PRIVACY POLICY

We care about the safety of your personal data, therefore, we aim to ensure the processing of personal data with utmost transparency. We prepared the present privacy policy, which specifies the types of personal data we collect, how we acquire these data, your rights and the procedure of implementation thereof.

This privacy policy (hereinafter – the Privacy Policy) is intended for the persons using UAB „Edukacinės sistemos” products and services or visiting the website https://apix.lt.

ABOUT US
UAB „Edukacinės sistemos” is a limited liability company established and operating in accordance with the laws of the Republic of Lithuania, having its registered office at Studentų g. 3A-11, Kaunas, Lithuania (hereinafter - the Company). We are the Personal Data controllers responsible for your Personal Data. A Personal Data controller is the person who decides for what purposes Personal Data will be used. Our contact details are as follows:

Our contact information:
UAB „Edukacinės sistemos”
Studentų str. 3A-11, Kaunas, Lietuva
Phone: +37037300833
Email: info@apix.lt

If you have questions about this Privacy Policy or wish to exercise your rights, contact us by email at info@apix.lt.

1. TERMS AND DEFINITIONS USED IN THE PRIVACY POLICY
Personal data shall mean any information pertaining to a natural person, whose identity is known or may be verified (data subject); a natural person whose identity can be verified is a person whose identity can be directly or indirectly verified, first of all, according to the indicators, such as name and surname, personal ID number, location data and online identifiers, or according to one or several physical, physiological, genetic, psychological, economic, cultural or social identity indicators of that natural person.
Data subject shall mean a person who is using our products or services or visits the website https://apix.lt, contacts us regarding our products or services or for other purposes.
Request shall mean the request of the data subject regarding implementation of his/her rights.
Regulation shall mean 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).
Website shall mean the website of the Company at https://apix.lt.
The present Privacy Policy may use other terms, the definitions of which shall conform to the provisions of the Regulation.

2. GENERAL PROVISIONS
The present Privacy Policy shall not constitute our agreement with you regarding processing of your personal data. By means of the present Privacy Policy, we intend to inform you about the main principles of processing of personal data and implementation of the rights of the data subjects.
By continuing surfing the Website, using the products or services of the Company, submitting your Personal data by email or by phone, you confirm that you have familiarised with the present Privacy Policy and understand its provisions.

3. PRINCIPLES OF PERSONAL DATA PROCESSING
The processes personal data in accordance with the legal acts of the European Union and the Republic of Lithuania regulating processing of personal data.
The scope of personal data processed depends on the Company’s legal relations with the data subject or other persons, as well as the information submitted by the person visiting the Website or contacting us by email or phone.
We process your personal data only in the presence of a lawful processing criterion – upon your consent; where processing of Personal Data is mandatory under the particular legal acts; where the Personal Data must be processed for the protection of our or the third party's legitimate interests.
The aim is to process the Personal Data in an accurate, fair and lawful manner, where the data processed for the purposes they were collected for and in conformity with the clear and transparent principles and requirements of processing of the Personal Data set forth in the legal acts.

4. HOW WE OBTAIN PERSONAL DATA
We can receive the Personal Data directly from you, when you:
Contact the Company by email of by phone;
Communicate with us via social networks or simply follow Company’s activities on social networks;
The Personal Data can be generated when you are calling us, sending SMS, e-mail, and visiting the Website.
You are not obliged to provide us with any of your Personal Data, however, it is possible that in the absence of availability thereof, we will be unable to perform certain actions.


5. RECIPIENTS OF PERSONAL DATA
Your privacy is important, therefore, we shall not transfer your personal data to other persons without your consent, except to the following persons, only when it is proportionally necessary:
Auditors and other consultants;
Data processors engaged;
The state institutions, law enforcement authorities and other persons in the procedure prescribed by the legal acts of the Republic of Lithuania.
Should we disclose your personal data to the data recipient groups other than those indicated in the present Privacy Policy, we will notify you about it no later than upon the first disclosure of the data, except in cases where such information has already been presented to you in other documents provided or documented concluded with you.

6. AIMS OF PROCESSING OF PERSONAL DATA
The Company shall process your personal data for the following purposes: website traffic statistics and monitoring, website improvement, complaint examination, improvement of services.

7. GROUPS OF DATA SUBJECTS WHOSE PERSONAL DATA ARE PROCESSED BY THE COMPANY

We shall process your personal data, if you belong to any of the groups of persons listed below:
Persons who use our products or services;
Persons visiting the Website https://apix.lt;
Persons who communicate in any manner with the Company or simply follow our activities in social networks;

8. CATEGORIES OF PERSONAL DATA PROCESSES BY THE COMPANY
The following principal categories of personal data may be processed by -- -- for the aforesaid purposes of processing of personal data, including, but not limited to:
data subject's name and surname,
date of birth, age,
telephone number,
city or country,
e-mail,
service/product used,
Website browsing history and date,
other data categories.

9. RETENTION PERIOD OF PERSONAL DATA
The personal data shall be processed for a period no longer than necessary to achieve the purposes of data processing or no longer than required by the data subjects and/or provided in the legal acts.
Company shall process your personal data obtained email, phone or via the social media platforms seeking to examine your complaints or respond to feedback, monitor our online reputation for the purposes of evaluation and improvement of the quality of our services no longer than for a period of 1 (one) year of the moment of collection of such data.
Where the data subject withdraws his/her consent for processing of the data or the processing term of data expires (where the data are processed on the ground of the data subject's consent), in this case only the data confirming the facts of consent granted by the data subject shall be retained.

10. DATA PROCESSORS
Your personal data may be processed by the data processors providing website hosting, data centre and/or server rental, IT maintenance or other services to the Company.
The data processor shall have the right to process the personal data only according to the Company’s instruction and only in the scope necessary seeking adequate implementation of the obligations established in the contract. By engaging the data processors, Company seeks to ensure that the data processors have implemented the suitable measures ensuring organisational and technical security and protect secrecy of personal data.

11. YOUR RIGHTS PERTAINING TO THE PERSONAL DATA
As a data subject, you shall have the following rights indicated in the present section.

A. The right to know (be informed) about processing of your personal data
When we receive information directly from you, we shall inform about processing of personal data at the moment of receipt of the data:
a) verbally (where communication with you is carried out by verbal means exclusively, e.g., on the phone);
b) in writing (information sent to you by e-mail shall be considered to have been provided in writing).
If we receive your data not directly from you, we shall inform you about processing of personal data verbally or in writing (as specified above) no later than within 1 (one) month of receipt of the data, and where we use your personal data to maintain communication with you – no later than at the moment of the first contact with you.

B. The right to familiarise with own personal data and a manner in which they are processed
You shall have the right to receive information on the retention period of personal data, information on the sources used to collect personal data, type of data collected, the purposes the data are processed for and who has access to the data.
Upon receipt of your request, we shall immediately, however, in any case no later than within 1 (one) month of the receipt of the request, verify whether your personal data are processed by the Company. Having established that we process your personal data, we shall provide to you the information on the personal data processed and a copy of the personal data in an electronic format or on a paper medium.
We shall be entitled, whenever necessary, to extend the response period depending on the complexity and number of your requests. We shall inform you about it by a separate notification. If we decide to extend the response period, you must contact the State Data Protection Inspectorate regarding such extension.
Normally, the information shall be provided free of charge. However, if your requests are obviously unsubstantiated or unreasonable, primarily due to their repeated content, or, if you prefer to receive a copy of the personal data processed in a format other than the electronic or paper form prepared by the Company, the Company may charge a fee comprising the expenses incurred by the Company due to provision of information or administration of the notification or actions requested.
Moreover, if your requests are obviously unsubstantiated or unreasonable, we shall have the right to refuse to execute your request.
Upon your request, the information may be provided verbally, allowing you to familiarise with the document by presenting a statement, document extract or a paper copy of the document or an electronic medium attached to the reference file. If you do not indicate the format for provision of information, we shall present the information to you in the same format as the request received.

C. The right to request correction of personal data or termination of processing of such personal data, if, upon familiarisation with your personal data you established that the data are incorrect, incomplete or inaccurate
The Company shall inform you immediately about performance or non-performance of correction, destruction or cancellation of processing of personal data initiated upon your request. We shall also notify the data recipients about personal data corrected or destroyed, data processing actions terminated upon your request, except in cases where provision of such information is impossible or exceedingly difficult. In this case, upon your request, we shall provide you the information pertaining to such data recipients.

D. The right to destroy personal data or restrict the data processing actions in the even where, upon familiarising with own personal data, the data subject determines that the personal data have been processed unlawfully or fraudulently

The Company shall notify you immediately about implementation or non-implementation of the data processing restrictions.
The personal data, the processing of which is restricted, shall be retained. Prior to removing the restrictions, we shall notify you about it by electronic means of communication. We shall also notify the data recipients regarding the restricted processing of data implemented upon your request, unless this proves impossible or involves a disproportionate effort. In this case, upon your request, we shall provide you the information pertaining to such data recipients.

E. The right not to consent to processing of your personal data, except in cases where these personal data are processed for the legitimate interest sought by the data controller or the third party these personal data are provided to, and where the interests of the data subject are not more important
If you express objection to processing of your personal data, the processing of thereof shall be performed only where it has been reasonably deemed that the reasons the processing of personal is performed take priority over your interests, rights and freedoms, or if your personal data are required to declare, implement or protect legal requirements.

F. The right to withdraw the consent for processing of personal data
You shall have the right to withdraw all your consents for processing of personal data at any time, if the ground for processing of your personal data is the consent provided to the Company upon your discretion.

G. The right to delete the data (the right “to be forgotten”)

You shall have the right to demand that the Company delete any personal data pertaining to you on the grounds prescribed in part 1 of the Regulation.
We shall have the right to refuse to comply with your request in cases prescribed by the legal acts, including, but not limited, to the cases described in Article 17(3) of the Regulation.
If we comply with your request, however, your personal data (deleted upon your request) have been transferred to the data recipients, we shall inform such data recipients, unless this proves impossible or involves a disproportionate effort. In this case, upon your request, we shall provide the information pertaining to such data recipients.
This right cannot be exercised, where we are obliged to retain the personal data according to law.

H. The right to data portability
You shall have the right to demand that the personal data you provided, if they are processed on the grounds of consent or contract, and where they are processed with the help of automated means, are transferred to another data controller or presented to you in a systematised, commonly used and computer-readable format, whenever technically possible. When contacting us to exercise the right to data portability, you shall indicate whether you prefer that your personal data are transferred to you or to another data controller.
You shall not have the right to portability of the personal data, which are processed in a non-automated manner by systematised media, such as paper files.
The personal data transferred upon your request shall not be automatically deleted. If you would like your data to be deleted, you shall contact the Company regarding the execution of the right to demand to delete the data (“right to be forgotten”).

I. The right to object to processing of data exclusively in an automated manner, including profiling, being applied in respect of the data subject
You shall have the right to know and be informed about the logic, according to which the personal data are processed automatically, and the possible consequences of such processing of personal data, where the data are processed exclusively in an automated manner.
If you contact us regarding the review of the decision concerning the automated data processing (if such were to be adopted by the Company in your respect) we shall conduct a thorough evaluation of the significant data, including the information you provided.

J. The right to lodge a complaint to the State Data Protection Inspectorate or a competent court regarding processing of personal data
You can appeal our actions related to implementation of the rights of the data subject or omission thereof to the State Data Protection Inspectorate, address A. Juozapavičius g. 6, Vilnius, e-mail: ada@ada.lt, website: www.ada.lt, as well as to a competent court of the Republic of Lithuania. You shall have the right to appeal the actions of the Company or omission thereof personally or through a duly authorised representative or a non-profit institution, organisation or association conforming with the requirements of Article 80 of the Regulation.

K. The right to compensation of damages suffered due to violation of the data subject's rights
You shall be entitled to compensation of pecuniary and non-pecuniary damages, for the award of which, you must contact a competent court of the Republic of Lithuania.

12. PROCEDURE OF CONTACTING THE COMPANY REGARDING IMPLEMENTATION OF THE RIGHTS OF THE DATA SUBJECT
You shall be entitled to contact us regarding implementation of the data subject's rights verbally or in writing, by submitting a request personally, by post or electronic means using the contact details provided in the present Privacy Policy.
If you contact us verbally regarding implementation of the data subject's rights or submit a written request personally, you must confirm your identity by producing an ID document. If you fail to do so, we will be unable to accept your request and your rights of the data subject shall not be implemented. This provision shall not apply, if you contact us regarding information on the processing of personal data on the grounds of Articles 13 and 14 of the Regulation.
If you decide to submit a written request regarding implementation of the data subject's rights by sending your request by post, you shall be obliged to provide together with the request a copy of the ID document certified by a notary public or in another procedure prescribed by the legal acts.
If your personal data, such as the name and surname, have been changed, you shall also provide the copies of the documents confirming the change of these data; if they are sent by mail, the copies must also be certified by a notary public or in another procedure prescribed by the legal acts.
If you decide to submit the request by electronic means, the request shall be endorsed by a qualified electronic signature or generated by electronic means, which allow to ensure that the text is integral and indelible. This provision shall not apply, if you contact us regarding information on the processing of personal data on the grounds of Articles 13 and 14 of the Regulation.
The request for implementation of the data subject's rights shall be legible, endorsed, and include your name, surname, address and/or other contact details for communication or where the response regarding implementation of the data subject's rights shall be sent to.
You shall be entitled to implement your rights personally or through a representative. If you decide to implement your rights through a representative, your representative shall indicate in the request his/her name, surname, address and/or other contact information for communication, to which your representative prefers to receive the response, as well as your name and surname, and provide other data necessary for proper identification of the data subject, and present a document confirming authorisation for representation or a copy thereof.
Should there be any doubts as to your identity and data, we shall have the right to request additional information necessary for verification thereof.
For all questions related to management of the personal data of a data subject and exercise of your rights, you should contact us.
If you contact us in prejudice to the procedure indicated in the present section, we shall inform you about it no later than within 7 (seven) calendar days of the date of receipt of your request and state the inconsistencies. If you fail to rectify the inconsistencies indicated or fail to provide the reasons to the Company why the inconsistencies indicated cannot be eliminated, your request shall not be examined.
In the presence of objective circumstances, due to which the said inconsistencies cannot be rectified, upon assessment of the circumstances, we could decide to accept and examine your request.
We shall not consider that your request has been submitted with inconsistencies, where your written request does not conform to the request format specified in the present section of the Privacy Policy.

13. ENSURING DATA SECURITY
Company implements appropriate organisational and technical data security measures, including protection against unauthorised processing of data or illegal processing of data, and accidental loss, destruction or damaging (integrity and confidentiality principle) thereof. The access to the personal data shall be granted only to those employees, service providers and authorised data processors, who require access thereto for performance of the job functions or provision of services.

14. COMPANY’S SOCIAL MEDIA ACCOUNTS
The Company has created and manages the social media accounts on LinkedIn and Facebook. All information you provide via the social media means on LinkedIn and/or Facebook (including notifications, use of ‘Like’ and ‘Follow’ buttons, and other communication), or which is received when you view our social media accounts (including information received through the use of cookies by the social network operators), shall be controlled by the social network operators. We recommend reading the privacy notifications of the social network operators and contacting them directly regarding the use of your personal data.
Facebook social network operator collects information on the type of content you view, your actions on Facebook social network, what persons you communicate with, how often and how long you have been communicating with them, your activity level on the social network and other information, including information on the end device you use. To learn more about the privacy policy of Facebook operator go to https://www.facebook.com/policy.php.

15. COOKIES
We use cookies seeking to improve your website experience – cookies are small elements of information created automatically during the Website browsing and stored on your computer or another end device.
Information collected allows us to ensure enhanced comfort while surfing the Website, make offers and learn more about the conduct of our Website users, analyse trends and improve both the Website and services provided, save your completed or incomplete reservations allowing you to return to them later. If Company’s Website contains links to other websites , which also use cookies, these have not been described herein.
Where the functional, tracking, advertising cookies and/or third party cookies are created, we shall ask for your consent. When necessary cookies are created, we shall use them on the ground of legitimate interest, which shall not require your consent for the use of such cookies.
If we receive your consent, when using the same cookie for the same purposes in the future, we shall not ask for your consent again. This also applies in the respect of using the third party cookies.
If you do not consent to cookies being stored on your computer or another end device, when we ask for your consent to store cookies, you can change your internet browser settings and disable all cookies, or to enable/disable them one by one. However, please be advised that, in certain cases, deleting cookies might slow down the browsing speed, limit certain functions of the Websites or block access to the Website.

16. STATISTICS
The Website visitor statistics shall be analysed with the help of Google Analytics. The information collected by Google Analytics cookies about our Website browsing history can be transferred and stored on the servers beyond the borders of the European Union.

17. OTHER PROVISIONS
By contacting us you express your will to allow the Company to contact you regarding your enquiry.
The enforcement and interpretation of the Privacy Policy shall be governed by the laws of the Republic of Lithuania. The Company may modify the present Privacy Policy upon its discretion, which shall come into force as of the moment of its publication on the Website https://apix.lt.

The present Privacy Policy has been updated on 4th of January, 2021.