Privacy policy

PRIVACY POLICY FOR THE USERS OF THE WEBSITE OF
PUBLIC LIMITED LIABILITY COMPANY SMILTYNĖS PERKĖLA

 I. GENERAL PROVISIONS

1. Privacy policy for the users (visitors) of the website (hereinafter – Privacy Policy) of the public limited liability company Smiltynės Perkėla (hereinafter – the Company) shall govern personal data processed by AB Smiltynės Perkėla, data provided by the entities to AB Smiltynės Perkėla when browsing the website https://www.keltas.lt/ (hereinafter – the Website) and the mobile application lt (hereinafter – the Mobile Application), also other data of entities processed on the Website for the purposes of the Website’s administration and publicity of the activities of AB Smiltynės Perkėla.

2. The holder of processed personal data: public limited liability company Smiltynės Perkėla (legal entity code 140285526, registered address: Klaipėda City Municipality, Klaipėda, Nemuno str. 8, Lithuania, data accumulated and stored in the Register of Legal Entities of State Enterprise Centre of Registers, e-mail info@keltas.lt, phone +370 46 31 11 17).

3. Privacy Policy shall apply regardless of what devices are used by the users to access the Website and the Mobile Application.

4. AB Smiltynės Perkėla shall have the right to employ other persons to process personal data of the users of the Website and the Mobile Application and for that purpose transfer personal information to other legal entities in accordance with the provisions set forth herein.

5. Links to other websites or mobile applications can be provided on the Website and the Mobile Application, including websites and mobile applications managed by third parties which are not related to this Privacy Policy and those privacy policy provisions may substantially differ. The users shall be offered to get acquaint with the privacy policy of these websites before submitting any identifying information.

6. Personal data shall be processed by AB Smiltynės Perkėla in accordance with data protection requirements defined in laws of the European Union and of the Republic of Lithuania;

7. Definitions:

7.1. Personal data shall mean any information related to a natural person (personal data subject), whose identity is known or may be directly or indirectly established using data, such as personal number, one or several physical, psychological, economic, cultural or social characteristics of a person.

7.2. Personal data processing shall mean any action related to data, i.e. collection, recording, accumulation, storage, classification, grouping, consolidation, provision, publication, use, logical and/or arithmetic operations, search, distribution, deletion or other action, or a set of actions.

7.3. Personal data subject shall mean a natural person, who is using the Website and the Mobile Application, also a natural person whose data are processed on the Website and the Mobile Application for the purposes defined herein.

7.4. Other concepts used in this Privacy Policy shall have the same meaning as those defined in laws.

II. COLLECTION AND USE OF PERSONAL DATA

 8. Collected information:

8.1. For the purposes defined herein, AB Smiltynės Perkėla shall process the following personal data on the Website and the Mobile Application:

8.1.1. Information which was provided by the personal data subject when buying tickets through the Mobile Application, including the name, surname, e-mail address, and the phone number;

8.1.2. Curriculum Vitae and other information provided by e-mail by the applicants to free vacancies in the section ‘Career’;

8.1.3. Information which was provided by the personal data subject when leaving a comment, including his/her name, surname, e-mail address and the comment itself;

8.1.4. Information about the personal data subject’s computer and his/her visits and usage of the Website, including IP address, time and date of browsing the Website;

8.1.5. The image of the personal data subject (video surveillance data and photos, if a photo of a person was taken in the public event of the Company, etc.);

8.1.6. Any other information, which may be provided by the personal data subject at any time during communication with the Company, or when using the services provided by the Website and the Mobile Application of the Company.

8.2. By leaving a comment on the Website, the users are asked not to disclose personal data of special categories (e.g. information about racial and ethnic origin, political attitudes, membership in trade unions, physical or mental health). If for any reasons, the user decides to provide to the Company personal data of special categories or other confidential information, such action shall be considered as an explicit consent of the user to collect and use such data and information by AB Smiltynės Perkėla for the purposes defined herein.

9. Personal data storage:

9.1. Personal information of the user shall be stored not longer than required for the achievement of the purposes defined herein.

9.2. Time limits for data storage:

9.2.1. For the purposes of ticket purchase, data of the personal data subject shall be stored for 10 (ten) years from the last purchase of the ticket;

9.2.2. For the purposes of comment processing, personal data shall be stored for maximum 2 (two) years from the submission of the comment;

9.2.3. For the purposes of application to free vacancies, personal data shall be stored until the end of the selection procedure (with the deadline for claims) or not longer than for 2 years after the end of the procedure to take other free vacancies, if a person has given his/her consent;

9.2.4. Video surveillance data shall be stored for 30 days.

9.2.5. Upon expiry of the aforementioned time limits, data shall be deleted without a recover possibility.

9.2.6. Personal information may be stored longer than the time limit specified in paragraph 9.2 of the Privacy Policy only in the event of reasonable suspicions regarding illegal activities (for the activities, which are under legal investigation), or when personal data are necessary for a proper resolution of a dispute or complaint, or in the event of other special grounds defined by laws.

10. Grounds for legal processing of personal data

10.1. 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), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other laws.

10.2. Fulfilment of legal interests of the Company (to manage and administrate the Website, reply to the requests, publish activities of AB Smiltynės Perkėla, etc.);

10.3. Consent of the user of the Website.

11. Purposes of personal data processing:

Personal data collected by the Company shall be used exclusively for the following purposes defined herein:

11.1. To provide the personal data subject with a possibility to use the Website, the Mobile Application and the provided services;

11.2. For the conclusion of the contract and its fulfilment (for ticket purchase) with the personal data subject;

11.3. To inform about ferry timetables, past events, social initiatives and other activities of AB Smiltynės Perkėla;

11.4. To get a feedback about the services provided by the Company and for communication with the clients of the Company (submission of comments);

11.5. To provide a possibility to apply to free vacancies;

11.6. To ensure protection of the Company’s property;

11.7. To inform the clients of the Company about traffic intensity and ferry loading;

11.8. To investigate the incidents related to the use of the Website.

12. Data transmission:

12.1. AB Smiltynės Perkėla shall have no right to transmit personal data to any third persons without a prior consent of a person, except for the cases when this is required by law enforcement, judicial and pre-judicial institutions for their investigations or in other cases defined by laws.

12.2. The Company may disclose information about the personal data subject to the employees of the Company or other data managers, if such transfer is necessary for the fulfilment of the purposes defined herein.  

12.3. Data of the personal data subjects shall not be provided to third parties, except for the cases defined herein.

III.THE RIGHTS OF THE USER OF THE WEBSITE

13. Data protection laws provide the personal data subjects with freely exercised rights, whereas the Company shall provide the users with this opportunity.

Personal data subjects shall have the following rights:

13.1. the right to get acquaint with their personal data processed by AB Smiltynės Perkėla. Personal data subjects shall have the right to receive confirmation from the Company that AB Smiltynės Perkėla processes their personal data, also get acquaint with their personal data processed by AB Smiltynės Perkėla and information about data processing purposes, categories of data processed, categories of data recipients, data processing period, and data sources. Requests of this kind shall be answered as quickly as possible, without violating the time limits and procedure defined by laws. Data shall be delivered in writing to the address or e-mail specified by the personal data subject. Information on the sources as well as information on the user’s personal data and the purpose for which they are processed and to what data recipients this information was provided during the last year, shall be provided free of charge once per calendar year;

13.2. The right to personal data rectification. Upon the change of data submitted by the personal data subject or when the user believes that the data processed by AB Smiltynės Perkėla about him/her is inaccurate or false, then the user shall have the right to request that this data be modified, clarified or corrected. The personal data subject shall have the right to require suspension, except for storage, of personal data processing operations where the data are processed in violation of laws and the terms and conditions hereof.

13.3. The right to erasure (the right to be forgotten). When there are circumstances specified in laws (e.g. when the processing of personal data is illegal, the basis of processing of data has disappeared), the users shall have the right to request that AB Smiltynės Perkėla erase their personal data;

13.4. The right to revoke user’s consent to process personal data. When personal data are processed by AB Smiltynės Perkėla on the basis of the consent of the user, the user shall have the right at any time to revoke his/her consent and data processing based on the user’s consent shall be terminated;

13.5. The right to disagree with the processing of personal data if it is processed on a legitimate interest basis. The users shall have the right to disagree with the processing of their personal data when personal data are processed on a legitimate interest basis of AB Smiltynės Perkėla;

13.6. In order to fulfil their right, the users shall have the right to send their inquiries by e-mail pranesk@keltas.lt or call + 370 675 12091. In case of any doubts regarding identity of a person, AB Smiltynės Perkėla may request additional information for proper identification of that person;

13.7. The right to submit a claim. If the user believes that his/her data are processed by AB Smiltynės Perkėla by breaching the requirements of data protection laws, s/he shall have the right to directly appeal to AB Smiltynės Perkėla. If the user is not satisfied with the solution to the problem proposed by AB Smiltynės Perkėla, or, in his/her opinion, AB Smiltynės Perkėla shall not take necessary actions to solve the problem, the user shall have the right to submit a claim to State Data Protection Inspectorate (address: A. Juozapavičiaus str. 6, 09310 Vilnius, e-mail ada@ada.lt).

14. By using the services provided on the Website and the Mobile Application, the users confirm that they have acquainted with this Privacy Policy and at the same time grant the right to the Company to collect, accumulate, systemize, use and process personal data for the purposes specified herein.

IV. COOKIES

15. AB Smiltynės Perkėla shall collect information about the users of the Website by using cookies and similar technologies. Cookies are small textual files that are temporarily stored on the hard disc of the user and permit to recognize the user during the next visits on the Website, save a person’s browsing history, options, adapt the content, speed up the searches on the Website, create a convenient and friendly environment of the Website, provide it more effectively and reliably. Cookies is a common practice used on the websites, which makes the use of the website easier.

A cookie is a simple text file that is stored on the user’s computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie.

Each cookie is unique to web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like the preferences of the user.

The Company uses cookies as a tool for improving the functionality of the Website. In this way, the Company can offer you a better browsing experience and easier access to information of certain content.

Cookies of different types that are used on the Website are described below:

15.1. For analysis: the Company uses some cookies to collect anonymous information to help it better understand the needs of the users and ensure a consistent functioning of the Website. Some cookies will disappear from the browser settings as soon as the session on the website is ended, while others will remain in the browser settings. Some cookies used by the Company may collect and store information, such as geographic location, the device the users use, operating systems, or the browser.

15.2. For login: persistent cookies are stored on the user’s computer until they expire or are deleted. This helps the Company to recognise the users as a unique user when they return, to remember their preferences or the services provided, thereby avoiding repetitive actions.

16. Informing about the cookies used by the Company. The first time a user logs in to the website, s/he will see a message with the ‘Learn More’ link to the section of the website that contains all the information about the cookies installed and used on this website. In any case, cookies are controlled by the users; therefore, they can opt out of or remove (delete, uninstall) them at any time.

17. Consent to the use of cookies. By using the Website and clicking the ‘ACCEPT’ button in the notification line, the users confirm that they agree and allow the webmaster to record cookies onto their terminal device (computer, tablet, smartphone, etc.).

If a user selects ‘DECLINE’ at the top of the aforementioned notification line, or if the user does not select anything and continues browsing the website, only the cookies necessary for the proper functioning of the Website will be recorded onto his/her terminal device.

18. Procedure for opt out of and/or uninstall cookies. The users can control and/or uninstall cookies themselves. The users can uninstall cookies in two ways. In the user’s browser, a user can view the cookies already installed on his/her computer and delete them one by one or all at once. The steps a user needs to take are different (e.g. in the Mozilla Firefox browser, select ︙at the top right of the page, then ‘Options’ and click ‘Privacy & Security’ on the right hand side of the page, then click ‘Remove individual cookies’ in the ‘History’ section. Then, to delete all cookies at once, while in the ‘Cookies’ section, click ‘Remove all’, finally click ‘Done’ at the bottom right, and to remove cookies one by one, while in the ‘Cookies’ section, go to the relevant cookie name and click ‘Remove Selected’); therefore, specific steps to be taken are determined by the browser a user is using.

The users can also set their web browser to block cookies or notify them of the installation of any cookie. The steps a user needs to take are different in each browser; therefore, specific steps to be taken are determined by the browser the user is using. The browser can be set individually for each device the user uses.

The uninstallation or blocking of cookies used on the Website may affect the performance and some functionalities of the website, as well as have negative effects on the user’s use of the services available on the Website.

19. The types of cookies. Cookies may be ‘session cookies’ that are used only while the users are surfing the Internet and are automatically deleted when they close the browser, ‘persistent cookies’, i.e. ones stored on their terminal device (computer, tablet, smartphone, etc.) until the set cookie lifetime expires or they refuse the cookie in one of the ways described above, or ‘third-party cookies’, i.e. ones used by a party other than the webmaster.

More information about the cookies used by the Company on the Website is given below:

Cookie name

Functions performed by the cookie

Data management purpose

Moment of creation

Lifetime

 

 

pll_language

 

Saves the language selected by the user

A cookie is used to save the language selected by the user

Entering the Website

1 year

 

_ga

 

A cookie is used to collect statistical information of the Website

IP addresses and unique ID numbers are used for accounting. Accounting result is statistical.

Entering the Website

2 years and 2 months

 

_gat

 

A cookie is used to limit the number of requests delivered through Google

No information about a user is recorded

Entering the Website

1 minute

 

_gid

 

A cookie is used to collect statistical information of the Website

This cookie collects and updates information about the sub-pages of the user. More information at: https://cookiepedia.co.uk/cookies/_gid

Entering the Website

2         days

 

20. Provisions of this chapter may be changed without a separate notice as AB Smiltynės Perkėla as it follows the laws governing the use of cookies and takes into account generally accepted cookie practice.

V.PERSONAL DATA PROTECTION

21. By implementing appropriate technical and organizational measures, AB Smiltynės Perkėla shall ensure the protection of personal data against loss, unlawful use, access, disclosure or alteration.

22. AB Smiltynės Perkėla, having evaluated the risk and established a breach of data security which may cause a huge danger to persons, shall immediately inform the persons concerned.

23. Personal data subjects shall be responsible for the submission of precise, correct and comprehensive data. Upon the change of the user’s data, the user shall immediately inform the Company about such changes. The Company shall not be liable for any loss caused to the user by the fact that s/he provided incorrect or incomplete personal data or failed to inform the Company about the change of personal data.

24. AB Smiltynės Perkėla shall be liable for data security breaches under the procedure defined in laws of the European Union and of the Republic of Lithuania.

VI. FINAL PROVISIONS

25. The Privacy Policy of AB Smiltynės Perkėla may be updated. The Company shall inform the users about the updates on its Website.

26. The Privacy Policy shall be applicable since its announcement on the Website.