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Privacy policy

Language and Governing Version Notice

This Privacy Policy has been translated from the Lithuanian language for convenience purposes only. In the event of any discrepancy, inconsistency, ambiguity, or conflict between the Lithuanian version and any translated version of this Privacy Policy, the Lithuanian version shall prevail and be legally binding.

We recommend that you read this document in order to familiarize yourself with how we manage and process your personal data on this website, how we obtain it and what your rights as an individual are. We, MB “Edufy group”, legal entity code 306007314, registered address – Paplaujos g. 3-38, LT-11342, Vilnius, (hereinafter referred to as the Platform Owner) administer and maintain this website.

When processing your personal data, we comply with 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 (also known as the General Data Protection Regulation, hereinafter referred to as the GDPR), the Law of the Republic of Lithuania on the Legal Protection of Personal Data and the requirements for the processing of personal data set out in other legal acts.

Personal data – any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data and an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

I. WHAT IS THE PRIVACY POLICY?

1. This document (hereinafter referred to as the Privacy Policy) sets out the privacy conditions for your use of the Platform and for your contact with us by telephone or social media regarding the services provided on the Platform. The Platform is called the website www.edufygroup.eu, which is also accessible via www.edufy.lt, www.edufy.lv, edufy.ee.

2. If you use the Platform, it means that you have read and agreed to this Privacy Policy and the purposes, methods and procedure for processing your personal data specified therein.

3. The Privacy Policy applies to all natural persons who have visited or registered on the Platform, as well as to the actions that They may perform on the Platform. Platform data subjects:

3.1. A person who visits the Platform and registers or has registered for the Service Provider’s service (hereinafter referred to as the Registered User);

3.2. A person, employee of the Service Provider or authorized person who manages the data of the Service Provider and Users who have registered for the Service Provider’s service (hereinafter referred to as the Service Provider’s Representative)

II. PRINCIPLES OF DATA PROCESSING

4. In accordance with the provisions of legal acts, representatives of Service Providers on the Platform are granted the right to manage and process the personal data of Registered Users, their own and other representatives of the Service Provider. The Service Provider, for whose services the Registered User registers on the Platform or a person authorized by the Service Provider, registers representatives of the Service Provider on the Platform to manage the services it provides and administer the data of Registered Users.

5. When processing your personal data on the Platform, the Service Provider representative ensures that:

5.1. will process your personal data in a lawful, fair and transparent manner;

5.2. will collect your personal data for established, clearly defined purposes to the extent required to provide services on the Platform;

5.3. will take all reasonable steps to ensure that personal data that are inaccurate or incomplete, having regard to the purposes for which they are processed, are promptly rectified, supplemented, the processing of which is suspended or destroyed;

5.4. will keep them in a form that permits identification for no longer than is necessary for the purposes for which the personal data are processed;

5.5. will not provide personal data to third parties or make them public, except as specified in the Privacy Policy or applicable legal acts;

5.6. will ensure that your personal data are processed in such a way that appropriate technical or organizational measures ensure adequate security of personal data, including protection against unauthorized or unlawful processing of data and against accidental loss, destruction or damage.

6. The Platform Administrator allows data processing only to responsible representatives of the Service Provider: employees, teachers, trainers, administrators and their deputies, and access to data is limited to the extent necessary to provide the Service Provider’s services.

III. HOW DO WE COLLECT YOUR PERSONAL DATA?

7. Your personal data obtained in the following ways is processed on the Platform:

7.1. when you provide us with personal data. You provide us with your personal data and other information by using the Platform, by calling us by phone, writing to us by email or social networks or by communicating with our customer service team, submitting your opinion, comments and (or) requests, subscribing to our newsletter, etc.;

7.2. when you provide personal data to the Service Provider. By registering for the Service Provider’s service, you provide the data that is necessary for the Service Provider’s services and administer services;

7.3. when you use the Platform. When you use the Platform, certain information (e.g. type of web browser used, number of visits to the Platform, viewed Platform pages, etc.) is collected automatically;

7.4. when we receive your personal data from other persons in accordance with the procedure established by legal acts and (or) this Privacy Policy.

8. We may combine the personal data received from you, which we received when you use the Platform, with our own collected from other public or accessible sources (e.g. we may combine the personal data provided by you with data obtained using the Platform’s cookies, or with data legally obtained from third parties).

IV. PERSONAL DATA PROCESSING AND PURPOSES

9. Your personal data is processed for the following purposes:

9.1. for the purpose of registration, identification and provision of services. You provide the Service Provider with your personal data when you use the Platform to search for Service Providers, register for the Service Provider’s service and create a Platform account, provide data, e.g. fill in the data in the registration form requested by the Service Provider, upload photos of your profile on the Platform. We also process your personal data when you register on the Platform or use it as a representative and/or contact person of the Service Provider. For this purpose, the following personal data are processed:

  • data categories: Name, surname, e-mail address, telephone number, IP address, address, other data provided by you on the Platform when registering for the Service Provider’s services;
  • legal basis for data processing – Agreement and/or Terms of Service);
  • data processing period – 5 years from the date of your last login to your account;
  • we receive data from you;
  • we provide or transfer data – to representatives of Service Providers registered on the Platform, who carry out service administration and your data processing on the Platform.

9.2. for the purpose of providing paid services, controlling payments, accounting and settlements, managing debts and recovering debts. You provide your personal data when you use the Service Provider’s service on the Platform at least once from the date of registration with the Service Provider until we decide to refuse the services. For this purpose, the following personal data are processed:

  • data categories: Name, surname, e. postal address, telephone number, , your child/guardian’s name, surname, data about the child/guardian, data about the provision of services (e.g. start date of service provision, end date, duration, status, fact of service use, etc.), data about ordered and used services and fees for them, data on issued invoices and payment information (e.g. services provided, invoice date, number, amount payable or paid, method of invoice submission and invoice payment, payment date, payment status, data related to indebtedness (e.g. date of debt occurrence, amount of debt, type of debt, etc.);
  • legal basis for data processing – Agreement (Terms of Service Provider’s Service Provision or Agreement with the Service Provider);
  • data processing period – 10 years from the date of termination of the Service Provider’s service;
  • we receive the data from you, representatives of the Service Providers, from the bank or electronic money institution where you have an account;
  • we provide the data or we transfer to your bank or electronic money institution where you have an account, we transfer the data necessary for payment of the service, when it is necessary to identify you as a Platform user who has ordered a service on the Platform to the Service Provider;
  • to companies carrying out debt collection, which mediate for us in debt collection and only to the extent necessary to initiate and carry out debt collection in favor of the Service Provider.

9.3. for the purpose of ensuring the quality of service provision and communication. You provide your personal data on the Platform by writing or communicating with representatives of the Service Provider, submitting your inquiries or complaints regarding the services provided by the Service Provider. For this purpose, the following personal data are processed:

  • data categories: Name, surname, e-mail address, telephone number, place of residence (address), the content of the complaint and (or) inquiry submitted in writing (e.g. date of writing, content, etc.);
  • data processing legal basis – Agreement (Terms of Service Provision of the Platform);
  • data processing term – 2 years from the date of submitting your inquiry on the Platform;
  • we receive data from you; when carrying out an inquiry or analyzing a complaint, we may create personal data ourselves (e.g., upon receiving your complaint, we contact our employees regarding the actual circumstances of the complaint and record them, etc.);
  • we provide or transfer data to representatives of Service Providers registered on the Platform, who carry out service administration and processing of personal data of Registered Users on the Platform.

9.4. In order to ensure the functionality of the Platform, as well as to improve it, we offer you

more relevant and tailored to you. We use your personal data and cookies that we receive when you use the Platform to improve and develop the Platform and to offer you better and more tailored functionality and a better experience of using the Platform.

9.5. for this purpose, we use your personal data received from you, created when you use the Platform and entered by representatives of the Service Providers.

9.6. for other purposes when we are obliged to process your personal data by legal acts or there is a legitimate interest.

10. We do not ask for and do not process your special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as health data or data about your sex life and sexual orientation. In the event that you provide us with this data using the Platform or in another way (in writing, by e-mail, by phone), it will be considered that this data was provided with your consent. Accordingly, we will process this data of yours together with other data of yours that you have provided in the ways specified in this Privacy Policy, if such data cannot be separated from each other or such separation would require disproportionate effort.

V. USE OF COOKIES

11. We collect information about you using technical cookies. Cookies are small text files that are temporarily stored on your device.

12. We may collect the following information using cookies: IP address, type of web browser used, number of visits to the Platform, Platform pages viewed, time spent on the Platform, demographic data and, if you arrived at the Platform from a third-party website – using the page navigation link, geographical data, if you have agreed to disclose your location using the Platform.

13. We use the information received in cookies for the following purposes:

13.1. to ensure full functionality of the Platform (e.g., allows you to recognize the next time you visit the Platform, customize content based on your previous browsing history and preferences, speed up searches on the Platform, etc.);

13.2. to improve and develop the Platform so that it better meets your needs;

13.3. for the development of services and analysis of the use of the Platform

14. All information about the cookies used on the Platform, their purpose, validity, management and data used is provided in the cookie policy.

VI. WHO DO WE PROVIDE YOUR PERSONAL DATA TO?

15. Your personal data is managed by the representative(s) of the Service Provider and will not be transferred to third parties without their consent or without a lawful basis, nor used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy or applicable legal acts. However, we reserve the right to provide information about you if we are obliged to do so by law or if we are required to do so by legitimate law enforcement or criminal prosecution authorities.

16. We may transfer your personal data to companies that help us carry out our activities, including direct marketing. In such cases, we require that your data be processed only in accordance with our instructions and applicable legal acts ensuring the protection of your data. We conclude contracts with these persons that oblige the parties to strictly comply with personal data protection requirements.

17. We may disclose the data we collect about you to the following third parties:

17.1. third-party service providers (e.g. technical service providers in the performance of our contracts with Service Providers, including the performance of services for sending information notices about changes in the Service Providers’ services, newsletters or other marketing actions);

17.2. third-party service providers whose services we usually use for the development and maintenance of information technology systems, data storage, telecommunications.

18. The ability of the above-mentioned service providers to use your data is limited – they cannot use this data for purposes other than providing the Platform services to us.

VII. PERSONAL DATA STORAGE PERIOD

19. We store your personal data for no longer than is required by the data processing purposes or provided for by legal acts, if they establish a longer data storage period, taking into account the service provided by the Service Provider.

20. We strive not to store outdated, irrelevant personal data, therefore, when updated, only relevant information is stored. Historical information is stored if it is necessary in accordance with the procedure established by law or for the performance of our activities.

VIII. HOW DO WE PROTECT YOUR PERSONAL DATA?

21. Your data, which you provide or we collect from you, will be stored only within the territory of the European Union (EU)

22. Considering that the transmission of information to the Platform via the Internet is not possible outside of to verify complete security when you transfer data to the Platform – you assume the risk associated with the transfer of data to the Platform due to various cyber attacks or viruses. Once we receive your data, we will apply strict procedures and security measures to protect your data from unauthorized access.

23. If unlikely circumstances arise and we learn about a breach of the security of your personal data that may pose a significant threat to your rights or freedoms, we will immediately inform you as soon as we learn about it and determine what information was accessed.

IX. EXTERNAL PLATFORMS

24. The Platform may contain links to external websites – websites of our business partners or websites that advertise our services and (or) products. When following such links to any of the websites, please note that these websites and the services accessible through them have their own separate privacy policies and we do not assume responsibility or liability for these policies or for personal data collected on these websites or in the course of providing services, such as contact or location data. Please review these policies before submitting personal data to these websites or using any services.

X. YOUR RIGHTS

25. When processing personal data, we ensure your rights under the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a personal data subject, you have the following rights:

25.1. to know (be informed) about the processing of your personal data;

25.2. to familiarize yourself with your personal data that we process;

25.3. to demand correction or supplementation, clarification of incorrect, inaccurate, incomplete personal data of yours;

25.4. to demand the destruction or anonymization of personal data when they are no longer needed for the purposes for which they were collected;

25.5. to demand the destruction of personal data if they are processed unlawfully or when you withdraw your consent to the processing of personal data or do not give such consent, which is necessary;

25.6. to object to the processing of personal data or to withdraw previously given consent;

25.7. to demand the suspension (except for storage) of your personal data processing activities if disputes arise or it is necessary to verify the lawfulness of data processing or the accuracy of the data;

25.8. to demand the provision, if technically feasible, of your personal data collected with your consent or for the performance of a contract in an easily readable format or to request their transmission to another data controller.

26. We will strive to guarantee the implementation of your rights as a personal data subject and create all conditions for the effective implementation of these rights, however, we reserve the right not to comply with your requirements when it is necessary to ensure:

26.1. the performance of legal obligations imposed on us;

26.2. national security or defense;

26.3. public order, prevention, investigation, detection or prosecution of criminal acts;

26.4. important economic or financial interests of the state;

26.5. prevention, investigation and detection of violations of official or professional ethics;

26.6. protection of your rights and freedoms or those of other persons.

27. You may submit to us requirements related to the implementation of your rights by electronic means of communication.

Upon receipt of your application, we may request the provision of identity documents, as well as other additional information related to the request that we need.

28. Upon receipt of your request, we will respond to you no later than within 30 calendar days from the date of receipt of your request and submission of all documents required for the response.

29. If we consider it necessary, we will suspend the processing of your data, except for storage, until your request is resolved. If you lawfully withdraw your consent, we will immediately but no later than within 30 calendar days terminate the processing of your personal data, except for the cases specified in clause 12.2 of this Privacy Policy and legal acts, i.e. when we are obliged to continue processing your data by valid legal acts, legal obligations incumbent on us, court decisions or mandatory instructions given to us by institutions.

30. If we refuse to comply with your request, we will clearly indicate the grounds for such refusal.

31. If you disagree with our actions or response to your request, you may complain about our actions and decisions to the competent state authority.

XI. COMPLAINT PROCEDURE

32. If you wish to file a complaint regarding our data processing, please submit it in writing, providing as much information as possible, using the contact details provided at the end of this policy. We will cooperate with you and try to resolve any issues promptly.

33. If you believe that your rights under the GDPR have been violated, you may file a complaint with our supervisory authority, the State Data Protection Inspectorate; more information and contact details can be found on the Inspectorate’s website (www.ada.lt). We would like to point out that we always aim to resolve all of your arising complaints promptly and amicably together with you.

XII. CHANGES TO THE PRIVACY POLICY

34. All changes to our Privacy Policy will be published on the Platform. If necessary, we will notify you about them on the Platform and by e-mail. You may need to read and agree to the updated or changed Privacy Policy terms in order to be sure that you are familiar with the change and can continue to use the Platform services.

XIII. OUR CONTACTS

35. Please send inquiries and documents related to the Privacy Policy to the following contacts:

  • in cases of service provision – to the contacts specified by the Service Providers;
  • Edufy platforms:
    • by mail – MB “Edufy group”, address Paplaujos g. 3-38, Vilnius;
    • by e-mail – [email protected]