Privacy policy

What data we collect and why

Depending on the services provided as well as the different ways in which the Client discloses their data, Definra may collect and manage the following data on the Client:

• basic information about the Client: first and last name, company name, personal or company registration number, address, copies and data of all disclosed documents, phone number, e-mail address;
• information on the services provided to the Client: software data, information on the selected services, order size and amount, the length of use of such services, data on any third-party services that were sold by Definra and/or were paid for via Definra;
• the contract details of the Client: the location and means in which a contract and/or adjustment of an existing contract was signed; when an agreement is signed remotely – a phone call recording and/or details of an order placed via electronic means of communication; data on the credit rating of the Client; information on whether the Client agrees or disagrees to receive marketing communications from Definra, participate in market research performed by Definra, data usage, provision of data to third parties as well as the agreement to perform a credit rating;
• payment information: details of Client invoices, data on payments made by and/or on behalf of the Client, information on credit management (including provision of data to third parties);
• information on communications and customer support: data on browsing in the Definra web page and associated web pages (collected via cookies and similar technologies); phone call recordings, details of any electronic communications between the Client and Definra; details of any claims by the Client and replies by Definra on any issues with the software and/or services provided or any other issues; data on any remote connections by Definra to Client systems;
• other data: details of market research participants, newsletter subscriptions.

We use the data you provide and/or generate ir order to achieve the following objectives:

• to prepare and sign a service contract, provide services and assure their quality;
• to run marketing campaigns and inform you on new products and services (if you have agreed to receive such communication);
• to provide customer support and related information;
• to manage our internal accounting;
• to perform credit ratings, prevent fraud and identify and prevent any other illegal activities by existing Clients and/or parties interested in our services;
• to manage Client debt;
• to enable provision of third-party services, accounting and payment collection for such services;
• to analyze, evaluate and improve the services provided by Definra;
• to perform statistical and marketing research;
• to ensure the controls, improvement and clarity of internal processes in Definra;
• to perform duties we are legally obliged to perform by applicable laws and regulations;
• other objectives for which Definra has the right to manage your data, when you express your consent, when it is required by a legal interest of Definra and/or any third parties, or when doing so is required by applicable laws and regulations.

Comments

When a visitor to our web page posts a comment, Definra collects data that is visible in the comment form, as well as the IP address and the user data shared by the browser of the visitor, in order to protect ourselves against spam.

An anonymous hash entry may be generated from your e-mail address and sent to the Gravatar service provider in order to test, whether you use this service. The privacy policy of Gravatar can be found here: https://automattic.com/privacy/. After your comment is confirmed, your profile picture may be visible next to your comment.

Files

If you upload any pictures or images to the web page, it is recommended to avoid uploading any image files that contain location information (EXIF GPS). Other visitors will be able to download those images and retrieve location information from them.

Contact forms

We only collect, store and use the data provided in contact forms in lawful ways, so that we can provide our services to you, improve our services, as well as provide support to you on any issues and/or questions you might have, send messages and other communications related to any special offers, protect our rights and the rights of any third parties, perform any duties we are legally obliged to perform. The contents of our communications to you may be tailored based on the data you provide.

Cookies

When you post a comment on our web page, you have the option to choose whether you want your name, e-mail address and web page data to be collected in cookies. This is done for your comfort, so that you do not need to repeatedly input this data every time you comment. These cookies are stored for one year.

If you have an account on our web page and sign in, we create a temporary cookie which stores information on whether your browser accepts cookies. These cookies do not hold any personal information and are cleared once you close your browser.

When you sign in, we also create several cookies that contain the information on your login, as well as your screen settings. Login cookies are stored for 2 days and the screen setting cookies are stored for one year. If you select the option to “Remember me”, your login cookies will be stored for 2 weeks. If you sign out of your account, your login cookies are cleared.

If you publish or edit a post, there is an extra cookie created in your browser. This cookie does not contain any personal data, but it does contain the ID of the post you have edited or published. This cookie is cleared after 1 day.

Content uploaded from other web pages

This web page may contain content from other sources (such as videos, images, text, etc.). Viewing and acting on such content is equal to visiting the web pages that the content originates from.

These web pages may collect information about you, use cookies, third-party tracking services and track the actions you take on said content, including cases when you have an account and are logged into these web pages.

Statistics

Browsing statistics from our web page, including your IP address, possible location and other similar details are collected, stored and used for market research.

Who we share your data with

In order to achieve the objectives stated above, Definra may share your data with the following data processors:

• data processors that require your data in order to enable the provision of our services to you or the performance of the legal obligations according to applicable laws and regulations (e.g. mail and delivery service providers);
• data processors that provide services and process your data on behalf or by the order of Definra (e.g. software providers, companies that issue certificates for training performed by Definra, etc.);

Please note that the data processors mentioned above process your data according to strict orders by Definra. These data processors are obliged to ensure the correct means of data protection and confidentiality according to separate contracts and agreements between Definra and these data processors. In the case of purchasing software licenses, separate data protection and confidentiality agreements are made between the software provider and the end customer.

Other types of data processors that process data controlled by Definra:

• Parties that provide Client debt management and collection services to Definra;
• Credit rating providers to Definra;
• Third parties that provide services and/or offers to existing or potential clients of Definra;
• Data analysis service providers to Definra;
• Auditors, consultants and lawyers that process data under orders by Definra;
• Parties responsible for the IT infrastructure of Definra;
• Direct marketing service providers to Definra;
• Service quality management, control and improvement service providers to Definra.

Please note that:

Any data to parties that are responsible for managing customer debt is only disclosed according to the rules of applicable laws and regulations.

We will only disclose information to parties that have a legal right to receive your information according to applicable laws and regulations (e.g., court, local authorities, etc.) to an extent in which we are in fact required to do so.

Data on your direct marketing and newsletter subscriptions is only disclosed to parties responsible for managing such data, if you consent to it. Such consent can be cancelled at any time. You have the right to view, edit or delete such data.

Your information can be disclosed to other third parties under lawful basis or your consent, that can be provided in separate agreements.

Comments of the visitors in our web page may be verified by using an automated spam filter.

Data processors, to which Definra discloses your data, may be established outside of Lithuania, the EU/EEA. Data is only disclosed to such data processors, if such disclosure is allowed by the applicable laws and regulations, taking all required measures to protect your privacy.

How we protect your data

Depending on the services provided as well as the different ways in which you may disclose your data to Definra, your data may be stored in printed documents and document copies and/or our information systems. When we use automated means to process your data, we use the technical and organizational measures of data protection that are defined by applicable laws and regulations, in order to ensure the protection of your data according to the 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 (General Data Protection Regulation), as well as other applicable national and international laws and regulations. In addition to that, Definra does its business strictly according to the personal data protection and processing principles defined in said Regulation. According to these principles, personal data is:

• processed lawfully, fairly and in a transparent manner in relation to the data subject (the principle of lawfulness, fairness and transparency)
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (the principle of purpose limitation);
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (the principle of data minimisation);
• accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (the principle of data quality);
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (the principle of storage limitation);
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (the principle of integrity and confidentiality).
• processed in such a way that ensures we are responsible for, and be able to demonstrate compliance with the above-mentioned principles (the principle of accountability).

How long do we store your data

If you post a comment on our web page, its text and metadata is stored for an infinite amount of time. This is done to enable recognition and approvals on future comments.

If you sign up to our web page and become a user, we store all data that you provide in your account. Every user can view, edit and delete their data (except for the username). The administrators of this web page can also view and edit this data.

If you subscribe to our newsletter, related data is stored until you cancel your subscription.

If you submit a contact form via our web page or contact Definra in any other way and provide your data, this data is stored for an infinite amount of time, unless otherwise specified in a separate agreement.

If you sign a service and/or software contract with Definra, this contract and/or any additional agreements attached to it will define any processing of your data.

Your rights

If you have an account or have ever posted a comment, subscribed to our newsletter or submitted a contact form on our web page, you can request an exported data file with data that we have on you. You also have the right to request for such data to be deleted from our systems. This does not apply to data that we are legally obliged to collect and store by applicable laws and regulations.

Contact information

We kindly ask you to express any questions, comments or requests regarding the Privacy policy of Definra or the data processing we perform via any of the following means of communication:

E-mail at info@robovirgin.com.

Phone: +370 654 81 936.