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    Privacy Policy

    This Privacy Policy (hereinafter – the Policy) details how the NOVIAN group of companies (hereinafter – the NOVIAN Group) processes personal data and how cookies are used on its companies’ websites and self-service portals. It also describes the basic rights of a Data Subject which are enshrined in data protection legislation.

    This Policy applies to the mutual relations of the NOVIAN Group and persons who use, have used or have expressed the intention to use, or who are in any way associated with, the services and/or activities of the NOVIAN Group.

    The NOVIAN Group shall ensure the confidentiality of personal data in keeping with the requirements of applicable legislation and the implementation of appropriate technical and organizational measures to protect personal data from unlawful access, disclosure, accidental loss, alteration or destruction, or other unlawful processing.

    In processing personal data, the NOVIAN Group shall abide by the General Data Protection Regulation, the Law on Legal Protection of Personal Data, and other legal acts regulating this area.

    Note that in the future this Policy may be modified in light of changes to legislation or NOVIAN Group activities, hence its periodic review is encouraged.

    1. DEFINITIONS

    A Personal Data Subject (hereinafter – Data Subject) in the NOVIAN Group is a natural person (who uses, has used or has expressed the intention to use services provided by the NOVIAN Group.

    The NOVIAN Group (hereinafter – NOVIAN) is any company belonging to the NOVIAN Group that acts as a Personal Data Controller. In the context of this Policy, NOVIAN may refer to UAB NOVIAN, UAB Novian Technologies, UAB Novian Systems,  Zissor AS, Andmevara AS, Andmevara Services OU, Andmevara SRL or all of these companies together.

    A Personal Data Controller is a company belonging to the NOVIAN Group whose services you use, have used or have expressed the intention of using or with whose activities you are associated. The list of NOVIAN companies and their contact details are published on the website novian.io.

    A Personal Data Processor is a natural or legal person who processes personal data in the name of or on behalf of a Personal Data Controller.

    Personal Data is any information relating to a natural person (Data Subject) whose identity is known or can be directly or indirectly established by use of such data as a personal identification number or one or more factors specific to the physical, physiological, psychological, economic, cultural or social identity of that person.

    Personal Data Processing is any action performed with personal data: collection, recording, storage, classification, grouping, combination, alteration, provision, publication, use, logical and/or arithmetic operations, search, dissemination, destruction, or another action or set of actions.

    The General Data Protection Regulation (hereinafter – GDPR) is Regulation (EU) 2016/679 of the European Parliament and 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. Other terms used in the Policy are understood as they are defined in the GDPR and other legal acts.

    2. CATEGORIES OF PERSONAL DATA

    Depending on the services or products which a Data Subject intends to use or does use, NOVIAN processes different categories of personal data. Personal data may be obtained directly from a Data Subject, from activities of the Data Subject in using services or NOVIAN websites, and from external sources such as registers and other third parties (for example, the State Social Insurance Fund Board, registers of debtors and legal persons when the Data Subject is a shareholder, etc.), if NOVIAN has the consent of the Data Subject or legal acts authorise that.
    If a Data Subject does not agree to provide their personal data, provision of NOVIAN services to them may be refused.
    If a Data Subject provides NOVIAN with data of other persons associated with them, the Data Subject must obtain those persons’ consent and acquaint them with this Policy.

    2.1 Main personal data categories

    The main categories of personal data include but are not limited to:
    • Personal identity data, such as name, surname, personal code, date of birth, and personal identity document data;
    • Contact details, such as address, telephone number and e-mail;
    • Data regarding education and professional activities;
    • Financial data, such as data regarding property, income and obligations;
    • Bank account data;
    • Data related to the provision of services and to the customers’ satisfaction with them, such as data regarding the performance or non-performance of agreements, agreements entered into, agreements which are in effect or have expired, requests submitted, declarations made, and a Data Subject’s feedback regarding services;
    • Data collected using means of communication or other technical means, such as video surveillance data, data collected while interacting by telephone or e-mail, and data related to a Data Subject’s visit to NOVIAN websites or use of self-service portals (for example, IP address, log-in details, website visit history, etc.).
    • Data obtained in fulfilling the requirements of legal acts, such as data obtained through inquiries made by notary publics, tax authorities, courts or debt collectors;
    • Data regarding legal representatives (acting under a power of attorney or on some other basis);
    • Data regarding ties to legal persons, such as a legal person’s head, shareholder, member of the board or other governance body, true beneficiary, or similar data needed for purposes of executing a transaction in the name of a legal person.

    3. PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA

    The basis for NOVIAN’s processing of personal data may be the performance of agreements made with a Data Subject or the intention to enter into an agreement, a Data Subject’s consent to the processing of their personal data for a specific purpose, or the fulfilment of obligations applicable to NOVIAN by law. NOVIAN may also process personal data based on the concept of legitimate interest (to strengthen IT security, for example) when it has met the requirements established by the GDPR. Under the conditions set out in the applicable legislation, one or more of the above specified legal bases may be adopted for the processing of the same personal data of a Data Subject.

    NOVIAN may process a Data Subject’s data for the following purposes (including but not limited to cases where separate consent of the Data Subject is obtained for processing the data):

    • In order to provide NOVIAN’s services and for other activities, including risk assessment, as foreseen in the legal acts applicable to NOVIAN’s activities;
    • In order to inform the Data Subject about the processing of their services, sales-purchases and securities, and about other agreements with NOVIAN;
    • In order to inform the Data Subject about NOVIAN’s services;
    • In order to obtain information from the Data Subject regarding NOVIAN’s services;
    • To ensure the security of NOVIAN and Data Subjects and their assets through video surveillance;
    • To assess the execution and performance of NOVIAN’s agreements and the quality of services provided by NOVIAN (for example, by recording phone calls), to request an opinion about services provided and their quality, to conduct market research, and to organise contests and campaigns for Data Subjects;
    • To analyse and forecast the Data Subject’s habits and needs and ongoing operations with regard to NOVIAN’s services in order to ensure provision of optimal service to the Data Subject and make personalised offers;
    • To perform legal obligations.
    • For the protection, maintenance and improvement of technical equipment and IT infrastructure by taking measures to prevent the abuse of services and by seeking to ensure appropriate provision of services;
    • For other lawful purposes, as set out in legal acts.

    4. RIGHTS OF A DATA SUBJECT

    A Data Subject has the right guaranteed by data protection legislation to ask that a Personal Data Controller, after confirming the Data Subject’s personal identity, do the following:

    • provide information on whether it processes personal data of the Data Subject and, if it does, to acquaint the Data Subject with the personal data of theirs which is processed, and to inform them what personal data of theirs is obtained from what sources for what purpose and how it is processed (including automated decision-making and its significance and consequences for the Data Subject), how long it is stored, and to whom it is provided (the right to get acquainted with one’s own personal data);
    • rectify or correct incorrect, incomplete or inaccurate personal data of the Data Subject (the right to demand the rectification of personal data)
    • under certain circumstances specified in the GDPR (when personal data have been processed unlawfully, the basis for processing the data has disappeared, and so on), to erase the Data Subject’s personal data (the right to demand the erasure of personal data – “the right to be forgotten”);
    • under certain circumstances specified in the GDPR (when personal data have been processed unlawfully, while a request of the Data Subject’s regarding the accuracy or processing of data is being considered, etc.), to restrict the processing of the Data Subject’s personal data, except for its storage (the right to restrict the processing of personal data);
    • provide in writing or in a commonly used electronic form personal data that the Data Subject has provided to the Personal Data Controller which is processed by automated means on the basis of that person’s consent or performance of an agreement, and, if possible, transfer such data to another service provider (the right to personal data portability).

    When NOVIAN processes a Data Subject’s personal data on the basis of their consent, the Data Subject has the right to withdraw the consent they have given at any time and the data processing based on that consent will be halted immediately. Note that when consent is withdrawn, it may be that NOVIAN will be unable to offer the Data Subject certain services or products but will continue to use personal data of the Data Subject, for example, to perform an agreement entered into with the Data Subject or if that is required by law.

    A Data Subject has the right at any time to object to:

    • the processing of their personal data, undertaking to present their legally grounded objection to the Personal Data Controller in writing or in another way by which the Data Subject’s identity can be established, if the basis for processing the personal data is the Personal Data Controller’s legitimate interests;
    • the processing of their personal data for purposes of direct marketing (including related profiling) and has the right to not give a reason for that objection;
    • being subject to a decision based solely on automated processing, including profiling, which has legal effects in their regard or similarly significantly affects the Data Subject. This right shall not apply if such decision making is necessary for entering into or performing an agreement with the Data Subject, is authorised by applicable legislation, or is based on the explicit consent of the Data Subject.
    A Data Subject has the right to present a complaint regarding processing of personal data to the State Data Protection Inspectorate (address L. Sapiegos St. 17, 10312 Vilnius, Lithuania; website https://vdai.lrv.lt/) if the Data Subject thinks their personal data is being processed in violation of their rights and lawful interests under the applicable legislation. We kindly request that issues which arise be addressed first of all to NOVIAN, so that we can resolve them as quickly as possible.

    5. PROCEDURE FOR HANDLING REQUESTS REGARDING EXERCISE OF A DATA SUBJECT’S RIGHTS

    A Data Subject must present any request to exercise the specified rights to their Personal Data Controller (see section 1, “DEFINITIONS”). Contact data for NOVIAN’s companies is published on the website novian.io.

    To protect against any disclosure of personal data processed by NOVIAN to persons without the right to receive it, when a request to provide data or exercise other rights is received from a Data Subject, first of all that person’s identity shall be established. If the identity verification process is successful, NOVIAN undertakes, without undue delay but never later than within one month of receiving the Data Subject’s request, to provide information about actions taken with regard to the request submitted by the Data Subject. In light of a request’s complexity or if a Data Subject submits several requests, NOVIAN shall have the right to extend the one-month period by two more months, informing the Data Subject about that by the end of the first month and specifying the reason for the extension.

    A Data Subject is not required to pay any fee to obtain information about their processed personal data (or to exercise any other rights). NOVIAN may, however, charge a reasonable fee if a Data Subject’s request is clearly unfounded, submitted repeatedly or disproportionate.

    6. RECIPIENTS OF PERSONAL DATA

    A Personal Data Controller may disclose/transmit a Data Subject’s personal data for processing to the following third parties, including but not limited to parties which assist the Personal Data Controller in performing and administering the provision of services:

    • companies which provide information technology services (in order to ensure the maintenance, improvement and upgrading of information systems);
    • companies which provide website administration and related services;
    • companies which provide document storage and archiving services;
    • companies which provide postal services (for sending reports and other notifications to a Data Subject);
    • auditors;
    • companies that belong to INVL Technology (with the Data Subject’s consent or if authorised by applicable legislation);
    • legal, tax and other consultants, the acquisition and/or provision of whose services NOVIAN intermediates according to the terms of agreements entered into by NOVIAN and the Data Subject;
    • debtor registers, which accumulate information about missed payments, and debt collection companies;
    • providers of call centre services, if NOVIAN retains such companies;
    • companies retained by NOVIAN which provide services of assessing the quality of services provided by NOVIAN (including the collection of opinions about services, customer service and their quality), market research, and the organisation of games and campaigns for Data Subjects;
    • other third parties retained by NOVIAN which help NOVIAN provide the Services and fulfil obligations arising under applicable laws and other legal acts.
    Data are also provided to:
    • state institutions and other persons performing functions entrusted to them by the law (for example, law enforcement bodies, bailiffs, notaries public);
    • the State Tax Inspectorate, in order to implement the Agreement between the Governments of the Republic of Lithuania and the United States of America to Improve International Tax Compliance and to Implement the Foreign Account Tax Compliance Act as well as other international obligations of the Republic of Lithuania in this area;
    • The State Social Insurance Fund Board.
    NOVIAN commits to take the necessary measures and endeavour that other persons to whom personal data may be provided, also process personal data in keeping with NOVIAN’s indications and the applicable legislation, and implement appropriate personal data protection measures.

    7. PERSONAL DATA RETENTION PERIOD

    Personal data shall be processed no longer than is necessary to fulfil the purposes of the data’s processing. Retention periods for personal data shall be defined in internal legal acts in light of the nature of agreements with a Data Subject, NOVIAN’s legitimate interests and requirements of the law (for example, accounting and anti-money laundering requirements, the statute of limitations for a claim, etc.).

    As a general rule, NOVIAN processes personal data collected in providing services for as long as the Data Subject uses NOVIAN’s services, and retains the data for 10 years after the Data Subject stops using those services.

    For the purpose of inquiring about a customer’s experience using NOVIAN services, a Data Subject’s personal data (name, surname, e-mail address, telephone number) shall be processed for 2 months after the end of business relations with the customer. A Data Subject has the right at any time to not consent to the processing of their personal data, as set out above.

    If a Data Subject uses contact forms on NOVIAN companies’ websites to submit queries, information provided in those forms, including the Data Subject’s contact details, will be retained until the query is addressed, and no longer than for 1 year after the query is submitted, unless a longer retention period is lawfully permitted for other reasons.

    If a Data Subject uses contact forms on NOVIAN companies’ websites to submit queries and provides an agreement to process data for marketing purposes, information provided in those forms, including the Data Subject’s contact details, will be retained until the query is addressed, and no longer than for 1 year after the query is submitted, unless a longer retention period is lawfully permitted for other reasons.

    If the Data Subject submits his / her data for employment in one of the companies of NOVIAN not applying for a specific position,this data is stored for one year and can be used to search for vacancies in the companies of the Novian Group.

    If a Data Subject submits data of theirs while seeking employment at one of the Novian group’s companies and applying for a specific position and does not give consent for longer storage of the data, that data shall be stored until the end of the hiring process.

    If a Data Subject submits data of theirs while seeking employment at one of the Novian group’s companies and applying for a specific position and gives consent for use of the data in seeking candidates for other positions, the data shall be stored for one year and may be used in seeking candidates for open positions at companies of the Novian group.

    If a Data Subject registers to participate in an event and submits data related to that registration, they shall be processed only for purposes related to informing about the event. If the person also gives consent for the processing of the data on a marketing basis, such data of theirs may be processed for one year from the time the consent was given, unless storage for a longer period is lawfully permitted for other reasons.

    To revoke consent which has been given to process a Data Subject’s data, the Data Subject should write to the e-mail address dap@novian.lt and specify the data whose processing they wish to cancel.

    8. GEOGRAPHICAL TERRITORY OF PROCESSING

    NOVIAN generally processes a Data Subject’s personal data only within the territory of the European Union/European Economic Area (EU/EEA), though in certain cases personal data may also be transmitted beyond the limits of the EU/EEA, for example when that is necessary for entering into or performing an agreement or if the Data Subject’s consent for such transmission is given. Personal data is transmitted beyond the limits of the EU/EEA only if suitable security measures have been implemented.

    9. AUTOMATED DECISION-MAKING

    In seeking to ensure the most appropriate service for a Data Subject and to provide marketing offers suited to the Data Subject’s needs and in improving the quality of the services NOVIAN provides, NOVIAN may use automated means to analyse a Data Subject’s personal data, including information about their use of services and behaviour on NOVIAN companies’ websites and self-service portals.
    Note that the actions taken by NOVIAN to analyse a Data Subject’s data do not have any legal or other similar significant effects for the Data Subject. A Data Subject may object at any time to the processing of their personal data for direct marketing purposes and configure their browser to refuse all or some browser cookies.

    10. CONTACT DETAILS

    • UAB „Novian“ (legal entity code 121998756, registered address Gynėjų St. 14, Vilnius, Lithuania, tel. +370 219 0000, e-mail info@novian.io, website www.novian.io);
    • UAB „Novian Technologies“ (legal entity code 301318539, address Gynėjų St. 14, Vilnius, Lithuania, tel. +370 219 0000, e-mail info.technologies@novian.lt, website www.novian.io, data protection officer’s e-mail dap@novian.lt);
    • UAB „Novian Systems“ (legal entity code 125774645, address Gynėjų St. 14, Vilnius, Lithuania, tel. +370 5 273 41 81, e-mail info.systems@novian.lt, website www.novian.io, data protection officer’s e-mail dap@novian.lt);
    • UTIB „INVL Technology“ (legal entity code 300893533, address Gynėjų St. 14, Vilnius, Lithuania, tel. +370 5 279 0601, e-mail info@invltechnology.lt, website www.invltechnology.lt);
    • „Andmevara Services“ OÜ (address Pärnu mnt 158, Tallinn, Estonia tel. +372 6715 188, e-mail mail@andmevara.ee, website www.andmevara.ee);
    • „Andmevara AS“ (address Pärnu mnt 158, Tallinn, Estonia tel. +372 6715 188, e-mail mail@andmevara.ee, website www.andmevara.ee);
    • „Andmevara SRL“ (address MD-2001, St. Sciusev A.,89, mun. Chisinau, Moldova, tel. +370 612 51955, e-mail a.smirnovas@baip.lt);
    • „Zissor“, (address Bragernes Torg 6, 3017 Drammen, Norway, tel. +47 22 83 85 00, e-mail post@zissor.com, website www.zissor.com).

    11. COOKIES

    Cookies are information that is recorded on the computer of a person visiting NOVIAN webpages. Cookies are used to recognise a visitor as someone who previously visited the website and to gather website traffic statistics, as well as to show the visitor advertisement intended specifically for them and to improve the functionality of actions performed on a self-service portal. Under their default settings, most browsers accept cookies. Visitors, however, have the ability to turn off cookies by changing their browser settings. Browser settings can also be set to accept only certain cookies or to generate a warning each time and offer a choice of whether or not to allow cookies to be saved on your computer. Note that if cookies are disabled, some website functions may not work.

    More information about cookies used by NOVIAN is available at: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

    Cookies used by NOVIAN on its companies’ websites:

    Where cookie is used
    Name of cookie
    Purpose of cookie
    Moment of creation
    Expiration time
    Data used
    Platform
    Novian.lt
    Novian.io
    _ga
    To collect statistical information about traffic on the site. The data is collected to prepare reports and to improve the site.
    When website is loaded
    26 months
    IP addresses and unique ID numbers are used for record-keeping, yielding a statistical result. Counters function via Google Analytics.
    Google Products
    Novian.lt
    Novian.io
    _gid
     24 hours
    Novian.lt
    Novian.io
    _gat
    1 minute
    Novian.lt
    Novian.io
    _ga_#
    Used to collect the number of times a user has visited the website, the dates for the first and most recent visit
    When website is loaded
    2 years
    Google Products
    Novian.lt
    Novian.io
    wp-wpml_current_language
    Designates the country code that is calculated based on the user’s IP address to determinate what language should be used for the visitor
    When website is loaded
    1 day
    IP address
    WPML
    Novian.lt
    Novian.io
    _lfa
    For the information about the pages request to visit by the IP addresses
    When website is loaded
    2 years
    IP address, the time spent on a website and pages visited
    Leadfeeder
    Novian.lt
    Novian.io
    _lfa_#
    Unclassified
    When website is loaded
    Persistent
    Leadfeeder
    Novian.lt
    Novian.io
    _lfa_expiry
    Contains the expiry-date for the cookie with corresponding name
    When website is loaded
    Persistent
    Leadfeeder

    NOVIAN’s websites may include links to third-party websites and legal acts as well as to social networks (an option to share site content on Facebook, LinkedIn, Instagram and YouTube, for example). It should be noted that the third-party websites whose links are provided on NOVIAN’s websites are subject to those websites’ privacy policies or other documents corresponding to a privacy policy, and NOVIAN does not take responsibility for the content presented on those websites, their activities or the provisions of their privacy policies.

    NOVIAN has the right at any time to unilaterally modify this Privacy Policy, informing data subjects about the changes on the websites of the NOVIAN Group.

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