We receive and process your personal data from you when you post certain information on our social media accounts (e.g. comments, messages, etc.). This means that we are the processor of your personal data.
We will process all your personal data in accordance with the European Union’s General Data Protection Regulation No. 2016/679 and other legal provisions.
1. Data controllers:
1) Novian group company that manages an appropriate social media account (Facebook, LinkedIn, Youtube) and whose details are listed in the account’s contact information (Data Protection Officer’s e-mail address: firstname.lastname@example.org)
2) social media platform operators: Facebook Int., Linkedin, Youtube.
In certain cases of data processing, together with platform operators we, i.e. the Novian group or a specific Novian group company, act as joint controllers in accordance with Article 26 of the General Data Protection Regulation (GDPR).
2. Liability of Platform Operators
We can make only limited influence on the processing of data by operators of social media platforms, such as administration of members and posting of information. Where we can make influence and set data processing parameters, we oversee, to the extent we can, that processing by a social media platform operator is carried out in a manner that is conducive to the protection of privacy. However, in many cases we cannot influence the processing of data by a social media platform operator and we do not know what data it processes.
A platform operator administers the whole IT infrastructure, sets its own data protection rules and maintains the relationship it has built with you as a user (if you are a registered user of a social media account). In addition, only the operator of the platform is responsible for your account data as a user to which we do not have access.
3. Personal data
You can post comments on our social media accounts and send us messages. Our account records your data – the name of the account from which we make the comment/message, the content of the comment/message, the time of submission.
4. Purpose and legal ground for processing
The purpose of our processing of data within our created and registered accounts is to inform potential and existing customers about offers, products, services, IT news and to communicate with our account visitors on these topics, answer their questions, respond to positive feedback, criticism, and organise marketing games as well as to improve (optimise) the performance of the account. The legal ground for this is Article 6(1)(f) of the GDPR, i. e. our legitimate interest or that of third parties, i.e. keeping you informed about your services, products and related communications, and optimising the performance of your account. It is also important for us to process communication data in order to protect ourselves from potential legal disputes, and therefore the legal basis for processing the data is also our legitimate interest in order to protect ourselves from potential legal disputes or claims by visitors to our accounts.
We reserve the right to delete comments if it proves to be necessary in accordance with the law or our internal policies. For example, is posts that are infringing or illegal, hate comments, obscene (sexually explicitly content) or profane reviews or attachments (e.g. photos or videos) which, inter alia, infringe copyright, personal rights of individuals, provisions of the legal acts or Novian principles of ethical conduct. If necessary, we will contact you via the social media platform.
5. Principles of data processing
We ensure that we use the personal data you post in accordance with applicable legal requirements, including but not limited to:
– Your personal data will be processed in accordance with the principles of lawfulness, fairness and transparency;
– Your personal data will be retained only for as long as necessary to achieve the purposes disclosed to you (or as long as we are required by applicable law);
– Your personal data will be used with an adequate level of security.
6. Data recipients / categories of data recipients
Our social media accounts are public, so the content of your comments is visible to other visitors to our accounts. For this reason, we advise you not to post any addresses, e-mail addresses, or other private information, either your own or that of others.
Please note that the content of some social media networks may also be shared directly on publicly available websites (e. g. in a questionnaire or comments), so other users may also see the fact of your involvement from your interactions with us. For example, in such cases, your win in a game can also be seen from social media posts. If you have registered with your real name on a social media network or you can be identified from photos in your account, it cannot be excluded that you will be identified by other visitors to our account.
Data is transferred to third parties (e. g. other companies within the Novian group) only if doing so is necessary to answer your question.
We normally do not transfer data that you transmit to us through confidential channels (e. g. personal message, letter or e-mail) to third parties not related to the Novian group.
Upon your request, we can send you free of charge the current list of our partners who are recipients of your data.
7. Data Retention
We delete or make completely anonymous all personal information that you send us in secure messages to make queries (when you make suggestions, give positive feedback or criticism) no later than 90 days after we give our final reply to you.
All of your public posts in our accounts and in our timeline remain for indefinite time unless we delete them if the main topic has been updated, the posts are in breach of law or these posts have been deleted by you.
We cannot make influence in the cases where your data is deleted by the platform operator itself. In this context, data protection rules of each individual platform operator are applied.
8. Joint data controllers under GDPR Article 26(1)
Certain relationships with a social media platform operator are subject to Article 26(1) of the GDPR (Joint Controllers).
When a social media platform operator applies user tracking methods, the platform operator and we act as joint data controllers. User tracking can be implemented regardless of whether or not you are registered on the social media platform. The legal ground for the use of web tracking methods is Article 6(1)(f) of the GDPR (legitimate interest). In accordance with the above provision, we have a legitimate interest to optimise the operation of the social media platform and the relevant account.
For more information about options available to you in order to exercise your rights to prohibit the use of tracking methods please read the privacy policies of platform operators.
We can only partially influence or disable the statistics provided to us by a social media platform operator but we monitor that the data we receive is not redundant.
Importantly, it cannot be excluded that a social media platform operator uses your account and behavioural data, for example, to analyse your habits, personal relationships, hobbies, etc. In this respect, Novian cannot influence the processing of your data by the social media platform operator.
9. Rights you have as a data subject
You have the following rights:
- Access your data and be informed how they are processed (right of access);
- Request rectification of personal data or, taking into account the purposes of the processing of personal data, have incomplete personal data completed (right to rectification);
- Obtain the erasure of your data (except storage) (right to erasure and ‘right to be forgotten’);
- Request that the data controller restrict the processing of personal data (right to restriction of processing);
- Exercise the right to data portability (right to data portability);
- Where the processing in based on the ground of a legitimate interest or based on your consent, object to the processing or, if your consent has been given, withdraw your consent at any time;
- Lodge a complaint with the State Data Protection Inspectorate.
You can exercise your rights as a data subject by contacting us using the details set out in this policy above.
Novian is the controller of all rights to the content of our accounts and the data contained in the accounts. Any modification, processing or copying of the content of our accounts by third parties without the written permission of Novian is an infringement of copyright and will be subject to liability under the laws of the Republic of Lithuania. This restriction does not apply to the publishers of advertisements, comments, messages in relation to their advertisements, comments, messages.
Revised: 22nd of August, 2023.