Your personal data controller is UAB Vedliai, legal entity code 305241691, registered office address: Šv. Stepono g. 25-30, Vilnius, Republic of Lithuania. Contact details for personal data matters: e-mail firstname.lastname@example.org, phone +370 647 31608.
Whose personal data does Vedliai collect?
When we provide our services, we may process personal data of the following categories of data subjects:
Persons who participate in programmes organised by Vedliai (Participants);
Persons who cooperate with us (partners/external service providers);
Persons submitting inquiries to us;
Candidates for vacancies.
How does Vedliai get your personal data?
We collect your personal data directly from you or we collect it ourselves:
When you enter into services/joint venture/other contracts with us;
When you participate in the Vedliai programmes we organise;
When you provide us with your data through our Websites;
When you send an e-mail to the e-mail address specified by Vedliai;
When you apply for our job vacancies;
When you otherwise provide or we receive information from third parties with your consent.
What personal data do we process and why?
5.1. For the purpose of coordinating Vedliai programmes, as well as for the purpose of signing up for the programmes and communicating about participation in the programmes, we process the following personal data of Participants:
Name, surname, e-mail address, phone number, name of the employer (school), information voluntarily entered by teachers in the free text field, job title, information about the work performed/occupation (e.g. number of children in the class, etc.), contact details of the employer’s person in charge, your Google account information (if you choose to use it for a sign-in), etc.
Please note that Vedliai deletes any superfluous personal data provided by data subjects that are not necessary for the purpose of submitting a request for participation in a Vedliai programme and receiving a response.
5.2. An audio and video recording of sessions may be made and shared with other Participants in a Vedliai programme for learning purposes, so we process the following personal data of the Participants:
Image, voice recording, and messaging.
5.3. For the purpose of cooperation/partnership, we process the following personal data of partners/external service providers:
Name, surname, phone number, city, e-mail address, bank account number, legal entity details, information about representatives/employees (if the partner/external service provider is a legal entity).
5.4. For the purpose of selecting new employees, we process the following personal data of candidates:
Name, surname, CV, phone number, e-mail address, certificates, graduation diploma, image, qualifications, and work experience (previous employers).
5.5. For the purpose of direct marketing, we process the following personal data:
Name and e-mail address.
5.6. When a visitor logs in or visits the Websites, the following technical personal data are collected and processed automatically:
Date and time of login/session;
Name and universal address (URL) of the web page that links to our Website;
Operating system data of the visitor’s device;
Geographic location data of the visitor;
Other related technical information.
Information on the visitor’s internet service provider.
5.7. For the purpose of increasing the awareness of our activities and other marketing activities on our Websites and social media
Your photo/video, description of your experience with us
What are the bases for lawful processing?
For the purposes as described above, we process your personal data based on:
Entry into and performance of a contract (for services/joint venture/participation in a programme/other) (for purposes 5.1., 5.4. as described in section 6 above);
Legitimate interest – to respond to your inquiries, provide information you ask for, to ensure the security and functionality of our Websites, to maintain cooperation with our partners and others (for purposes 5.3., 5.6. as described in section 6 above).
Performance of statutory obligations (for the purpose 5.4. as described in section 6 above);
Consent (e.g. for the processing of personal data for direct marketing purposes, the use of an image, etc.) (for purposes 5.2., 5.5., 5.7. as described in section 6 above).
If you do not provide your personal data where we process it on the basis of entry into or performance of a contract or statutory obligations, we will be unable to provide you with our services.
How long do we store personal data?
The personal data you provide to us for direct marketing purposes are actively processed (used) for a period of three (3) years after you give your consent or until you withdraw your consent and then stored in the archive for another one (1) year from the end of this period.
The data provided by the Participant at the time of registration will be stored for the duration of the programme, i.e. for as long as the Participant has logins for the platform/programme and for one (1) year after the end of this period.
The image (video) and voice recordings of the Participant (teacher) will, subject to their consent, be used for three (3) years from the date of consent or until the consent is withdrawn.
At the end of the selection of employees, we undertake to erase and/or destroy the personal data of non-selected candidates within three (3) months after the end of the selection process, unless you consent to the continued use of your data for the purposes specified in your consent.
We make sure and take all necessary measures to ensure that no outdated or unnecessary information about you is stored and that your data is updated on a regular basis and correct.
Disclosure of data
Your personal data can only be accessed by a limited number of our employees and entities providing IT/organisational/communication/consulting/audit/legal services to our company and only to the extent that it is necessary to perform their functions or provide services, and all of these persons are subject to strict requirements for the protection of confidential information.
Where audio and video recordings of sessions are made for learning purposes, we may upload such recordings to the platform to facilitate the learning process and they will become available to other Participants in the Vedliai programme.
data processors that provide services and process your data in our name, on our behalf and at our behest (e.g. IT service providers, including the Zoom Video Communications, Inc. remote meeting platform operator, etc.). We note that our data processors process your data exclusively according to our explicit instructions, committing to ensure adequate protection, confidentiality, and organisational and technical measures that meet the security requirements for the data received from us for processing, as specified in more detail in the data processing agreements between us and the service providers;
entities entitled to receive information under the law (e.g. courts, state and local government authorities, etc.) only to the extent that it is necessary to properly fulfil the requirements of the existing legislation.
In certain circumstances, we may be obliged to transfer personal data where:
we are required to disclose information under the law, including cases where we must disclose personal data to the tax authority and law enforcement authorities for crime prevention and detection purposes;
we need to disclose personal data for legal proceedings or in order to obtain legal advice, or where disclosure is necessary to establish, exercise or defend our rights;
disclosure is necessary to protect our interests or the interests of other persons (for example, to prevent fraud);
information has to be disclosed to a potential buyer of our company’s assets or organisation.
This section provides information about the rights you have in relation to our processing of your personal data and the cases when you can exercise these rights. If you wish to get more information about your rights or to exercise them, please contact us at the following e-mail address: email@example.com.
Right to withdraw your consent. If you have given us your express consent for the processing of your data.
Right of access to your personal data. You can contact us at any time and ask whether we process any of your personal data. If we store or use your personal data in any way, you have the right to access them.
You have the right to ask us to rectify any inaccuracies in the data we hold. In this case, we may ask you to confirm the rectified information.
You have the right to ask us to erase your personal data. Please note that we will only be able to fulfil such a request if:
Your personal data is no longer needed to achieve the purposes for which they have been collected (for example, we need your personal data to be able to reply to your letters);
The law prohibits us from collecting, storing or using personal data;
Your personal data is not necessary to establish, exercise or defend a legal claim, for example, in a legal process.
You have the right to request us to restrict the processing of your personal data or not to process it:
During the period necessary for us to verify the accuracy of your personal data where you submit claims regarding the accuracy of the data;
Where our collection, storage or use of your personal data is unlawful, but you choose not to request data erasure;
Where we no longer need your personal data, but you need it to establish, exercise or defend a legal claim;
During the period required to determine whether we have an overriding legal basis to continue processing your personal data if you exercise your right to object to the processing of personal data.
You have the right to the portability of the data we have received from you with your consent or for the purposes of entering into a contract. If you exercise this right, we will transfer a copy of the data you have provided upon your request.
You have the right to object to our use of your personal data where we use such data to secure our legitimate interests but do not have an overriding legal basis to continue using your personal data.
If you believe that your rights as a personal data subject have been and/or may be violated, please send us your complaint immediately at the e-mail address firstname.lastname@example.org. Once we have received your complaint, we will contact you within a reasonable period of time and let you know about the progress of the investigation of the complaint, as well as inform you about the results.
At any time, you can file a complaint directly with the State Data Protection Inspectorate (L. Sapiegos g. 17, LT-10312 Vilnius, e-mail: email@example.com).
Accuracy of Personal Data
You are responsible for ensuring that the data you provide to us is accurate, correct and complete. In the event of any change in the data you have provided, you must immediately inform us by e-mail at firstname.lastname@example.org. In no case will we be liable for any damage caused to you as a result of you providing incorrect or incomplete personal data or failing to inform us of any changes to such data.