Privacy policy
Privacy policy Estonia
Privacy policy Latvia
Privacy policy Lithuania
Last updated: January 28, 2022
Last updated: January 28, 2022
Last updated: January 28, 2022
Last updated: January 28, 2022
1. GENERAL PROVISIONS
1.1. We care about your privacy and the security of your personal data, therefore we have created the present Privacy Policy (hereinafter referred to as the “Privacy Policy”), which explains how we process and protect your personal data, what your rights are secured, and provides other information about the processing of your personal data.
1.2. As used in this Privacy Policy, the term “personal data” (hereinafter referred to as the “Personal Data”) means any information or set of information by which we may directly or indirectly establish your identity, such as your name, surname, e-mail address, telephone number, etc.
1.3. When processing your Personal Data, we comply with the provisions of the General Data Protection Regulation No. 2016/679 (ES) (hereinafter referred to as the GDPR) and the requirements of the legal acts of the Republic of Lithuania, as well as the instructions of the controlling authorities.
1.4. The Privacy Policy applies when you visit our website, available at triniti.eu/lt (or www.triniti.lt which redirects you to before-mentioned web domain) (hereinafter referred to as the “Website”), our social network accounts on Facebook and LinkedIn (hereinafter referred to as the “Social Network Accounts”), review the information we provide, enter into a legal services agreement with us, and we provide you with legal services, register and seek to use, use our Dispute Success Index or No Surprises (hereinafter referred to collectively as the Services) services, supply or provide us with your goods or services, register and participate in events organised by us, subscribe to our newsletter, contact us by phone, e-mail communication channels, asking other questions, applying for a job we offer, etc.
1.5. The Website may contain links to external websites, such as the websites of our business partners or websites promoting us and our Services. By following such links to any of these websites, please note that these websites have their own separate privacy policies and that this Privacy Policy does not apply to them. Please review their privacy policies before submitting your Personal Data to these websites or using their offers.
1.6. Please be advised that this Privacy Policy is subject to change, therefore please visit the Website from time to time to read the latest version of the Privacy Policy published.
2. WHO ARE WE?
2.1. The controller of your Personal Data is Law Firm TRINITI, legal entity code 302633203, address Vilniaus g. 31, LT-01402 Vilnius, Lithuania, data are collected and processed in the Register of Legal Entities of SE “Registrų centras” (hereinafter referred to as TRINITI or we).
2.2. We operate the Website and Social Network Accounts, and we act as your controller of your Personal Data by offering and providing the Services, performing our day-to-day operations or complying with legal requirements.
3. WHICH OF YOUR PERSONAL DATA ARE WE PROCESSING?
3.1. We are processing your Personal Data obtained in the following ways:
3.1.1. When you provide us with Personal Data, for example, you enter into an agreement with us, receive our Services, participate in events organised by us, contact us by e-mail or phone, subscribe to our newsletter, etc.;
3.1.2. When we collect your Personal Data during your use of the Website, Social Network Accounts, such as your IP address, history of visits to the Website, choices, URL links opened, etc. automatically.
3.1.3. When we receive the Personal Data from other persons, such as when we receive information about payments made, etc. from public registers, state or local government institutions or bodies, our partners, for example, other third parties, such as payment institutions.
3.1.4. When your Personal Data is provided to us by your relatives or acquaintances with your consent, as well as when your data is provided by companies (your employers), for example, specifying your contact information referring to you as an authorised person, etc.
3.2. We process your Personal Data in order to offer and provide you with the Services, to fulfil our contractual obligations, as well as to pursue our or third parties’ legitimate interest in carrying out instructions or obligations prescribed by the legal acts.
3.3. By providing Personal Data to us, you are responsible for the accuracy, completeness and relevance of such Personal Data. When providing us with their personal data, a person must provide complete, complete and correct information about themselves. If we are provided with inaccurate, false or misleading Personal Data, we have the right to delete such data or restrict access to the Website, the Services and so on.
3.4. When providing the Personal Data about other persons (e.g. your relatives, employees, other authorised persons), you shall be responsible for the accuracy, completeness and relevance of such Personal Data, as well as for such person’s consent to the disclosure of his or her Personal Data to us. When you provide such data, we may ask you to confirm that you have the right to provide it. If necessary (for example, such a person inquires us about the receipt of his or her Personal Data), we will identify you as the provider of such data.
3.5. We process your Personal Data for the following purposes and under the following conditions:
| Purpose of processing of the Personal Data | Personal Data being processed | Terms of processing of the Personal Data | Legal basis for the processing of Personal Data |
| Provision of legal services, consultations before concluding a contract for the provision of legal services | Name, surname, date of birth, personal identification number, individual activity certificate number, VAT payer code, signature, address / workplace address, telephone number, e-mail address, data of other communication channels (Skype, Facebook Messenger account data, etc.), place of work, position held, data related to the object of performance of the concluded legal services contract – contracts, procedural documents, company performance documents, financial documents, correspondence of any kind, decisions of state / local self-government institutions, courts, other similar institutions, any communication, extracts from registers, other documents and information), including data on persons other than the client (client’s representatives) (contractors, litigants, partners, information on the client’s activities, personal life, data on minors (when they are customers or when the provision of services requires such information), etc., data on the health of persons, religious beliefs, sexual orientation, data on the criminal record of persons, if directly related to the provision of legal services, name, surname of parents, guardians, caregivers, relation of these persons with the client, correspondence (e-mail correspondence, mail correspondence), the content of the power of attorney to represent the person, as well as other Personal Data presented or required for the provision of legal services | For the entire period of provision of legal services and 10 (ten) years after the end of the provision of services (last contact), unless a longer mandatory minimum retention period would apply in accordance with the General Document Retention Time Index approved by Order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011.If the Personal Data is processed on the basis of consent – for the period of validity of the consent, and if the consent to process Personal Data is revoked earlier, then the Personal Data shall be retained until the expiry of the consent | Processing of the data is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)The processing is necessary for fulfilment of a legal obligation imposed on the controller (Article 6 (1) (c) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR)The data subject has explicitly consented to the processing of his or her special categories of personal data for one or more of the specified purposes (Article 9 (2) (a) of the GDPR)Processing of special categories of personal data which are manifestly made public by the data subject (Article 9 (2) (e) of the GDPR)Processing of special categories of personal data is necessary for the establishment, exercise or defence of legal claims (Article 9 (2) (f) of the GDPR) |
| Provision of the No Surprises service | Name, surname, position, place of work, address of the place of work, telephone number, e-mail address, content of the power of attorney to represent the person, communication details, information about the ordered services | For the entire period of provision of services/validity of the agreement/maintenance of relations and 10 (ten) years after the end of the agreement/relations, unless a longer mandatory minimum retention period would apply in accordance with the General Document Retention Time Index approved by Order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011. | Processing of the data is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Provision of the Dispute Success Index service | Name, surname, telephone number, e-mail address, organisation represented, data presented in the description of the subject matter of the dispute | Personal Data and documents are retained for the entire period of the provision of the Services and for 10 (ten) years after the end of the provision of the ServicesFinancial and other documents for which legal acts establish special retention periods shall be retained for the periods specified by legal acts | Processing of the data is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Conclusion and performance of agreements necessary for the performance, administration and maintenance of the business, as well as our business-related internal administration, other than employment relations | Name, surname, personal identification code (if such information is required to be collected), individual activity certificate number, position, place of work, signature (in contracts, other documents), address / address of the place of work, telephone number, e-mail address, correspondence (e-mail, mail correspondence), content of the power of attorney to represent the person, information on the qualifications of the party to the contract, transaction and / or their employees | For the entire period of cooperation / validity of the agreement and 10 (ten) years after the termination of the cooperation / agreement (last contact), unless a longer mandatory minimum retention period would apply in accordance with the General Document Retention Time Index approved by Order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011. | Processing of the data is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Execution of financial operations and bookkeeping, management of material and financial resources, management of debts, fulfilment of tax obligations (other than employment relations), management of payments for the Services | Name, surname, personal identification number (if such information is required to be collected), individual activity certificate number, position, place of work, signature (in contracts and similar documents), address / address of the work place, e-mail address, telephone number, account number, credit / payment institution, payment details, VAT payer code, information presented in tax returns, other official tax documents, history of arrears, history of their payment and other information, e-mail messages received and sent as well as their attachments, other e-mail messages, the content of the power of attorney to represent the person | According to the legal acts regulating financial transactions and accounting, as well as pursuant the General Document Retention Time Index approved by Order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011The data that does not fall within the scope of retention of the above-mentioned legal acts shall be retained for the entire period of validity of the contract or cooperation between the parties and for 10 (ten) years after the end of the contract / relations (last contact) | Processing of the data is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)Processing of the data is necessary for fulfilment of a legal obligation imposed on the controller (Article 6 (1) (c) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Management, securing of operation and quality improvement of electronic information submission channels (the Website, the Social Network Accounts) | Data collected using the website cookies, IP address, data collected automatically by the accounts of social networks Facebook, LinkedIn | Website data is retained for up to 2 (two) yearsthe information is retained on Facebook and LinkedIn accounts in accordance with the conditions set by the owners of these networks | Consent of the data subject to such processing of the data (Article 6 (1) (a) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Administration of queries received through electronic information delivery channels, by telephone and e-mail | Name, surname, user account name, other account information, phone number, email address, address, address / address of the work place, name of the company being represented, position, topic of the query, content of the query | Data related to the queries is retained for the entire communication period and 1 (one) year after the end of the communicationIf the Personal Data is processed on the basis of consent – for the period of validity of the consent, and if the consent to process Personal Data is revoked earlier, then the Personal Data shall be retained until the expiry of the consent | Consent of the data subject to such processing of the data (Article 6 (1) (a) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Organisation and conducting of events, including invitations for persons to the events and informing them about the events | Name, surname, telephone number, e-mail address, organisation represented, image data (image captured by capturing moments of the event) | Data is retained for the entire period of organisation and execution of the event and 1 (one) year after the date of the eventIf the Personal Data is processed on the basis of consent – for the period of validity of the consent, and if the consent to process Personal Data is revoked earlier, then the Personal Data shall be retained until the expiry of the consent | Consent of the data subject to such processing of the data (Article 6 (1) (a) of the GDPR)Processing of the data is necessary for the conclusion and performance of the contract (Article 6 (1) (b) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Execution of direct marketing, presentation and publicity of our activities and analysis of the quality of our activities | Name, surname, telephone number, e-mail address, position, organisation represented | Data is retained for 5 (five) years from the date of receipt, unless the person withdraws his or her consent. The personal data shall then be retained until the expiry of the validity of the consent | Consent of the data subject to such processing of the data (Article 6 (1) (a) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
| Evaluation, selection and data processing of data of candidates for the offered job in order to offer a job in the future | Name, surname, telephone number, e-mail address, address / address of the place of work, education and activity data, content of the CV, other information required for the selection / evaluation of the candidate or the information provided by the candidate itself | Data is retained for the entire period of the selection and for 3 (three) months after the end of the selection (if the consent of the data subject has been obtained), unless the person revokes his or her consent earlier | Consent of the data subject to such processing of the data (Article 6 (1) (a) of the GDPR)Legitimate interests of the controller or of a third party (Article 6 (1) (f) of the GDPR) |
| Judicial and extrajudicial processing of requests, complaints, claims, disputes, formal inquiries related to Our activities | Name, surname, personal identification number (if required or provided by the person) position, place of work, signature on documents, address/ address of the place of work , telephone number, e-mail address, contents of the request, complaint, demand, claim, procedural document and the enclosures accompanying such documents, response to the request, complaint, demand, claim, procedural document and the enclosures accompanying such documents | For the entire period of extra-judicial hearing of requests, complaints, demands, claims, disputes and 3 (three) years after the end of the administration of the query, unless a longer mandatory minimum retention period would apply in accordance with the General Document Retention Time Index approved by Order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011.Documents of judicial disputes shall be kept for the entire period of the dispute and for 10 (years) after the final decision enters into force, unless a longer mandatory minimum retention period would apply in accordance with the General Document Retention Time Index approved by Order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011 | For compliance with a legal obligation to which the controller is subject (Article 6 (1) (c) of the GDPR)Legitimate interests of the controller or a third party (Article 6 (1) (f) of the GDPR) |
You have the right to refuse or withdraw your consent to the processing of your data at any time when the data is processed on the basis of your consent.
3.6. In some cases, we may send you messages related to the provision of the Services or call you, for example, we may inform you about the performance of the Services, etc. Such messages are necessary for the proper provision of the Services and shall not be considered promotional messages.
3.7. We publish information about ourselves and our activities in Social Network Accounts. In addition to this Privacy Policy, the users of Social Network Accounts are also subject to the privacy policies and policies of the managers of social networks that contain Social Network Accounts. When you contact us on Social Network Accounts, we may see certain information about your account, depending on the social network privacy settings you choose. If you post information by communicating with us on Social Network Accounts, depending on the privacy settings you choose, the information you post may be made public (for example, displayed on our specific Social Network Account).
3.8. You have the right to change and update your information provided to us. In some cases, we need to have accurate, up-to-date information about you, so we may ask you to periodically confirm that the information we have about you is correct.
4. HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE APPLY?
4.1. We collect and process only such Personal Data which is necessary to achieve the purposes of the Personal Data processing we have specified.
4.2. When processing your Personal Data, we:
4.2.1. Comply with the requirements of effective and applicable legislation, including the GDPR;
4.2.2. Process your Personal Data in a lawful, fair and transparent manner;
4.2.3. Collect your Personal Data for specified, clearly defined and legitimate purposes and do not process it in a way incompatible with those purposes, except to the extent permitted by law;
4.2.4. Take all reasonable steps to ensure that Personal Data that is inaccurate or incomplete, in accordance with the purposes for which it is processed, would be rectified, supplemented, suspended or deleted without delay;
4.2.5. Keep it in such a form that your identity can be established for no longer than it is necessary for the purposes for which the Personal Data is processed;
4.2.6. Do not provide the Personal Data to third parties or disclose it, in other ways than as set forth in the Privacy Policy or applicable law;
4.2.7. Ensure that your Personal Data is processed securely.
5. TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?
5.1. We will only transfer your Personal Data as described in this Privacy Policy.
5.2. We may transfer your Personal Data to:
5.2.1. Our partners or consultants, such as auditors, other attorneys, tax consultants, etc., as well as Personal Data processors invoked by us, such as ancillary service providers, IT companies, advertising and marketing service companies, archive service providers, accounting services companies, companies providing insurance services or collecting payments, etc. We require the data processors to retain, process and handle the Personal Data as responsibly as we do and only in accordance with our instructions. You can find a list of our partners here:
5.2.1.1. Advertising, marketing – UAB We Are Marketing (Lithuania);
5.2.1.2. Accounting and financial services – UAB BDO auditas ir apskaita (Lithuania);
5.2.1.3. IT solutions – UAB Simplit (Lithuania);
5.2.1.4. Telecommunication services – AB Telia Lietuva (Lithuania).
5.2.2. In order to publish your content to Social Network Accounts, we provide the data to the following social network platform operators:
5.2.2.1. LinkedIn Ireland Unlimited Company (Ireland) and LinkedIn Corporation (USA) (the data shall be securely transferred upon signing by the service provider the standard contractual clauses for data transfers outside the EEA, approved by the European Commission);
5.2.2.2. Facebook Ireland Ltd. (Ireland) and Facebook, Inc. (US) (the data shall be securely transferred upon signing by the service provider the standard contractual clauses for data transfers outside the EEA, approved by the European Commission);
5.2.3. State or local self-government institutions and establishments, law enforcement and pre-trial investigation institutions, courts and other dispute resolution institutions, other persons performing functions assigned by law, in accordance with the procedure provided for by legal acts of the Republic of Lithuania.
5.2.4. Our partners in other countries (if required for the provision of the Services) who provide legal services;
5.2.5. Other third parties (such as payment institutions, etc.);
5.2.6. If necessary, to companies that would cooperate with us or cooperate in another form, as well as to companies established by us.
5.3. We normally process Personal Data in the EEA, but in some cases your Personal Data may be transferred outside the EEA. Your Personal Data will only be transferred outside the EEA under the following conditions:
5.3.1. The data is transferred only to our trusted partners, with whom we have signed standard contractual clauses approved by the European Commission, which ensure the security of your Personal Data;
5.3.2. A special permit has been obtained from the State Data Protection Inspectorate of the Republic of Lithuania to carry out such a transfer;
5.3.3. The European Commission has taken a decision on the suitability of the country in which our partner is established, i.e. an adequate level of security is ensured; or
5.3.4. You have given consent to the transfer of your Personal Data outside the EEA.
6. WHAT DO WE EXPECT FROM YOU WHEN YOU PROCESS THE PERSONAL INFORMATION WE PROVIDE?
6.1. When you receive personal data from us during the provision of the Services or cooperation with us, you agree to:
6.1.1. comply with the GDPR and other laws governing the processing of the Personal Data and cooperate with us in order to enable us to fulfil our obligations under the said legal acts;
6.1.2. no later than within 4 hours from the incident having occurred, notify us about the personal data security breach related to the Personal Data transferred to you, by specifying at least the circumstances of the breach and the measures taken to mitigate the consequences of the breach.
6.2. When you provide us with Personal Data in the course of cooperation, you agree to:
6.2.1. inform all natural persons whose Personal Data you transfer (employees, agents, members of the management bodies, other persons), to the extent provided by the GDPR and before the transfer of the Personal Data, that their Personal Data may be transferred to us and may be processed by us for the conclusion and/or performance of the contract between you and TRINITI, and, upon our request, provide evidence to that effect without delay;
6.2.2. notify us of the obligation to update, delete or restrict the processing of the Personal Data transferred;
6.2.3. not to transfer to us the Personal Data of any persons who have not been notified of the processing of their data by us.
7. WHAT RIGHTS DO YOU HAVE?
7.1. As a data subject, you have the following rights with regard to your Personal Data:
| Your right | Implementation and certain restrictions (depending on the situation and additional conditions imposed by the GDPR) |
| Be aware (informed) about the processing of your Personal Data (right to be aware); | You have the right to receive information about the processing of your Personal Data in a concise, simple and comprehensible language. |
| Access to your Personal Data and be aware of how they are processed (right of access) | This right means that you can ask us to provide you with:· Confirmation that we are processing your Personal Data;· A list of your Personal Data being processed;· A list of the purposes and legal basis of the processing of your Personal Data;· A confirmation whether we are sending Personal Data to third countries and, if so, what safety measures have been taken;· The source of your Personal Data;· The information on whether profiling is applied;· The indication of the data retention period.We will provide the above information provided that this does not infringe on the rights and freedoms of others. |
| Right to request rectification or, depending on the purposes of the processing of personal data, supplementation of you incomplete Personal Data (right of rectification) | Applicable if the information we hold about your Personal Data is incomplete or inaccurate. |
| Require the erasure of your Personal Data or the suspension of the actions of processing of your Personal Data (except for retention) (the right to erasure and the right “to be forgotten”); | Applicable if:· The information we have is no longer needed to achieve the stated purposes;· We process the data with your consent and you withdraw your consent;· We process the data on the basis of legitimate interests and it is established, upon your request, that your private interests prevail;· The information has been obtained unlawfully. |
| Require us to restrict the processing of Personal Data for one of the legitimate reasons (right to restriction) | This right can be exercised for the period when will be analysing the situation, i.e.:· If you dispute the accuracy of the information;· If you object to the processing of Personal Data when it is done on the basis of a legitimate interest;· We are using the information unlawfully, but you object to its deletion;We no longer need the information, but you are asking to retain it for the purpose of litigation. |
| Right to data portability | This right can be exercised if you have provided your data and we process it in an automated manner based on your consent or a contract concluded with you. |
7.2. If you do not want your Personal Data to be processed for direct marketing purposes, including profiling, you can opt out of such processing without giving reasons for your refusal (opposition) by writing an e-mail to info@triniti.lt or in any other way specified in the message provided to you (for example, by clicking on the relevant link in the newsletter).
7.3. We may waive your rights listed above, except for refusing to process your Personal Data for direct marketing purposes or in other cases where the Personal Data is processed with your consent, where the provisions of the GDPR allow us to disregard your request or where in the cases provided for in the laws it is required to ensure the prevention, investigation and detection of crimes, violations of official or professional ethics, as well as the protection of the rights and freedoms of the data subject, us and others.
7.4. You may submit any request or instruction related to the processing of the Personal Data to us in writing by e-mail info@triniti.lt. When making such a request, we may, in order to better understand the content of your request, ask you to complete the necessary forms, as well as provide an identity document or other information (e.g., to confirm your identity with an electronic signature) that will help us verify your identity. Upon request by e-mail, depending on its content, we may ask you to come to us or make a written request.
7.5. Upon receipt of your request or instruction regarding the processing of the Personal Data, we will, no later than within 1 month from the date of the request, provide a response and carry out the actions specified in the request or inform you on the reason behind our refusal to perform them. If necessary, the specified period may be extended by a further 2 months, depending on the complexity and number of applications. In this case, we will notify you of such an extension within 1 month of the date of receipt of the request.
7.6. We undertake to make every effort to respond to your requests in a timely manner and free of charge, except to the extent that it requires a disproportionate effort. We may charge a reasonable fee if your requests are manifestly unfounded, repetitive, or excessive.
7.7. If the Personal Data is deleted at your request, we will retain only copies of information that is necessary to protect the legitimate interests of us and other persons, to comply with the obligations imposed by governmental authorities, to resolve disputes, to identify disruptions, or to comply with any agreements you have concluded with us.
8. WILL WE BE SENDING YOU UPDATES?
8.1. With your consent, we may use your Personal Data for direct marketing purposes to provide you with newsletters, offers and information about our activities and Services that we believe may be of interest to you, as well as information about the quality of the Services we provide.
8.2. Updates can be sent by e-mail specified by you. After receiving your consent, we may inquire by e-mail about the quality of our Services, as well as invite you to fill out quality assessment forms. Your contacts may be passed on to our partners / managers who provide us with news delivery or quality assessment services.
8.3. We will do our best not to abuse the right to share the updates you have given to us. After sending the updates, we may collect information about the people who received it, for example, which message the people opened, what links they clicked on, and so on. Such information shall be collected in order to offer you relevant and better tailored updates.
8.4. Even if you have given your consent to the processing of Personal Data for direct marketing purposes, you can easily revoke this consent at any time for all or part of your Personal Data Processing activity. In order to do this, you may:
8.4.1. notify us of your opt-out in the manner specified in the electronic notices and / or offers (for example, by clicking on the “unsubscribe” link in the newsletter, etc.); or
8.4.2. send us a notification to the email address specified in this Privacy Policy. If you request to withdraw consent in this way, we may ask you to verify your identity.
8.5. Withdrawal of the consent shall not automatically oblige us to delete your Personal Data or provide you with information about the Personal Data processed by us, therefore you must make such a request separately in order for us to take these steps as well.
9. HOW DO WE PROTECT YOUR PERSONAL DATA?
9.1. Your Personal Data shall be handled responsibly, securely and is protected from loss, unauthorised use and alteration. We have put in place physical and technical measures to protect the information we collect from accidental or unlawful deletion, damage, alteration, loss, disclosure, as well as from any other unlawful processing. Security measures for the Personal Data shall be determined taking into account the risks arising from the processing of the Personal Data.
9.2. Our employees have signed a written undertaking not to disclose or distribute your Personal Data to third parties, unauthorised persons.
9.3. The Personal Data being processed by us shall be processed by our employees as well as by advocates and assistant advocates who provide services to us under a service agreement.
10. HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
10.1. Cookies are a small text file that stores information (often made up of a sequence of numbers and letters that identifies a device, but may contain other information) that is used in a browser of a device (computer, tablet, mobile phone, etc.) (e.g. Google Chrome, Internet Explorer, Firefox, Mozilla, Opera, etc.) according to its settings and saved on your device’s hard disk. In the Privacy Policy, we use the term “cookies” to describe cookies and other similar technologies, such as pixel tags, web beacons, and clear gifs. The use of cookies ensures better and more efficient operation of the Website, as well as integrations with Social Network Accounts.
10.2. You can choose whether you want to accept cookies or not. If you do not agree to the saving of cookies on your computer or another device, you can check the box on the cookie consent bar, change the settings of the browser you are using and disable cookies (all at once or one by one, or in groups). To opt out of cookies on your mobile device, you must follow the official instructions for that device. Please note that in some cases opting out of cookies may slow down your browsing experience, limit the functionality of certain websites or block access to a website. For more information, visit http://www.AllAboutCookies.org or http://www.google.com/privacy_ads.html or .http://www.google.com/privacy_ads.html.
10.3. We may use mandatory cookies that are necessary for the operation of the Website, analytical cookies, functional cookies to analyse website traffic, memorise user preferences and adapt them to the Website so that we can provide enhanced functionality, performance cookies, third-party cookies used by third parties, advertising cookies to serve you personalised and general advertising.
10.4. We use the following Google Inc. products that store cookies:
10.4.1. Google Analytics – analyses how you use the Website, generates reports based on that analysis, and helps you plan and anticipate the operation of the Website. The data collected by Google Analytics is typically transferred to and stored on a Google Inc. server in the United States. You may change your browser settings to prevent Google Analytics from analysing your information. In this case, you will receive a opt-out cookie. However, if you delete all cookies, the opt-out cookie may be deleted as well. You can also prevent Google from capturing data by downloading and installing a browser plug-in from https://tools.google.com/dlpage/gaoptout?hl=en.
10.4.2. Google Tag Manager – performs the analysis of the use of the Website. The information we collect about your use of the Website (along with your IP address) is transferred to and stored on a Google server in the United States. This information is used to analyse the use of the Website, to prepare reports on the popularity of the Website, to provide other services related to the Website and its use. Google may transfer this information to third parties where required to do so by applicable law, or where such third parties are processing the information on Google’s behalf. Google will not associate your IP address with any other data retained by Google. More information: https://support.google.com/tagmanager/answer/9323295?hl=en.
10.4.3. Google Remarketing – enables the users to re-receive ads on the websites of the Google Inc. partner network. If you do not wish to receive customised advertising and/or wish to opt out of Google Inc.’s cookies, you can disable Google Inc.’s advertising settings at https://www.google.com/settings/ads by changing your settings as needed. In this case, you may receive a opt-out cookie. However, if you delete all cookies, the opt-out cookie may be deleted as well
10.5. Other tools we use:
10.5.1. Facebook Pixel – is used for remarketing purposes so we can get back to you within 180 days. This allows us to display interest-based advertising (Facebook Ads) to you when you visit the social network Facebook or other websites that also use this tool. In this way, we try to show you the advertisements that interest you to make our site or offers more interesting for you. More information on how Facebook Pixel works: https://www.facebook.com/business/learn/facebook-ads-pixel.
10.5.2. LinkedIn Insight tag – helps to measure traffic to our LinkedIn page, the effectiveness of its advertisements, and display updated messages / promotional messages based on this data. Depersonalised information is made accessible through the LinkedIn page: page traffic, the number of people following our posts; the number of people who are reached by the content of the page / advertisement and their actions (share, click “like”, etc.); the number of new followers, your distribution by gender, city, country, browser language. More information at: https://www.linkedin.com/legal/cookie-policy.
10.5.3. Hotjar – an analytical and feedback tool that allows us to better understand how the Website is used and how to improve its usability. Hotjar stores cookies to help us track the activities of visitors to the Website and these cookies do not store any personally identifiable information. More information at https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookie-Information.
10.5.4. DB-IP – we establish the country you are visiting from so that we can offer you the Website in the language of that country. To do so, we read the IP address from which your browser connects and match it against a country database (DB-IP Lite, IP Geolocation by DB-IP) held on our own server. The lookup takes place entirely on our server: your IP address is not sent to DB-IP or to any other third party, it is used only to resolve a two-letter country code for that one request, and we do not store or log it for this purpose. We download an updated copy of the database from db-ip.com once a month; that download carries no information about you or your visit. The legal basis for this processing is our legitimate interest in presenting the Website in a language you understand (Article 6(1)(f) of the GDPR).
10.6. Cookies used on our Website:
| Name of the cookie | Purpose of the cookie | Moment of creation | Expiration time | Data used |
| NID | The NID cookie set by Google is used for advertising purposes; to limit the number of times a user sees an advertisement, prevent displaying of unwanted advertisements, and evaluate the effectiveness of advertisements. | Upon agreeing to the use of this cookie. | 6 months | The NID cookie contains a unique ID that Google uses to remember settings and other information. |
| vuid | Vimeo installs this cookie to collect tracking information by setting a unique ID to embed videos on the website. | Upon agreeing to the use of this cookie. | 2 years | Unique visitor ID. |
| aka_debug | Vimeo sets this cookie, which is necessary for the website to play video features. | Upon agreeing to the use of this cookie. | Session | Unique visitor ID. |
| AWSALBCORS | This cookie is managed by Amazon Web Services and is used for load balancing. | When you visit the Website. | 7 days | Unique visitor ID. |
| wp-wpml_current_language | With the help of a cookie, the choice of the language of the website is saved. | When you visit the Website. | Session | Unique visitor ID. |
| AWSALB | AWSALB is an application load balancing cookie set by Amazon Web Services to associate a session with a target. | When you visit the Website. | 7 days | Unique visitor ID. |
| _ga | The _ga cookie built into Google Analytics calculates visitor, session, and campaign data, and monitors site usage in the Site Analytics report. A cookie stores information anonymously and assigns a randomly generated number to identify unique visitors. | Upon agreeing to the use of this cookie. | 2 years | Unique identifier of a visitor of the Website |
| _gid | Used to distinguish users. | Upon agreeing to the use of this cookie. | 24 hours | Unique identifier of a visitor of the Website |
| _ga_<container-id> | Used to maintain the state of the session. | Upon agreeing to the use of this cookie. | 2 years | Unique identifier of a visitor of the Website |
| _gac_gb_<container-id> | Provides campaign-related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads Website Conversion Tags will read this cookie unless you opt out. Learn more, learn more. | Upon agreeing to the use of this cookie. | 90 days | Unique identifier of a visitor of the Website |
| triniti_geo_seen | Records that the language offer described in clause 10.5.4 has already been made, so that it is made only once. | When you visit the Website. | 1 year | Stores only the value “1”; it does not identify you. |
| triniti_geo_dismissed | Records that you have accepted or closed the language suggestion, so that it is not shown to you again. | When you accept or close the language suggestion. | 1 year | Stores only the value “1”; it does not identify you. |
11. CONTACT US
11.1. If you have any questions about the information provided in this Privacy Policy, please contact:
By e-mail to: info@triniti.lt;
By phone: +370 5231 2211;
Address: Vilniaus g. 31, LT-01402 Vilnius.
11.2. If you wish to make a complaint about our processing of the Personal Data, please bring it to us in writing, providing as much information as possible. We will work with you and try to resolve any issues immediately.
11.3. If you think that your rights have been violated in accordance with the GDPR, you may submit a complaint to our supervisory authority – the State Data Protection Inspectorate, more information and contact details can be found on the Inspectorate’s website (https://vdai.lrv.lt/). We strive to resolve all disputes promptly and amicably, so we invite you to contact us first.
12. FINAL PROVISIONS
12.1. We have the right to change this Privacy Policy. We will notify you of any changes on the Website by posting an updated Privacy Policy or by other ordinary means of communication. Additions or changes to the Privacy Policy will be effective from the date of updating specified in the Privacy Policy, unless a different effective date is specified.
12.2. If you continue to use the Website after changing the terms of the Privacy Policy, enter into a contract with us or order the Services, use our Social Network Accounts, contact us, it shall be considered that you have consented to the changed terms of the Privacy Policy.