Privacy Policy
This notice on the processing of personal data (hereinafter – Privacy Notice) has been prepared in accordance with the requirements of the General Data Protection Regulation (hereinafter – GDPR ) and other legal acts, so that you know what data we collect about you, why we collect it, how we process and protect it. We recommend that you take the time to familiarize yourself with this Privacy Notice in detail.
General provisions
Personal data (hereinafter – Personal data ) means any information or set of information by which we can directly or indirectly determine your identity, in particular, by an identifier, for example: name, surname, e-mail address, etc.
The controller of personal data (hereinafter – the Company or us ) is: UAB “ST Impress”, company code – 300605073, VAT payer code – LT100002663717, address – V. Mykolaičio -Putino str. 10, Vilnius.
If you have any questions regarding this Privacy Notice or if you have any questions, observations or requests related to the protection or processing of your Personal Data, please contact us by e-mail. by email: Travelwith@2birdsonboard.com .
This Privacy Notice may be updated and changed. You can always find the current version of the Privacy Notice on our website https://www.2birdsonboard.com .
The Privacy Notice explains how the Company collects and uses your Personal Data when you:
- You purchase the Company’s Digital Products on the website https://www.2birdsonboard.com or by any other means;
- you subscribe to the Company’s newsletters, information about the digital products provided, or such messages are sent to you on other legal grounds, named in this Privacy Notice;
- you contact us (for example, you write us a request on the Company’s website, contact us via a private message on social networks, give us feedback, a complaint, etc.);
- you communicate or cooperate with the Company as a supplier, contractor or other person who has business, professional and/or other civil-contractual relations with the Company.
What kind of data do we process, in what cases and for what purposes?
Processing of personal data of the company’s customers
When you order the Company’s digital products and become our customer, the Company collects and processes your Personal Data:
- Your personal data (name, surname);
- Your contact details (email address, residential address, telephone number);
- The company you represent, company code, VAT code, address and duties, if you order the Company’s services on behalf of the company;
- Details of your payments for services (amount, payment method, date and/or time);
- Other Personal Data that the Company needs to process due to the fulfillment of applicable legal obligations (for accounting and similar purposes).
We process your Personal Data in order to be able to enter into a contract with you and provide you with the services you have ordered (Digital Products), as well as to implement the requirements of legal acts regarding accounting, document storage, etc.
For this purpose, we store personal data for as long as it is necessary to fulfill the contract concluded with you, to resolve issues related to the contract and its execution, and to implement legal requirements. Generally, contracts, evidence of their fulfillment, accounting documents and related Personal Data are stored for 10 years after the date of the contract’s fulfillment or termination on other grounds.
Publicizing the Company’s activities, direct marketing, informing about the Company’s services and/or products
We may send you information about the Company’s services and/or products by e-mail and process your Personal Data for the purpose of direct marketing in the following cases:
- when you subscribe to the Company’s newsletters on the Company’s website or otherwise give your consent to receive advertising information. In this case, the basis for the processing of Personal Data is your consent (GDPR Article 6 d. 1 point a) and the data is processed until you cancel the subscription or consent, but no longer than 5 years;
- when you are our customer ie . you have purchased the Company’s products. In this case, we may provide you with offers and information about similar services and/or products, if and as long as you have not expressed an objection to receiving such offers and information. The basis for the processing of personal data is our legitimate interest in informing our customers about the services and products offered (GDPR Article 6 d. 1. point f)) and Personal data for this purpose can be processed for 2 years after your last purchase or download of a free product.
In both of the above cases, you can unsubscribe from our newsletters or other marketing communications at any time by simply clicking on the unsubscribe link in the newsletter or e-mail, or by writing to us at Travelwith@2birdsonboard.com .
For the purpose of direct marketing, we can process your personal data: name, surname, e-mail address, data on product orders (purchases) and other history of our cooperation.
We may also collect statistical information about email. e-mailed newsletters and marketing messages: we track whether you read the newsletter or message, when and how many times you read it or opened the links, whether you forwarded it to others, what operating system and email mail server (its location) you used.
Administration of requests
When you contact us (for example, you write us a request on the Company’s website, contact us in a private message on social networks, give us feedback, a complaint, etc.), we can process the following Your data:
- Your request contains identification and contact information: name, surname, phone number, e-mail address, residential address, date of birth, social network account name and other publicly available information in your account, if you submit the request via social networks;
- The content of your request: the question you are applying for, your request, demand or feedback, other information provided in or together with the request;
- Information collected by the Company is necessary to examine the request and make a decision, e.g. Your order, service history, information about our other cooperation, etc.
The purpose of processing personal data is to properly and objectively examine your request, provide you with the necessary information, answer your questions, resolve your requests or demands. We can also analyze the request data in order to improve the quality of our activities, services and/or service, taking into account your opinion and suggestions.
We process and store your request and your Personal Data related to it until we examine the request, provide you with an answer and implement the decisions made, and also for another 6 (six) months after the request is resolved. If you become our customer after submitting a request, Personal Data is further processed as provided in the section “Processing of Personal Data of Company Customers” of this Privacy Notice.
Cooperation with suppliers, partners, other parties to transactions, conclusion and execution of contracts
In its activities, the Company processes the Personal Data of different categories of data subjects (business partners, suppliers, other parties to the transaction, as well as their employees, managers, shareholders, representatives and/or agents). The scope of Personal Data processed depends on the nature and objectives of the business or other legal relationship, but generally speaking, the following may be processed:
- When the data subject acts as an individual business partner of the Company, supplier, party to another transaction : name, surname, personal identification number, date of birth, address, telephone number, e-mail postal address, bank account details, date of financial transaction or transaction, amount, currency, data contained in the business certificate, individual activity certificate number, VAT payer data, other transaction or business relationship data;
- When the data subject acts as an employee, manager, shareholder, representative and/or agent of a business partner, supplier, other party to the transaction : name, surname, workplace and duties or other basis of operation, official telephone number, official e-mail postal address, as well as date of birth/personal identification number and address local address, if acting on the basis of a power of attorney or representation/agency agreement and these data are necessary to identify a person, or when the data subject is a manager or shareholder.
This Personal Data is collected and processed for the following purposes:
- the aforementioned persons establishing, maintaining and developing business, professional and/or other legal relations with the Company;
- concluding, executing, administering transactions, contracts and agreements;
- developing and ensuring the legitimate interests of the Company;
- Defending the company against lawsuits, demands, and claims brought against it;
- The company is subject to the obligations and obligations in accordance with the applicable legal acts.
The company stores this data as long as it is necessary to achieve the purposes for which it is processed, as well as in accordance with the requirements for the storage of this type of data, established by legal acts, during the limitation periods for asserting or defending legal claims, and if such are asserted, as much as is necessary for this purpose.
Longer storage of Personal Data
In the cases provided below, we may store your Personal Data for a longer period of time than provided for in this Privacy Notice. Longer storage of Personal Data may be carried out when:
- it is necessary for us to defend ourselves against demands, claims or lawsuits and to enforce our rights;
- there are reasonable suspicions of an illegal act, which is the subject of an investigation;
- Your data is necessary for the proper resolution of a dispute or complaint;
- for backup, archiving and other similar purposes;
- in the presence of other legal grounds.
In other cases, upon the expiration of the set term for the storage of Personal Data, Your Personal Data will be destroyed or irreversibly depersonalized within a reasonable period of time.
From which sources do we receive your Personal Data?
In most cases, we only collect and process data that you have provided to the Company. For example, when you order the Company’s services (Digital Products), subscribe to newsletters, contact us with a request for information or for another purpose, enter into and/or execute a contract with the Company, supply the Company with goods and services, etc.
In exceptional cases, we can process data that comes from other legal sources – parties to the contract and contractors (e.g. data about representatives of the contract party, employees, etc.), our partners, if you have provided them with your information, agreeing that we process it for the purposes set out in this Privacy Notice or your consent.
How do we use your Personal Data and what principles do we follow?
When processing your Personal Data, we:
- we comply with valid and applicable legal acts, including GDPR requirements;
- we process your Personal Data in a legal, fair and transparent manner;
- we collect your Personal Data for established, clearly defined and legal purposes and do not process them in a way incompatible with those purposes, except to the extent permitted by legal acts;
- we take reasonable measures to ensure that Personal Data that are not accurate or complete, taking into account the purposes of their processing, are immediately corrected, supplemented, suspended or destroyed;
- we process and store your Personal Data for no longer than is necessary for the purposes for which the Personal Data is collected and processed;
- we do not provide Personal Data to third parties and will not disclose them, except for the cases specified in this Privacy Notice or applicable legal acts;
- we apply appropriate technical or organizational measures to ensure the security of Personal Data, including protection against unauthorized processing and against accidental loss, destruction or damage.
To whom do we transfer your Personal Data?
We may transfer your Personal Data to:
- For Personal Data Processors employed by the Company (for example, companies providing information technology, website administration and similar services, accounting companies, companies providing advertising and/or marketing services, etc.). We have concluded relevant contracts with all Personal Data Processors we use and require them to store Personal Data, process it only in accordance with our instructions and treat it as responsibly as we do;
- to other data controllers, when and to what extent such transfer is necessary to properly provide services to you;
- to state institutions and institutions, law enforcement institutions, courts, other persons performing the functions assigned by law, in accordance with the procedure provided by the applicable legal acts. We provide these entities with mandatory information prescribed by law or specified by the entities themselves;
- Debt collection companies, to which the client’s claims are transferred, to courts, non-judicial dispute resolution institutions and bankruptcy administrators;
- In other cases, if we have your consent for the disclosure or transfer of Personal Data.
Currently, we do not transfer or process your Personal Data outside the European Union or the European Economic Area.
What rights do the Personal Data Protection legislation give you?
With respect to your Personal Data, you have the right to:
- Ask to provide you with information about your personal data being processed and how it is processed;
- Request correction of Your Personal data and/or stop the processing of such Personal data, except for storage – in the event that, upon familiarization with the Personal data, You believe that the data are incorrect, incomplete or inaccurate;
- To request the destruction of Personal Data or to stop the processing of such Personal Data, with the exception of storage – in the event that, upon familiarization with your Personal Data, you determine that the Personal Data is being processed illegally or dishonestly;
- Disagree and/or object to the processing of your Personal Data when it is processed or intended to be processed for the purposes of direct marketing or for a legitimate interest pursued by us or pursued by a third party to whom Personal Data is provided;
- in cases where your Personal data is processed on the basis of separate consent, you have the right to withdraw the given consent to the processing of your Personal data at any time;
- Request to transfer your Personal Data to another data controller or provide it directly in a form convenient for you (applies only to those Personal Data that you have provided and which are processed by automated means on the basis of a contract or consent).
You can exercise your rights by submitting a written request to us. You can submit a request in any convenient way to the contacts below, if your identity can be determined from such a request and/or the documents submitted with it:
You can also contact these contacts if you believe that we are not complying with our obligations specified in this Privacy Notice regarding your Personal Data. We will immediately take steps to ensure your rights.
email by mail: Travelwith@2birdsonboard.com ;
The company’s headquarters are at: V. Mykolaičius – Putino str. 10, Vilnius.