collect your personal data for established, clearly defined and legitimate purposes and will not continue to process them in a manner incompatible with those purposes, except to the extent permitted by legal acts;

d) we will take all reasonable measures to ensure that personal data that are not accurate or complete, taking into account the purposes of their processing, are immediately corrected, supplemented, suspended or destroyed;

e) we will keep them in such a form that your identity can be determined no longer than is necessary for the purposes for which the personal data is processed;

f) we will not provide personal data to third parties and will not disclose them, except for the cases specified in the Privacy Policy or applicable legal acts;

g) we will ensure that your personal data is processed in such a way that adequate security of personal data is ensured through the application of appropriate technical or organizational measures, including protection against unauthorized or unlawful data processing and against accidental loss, destruction or damage.

  1. HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1. We process your personal data obtained in the following ways:

A) when you provide personal data to us. You provide us with your personal data and other information by using the Site, writing to us or communicating with our customer service team by phone, email. by post or otherwise, submitting your complaints and/or enquiries, subscribing to our newsletter or otherwise;

B) when you use the Website. When you use the Website, certain information (for example, the type of Internet browser used, the number of visits to the Website, the pages of the Website viewed, etc.) is collected automatically;

C) when we receive your personal data from the legal acts of other persons and/or in accordance with the procedure established by this Privacy Policy.

4.2. We may combine the personal data received from you, which we received from you using the Website, with:

a) Your data, which we received from you using other websites managed and administered by us.

b) collected by us from other public or accessible sources (for example, we may combine the personal data you provide with data obtained using Site cookies or with data lawfully obtained from third parties).

  1. WHAT DATA WE PROCESS AND FOR WHAT PURPOSES

5.1. We process your personal data for the following purposes:

a) for the purpose of registration, identification and provision of services. You provide us with your personal data when you use the Website, register on it (create an account), place content you have created on the Website (e.g. post ads, their descriptions, photos of the goods or services you buy or sell, etc.). We also process your personal data when you register on the Website or use it as a representative and/or contact person of a legal entity. For this purpose, personal data is processed:

Data categories Name, surname, e-mail e-mail address, phone number, place of residence (city), IP address, other content created by you and uploaded to the Website (e.g. advertisement text, photo, comment, etc.)
Legal basis for data processing Agreement (Rules of Use)
Data processing term Up to 2 years from the day of the last login to your account
We receive data from you; from third parties
We provide or transfer data to users of the Website when a buyer and a seller seek to communicate with each other by phone and/or e-mail. by mail, through live chat (chat function) regarding advertisements placed on the Website; authentication service providers.
If you connect to the Website using third-party authentication tools or later link your account on the Website with accounts of third parties (e.g. Facebook, Google), these third parties will (i) transfer to us or (ii) receive from us certain personal data about you, as specified below:
• if you connect to the Site using Google, authentication services are provided to us by Google Ireland Limited; from it we receive your name, surname, profile picture, e-mail address, Google account identification number; in this case, you are additionally subject to the privacy policy of Google Ireland Limited, which describes in detail how this company handles your data;
• if you connect to the Site using Facebook, authentication services are provided to us by Facebook Ireland Ltd.; from it we receive your name, surname, profile picture, e-mail address, Google account identification number P; in this case, you are additionally subject to the privacy policy of Facebook Ireland Ltd, which describes in detail how this company handles your data;

b) for the purpose of providing paid services, controlling payments, accounting and settlements, debt management and debt collection. You provide us with your personal data when you order paid services from us on the Site. For this purpose, personal data is processed:

Data category Name, surname, data of a document confirming personal identity (e.g. passport, personal identity card), e. e-mail address, telephone number, VAT identification number, data on the provision of services (e.g. service start date, end date, duration, status, etc.), data on ordered and used services and their fees, invoice data and payments information (e.g. services provided, invoice date, number, amount due or paid), bank account number, invoice presentation and invoice payment method, payment date, payment status, data related to indebtedness (e.g. date of origination of debt, debts amount, type of debt, etc.)
Legal basis for data processing Agreement (Terms of Use and/or Service Provision Agreement)
Data processing term Up to 3 years from the date of receipt of payment for the service or after the expiration of the contract, whichever is later.
We receive data from you; from third parties: from your mobile operator, bank or electronic money institution where you have an account.
We provide or transfer data to your mobile operator, bank or electronic money institution where you have an account, we transfer data necessary for payment of the service when it is necessary to identify you as a user of the Website ordering a paid service on the Website; to debt collection companies that mediate our debt collection and only to the extent necessary to initiate and carry out debt collection.
c) for the purpose of quality assurance and communication. You provide us with your personal data by writing to us, e. by mail or by contacting our customer service team by phone, submitting your complaints, inquiries about the Site or the services we provide. For this purpose, personal data is processed:

Data categories Name, surname, e-mail postal address, telephone number, place of residence (address), content of the complaint and/or request submitted in writing (eg, date of the letter, content, etc.), e. by mail (e.g. e-mail date, content, etc.), by telephone (e.g. phone number, date, time and duration of the call, data provided during the call, etc.)
The legal basis for data processing is the Agreement (Terms of Use), as well as our legitimate interest in evaluating our customers’ feedback, in order to improve the quality of our activities and services.
Data processing term Up to 2 years from the date of submission of your inquiry to us, unless we process the data longer in order to resolve a mutual dispute or preserve its evidence.
We receive data from you; when executing a request or analyzing a complaint, we may create personal data ourselves (e.g. after receiving your complaint, we contact our employees about the actual circumstances of the complaint and record them, etc.); from third parties.
We provide or transfer data When executing a request or analyzing a complaint, we may transfer data to companies that provide us with legal advice, internet connection, payments or other services.
d) for direct marketing purposes. After receiving your consent and in order to provide you with newsletters, offers, including personal ones, and information about our services and/or goods of persons and partners related to us, or other information, while improving our services, we process your personal data. If you have given your consent to use your data for this purpose when registering on the Website or using it (e.g. when placing ads), we, in order to get to know you as well as possible and adapt offers according to your needs, to provide other benefits specially intended for you, will not only process you for this purpose identifying data, but we will additionally analyze your behavior on the Website, the history of data about service orders. For this purpose, we use automated data analysis and decision-making, including profiling, with the help of which, after grouping your identifying data and (or) data about the services ordered on the Website, your behavior on the Website, we can provide you with relevant, interesting and useful offers and other information. For this purpose, personal data is processed:

Data categories Telephone connection number, e. e-mail address, data about services ordered on the Website (e.g. date and time of services ordered, name of services, quantity, type of services ordered), history of personal offers provided to you and information about using them
Legal basis for data processing Your consent to receive newsletters, offers, including personal ones, and information
Data processing term Up to 2 years from the day of the last login to your account
We receive data from you, including your use of the Website.
We provide or transfer data to Information Business Management Systems companies.
Read more about the processing of personal data for the purpose of direct marketing in Chapter 6 of this Privacy Policy.

e) In order to ensure the website’s functionality, as well as to improve it, to offer you better and customized services. We use your personal data, including personal data and cookies that we receive when you use our Website, in order to improve and develop the Website and offer better and more tailored services to you.

For this purpose, we use personal data received from you, created by you using the Website and/or received from other persons.

Read more about how we use cookies and similar technologies in Section 7 of this Privacy Policy.

f) for other purposes provided for in our Personal Data Processing Rules and/or other internal documents, when we are required to process your personal data by legal acts or there is a legitimate interest.

5.2. We do not ask for or process your special categories of personal data that reveal your racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, as well as health data or data about your sex life and sexual orientation. In the event that you provide us with these data while using the Website or in another way (in writing, by e-mail, by phone), it will be considered that these data were provided with your consent. Accordingly, we will process this data of yours together with other data of yours that you have provided in 5.1 of the Privacy Policy. in the ways specified in point, if those data cannot be separated from each other or such separation would require disproportionately large efforts.

  1. IS YOUR DATA USED FOR DIRECT MARKETING PURPOSES?

6.1. With your additional consent, we may use your personal data for direct marketing purposes in order to provide you with newsletters, offers, including personal ones, and information about our services and/or goods of our affiliates and partners, which we believe may be of interest to you. to be interested However, we will use your personal data for this purpose only with your additional consent.

6.2. For this purpose, we process your personal data specified in 5.1 of the Privacy Policy. in clause (d).

6.3. You can choose whether you allow us to use your personal data for direct marketing purposes. You can do this:

a) in the “My information” section of the account, mark the consent text “Send news by e-mail” with a check mark. by mail” or without marking it.

b) when registering on the Website, placing an ad on it, mark the consent text “I want to receive nepemesk.lt newsletters” with a check mark or leave it unmarked;

6.4. By giving the right to process data for the purpose of direct marketing, you also give permission for us to contact you for this purpose by appropriate means of communication (e.g. e-mail or telephone)

6.5. We may combine the information we hold about you with information held by third parties.

6.6. If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyze and improve the effectiveness of our websites, advertising and market research, and for other company marketing and sales purposes. In this case, we will use your personalized data.

6.7. Even if you have given your consent to the processing of your personal data for direct marketing purposes, you can easily withdraw this consent at any time for all or part of the processing of your personal data. For this you can:

a) Change the settings in the section “My information” on the website, indicating that you no longer want your personal data to be used for direct marketing purposes, and remove the check mark from the item “Send news by e-mail”. by mail” or

b) notify the opt-out e. in the manner specified in newsletters, offers received by mail (e.g. by clicking on the “Unsubscribe” link in newsletters, offers, etc.) or

c) send us a request by e-mail. by mail hello@holdsocks.com. In the application, it is necessary to clearly indicate your name, surname and other registration data (if any). If you wish to withdraw your consent in this way, we may ask for proof of identity.

6.8. If you withdraw your consent, we will try to stop processing your personal data for direct marketing purposes as soon as possible.

6.9. Withdrawal of consent does not automatically oblige us to destroy your personal data or provide you with information about the personal data we process, therefore, in order for us to perform these actions as well, you must indicate such a request separately.

  1. HOW ARE COOKIES USED?

7.1. We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily saved on the hard drive of your device and allow you to be recognized during other visits to the Website, save personal browsing history, options, customize content, speed up searches on the Website, create a convenient and friendly environment on the Website, present it more efficiently and reliably. Cookies are a common web browsing practice that makes the website easier to use.

7.2. With cookies, we can collect the following information: IP address, type of Internet browser used, number of visits to the Site, pages of the Site viewed, time spent on the Site, demographic data and, if you came to the Site from a third-party website, the URL link of the page.

7.3. We use the information obtained through cookies for the following purposes:

a) to ensure the functionality of the Website (for example, so that you can use the personalization of the Website);

b) so that we can improve and develop the Website so that it meets your needs even better;

c) for the development of services and analysis of the use of the Website;

d) for targeted marketing guidance.

7.4. We may, without violating legal acts, combine information obtained using cookies with information obtained about you by other means (e.g. combine information about the use of the Website with personal data provided by you).

7.5. The website may use the following cookies:

a) technical cookies are cookies that are necessary for the operation of the Website;

b) functional cookies are cookies that, although not necessary for the operation of the Website, significantly improve its operation, quality and user experience;

c) analytical cookies are cookies that are used to prepare a statistical analysis of the website visitors’ navigation methods; the data collected by these cookies is used anonymously;

d) targeted or advertising cookies are cookies that are used to show you offers or other information that might be of interest to you;

e) Social network cookies are cookies that are necessary to use the Website information in your social profile account.

7.6. All information about the cookies used on the Website, their purpose, validity and the data used is presented in the table below:

7.7. You can give your consent to the use of cookies in the following ways:

a) not deleting them and/or changing the settings of your internet browser so that it does not accept cookies;

b) By clicking on the “I agree” tag in the link (bar) on the website about cookies.

7.8. You may revoke your consent to our use of cookies at any time by changing your web browser settings so that it does not accept cookies. How to do this depends on the operating system and internet browser you use.

7.9. In some cases, turning off technical and functional cookies in particular, refusing to accept cookies or deleting them can slow down the speed of Internet browsing, limit the operation of certain functions of the Website, block access to the Website.

  1. TO WHOM IS YOUR PERSONAL DATA PROVIDED?

8.1. We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without a legal basis, as well as used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy or applicable legislation. However, we reserve the right to provide information about you if we are required to do so in accordance with the law or if we are required to do so by lawfully operating law enforcement authorities or criminal prosecution authorities.

8.2. We may transfer your personal data to companies that help us carry out our activities, as well as direct marketing. From such partners, we require that your data be processed only in accordance with the instructions given by us and the valid legislation ensuring the protection of your data. We enter into contracts with these persons, which oblige the parties to strictly comply with the requirements for personal data protection.

8.3. We may disclose the data we collect about you to the following third parties:

a) to third-party service providers (such as technical service providers in the performance of our contracts with these service providers, including the performance of services for sending newsletters or performing other marketing activities);

b) to third party service providers whose services we generally use for data storage, telecommunications and website hosting purposes.

8.4. The above-mentioned service providers’ ability to use your data is limited – they cannot use this data for purposes other than providing services to us, with the exception of third parties – credit service providers who will process and use your data independently for the provision of credit services.

8.5. The (non-exhaustive) list of persons and their categories to whom we transfer your personal data is provided in 5.1 of this Privacy Policy. point separately for each purpose of using personal data.

  1. HOW LONG ARE PERSONAL DATA STORED?

9.1. We store your personal data for no longer than is required by the purposes of data processing or provided for by legal acts, if a longer data retention period is set in them.

9.2. We strive not to store outdated, irrelevant personal data, therefore only relevant information is stored after updating it. Historical information is stored if it is necessary in accordance with the procedure established by legislation or to carry out our activities.

9.3. Clause 5.1 of the privacy policy specifies the storage terms of your personal data separately for each purpose of using personal data.

  1. HOW ARE PERSONAL DATA STORED?

10.1. The data we collect from you will be in the territory of the European Union (EU), but may be transferred or stored outside the EU. They may also be processed by our or our suppliers’ personnel based outside the EU. When transferring your data outside the EU, we will take all necessary steps to ensure that your data is handled securely and in accordance with this Privacy Policy.

10.2. Unfortunately, the transmission of information over the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee data security when you transfer data to the Website – you assume the risks associated with the transfer of data to the Website. Once we receive your data, we will apply strict procedures and security measures to protect your data from unauthorized access.

10.3. If unlikely circumstances occur and we become aware of a security breach of your personal data that may pose a significant threat to your rights or freedoms, we will immediately inform you as soon as we learn about it and determine what information has been accessed.

  1. EXTERNAL SITES

11.1. The website may contain links to external websites – websites of our business partners or websites that advertise our services and/or goods. When following such links to any of the websites, please note that these websites and the services available through them have their own separate privacy policies and we are not responsible or liable for these policies or for any personal data collected on these websites or services, such as contact or location details. Please review these policies before submitting personal data to these websites or using any services.

  1. YOUR RIGHTS

12.1. When processing personal data, we ensure your rights in accordance with GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a subject of personal data, you have the following rights:

a) know (be informed) about the processing of your personal data;

b) access your personal data that we process;

c) demand correction or addition, clarification of incorrect, inaccurate or incomplete personal data;

d) require the destruction of personal data when they are no longer needed for the purposes for which they were collected;

e) require the destruction of personal data if they are processed illegally or when you withdraw your consent to the processing of personal data or do not give such consent, and it is necessary;

f) disagree with the processing of personal data or withdraw previously given consent;

g) demand the suspension (except for storage) of the processing of your personal data, if there are disputes or it is necessary to check the legality of data processing, the accuracy of the data, as well as in cases where we no longer need your personal data, but you do not want us to destroy them;

h) demand to provide, if it is technically possible, your personal data collected with your consent or for the purposes of contract performance in an easy-to-read format or to request that they be forwarded to another data controller.

12.2. We will try to guarantee the implementation of your rights as a subject of personal data and create all the conditions for the effective implementation of these rights, but we reserve the right not to fulfill your requirements when it is necessary to ensure:

a) performance of legal obligations imposed on us;

b) state security or defense;

c) public order, prevention, investigation, detection or prosecution of criminal acts;

d) important economic or financial interests of the state;

e) prevention, investigation and determination of violations of official or professional ethics;

f) Protection of your or other persons’ rights and freedoms.

12.3. You can submit requirements related to the exercise of your rights to us in person, by mail or by electronic means of communication. After receiving your application, we may ask you to provide proof of identity, as well as other additional information we need related to the application.

12.4. Upon receipt of your request, we will respond to you no later than within 30 calendar days from the date of receipt of your request and submission of all documents required for the response.

12.5. If we deem it necessary, we will stop processing your data, except for storage, until your request is resolved. If you legally withdraw your consent, we will immediately, but no later than within 30 calendar days, stop the processing of your personal data, except for the cases established in clause 12.2 of this Privacy Policy and legal acts, i.e. i.e. when we are required to continue processing your data by valid legal acts, legal obligations falling on us, court decisions or mandatory instructions given to us by the authorities.

12.6. If we refuse to comply with your request, we will clearly indicate the reason for such refusal.

12.7. If you do not agree with our actions or the response to your request, you can complain about our actions and decisions to a competent state institution.

  1. PRIVACY POLICY CORRECTIONS

13.1. Any changes to our Privacy Policy will be posted on the Site. If necessary, we will inform you about them. New Privacy Policy terms may also be posted on the Website and you may need to read and familiarize yourself with them in order to continue using the Website and/or our services.

  1. CONTACT INFORMATION

15.1. Please send all documents related to this Privacy Policy or contact us at the following contacts:

When sending e-mail by mail – hello@holdsocks.com