Who is this Privacy Policy intended for?
This Privacy Policy (hereinafter – Privacy Policy) is intended to inform data subjects about the processing of personal data carried out by UAB “Hotrema”. In this Privacy Policy, we provide our clients, suppliers, and other partners, individuals related to them, candidates, correspondents of contracts, and other data subjects specified in the Privacy Policy with information about how we process their personal data. Fr
About the company
The company refers to UAB “Hotrema,” legal entity code 302747986, with its registered office address at Montuotojų St. 1C, LT-89101 Mažeikiai, Republic of Lithuania. Our contact email address for personal data protection inquires is info@hotrema.lt.
What are personal data?
Personal data refers to any information about a Data Subject collected by the Company that can be used to identify the individual, whether stored electronically or in another format.
Personal data encompasses any information collected by the Company about Data Subjects, such as first name, last name, and address, for the purposes outlined in this Privacy Policy or in a separate consent or agreement with the Company. This also includes publicly available information about individuals that the Company may obtain when you contact us through social media channels or engage with the Company’s social media accounts.
In processing personal data, the Company complies with 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of natural persons with regard to the processing of personal data and on the free movement of such data, which repealed Directive 95/46/EC (General Data Protection Regulation – GDPR), as well as the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other applicable legal acts governing personal data protection
Below you can find information on how we process your personal data: what personal data we process, for what purposes we process it, how long we keep it, and what rights you have. You can do this by clicking on the option that interests you.
Processing of Personal Data Arising from the Execution of Contracts with Clients and Suppliers
1. Purpose – conclusion and execution of contracts with clients and suppliers who are natural persons
| Personal data | Legal basis | Retention term |
|---|---|---|
| Client’s or supplier’s personal name, surname, date of birth, address, business license/individual activity certificate number (for service provider), bank account number | GDPR Article 6(1)(b) (contract) | During the validity of the contract. Personal data is transferred to data processors. |
2. Purpose – conclusion and execution of contracts with suppliers, partners, and similar legal entities
| Personal data | Legal basis | Retention term |
|---|---|---|
| Client’s or supplier’s (legal entity) employee’s name, surname, position, basis of representation, email address, phone number, correspondence content | GDPR Article 6(1)(f) (legitimate interest) | During the validity of the contract. Personal data is transferred to data processors. |
3. Purpose – conclusion and execution of residential lease agreements for the benefit of employees
| Personal data | Legal basis | Retention term |
|---|---|---|
| Name, surname, date of birth, address, contact details, leased property, rental price, bank account number, payments, communication, and other information related to the conclusion and execution of the contract | GDPR Article 6(1)(b) (contract) | During the validity of the contract. Personal data is transferred to data processors. |
4. Purpose – protection of rights and legitimate interests
| Personal data | Legal basis | Retention term |
|---|---|---|
| All and any personal data collected in the performance of contracts that are necessary to resolve a dispute | GDPR Article 6(1)(f) (legitimate interest – protection of legal claims) | 10 years after the termination of the contract. Data is transferred to courts, state institutions resolving disputes, dispute parties, lawyers, and other entities providing legal services. |
Candidate selection
We collect and process your personal data (workplace, email address, date of birth, address, education, surname, phone number, first name, desired position, date of receipt of CV, information about your personal qualities, work experience (last workplace, length of service at workplace, positions held, other work experience), information about foreign language proficiency (language, reading, writing, speaking levels), ability to use computer programs, other information provided in the CV, recommendation and/or cover letter; desired salary, information about possible conflicts of interest, etc.) during participation in recruitment for the purpose of conducting the recruitment process, based on your consent, which you express to the Company by sending your CV and/or cover letter. If you do not provide your CV and/or cover letter, we will not be able to assess your suitability for the proposed position.
With your consent, we will contact your current employer. In addition, we may contact your former employer based on our legitimate interest in selecting a suitable candidate and in accordance with Article 5(2) of the Law on Legal Protection of Personal Data of the Republic of Lithuania. This is done to verify information regarding your qualifications, professional skills, and personal qualities—for example, your work results, relationships with clients and/or colleagues, and evaluations of your performance.
If you do not provide separate consent for your personal data to be processed for a longer period, we will delete and/or destroy your data within three working days after the recruitment process is completed—either following the signing of a contract with the selected candidate or after a decision has been made to end the recruitment process. If your application is not successful but you have consented to the processing of your personal data for the purpose of future job opportunities, we will retain your data on the basis of that consent for one year after the conclusion of the recruitment process.
On the basis of our legitimate interest, we will process the personal data of individuals indicated by the candidate—such as name, surname, email address, phone number, and any information they provide. These individuals may include former or current employers or persons providing recommendations. The information obtained from them will be used solely for the purpose of candidate selection. Our legitimate interest in this case is to ensure the selection of a suitable candidate for the position in question. We will delete and/or destroy this data within three working days after either the signing of a contract with the selected candidate or the decision to conclude the recruitment process.
Clearly unsuitable candidates
If we determine that a candidate clearly does not align with the Company’s values or culture, or fails to fulfill commitments, the candidate may be added to a list of clearly unsuitable candidates. In such cases, based on our legitimate interest to protect the Company’s interests and to exclude unsuitable candidates from future recruitment processes, we process the following personal data: name, surname, previous positions or positions previously applied for, the reason for inclusion, and the date of inclusion in the “blacklist” (list of clearly unsuitable candidates).
“Recommend a Friend” Program
To help attract new talent to the Company, we operate the “Recommend a Friend” program, through which current employees are encouraged to suggest acquaintances for open positions.
For this purpose, and on the basis of our legitimate interest, we process the following personal data of recommended individuals: name, surname, profession/qualification, the position for which the candidate is recommended, contact details (email, phone number, LinkedIn or Facebook account name), information available on social network accounts regarding qualifications and professional experience, as well as the details of the employee who made the recommendation.
We process this personal data until we receive a response regarding participation in the recruitment process. If you agree to participate, your personal data will continue to be processed on the basis of consent, as outlined in this section of the Privacy Policy.
Direct marketing
We conduct direct marketing only with respect to business entities!
For individuals who have provided their contact details and expressed a desire to receive information about the services we offer, our activities, etc., we provide commercial offers, information about our services, activity updates, and share other promotional materials. For the purpose of direct marketing, we process the following personal data: email address, phone number, information about sent messages, and responses to them. Your data will be processed for direct marketing purposes for 3 years from the date of consent. Direct marketing messages are sent (your contact details are processed) based on consent, while information about sent messages and responses to them is processed based on our legitimate interest in assessing marketing effectiveness.
If you are our client and have not objected to receiving information about products or services similar to those you have purchased from us, we will send direct marketing messages based on our legitimate interest. In this case, we will process your personal data for direct marketing purposes for 1 year from the end of the contractual relationship.
You have the right to object or opt out of receiving direct marketing messages at any time by contacting us at the email address provided in Section 2.
Video surveilance
In order to protect the safety of clients, visitors, employees, and other individuals entering the surveillance area, as well as the property of these individuals and the Company, to collect evidence of violations, and to defend its rights, the Company conducts video surveillance. Video surveillance is carried out based on the legitimate interest of these individuals and the Company. While conducting video surveillance, the Company processes the following personal data: image, movement trajectory, and items possessed by individuals. Recorded video data is stored for 10 days. You visited the Company’s premises (all areas of the Company that are under surveillance are marked with informational signs). More detailed information will be provided to you by contacting the email address indicated in Section 2 of the Privacy Policy.
Protection of the company’s confidential information and business continuity
In order to protect the company’s confidential information and ensure business continuity in its legitimate interest, the company may review its employees’ correspondence with contractors. For these purposes, the company processes the following personal data of its employees and individuals who send or receive employees’ emails: email address, sender’s or recipient’s first and last name, date, and the content of information in electronic work tools. Such data is retained for 4 years.
Protection of legitimate interests
The company, on the basis of its legitimate interest in defending its rights, including in the case of civil disputes, processes the names, surnames, personal identification numbers, case circumstances, other case-related information, and publicly available information of the individuals involved in the case or their employees. The data may be transferred to law enforcement authorities, lawyers, or bailiffs carrying out enforcement. The data is destroyed one year after the final resolution of the case and full satisfaction of the company’s claims (if the claims are met).
Archiving
Contracts for goods, works, services, and acceptance acts for goods, works, and services, when no longer needed for their primary purpose (generally – for the conclusion and execution of the contract), are subsequently kept for archiving purposes (10 years from the termination of the contract). We process personal data for this purpose in order to fulfill a legal obligation (GDPR Article 6(1)(c)), established in the Index of General Document Retention Periods, approved by the Order No. V-100 of the State Archiver of the Republic of Lithuania on March 9, 2011, point 10.37. The retention periods for other personal data for archiving purposes are specified for each specific purpose of personal data processing.
Contact Us
There are several ways you can get in touch with the Company: by phone, email, through social media accounts, via the contact form on the website, or by sending a letter to the Company’s registered address. We receive, review, and respond to all messages ourselves. If you contact us, we may process the data you provide to us, such as your email address, first and last name (if provided), username (if the inquiry is sent through a social media account), workplace (if provided), the date and time of sent and received messages, recipient, sender (when the message is addressed to you), and content.
Such data will be processed in order to respond to your questions and review your suggestions. If you do not provide your contact details, it will not be possible to get in touch with you. Correspondence is stored for 1 year from the receipt of the message, except for information for which other retention periods are established in the Privacy Policy or legal acts. All personal data you provide when communicating with us is used only for the purposes stated above and for reviewing messages and administering and managing communication flows. We commit not to use your personal data in any publications in a way that would allow your personal identity to be determined without your explicit consent. Please note that we may need to contact you by mail, email, or phone. Please inform us about any changes to your personal data.
Cookies and Other Tracking Technologies
Mūsų interneto svetainėje yra naudojami slapukai ir kitos sekimo technologijos. Slapukas yra nedidelis iš raidžių ir skaitmenų sudarytas failas, kurį Jūsų sutikimu mes įrašome į Jūsų naršyklę arba standųjį Jūsų kompiuterio diską. Siekdami skirtingų tikslų, naudojame skirtingus slapukus. Slapukai taip pat padeda mums atskirti Jus nuo kitų interneto svetainės naudotojų, taigi užtikrina malonesnę svetainės naudojimo patirtį ir leidžia tobulinti Interneto svetainę.
Dauguma naršyklių leidžia atmesti visus slapukus, o kai kuriose naršyklėse yra galimybė atmesti tik trečiųjų šalių slapukus. Tad Jūs galite pasinaudoti šiomis galimybėmis. Tačiau atkreipkite dėmesį į tai, kad visų slapukų blokavimas turės neigiamą poveikį Interneto svetainės naudojimui, ir be slapukų Jūs negalėsite naudotis visomis Interneto svetainėje teikiamomis paslaugomis. Išsamesnė informacija pateikta adresu AllAboutCookies.org arba www.google.com/privacy_ads.html.
Absolutely necessary cookies.
These cookies are necessary for our website to function. The legal basis for using such cookies is Article 73, Paragraph 4 of the Electronic Communications Law of the Republic of Lithuania. These cookies are essential for the operation of the website and cannot be disabled in our systems. They are most often used in response to your actions on the site, for example, when you start browsing or select your privacy settings. These cookies do not store any personal information that could identify you and are deleted as soon as you leave the website.
Analytical and/or performance cookies.
These cookies allow us to count the number of visits to the website and monitor visitor traffic in order to improve the website’s performance. They let us know which pages on the website are the most or least visited and track how visitors navigate the site. The collected data is not available to any other parties. Information collected through cookies is anonymous and is not intended to identify you or influence your browsing experience while you are on the website. If you do not agree to the use of these cookies, your visits will not be recorded in the statistics. The legal basis for processing the data collected by these cookies is your consent.
Commercial cookies.
These cookies, used by us and third parties, are intended to display offers or other advertising information that might interest you. We use cookies that collect data about your browsing history and determine your areas of interest in order to show you relevant marketing information. The legal basis for processing the data collected by these cookies is your consent.
| Cookie namie | Purpose + Data used | Expiration time + type + link |
|---|---|---|
| _ga_ | Google Analytics sets this cookie to store and count page views. Unique user ID (anonymous); Page views; Date and time of visits; Browser and device information; Geographic location; Traffic source | 1 year 1 month 4 days Analytical Privacy Policy – Privacy and Terms – Google |
| _ga | The _ga cookie, installed by Google Analytics, calculates visitor, session, and campaign data, and also tracks site usage for analytics reports. It stores information anonymously and assigns a randomly generated number to identify unique visitors. Unique user ID; Session information; Device and browser information; Geo-location; Traffic source; Navigation path; Demographic and interest data | 1 year 1 month 4 days Analytical Privacy Policy – Privacy and Terms – Google |
| _fbp | Facebook sets this cookie to store and track interactions. Pages visited; Actions taken (e.g., clicks, adding items to cart, purchases); Time spent on site | 3 months Analytical |
| _gid | The _gid cookie, installed by Google Analytics, stores information on how visitors use the website and generates analytical performance reports. Some collected data includes visitor count, source, and pages visited anonymously. Device data including: Browser type and version; Operating system; Screen resolution | 1 day Analytical Privacy Policy – Privacy and Terms – Google |
_gat_gtag_UA_ | Google Analytics sets this cookie to store a unique user ID. | 1 minute Analytical Privacy Policy – Privacy and Terms – Google |
| _ga_ | Google Analytics sets this cookie to store and count page views. | 1 year 1 month 4 days Analytical Privacy Policy – Privacy and Terms – Google |
Administration of Social Media Accounts
The information you provide to us through social media platforms (including messages, use of “Like” and “Follow” buttons, and other communication) is controlled by the social network operator.
Currently, we have the following corporate accounts on social media:
- Hotremasolutions account on Facebook;
- Hotrema.uab account on Instagram;
- UAB Hotrema account on LinkedIn;
The information contained in these social media accounts is processed for the purpose of their administration, based on your consent. We do not store this information separately (when data is processed for the purpose of social media account administration, but data may be stored if it needs to be processed for another purpose, such as the protection of rights).
When you visit our social media accounts, the social network administrator places cookies on your device that collect personal data. Cookies are stored both if you are a registered user of the social network and if you do not have an account on the respective social network. We do not have access to such personal data, and from social network administrators we may only receive statistical information about the visits to our social media accounts.
We recommend reading the privacy notices of third parties and contacting the service providers directly if you have any questions about how they use your personal data.
In addition to the general corporate social media accounts mentioned above, we also have a Hotrema HR account on Facebook, which is intended solely for employee recruitment and communication with potential candidates.
Data Collection and Disclosure
We receive your data from you, your employers, our contractual partners, or generate it from software. Certain personal data may be transferred to our authorized data processors, such as companies providing IT or cloud services (e.g., when renting servers from an IT company, your personal data will be physically hosted by that company), archiving service providers, etc. We require our data processors to ensure appropriate protection of your data and guarantee that your personal data is processed only to the extent we instruct them and solely for the specified purposes.
Personal data may also be transferred to data recipients who act as data controllers (independently or jointly with us). For example, lawyers, social network operators, banks, etc. Most categories of data recipients are specified alongside information about particular data processing purposes.
If you have questions about our service providers, please contact us at the email address provided in the Privacy Policy.
In addition to the categories of data recipients specified in this Privacy Policy, we may also disclose information about you:
- if required by law (e.g., upon receiving a court order or request from law enforcement authorities);
- when intending to sell part of the Company’s business or assets, disclosing your personal data to a potential buyer;
- after selling the Company’s business or a substantial part of its assets to third parties;
- when necessary to defend our rights and legitimate interests.
Except as provided in this Privacy Policy, we do not disclose your personal data to any third parties.
Security of Your Personal Data
Your personal data will be processed in accordance with the General Data Protection Regulation (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable legal requirements. When processing your personal data, we implement organizational and technical measures to protect it against accidental or unlawful destruction, alteration, disclosure, and any other unlawful processing.
Your rights
This section provides information about your rights related to our processing of your personal data and the circumstances under which you may exercise these rights. If you wish to obtain more information about your rights or exercise them, please contact us at the email address provided in this Privacy Policy.
The Company will provide you with information about actions taken upon receiving your request to exercise your rights without undue delay, but no later than within 1 (one) month of receiving the request. Depending on the complexity of the request and the number of requests received, this period may be extended by 2 (two) additional months. In such cases, we will inform you within 1 (one) month of receiving the request about the extension and the reasons for it. The Company will refuse to implement your rights only in cases provided by law.
Right to Access Your Personal Data
We aim to ensure that you fully understand how we use your personal data and that you do not experience any inconvenience. You may contact us at any time to inquire whether we process any of your personal data. If we store or otherwise use your personal data, you have the right to access it. To do so, submit a written request to the email address provided in this Privacy Policy, confirm your identity, and follow the principles of fairness and reasonableness when making such a request.
Right to Withdraw Consent
If you have given us explicit consent to process your data, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of data processing carried out before the withdrawal.
Additional Rights
You also have the following rights, which you may exercise in accordance with the procedures described below: (a) The right to request correction of any inaccuracies in your data. In such cases, we may ask you to confirm the corrected information. (b) The right to request deletion of your personal data. This right is exercised in cases provided for in Article 17 of the GDPR (EU) 2016/679. (c) The right to request restriction of processing or non-processing of your personal data:
- for the period necessary to verify the accuracy of your personal data when you contest its accuracy;
- when the collection, storage, or use of your personal data by us is unlawful, but you choose not to request deletion;
- when your personal data is no longer needed by us, but you require it to establish, exercise, or defend a legal claim;
- for the period necessary to determine whether we have a more compelling legal basis to continue processing your personal data if you have exercised your right to object to processing. (d) The right to data portability of data processed by automated means, which we received from you in a structured, commonly used, and machine-readable format, based on your consent or for the purpose of contract performance. Upon your request, we will transfer a copy of your provided data to you or to a data controller of your choice. (e) The right to object, under Article 21 of the GDPR, to our use of your personal data. You have the right to object when your personal data is processed on the basis of legitimate interest (the legal basis for each processing purpose is indicated above) or for direct marketing purposes.
Right to Request More Information
We hope you understand that it is very difficult to cover all possible ways of collecting and using personal data. We strive to provide the clearest and most comprehensive information possible and commit to updating this Privacy Notice if the data usage process changes. Nevertheless, if you have any questions about the use of your personal data, we will be happy to answer them or provide any additional information we can disclose. If you have specific questions or do not understand the information provided, please contact us.
Complaints
If you believe that your rights as a data subject are or may be violated, please contact us immediately at the email address provided in this Privacy Policy. We ensure that upon receiving your complaint, we will contact you within a reasonable period and inform you about the progress of the investigation, and later about the outcome.
If you are not satisfied with the results of the investigation, you may file a complaint with the supervisory authority – the State Data Protection Inspectorate: https://vdai.lrv.lt/.
Responsibility
You are responsible for the confidentiality of the data you provide, as well as for ensuring that the data you provide to us is accurate, correct, and complete. If the data you have provided changes, you must inform us immediately by email. We will not be liable for any damage caused to you as a result of providing incorrect or incomplete personal data or failing to inform us of changes.
Changes to the Privacy Policy
We may update or amend this Privacy Policy at any time. If you wish to receive the updated Privacy Policy, please notify us at the email address provided in Section 2.