PRIVACY POLICY

This privacy policy defines the principles and procedure of personal data processing performed by UAB “Baltic Asset Management” and the operating conditions of the website www.balticam.lt.

I. GENERAL PROVISIONS

1. This Privacy Policy (hereinafter - the Policy) defines the principles and procedure of personal data processing performed by UAB “Baltic Asset Management” and the operating conditions of the website www.balticam.lt. UAB “Baltic Asset Management” ensures that personal data is processed in a lawful, fair and transparent manner, collected for specified and clearly defined purposes and not further processed in a manner incompatible with those purposes;

2. Definitions used in this Policy: Personal data means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person, is a person who can be identified, directly or indirectly, in particular by an identifier such as name, personal identification number, location and internet identifier or by one or more physical, physiological, genetic, mental, economic, signs of cultural or social identity;

3. Data Controller - UAB “Baltic Asset Management”, code: 304602224, registered office address: Upės str. 21, Vilnius;

4. Data subject - the Company's client - any natural person whose personal data is processed by the Data Controller;

5. Data Processing - any operation or sequence of operations carried out by automated or non-automated means on personal data or personal data sets, such as collection, recording, sorting, systematization, storage, adaptation or modification, retrieval, access, use, disclosure, transfer, distribution or otherwise making them available, as well as collating or merging with other data, limiting, deleting or destroying them;

6. The concepts, principles and other provisions used in this Policy comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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; hereinafter referred to as the GDPR), The Law on the Legal Protection of Personal Data of the Republic of Lithuania, other relevant legal acts;

7. The data subject is considered to be acquainted with this Policy and to have read it when they voluntarily give their data (email address and telephone number) on the Company's website www.balticam.lt.

The data controller follows these data processing principles.

Personal data must be processed in a lawful, fair and transparent manner vis-à-vis the data subject (principle of lawfulness, fairness and transparency);

Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes (purpose limitation principle);

Personal data must be adequate, relevant and not excessive in relation to the purposes for which they are processed (data reduction principle);

Personal data must be accurate and, where necessary, kept up to date; all reasonable steps must be taken to ensure that personal data which is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay (principle of accuracy);

Personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed (retention limitation principle);

Personal data must be processed in such a way as to ensure adequate security of personal data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing and against unintentional loss, destruction (principle of integrity and confidentiality);

The controller is responsible for ensuring that the above principles are complied with and must be able to demonstrate that they are complied with (accountability principle).

The use of third party services, such as visits to the Data Controller's accounts on social networks, may be subject to third party terms. Therefore, when using the services of such third parties, it is also recommended to familiarize yourself with the conditions applicable by them.

II. COLLECTION, PROCESSING, STORAGE OF PERSONAL DATA

1. The Data Subject agrees that for the purpose of providing, purchasing and participating in the services provided and performed by the Company, for the purpose of invoicing, data analysis, the Data Controller processes the following personal data related to the Data Subject: name, surname, personal identification number or date of birth, email address, address of residence, bank account number (for payment for services), data on real estate purchased / sold / owned by the data subject (extract about the object from the Real Estate and Cadastre Register of the State Enterprise Center of Registers), IP address, correspondence by email and social media (non-public posts).

2. For the purpose of direct marketing, the Data Controller shall process the name, email address and telephone number of the Data Subject.

3. For the purposes of administration of customer inquiries, provision of quality services, the Data Controller handles the Data Subject's comments, name, surname, email address, telephone number.

4. Storage of personal data:

5. Personal data, as far as the main activities of the Company are concerned, that is, the purchase and sale of real estate objects, project management and development, shall be stored for 10 (ten) years. This deadline is due to possible inspections initiated by various state institutions (STI, SoDra, etc.), which can start 5 (five) years after the conclusion of a specific agreements (e.g.: contracts) and data are requested for the previous 5 (five) years;

6. Data obtained for the purpose of direct marketing (i.e., offering data subjects to buy / sell / otherwise transfer real estate relevant to them in part or in full, to contribute to real estate projects under development) is stored for 5 (five) years from the date of data receipt;

7. For the purpose of request administration, personal data is stored for 1 (one) year from the date of receipt of the data;

8. For the purpose of invoicing, personal data shall be stored in accordance with the legal requirements applicable to accounting.

9. The Data Subject may at any time submit a request to revoke the consent to process his / her personal data by sending an e-mail to: info@balticam.lt or upon arrival at the Company's office at: Upės str. 21, Vilnius.

10. The Data Controller confirms that personal data is collected both directly from the Data Subject and from publicly available sources, i.e., publicly available data of business partners and / or their representatives are collected by the Company in publicly available systems (social networks, public databases, etc.) when preparing to announce relevant tenders, develop projects, etc. Also, the Company has implemented a database that includes all real estate brokers operating in Lithuania. Their data is publicly available and accessible. Every time the Company sends relevant inquiries to brokers, e-mails give them the opportunity to refuse to receive relevant offers for cooperation in the future.

11. The Data Controller undertakes not to disclose the processed Personal Data to third parties, except in the following cases:

If there is the Data Subject's consent to such disclosure of personal data;

When data is provided to Data Processors providing accounting, Internet system maintenance, payment and other services;

When data is provided for other relevant actions in fulfillment of legal obligations.

By submitting personal data, the Data Subject grants the Data Controller the right to collect, store, systematize, use and process for the purposes provided for in this Policy all personal data which he / she provides directly or indirectly by visiting the Website.

12. The data subject is responsible for ensuring that the data he or she provides is accurate, correct and complete. Intentional entering of incorrect data is considered a violation of the Policy. If the submitted data changes, the Data Subject must correct it immediately, and if it is not possible to do so, inform the Data Controller. In no case will the Data Controller be liable for any damage caused to the Data Subject and / or third parties as a result of the Data Subject providing incorrect and / or incomplete personal data or not requesting the addition and / or change of data.

13. The Data Controller uses cookies on its Website in order to properly process information about the Data Subjects (hereinafter referred to as Visitors) when they visit the Data Controller's Website. Cookies are files that store information on a visitor's computer hard drive or in a search engine. They can be used to detect visits to the Data Controller's Website, to view the history of the visit and to adapt the content accordingly. Cookies are also used to ensure the most convenient viewing of the website, its smooth operation, allows monitoring the duration and frequency of visits and collecting statistical information on the number of visitors to the website. In addition, they help to improve the operation of the Website and to implement improvements and to adapt the Website to the optimal needs of its Visitors.

14. Data that the Data Controller may process about Visitors when they visit the Data Controller's Website:

details of viewed websites;

IP address;

clicked links;

the websites visited before accessing the Data Controller's website.

15. Processing of data using cookies does not allow the direct or indirect identification of Website Visitors

16. A website visitor may delete cookies from their computer or block them in their web browser, but in this case some of the website's functionality may not work or may work incorrectly.

III. RIGHTS OF DATA SUBJECTS

1. A Data Subject who has submitted an identity document or confirmed his / her identity in accordance with the procedure established by legal acts or by electronic means (if they allow proper identification of a person), has the right at any time, upon submission of a request to the Data Controller, to get acquainted with his / her data processed in the Company free of charge and to receive information from which sources and which personal data have been collected, for what purpose they are processed, to which data recipients they are and have been provided within 1 (one) yea. The Data Subject also has the right to demand the correction of incorrect, incomplete, inaccurate personal data, to demand the suspension, except for storage, of the processing of his / her personal data when the data is processed in violation of the law and the provisions of this Policy.

2. The Data Subject may submit a request for the exercise of his or her said rights at the Company's office at the address: Upės str. 21, Vilnius, by filling in the application form or sending such a request by e-mail: info@balticam.lt

3. To the extent that the processing of personal data is based on consent, the Data Subject has the right to withdraw consent at any time, without prejudice to the lawfulness of the processing of data prior to withdrawal, as provided for in the Policy.

4. Not satisfied with the response of the Data Controller or considering that the Data Controller processes personal data without complying with legal requirements, the Data Subject has the right to submit a complaint to the State Data Protection Inspectorate of the Republic of Lithuania.

IV. FINAL PROVISIONS

1. The law of the Republic of Lithuania shall apply to legal relations related to this Policy.

2. The Data Controller shall not be liable for any damage, including damage caused by the disruption of the use of the Website, for the loss or damage of data resulting from the actions or omissions of the Data Subject or third parties acting on the Data Subject's knowledge, including incorrect data entry, other errors, intentional harm, other misuse of the Website. The Website Provider is also not liable for any disruption of connection and / or use of the Website and / or any damage caused by it, resulting from acts or omissions of third parties not related to the Data Controller or the Data Subject, including power, internet access supply failures, etc.

3. The Data Controller has the right to amend the Policy in part or in full. This Privacy Policy is reviewed every 2 (two) years and updated as necessary.

4. Additions or changes to the Policy shall take effect from the date of their publication on the Website.

5. If the Data Subject continues to use the Website after the addition to or change of the Policy, it is considered that the Data Subject does not object to such additions and / or changes.