privacy policy

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. After reading this privacy policy (hereinafter - Privacy Policy), you will find out how and for what purposes we process your personal data, where we get it, who we provide it to and store it, and what your rights are as a subject of personal data.

1.2. 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.

1.3. The privacy policy applies to all persons whose data we process.

2. Who are we?

2.1. We - MB "SMART HR", based on the provisions of legal acts, we are the controller of your personal data.

2.2. More information on all issues discussed in this Privacy Policy will be provided by: Inesa Minsevičienė, e-mail: mail: inesa@smarthr.lt, telephone: +37061489592

3. What principles do 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 in the cases established by 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.

4. How do we collect your personal data?

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

a) When you submit them to us. You provide us with your personal data when you send us your CV, motivational letters, register on our website, communicate with us by phone, e-mail. by mail or during meetings, you answer questionnaires provided by us, perform tasks or tests. If you contact us in writing or by e-mail by mail, we will save the correspondence data.

b) When you use websites managed by us. When you use websites managed by us, certain information (e.g. Internet address (IP), type of Internet browser used, number of visits, viewed website pages, time spent on the website, etc.)

c) When we receive your personal data from other persons (recommendation) in accordance with the procedure established by legal acts and/or this Privacy Policy.

4.2. We may combine personal data received from you with data collected by us from other public or accessible sources. For example, we can combine the personal data you provide with data obtained using website cookies, data collected by you when providing our services, or with data legally obtained from third parties. By exercising your rights, you can always demand the correction of incorrect personal data.

5. For what purposes we process your personal data

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

a) For the purpose of providing services to our customers.We process your personal data in order to provide our services to you and others: to find and select candidates who meet the needs of our customers, to assess whether candidates are suitable for the job offered, and to present candidates to employers.

For this purpose, we process your personal data received from you yourself (e.g. data provided in your CV, data collected during communication, etc.), collected by you using our and other websites and/or received from other persons (e.g. existing or recommendations from former employers or acquaintances, social networks, public information tools, etc.).

For this purpose, we provide or transfer your data to our clients - employers who are looking for employees. Together with us, they will be the controllers of your personal data. We will not transfer more of your personal data to customers than we will process on the basis of this Privacy Policy. We have signed contracts with our clients, in which both parties undertake to protect your personal data.

For this purpose, we store your data for 5 years from the day you last provided us with your data or updated them, unless we have received your separate consent to store data longer.

b) For the purpose of administering the candidate database.At the end of the specific selection for which you submitted your data, we process your personal data in order to be able to offer you jobs and career opportunities in the future, to find and select candidates who meet the needs of our customers, to assess whether candidates are suitable for the job offered, and to present candidates to employers .

For this purpose, we process the same personal data as for the purpose of providing the services, provide them to the same persons and store them for the same period as stated in clause 5.1(a).

c) For direct marketing purposes. After receiving your consent and in order to offer you our services, those of our affiliates and our partners, which we think might be of interest to you (e.g. events, conferences), to improve our services, we process your personal data.

For this purpose, we process your personal data:

  • Name, surname, phone number, education, workplace, current and previous positions, e-mail address, date of birth, place of residence (address), gender.

For this purpose, we receive your personal data from:

  • Your own;

For this purpose, we store your data until the end of the validity period of the contract with you, unless we have received your consent to store personal data longer.

d) Companies for the purpose of administration of employees' work and employees' activities.To the extent that we are required or permitted by law, we process the personal data of our employees. We process the personal data of our employees in accordance with the procedure set out in the description of the processing of personal data of employees.

e)  For the purpose of executing contracts.In order to identify a customer or supplier, carry out products, solutions trading, service provision activities, process and administer customer or supplier orders, write out to the customer or accept the supplier's accounting documents, solve problems related to the scope of the product, solution or services provided to the customer, carry out other Company, as a seller or buyer, or a service provider or buyer, we process personal data.

For this purpose, we process your personal data:

  • name, surname, date of birth, personal identification number (personal identification number of a resident of the Republic of Lithuania or personal identification number of a citizen of a foreign country or other identification number), age, residential address, telephone number, e-mail address;

For this purpose, we receive your personal data directly from the data subjects when a potential customer or supplier represented by the data subject seeks to conclude a contract with the Company or during the execution of a contract concluded between the customer or supplier represented by the data subject and the Company.

f) Selection of candidates to Companies jobs offered CompaniesWe process your personal data in order to find candidates who meet our needs to work for us, select them and assess whether the candidates are suitable for the job offered.

For this purpose, we process your personal data received from you yourself (e.g. data provided in your CV, data collected during communication, etc.), collected by you using our and other websites and/or received from other persons (e.g. existing or recommendations from former employers or acquaintances, social networks, public information tools, etc.).

For this purpose, we store your data for 12 months from the day you last provided us with your data or updated them, unless we have received your separate consent to store data longer.

g) Candidates to work In the company for database administration purposes.After the specific selection in our Company, to which you submitted your data, we process your personal data in order to be able to offer you work and career opportunities in the future and to recommend suitable candidates to our clients.

For this purpose, we process the same personal data as for the purpose of providing the services, provide them to the same persons and store them for the same period as stated in clause 5.1(i).

h) For the purpose of debt administration.

For this purpose, we process your name, surname, telephone number, e-mail address.

For this purpose, we receive your personal data directly from you, from publicly available sources (e.g. population register, data provided by third parties, etc.) and from third parties.

For this purpose, we store your data until the end of debt administration (debt liquidation) and taking into account the statutes of limitation for claims established by legal acts (Civil Code of the Republic of Lithuania and others).

i) For the purpose of improving the managed websites and in order to offer you better and customized services. We use your personal data, including the personal data we receive when you use our websites, to improve and develop our website and offer you better and more customized services. For this purpose, we use your personal data received from you, received by you using our website and received from other persons.

Read more about how we use cookies and similar technologies in Section 6 of this Privacy Policy.

5.2. We do not process your personal data for any other purposes incompatible with the purposes listed above.

6. How do we use cookies?

6.1. 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 websites, save a person's browsing history, options, customize content, speed up searches on websites, create a convenient and friendly website environment, present it more efficiently and more reliable. Cookies are a common web browsing practice that makes the website easier to use.

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

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

b) for the analysis of the use of websites;

c) so that we can improve and develop the websites so that they meet your needs even better;

d) for service development and targeted marketing orientation.

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

6.4. 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 (ribbon) provided on the websites about cookies;

c) by expressing consent during registration on the websites.

6.5. All information about the cookies used on the website, their purpose and validity is provided here.

6.6. You can revoke your permission to use cookies at any time. You can do this by changing the settings of your internet browser so that it does not accept cookies. How to do this depends on the operating system and internet browser you use. Detailed information about cookies, their use, opt-out options can be found at http://AllAboutCookies.org or http://google.com/privacy_ads.html.

6.7. In some cases, turning off technical and functional cookies in particular, refusing to accept cookies or deleting them can slow down browsing, limit the functionality of certain website functions or even block access to websites.

7. To whom do we provide your personal data?

7.1. 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 and legal acts. 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 legally operating authorities or criminal prosecution authorities.

7.2. 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 valid legal acts ensuring the protection of your data. We enter into contracts with these persons, which obligate them to strictly comply with the requirements for personal data protection.

8. How long do we store your personal data?

8.1. 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.

8.2. We strive not to store outdated, out-of-date personal data, so when they are updated (e.g., by clarifying the account, changing information, etc.), only relevant information is stored. Historical information is stored if it is necessary in accordance with the procedure established by legislation or to carry out our activities.

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

9. How do we store your personal data?

9.1. The data we collect from you will be in the territory of the European Union, 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.

9.2. Unfortunately, the transmission of information over the Internet is not completely secure. Although we try very hard to protect your personal data, we cannot guarantee data security when you transfer data to websites - you assume the risks associated with the transfer of data to websites. Once we receive your data, we will apply strict procedures and security measures to protect your data from unauthorized access.

9.3. If unlikely circumstances arise and we become aware of a security breach of your personal data, which 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 was accessed.

10. External Sites

10.1. The websites may contain links to external websites - websites of our business partners or websites that advertise our services. 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.

11. What rights do you have?

11.1. 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, incomplete personal data of yours;

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.

11.2. 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.

11.3. 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.

11.4. 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.

11.5. 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 30 calendar days, stop processing your personal data, except for the cases specified in point 12.2 of this Privacy Policy and legal acts, i.e. when we are required to continue processing your data by valid legal acts, legal obligations incumbent on us , court decisions or mandatory instructions given to us by the authorities.

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

11.7. 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.

12. To whom can you submit a complaint?

12.1. If you wish to make a complaint about our data processing, please submit it in writing, giving as much detail as possible, using the contact details provided at the end of this policy. We will work with you and try to resolve any issues promptly.

12.2. If you believe that your rights have been violated in accordance with the GDPR, you can file a complaint with our supervisory authority - the State Data Protection Inspectorate, although, above all, we will try to resolve all disputes together with you.

13. How will this Privacy Policy be changed?

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

14. How to contact us?

14.1. Please send all documents related to this Privacy Policy to the following contacts:
by mail - MB "SMART HR", Paeglinės sodų 2-oji, 13, LT- 11305, Vilnius by email by post - inesa@smarthr.lt

Privacy policy publication date 2018 May 25