Privacy policy

PRIVACY POLICY

In this privacy policy, you can familiarize yourself with your rights and information about the processing of your personal data. We ensure that your personal data are processed in a very transparent and fair manner by implementing Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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).

 

1. WHICH OF MY PERSONAL DATA YOU DO NOT COLLECT AND ADMINISTER?

1.1 We do not collect and do not store the history of your browsing on third party websites;
1.2 We do not transfer any data about your browsing on our site from which you may be identified.

2. WHICH OF MY PERSONAL DATA ARE COLLECTED AND FOR WHAT PURPOSES?

2.1 We collect and process only the adequate and appropriate personal data required to achieve the purposes for which they are processed.
2.2 Personal data we collect and process:
2.2.1 Purchase data: Name, Surname, E-mail address, Phone number, Delivery address (where applicable), Ordering data, pick-up method, Delivery method, Payment method, Payment details (including bank account number), Basic information on third parties receiving the product. By placing an order, you may specify another person who will take back the goods you have purchased, provided that such person has given his consent. By providing us with the information of third parties who receive the goods, you confirm that you have the consent of such persons regarding the transfer, use and processing of their personal data. We process these data between you and us on the basis of a sales contract and a legal obligation.
2.2.1.1 Purpose: To conclude and execute a sales contract and to deal with requests and questions.
2.2.1.2 Storage time: 10 years.

2.2.2 Registration details: E-mail address, First name, Surname, Phone number, Date of birth, Gender, Delivery address, Payment card details. We process these data on the basis of your consent, which you give during the registration process.
2.2.2.1 Objective: To provide you with wider access to our services.
2.2.2.2 Storage time: As long as your account is active and 2 years after its removal.

2.2.3 Data on the use of www.tramtrys.lt e-shop services: Name, Surname, E-mail address, Your published opinion on the goods sold by www.tramtrys.lt, Your wish list, Communication history between you and us, Phone number, IP address, details of the goods left in shopping cart, history of responses to polls conducted by www.tramtrys.lt as well as your purchase details, Order History, Payment History. In addition, depending on the services provided by the e-shop www.tramtrys.lt, additional personal data of yours may be collected which is related to your use of the www.tramtrys.lt online store. We process these data on the basis of a contract or an attempt to conclude a contract and our legitimate interest in ensuring the functioning of the online store.
2.2.3.1 Purpose: To provide you with wider access to our services.
2.2.3.2 Storage time: 3 years.

2.2.4 Cookie data: History of behavior in our online shop. Details of cookies are provided in the Cookie Policy. We process these data on the basis of your consent.
2.2.4.1 Purpose: continuous analysis of performance for service enhancement purposes to make our online store www.tramtrys.lt as simple and convenient as possible.
2.2.4.2 Storage time: Please check the cookie storage time for information about cookies.

2.2.5 Reliability Data: Personal data related to your orders and withdrawals. We process these data on the basis of legitimate www.tramtrys.lt interest to protect our interests and ensure efficient delivery of goods.
2.2.5.1 Purpose: protection of the company's activities and interests, security, fraud prevention. Based on this data, your rating is calculated, which shows the likelihood that you will pick up your order in the way you chose to buy the item. If you do not withdraw your order very often, your rating decreases and you may be asked to pay for the ordered goods in advance and not at the time of picking up. This rating will not cause no legal or other consequences that could be considered significant. If you disagree with this rating, you can submit your disapproval arguments and we will review your ranking.
2.2.5.2 Storage time: 3 years.

2.2.6 Analytical data: We want you to use our online e-shop www.tramtrys.lt as simply and conveniently as possible, so we conduct a continuous analysis of your activities.
2.2.6.1 Purpose: continuous analysis of performance for service enhancement purposes to make our online store www.tramtrys.lt as simple and convenient as possible.
2.2.6.2 Storage time: 3 years.

2.2.7 Updates: By providing you with generic product offers and lotteries, promotions, shares and projects, we manage your personal data: Name, Phone Number, Email Address, Device Identification Numbers. We process these data on the basis of your consent.
2.2.7.1 Purpose: General and customized offers when you subscribe newsletters or SMS messages
2.2.7.2 Storage time: 3 years.

2.2.7.3 You have the right to cancel the services you have subscribed to at any time.

2.2.8 Customized Data: Name, Phone Number, Email Address, Delivery Address, Delivery History, Payment Method History, Browsing History, Purchase History, IP Address, Device Identification Numbers. We process these data between you and us on the basis of our agreement to use the online e-shop and the service you have ordered.
2.2.8.1 Purpose: Providing ordered services to save your time and automate your specific and relevant items to provide you with customized offers.
2.2.8.2 Storage time: 3 years.

2.2.9 Security Data: Image in footage when you visit our sales outlets and pick-up locations. We review video clips in case of incidents, theft or other criminal acts in order to protect the legitimate interests of victims. We process data on the basis of our legitimate interest.
2.2.9.1 Objective: To ensure the safety, public order, protection of the life, health, property and other rights and freedoms of the staff and others. Video surveillance is carried out in shops and pick-up points. We review video clips in case of incidents, theft or other criminal acts in order to protect the legitimate interests of victims.
2.2.9.2 Storage time: 30 days and, if violation is detected, until the end of the investigation.

3. WHAT ARE THE CONSEQUENCES OF NON-SUBMITTED DATA?

3.1 We regret, however, that if you do not provide the personal data specified in this policy, we will not be able to sell the goods or provide you with other services because processing of these data is necessary for the conclusion and performance of the contract and for the provision of other services. Also, personal data shall be processed according to the legal acts of the Republic of Lithuania regulating online payments and accounting management.

4. WHERE ARE MY PERSONAL DATA TRANSFERED?

4.1 Personal data shall only be transferred to trusted third parties with whom we have concluded a contract and only to the extent necessary for the provision of the service. For the purpose of providing the right services for you, we forward your personal data to the following partners:
4.1.1 Courier companies that deliver goods to you at the addresses you have specified;
4.1.2 Companies providing call center services;
4.1.3 Companies providing IT maintenance services;
4.1.4 Marketing companies.

4.2 We also provide your Personal Data to:
4.2.1 Law enforcement institutions according to the procedures provided by the legislation of the Republic of Lithuania;
4.2.2 State institutions and courts where such obligation is prescribed by applicable law.

4.3 For the purposes of saving your time and removing any inconvenience caused by the fact that the product was delivered to you in incomplete composition or damaged with warranty service we deliver your personal data, i. e. name, surname, telephone number and the delivery address of the product you bought to the manufacturer with regard to missing details and for the purposes of new items for the delivery of goods.

4.4 Please be informed that your personal data may be transferred outside the European Union. Your personal data are transmitted outside the under the following conditions:
4.4.1 Data are only transferred to our trusted partners to provide our services to you;
4.4.2 Data processing agreements have been signed with such partners (standard contract terms approved by the European Commission) to ensure the security of your personal data in accordance with legal requirements;
4.4.3 The Commission of the European Union has taken a decision on the eligibility of the country in which our partner is established; this means that an adequate level of security is ensured;
4.4.4 The level of security of the personal data is ensured by the Partners in accordance with the EU-US Privacy Panel.

5. WHAT ARE MY RIGHTS?

5.1 Modify / revise incomplete or inaccurate data;
5.2 Request that we no longer process your data and delete them. This right is not absolute and, in some cases, for serious statutory reasons we will not be able to delete your data (for example, when data are required for a valid contract)
5.3 Restrict data processing;
5.4 Cancel the consent. You may revoke your consent in your personal account in the edit panel of your profile by unchecking the box with your consent or by clicking on the Unsubscribe button at the bottom of the email, or by other means specified in this policy. You can also opt out of Facebook Messenger by using the Unsubscribe feature. You are informed about the method of refusing SMS messages in the received SMS message.
5.5 Access the personal data processed in this policy.
5.6 Transfer data, which means that you are allowed to receive, in a structured easy-to-use, computer-readable and interoperable format, the personal data that you provide and which we process by automated means. Right to Data Portability. When available and at your request, your data may be forwarded directly to another person designated by you.
5.7 If you believe your rights have been violated, you may apply to the National Personal Data Protection Inspectorate for your rights.

6. HOW CAN I REQUEST FOR THE IMPLEMENTATION OF MY RIGHTS?

6.1 You may submit requests relating to the processing of your personal data in the following ways:
6.1.1 By sending us an application via email: info@tramtrys.lt;
6.1.2 By submitting a request to us by phone: +37068648271;
6.1.3 By arriving at our shops;
6.1.4 You can implement your certain rights through your personal www.tramtrys.lt account.

6.2 In our system, we perform your identification according to your email address. When submitting a request to us in one of the following ways, always indicate your email address for which the information is provided. If you do not specify an e-mail, or if you do not agree with the e-mail address of the person submitting the request, we will not have the opportunity to properly identify you and provide the information you request or implement your request.

7. WHAT ARE COOKIES?

7.1 Cookies are small text files that are downloaded to your device when you visit the relevant website. Cookies help us recognize your device and improve the functionality and facilitate the use our website.
7.2 Read more about cookies and how to use them in our Cookie Policy.

PRIVACY POLICY FOR SOCIAL NETWORKS

This policy applies to all information and data that you provide to us or which we collect and process from our Facebook, Instagram, and other social networking or sharing platforms pages hosted by www.tramtrys.lt , https://www.facebook.com/TramTrys/ https://www.instagram.com/tramtrys/

We respect your privacy and protect your personal data and the information you provide to us and which is collected by us in accordance with this Privacy Policy. The Privacy Policy explains why we collect and use your personal data.

WHY WE COLLECT DATA

We use Facebook and Instagram and other social networks to promote our services and products and to communicate with you as visitors of these pages. More information about our activities can be found at www.tramtrys.lt
The functioning of these social pages, including the processing of visitors’ personal data based on our legitimate interest in communicating with our followers and social networks visitors.

DATA COLLECTED ON FACEBOOK

In 2018 June 5 resolution, the European Court of Justice (reference: https://curia.europa.eu/jcms/upload/docs/application/pdf/2018-06/cp180081en.pdf) decided that Facebook page manager is responsible for processing personal data together with Facebook.

Facebook manages data for:
• Advertising (analysis, personalized advertising)
• Creating user profiles
•  Market research purposes.

Facebook and Instagram use cookies to save and manage the collected information. Cookies are small text files that are stored on various devices. Facebook Privacy Policy (https://lt-lt.facebook.com/privacy/explanation) and Instagram Data Policy (https://help.instagram.com/519522125107875) provide additional information on data processing.

Here you can disagree about data processing - https://www.facebook.com/settings?tab=ads or at www.youronlinechoices.com.

Facebook Inc., which is the parent company of Facebook Ireland Ltd., is certified by the EU-US Privacy Shield and is committed to follow European data protection requirements. More information about Facebook Privacy Panel available at www.privacyshield.gov

STATISTICS

Facebook Insights feature collects statistics about these pages and its different categories and may be available to us. This statistics is collected and provided by Facebook. As the managers of these pages we have no influence on the generation and submission of the data. We cannot cancel this function or prevent the collection and processing of the data.

We may choose a time interval to get statistics from Facebook about the people who clicked "like", subscribers, people who the information has reached and people who have expressed interest:

• Total page views, "likes", page activity, reactions to posts, availability, video views, posts, accessibility, comments, promotions, answers, men / women proportion, country and city, language, age, interests, behavior, used devices, sex, visits and clicks, clicks on phone numbers.

Facebook also provides information about Facebook groups related to our Facebook and Instagram pages, because Facebook is constantly evolving, access to data and management of data is constantly changing, so we recommend to visit the links above to learn more about Facebook, Instagram, or other social networks privacy policies.

We use this aggregated data to make our Facebook and Instagram pages more attractive to users. For example, we use age and gender information to address our customers properly. Also we use activity data to publish information at the most appropriate time.

COLLECTED DATA

We can contact people who have expressed their willingness to participate in our contests and games. In order to identify the winner and transfer the prize, we may collect certain data such as the first and the last name, location of the prize collection or other data necessary for identification and the prize transfer.

If you have a Facebook, Instagram or other social network account and you "like" or "follow" our pages, you can post comments or click “like” on specific posts. If you comment or click "Like" on our posted content, this information will be visible to us and other social network users. Your data visible to others will depend on your individual privacy settings and your activity, i.e. how much data you personally publish.

If you start to follow our Instagram profile, you may receive information in your Instagram messages about the tracking as well as any promotions or discounts valid at that time.

DATA TRANSFER

We can disclose limited anonymous information to trusted third parties which help us to analyze usage models, improve the performance of social networks, and provide useful information to the users.

SECURITY OF YOUR DATA

We regularly update and improve our security standards, procedures and technologies to protect against unauthorized access to your confidential information. Information collected on the pages of our social networks is only available to those who need the information to perform their duties.

YOUR RIGHTS

Given that only Facebook can access your full information and data, we recommend that you contact Facebook directly to request information or ask other questions about your user rights (such as the right to delete data). If you need help or have any other questions, please contact us by email to info@tramtrys.lt

If you don’t want your personal data be processed any longer on our pages you may do so by opting out of "unlike" or "unfollow" these pages as described in this Privacy Policy,.

VALIDITY AND CHANGES

This privacy policy is valid since 2020 January 10. If there are any changes to the privacy policy,  the updated version will be published on our Facebook, Instagram, or other social network pages. Changes and / or additions to the Privacy Policy shall take effect after their publication.