Current version (v.1). Valid from 2024-05-15
LIV_IN PRIVACY POLICY
GENERAL PROVISIONS AND APPLICATION OF THE PRIVACY POLICY
The Data Controller – UAB "Liv in LT", legal entity code 305529989, registered office address Rinktinės st. 5, Vilnius, Republic of Lithuania (hereinafter, the Company), respects the privacy of the visitors of the Website, their representatives, and other persons who provide the Company with the Personal Data, or the Company receives such data with a lawful basis for obtaining and processing the Personal Data, including from third parties (hereinafter, You or Yours or Your).
In this regard, the Company collects, stores, uses and discloses or otherwise processes Personal Data only as described in this Privacy Policy and/or applicable law, including the GDPR, the LLPPD, as well as other information provided to You. Please note that additional and/or more detailed information about how We process Personal Data may be contained in contracts and other information and documents provided by the Company.
This Privacy Policy describes the principles of collecting, using or otherwise processing information on the Website operated by us, as well as other information about the Personal Data processed in the Company's operations, and the policies and principles applied to ensure the protection of Personal Data.
This Privacy Policy is addressed to persons who are:
- Visitors to the Website or users of its functionalities (e.g. by submitting enquiries via the enquiry form); or
- Clients of the Company or residents of the apartments who use the rental and other services provided by LIV_IN; or
- other persons who provide Personal Data to the Company or the Company receives such data, including from third parties, on legitimate grounds for receiving and processing Personal Data.
By using the Website and/or LIV_IN services and/or providing us with Personal Data (except where we are required to obtain your explicit consent under applicable law), You consent to the processing of the Personal Data You provide to the Company in accordance with this Privacy Policy.
The provision of your Personal Data on the Website or as otherwise requested by the Company is usually voluntary, but is necessary to enable Us, for example, to respond to Your enquiries, to carry out the Company's transactions with You or Your representative, to provide rental services for apartments and other premises, to comply with obligations arising from legislation, etc.
The Data Controller has the right to process Personal Data in other cases and for other purposes not specified in this Privacy Policy, but in any case you will be informed about the processing of your Personal Data in accordance with the procedure established by law.
Please make the information contained in this Privacy Policy known to Your current or future representatives (persons who represent You in Your dealings with us (if You are, for example, a Client of ours), as well as to any other persons who may be affected by the fact that You provide Us with their Personal Data (for example, persons who use the premises You rent from LIV_IN).
Definitions
In the Privacy Policy definitions, which are written in the capital letter, shall have the same meaning as defined down below:
- LLPPD – the Law on Legal Protection of Personal data of the Republic of Lithuania;
- Personal data – any information about You, as a natural person, whose identity has been identified or can be identified (the Data subject); the natural person, whose identity can be identified, is the person, whose identity can be identified directly (using an identifier such as name and surname, internet identifier) or indirectly (according to one or more physical, physiological, genetic, psychological, economic, cultural or social identity features);
- GDPR – 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;
- Controller or Company, or LIV_IN, or We, or Us, or Our, – UAB „Liv in LT“, legal entity code 305529989, having its registered office address at Rinktinės st. 5, Vilnius, the Republic of Lithuania;
- You or Your or Yours – any person, including who visits the Website and uses its functionalities or is Company‘s client, partner and/or its representative and provide the Personal data to the Company or the Company, having legitimate ground for receiving and processing of the Personal data, receives such data, including from third parties;
- Privacy Policy – the principles, rules and requirements provided by the Company that establish the procedure of collection, storage, use and any other processing of information, including Personal data, related to the use of the Website and its functionalities, also processed in Company's activity, as well as other relevant provisions;
- Cookies – small files, which are sent into Your browser and stored in your computer, mobile phone or other devise, which You are using to connect to the Website, also other technologies, such as pixels;
- Direct marketing – the activity of offering goods or services to persons by post, telephone or other direct means and/or seeking their opinion on the goods or services offered;
- Website– a website accessible via the Internet at https://liv-in.lt/ and the Controller of which is the Company.
CONNECTION TO THE WEBSITE
Each time You visit the Website, servers of the Website temporarily store information about the connecting device in the login file. In this procedure, regardless of Your actions, the following data is automatically collected and stored for as long as it is automatically and (or) manually deleted, i. e. date and time of connection, information about browser You are using and its version, type of the device, and other technical details. This information is collected and processed in order for You to use Our Website, also to guarantee the continued security and stability of the system, technical administration of the network infrastructure, as well as for internal statistical purposes.
PURPOSES OF THE PROCESSING OF PERSONAL DATA, SOURCES OF DATA, CATEGORIES OF THE DATA SUBJECTS, OTHER INFORMATION RELATED WITH THE PROCESSING OF YOUR PERSONAL DATA
To ensure transparency and responsible processing of Personal data, We inform that the Company processes Your Personal data for the following purposes and under the following conditions:
Management of available material and financial resources
In order to ensure our independent functioning and to manage the financial and material resources available to Us, including to maintain the Company's accounting records, to issue invoices to Clients, to account for invoices received, We may process Personal Data of Clients (including those who use the apartment and other space rental services provided by LIV_IN) and of their representatives/employees.
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Processed Personal data
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Client's name, surname, personal identification number (if applicable), bank account number, information on the price of the services/goods received/provided, the amount of taxes deducted, the amount paid, and where the Client is represented by a representative/employee, his/her name, surname, telephone number, email address.
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Legal basis for the processing of Personal data
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The processing of the Client's Personal Data is for the purpose of performance of the contract to which the Client is a party, as well as for the fulfilment of the Company's legal obligation to keep proper accounting records, and, in the case of the processing of the Company's Client's Personal Data or the Personal Data of the Company's representative/employee, for the Company's legitimate interest in the identification of the representative, the fulfilment of its contractual obligations to the Client, and the contact of the representative/employee for the purposes of the Company's accounting records.
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Period of storage of Personal data
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10 (ten) years after the relevant accounting transaction.
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Source of the Personal data
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The Personal Data of the Client shall be obtained from the Data Subject himself/herself, and where Personal Data of his/her representative/employee is processed, it may be obtained from the representative's employer or other represented person (the Client of the Company).
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Establishing and executing contracts
In order to enter into and properly perform Our contracts with Our Clients, for example, to record transactions, to monitor performance and payment, to collect debts, to issue an electronic key, to communicate for the purposes of service provision/facility management, We may process the Personal Data of Our Clients (including those who use the services of LIV_IN for the rental of apartments and other premises) and of their representatives.
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Processed Personal data
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Client's name, surname, date of birth, telephone no., email address, gender (only if you are choosing an apartment based on this criterion), country of arrival, data relating to amounts due/settled and payments made (amount and date of arrears for services, amounts paid and dates of payment, etc.), bank account number, purpose of the payment order, other information relating to the conclusion of the contract and the performance of the contractual obligations, including the services purchased and, where the Client (natural or legal person) is represented by a representative, the VAT number of the legal person (where applicable), the name, surname, telephone number, e-mail address of the signatory, and any other information specified by the representative.
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Legal basis for the processing of Personal data
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The Client's Personal Data shall be processed for the purpose of entering into and/or performance of a contract to which he/she is a party, and in the case of the processing of the Personal Data of the Company's Client's representative, for the Company's legitimate interest in the identification of the representative and in the performance of its contractual obligations with the Client.
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Period of storage of Personal data
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10 (ten) years from the due execution of the contract, or 2 (two) months in the case of a failure to conclude the contract (e.g. the booking is not confirmed/not paid for at the time of booking).
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Source of the Personal data
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The Personal Data of the Client shall be obtained from the Data Subject himself or herself, and where Personal Data of his or her representative is processed, it may be obtained from the representative's employer or another represented person (the Company's Client).
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Managing enquiries or feedback submitted through the Company's contacts (including by email) or through the functionalities available on the Website, including providing responses
In order to enable You to use the tools available on the Website (e.g. enquiry form, where available on the Website), as well as the Company's contacts (e.g. on the Website or via the email address specified in this Privacy Policy) to provide Us with Your enquiries or feedback, and to provide You with a reply to Your enquiries or feedback, We may process Personal Data about You as a person who has made an enquiry or given a feedback.
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Processed Personal data
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Name, email address, telephone number, the content of the message, including other Personal Data voluntarily provided in the communication.
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Legal basis for the processing of Personal data
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The processing of Personal Data shall be based on the Data Subject's consent, which may be expressed by submitting a request or feedback to the Company.
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Period of storage of Personal data
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1 (one) year from the date of the relevant enquiry or response.
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Source of the Personal data
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The Personal Data is obtained from the Data Subject themselves.
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Direct marketing through newsletters
Where We obtain Your separate consent for Direct Marketing, We may process Your Personal Data for the purpose of offering You offers of apartments and other premises for rent provided by LIV_IN, notifying You of Our news and/or asking for Your opinion on Our services.
Your consent to the processing of Personal Data for Direct Marketing purposes is obtained in advance, i.e. prior to the commencement of the processing of Personal Data for Direct Marketing purposes.
You are given the opportunity to object at any time to the processing of Personal Data for Direct Marketing purposes by withdrawing Your consent to the processing of Personal Data for this purpose.
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Processed Personal data
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Name, telephone number, email address
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Legal basis for the processing of Personal data
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The processing of personal data is based on the Data Subject's consent (Article 6(1)(a) GDPR)
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Period of storage of Personal data
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10 (ten) years from the date of consent (unless you withdraw your consent earlier, in which case We will retain your Data for this purpose until the moment you withdraw your consent).
Please also note that if Your consent expires or is withdrawn, We will retain Your consent for a further period of 3 (three) years on the basis of Our legitimate interest in order to be able to defend legal claims.
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Source of the Personal data
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The Personal Data is obtained from the Data Subject themselves.
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Service quality improvement and statistical purposes
Where You voluntarily provide certain optional Personal Data in LIV_IN questionnaires or contracts, We may process Your Personal Data for the purposes of improving the quality of the service and for statistical purposes, e.g. to assess the guests staying in LIV_IN apartments and to provide new and/or improved common areas according to their needs, to decide on new services, etc.
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Processed Personal data
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Occupation, workplace / education institution.
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Legal basis for the processing of Personal data
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The processing of Personal Data is based on the Data Subject's consent, which is expressed voluntarily by filling in the relevant fields and providing the Company with the relevant Personal Data.
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Period of storage of Personal data
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1 (one) year.
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Source of the Personal data
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The Personal Data is obtained from the Data Subject themselves.
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Ensuring the security of the Company's assets and the safety of the Company's employees, Clients and other persons and their property (video surveillance)
In cases when You visit the LIV_IN co-living complex (premises and territory owned by the Company, located on the land plot at Kauno st. 33, Vilnius) and You enter the field of surveillance of video surveillance cameras, we may process Your video data, i.e., Personal Data captured in the video recording (e.g, facial image) in order to ensure the protection of material resources (assets) owned or otherwise legally managed by the Company, the security of the Company's employees, Clients and other third parties and their property.
We organise video surveillance in such a way that no area or premises larger than our complex are included in the surveillance field. The interior of our complex and the entrances to Our buildings are monitored.
Video surveillance is not carried out in rooms and/or areas intended for private use, such as toilets, changing rooms, etc., as well as in apartments. You will be informed about video surveillance in certain premises or areas of the Company by means of information notices (e.g. information stickers) visible before entering the monitored premises or area.
Please note that video recordings may be submitted by the Company's decision to a pre-trial investigation body, prosecutor or court in connection with administrative, civil, criminal cases at their disposal, as evidence or in other cases provided for by law. Such provision shall be carried out in accordance with the procedure laid down by law.
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Processed Personal data
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Video Data - the image and other Personal Data captured in a video recording of persons within the field of view of the CCTV cameras (e.g. customers, residents of other apartments, suppliers or their representatives, other third parties).
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Legal basis for the processing of Personal data
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The processing is carried out for the purposes of the legitimate interests of the Data Controller, i.e. the protection of the Data Controller's material resources, the security of the Data Controller's Clients as well as other third parties and their property.
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Period of storage of Personal data
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The data collected during the video surveillance shall be kept for 30 (thirty) days from the date of the video recording.
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Source of the Personal data
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The personal data is obtained from the Data Subject himself/herself (by means of video recording devices).
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USE OF SOCIAL NETWORKS
Any information You provide through social networks (including messages, use of the "Like" and "Follow" boxes and other communications) is controlled by the operator of the relevant social network. Our Company currently has accounts on the following social networks:
- „Instagram“, which has a privacy policy available at https://help.instagram.com/519522125107875;
- „Facebook“, which has a privacy policy available at https://www.facebook.com/privacy/policy/;
- „Linkedin“, which has a privacy policy available at https://www.linkedin.com/legal/privacy-policy.
COOKIES
General provisions relating to Cookies and their use on the Website
On the Website we use Cookies in order to ensure the proper functioning of the Website, smooth use of the Website, also for the Website’s traffic statistic, user’s experience improving and other below mentioned purposes.
Cookies can be "session cookies", which are only used while you are browsing the internet and are automatically deleted when you close Your browser, or "persistent cookies", which are cookies that are stored on Your end device (computer, tablet, smartphone, etc.) or "third-party cookies", i.e. cookies used by a person other than the Website controller.
When You visit the Website, a pop-up message with a link to this Privacy Policy will inform You about the use of Cookies on the Website. By making the appropriate choices in the pop-up message, you consent to the Company placing on your terminal device (computer, tablet, smartphone, etc.) the relevant Cookies of your choice, which are described in more detail below. You have the right to choose and consent to the use of all or the relevant type of Cookies.
Regardless of Your choice, i.e. as You continue to browse the Website, strictly mandatory (necessary) Cookies will be recorded in any case.
Please note that Cookies may also be used by other third parties that are not under the control of the Website Controller. The Company cannot and is not responsible for the actions of such persons. If you suspect that Cookies are being used without Your consent by other third parties not under the control of the Website Controller, You should contact the third party concerned.
Refusal of cookies
If You do not wish or do not consent to the recording of Cookies on Your computer or other device, You may choose not to take the appropriate steps to consent, and You can always opt out of relevant or all Cookies by using the instructions below.
You can uninstall Cookies in the following ways:
- You can waive or withdraw Your consent at any time regarding specific or all Cookies here.
- on Your browser you can preview the Cookies installed on Your computer or other device and delete them one by one or all at once. The steps You need to make are different (see the instructions of Cookies of the most popular browsers by clicking on the following browser name Opera, Firefox, Chrome, Safari, Internet Explorer), thus the specific actions that shall be made should be set according to the browser You are using;
- You can also set Your internet browser to block Cookies or receive a warning about installing of any Cookies. The steps You need to make are different in each browser, therefore, the specific action You want to perform should be set according to the browser You are using.
List and types of Cookies used on the Website
Website uses Cookies specified below in the table, which are classified into four types. All of the following Cookies, except the strictly necessary Cookies, will be installed only upon your consent.
- Strictly necessary Cookies
These Cookies are necessary in order for the Visitor to use the possibilities of the Website as well as they are necessary to ensure the functioning of Our Website and electronic services. These Cookies are installed in all cases and Your consent is not necessary.
These Cookies allow the Website to remember the choices made by the Visitor (e.g. username, language used, etc.) and to improve and personalise the Website and its features.
These Cookies are used to track, collect and analyse statistical (anonymous) data about the number of users visiting Our Website and the use of electronic services, and to help Us to improve the functioning of the Website.
These Cookies allow Us to target the Website visitor with promotional offers on other websites (e.g. YouTube, Facebook, etc.), as well as to provide more interesting and relevant advertising to Your interests.
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Name
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Function
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Duration
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Domain
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Strictly mandatory (necessary) Cookies
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test_cookie
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1 day
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doubleclick.net
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twk_token_5f635e9f4704467e89efd506
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Persistent
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embed.tawk.to
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previousNav
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Session
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embed.tawk.to
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1.gif
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Session
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imgsct.cookiebot.com
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modal_shown
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Session
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liv-in.lt
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PHPSESSID
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1 day
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liv-in.lt
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CookieConsent
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Stores the Cookie consent state of the Website’s user for the current domain.
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1 year
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liv-in.lt
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Analytical
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collect
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Session
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google-analytics.com
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_ga
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Registers a unique ID that is used to generate statistical data on how the Website’s visitor uses the Website.
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2 years
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liv-in.lt
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_gid
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Registers a unique ID that is used to generate statistical data on how the Website’s visitor uses the Website.
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1 day
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liv-in.lt
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_gat
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Used by Google Analytics to throttle request rate.
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1 day
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liv-in.lt
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_ga_#
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2 years
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liv-in.lt
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TawkConnectionTime
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Session
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liv-in.lt
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Functional
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twk_#
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Persistent
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embed.tawk.to
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twk_idm_key
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Session
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liv-in.lt
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twk_uuid_#
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180 days
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liv-in.lt
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Advertising
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lastExternalReferrer
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Persistent
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connect.facebook.net
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lastExternalReferrerTime
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Persistent
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connect.facebook.net
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pagead/landing
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Session
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doubleclick.net
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ads/ga-audiences
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Session
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google.com
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_fbp
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Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
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3 months
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liv-in.lt
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_gcl_au
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3 months
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liv-in.lt
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STORAGE OF THE PERSONAL DATA
Your Personal Data will be processed by the Company to the extent specified in this Privacy Policy above.
Please note that in certain cases, a longer retention period or the right for Us to retain Personal Data for longer periods of time may be provided for by law, e.g. where the processing of Personal Data is necessary in order to comply with the requirements of the law applicable to the Company requiring the processing of the Personal Data, or where the processing of Personal Data is necessary for the exercise, execution, or defence of legal claims.
In this case, We may process your Personal Data for a longer period of time, but only for as long as is necessary for the purposes of processing your Personal Data. Such Personal Data will be destroyed as soon as it is no longer necessary.
DISCLOSURE OF PERSONAL DATA
We may disclose Your Personal Data only under the legitimate basis (for example, when required by legal acts, agreement concluded with You or when We have your consent) and in accordance with the requirements of applicable legal acts.
In addition to the cases already mentioned in this Privacy Policy, You are informed that We may transfer Your Personal Data to the following:
- service providers, who act as processors of the Personal Data and provide services to the Company related to IT, Website support and maintenance, maintenance of applications used by the Company, provision of servers and its maintenance, accounting or other administrative services, premises and property security services, etc.
- in the cases specified in legal acts, to law enforcement and supervisory, as well as other state and municipal authorities, in order to comply with legal requirements, including to the State Tax Inspectorate;
- to persons providing services in connection with the performance of a contract with You or with Your representative, including postal and parcel service providers, service providers providing troubleshooting/incident resolution services, and payment initiation services;
- bailiffs, courts, other bodies dealing with disputes;
- other third parties, when you submit relevant request to submit your Personal Data, or to third parties, about which You are clearly informed in the other way and/or Your consent is received and provision of the information is agreed while using the specific service;
- companies providing Company’s audit and related services, providers of legal and financial advisory services;
- other business subjects, in case of Company’s merger with other legal entity or acquisition, including to subjects carrying out legal due diligence.
YOUR (AS THE DATA SUBJECT) RIGHTS AND ITS IMPLEMENTATION
You, as the Data subject, have all rights specified in the applicable legal acts, including indicated down below:
Right to revoke the given consent
If You have given Us your consent to process Your Personal Data, You may revoke it at any time (withdrawal of the consent shall not affect the lawfulness of the processing of Personal data based on the consent before its withdrawal) by contacting Us using the contact details specified in this Privacy Policy or by using other functionalities provided by the Company.
Right to request the access to Your Personal Data.
You can access Your Personal Data, which are processed by the Company. You can get information on how it is collected, period for which Your data are stored and who and to what extent receive Your data. However, Your right of access may be limited by legal acts;
Right to request rectification of Personal Data
You may require the Company to rectify processed Personal Data that is related to You, if it is incorrect, inaccurate or incomplete;
Right to object
Under the certain circumstances, You have the right to object the processing of Your Personal Data, including when Your Personal Data are processed on the basis of the legitimate interest. You also have the right to object the use of Your Personal Data for the direct marketing purposes (only if and when We process data for these purposes);
Right to restriction of the processing
If You think that your Personal Data processed by the Company is incorrect or You disagree with the use of the data, You may require the Company that the use of this data would be limited solely to storage. The use will be limited to the storage until the verification of the accuracy of the data or until the verification whether the legitimate grounds of the Company override those of the Data subject.
Right to erasure
If Your Personal Data are processed illegally, You disagree to such processing of Your Personal Data or there are other legal grounds, You shall have the right to obtain from the Company the erasure of the Personal data in accordance with the restrictions specified in legal acts.
Right to data portability
You have the right to get the Personal Data related to You, which You submitted to the Company, in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller in accordance with the procedure established by legal acts.
The right to lodge a complaint
You also have the right to lodge a complaint to the State Data Protection Inspectorate, if You consider that the processing of Personal data relating to You infringes requirements of legal acts. However, We kindly as You to firstly contact Us using the contacts indicated in this Privacy Policy.
Procedure of implementation of the Data subject’s rights
If You have additional questions or You want to implement Your rights indicated in this Privacy Policy and related to the processing of the Personal Data, You should contact Us by using the contacts indicated in this Privacy Policy (by email, by post (by sending to the indicated address) or physically upon arrival at the Company's registered office).
When submitting requests on rights related to the processing of Personal Data, You will be asked to confirm Your identity (e. g. in case You submit an application by electronic means, You must sign it by electronic signature, in case You apply to the Company upon physical arrival/send request by post, You must provide an identity document or a its copy confirmed in a manner prescribed by legal acts).
We will only accept those requests on implementation of the Data subject’s rights that will be completed/submitted in a coherent and understandable state language (Lithuanian language), in readable characters, does not contain offensive or disrespectful expressions, clearly and specifically specifies the right(s) to be used and circumstances related to the implementation of the right.
We will consider the request on the right(s) of the Data subject as unjustified and may not execute it in cases where it does not specify the right(s) to be implemented, as well as any other information required by the Privacy Policy or the GDPR. We may also not execute your request if We do not process Your Personal Data, the appropriate documentation to identify Your (or Your representative‘s) identity are not provided together with the request, the person submitting the request is not duly authorized or has no right to make the request (no Power of Attorney or other document granting the right to represent You is submitted) or legal acts do not provide possibility of satisfying Your request.
Please note that in cases where You abuse Your right to submit the request, We have the right to charge a fee for execution of the request.
We will respond to all Your requests related to the implementation of Your, as the Data subject, rights without undue delay and no later than within 1 (one) month after receiving the request. That period may be extended by 2 (two) months by informing You in advance.
INFORMATION SECURITY
We use reasonable technical and organizational measures in order to secure Our information (including the Personal Data) from the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to the Personal data.
THIRD PERSONS
The Company does not control privacy policies and (or) other rules that are applied to You by the third parties. Therefore, You, at Your own discretion and risk, are liable and obligated to comply with them in those cases, when it is applied to You (e. g., when links to websites not managed by the Company are provided in the Website). The Company is not liable for other websites’ privacy policies or any other content, when reference to the other websites is provided on the Website, or the reference to the Website is given on other websites. When you are pressing the reference, logo or any other element of the Website, or when using the services available in the Website, We draw Your attention that at the time, when You click on any mentioned element, You may leave the Website.
The Company does not collect any information about you from third parties, except the cases specified in the Privacy Policy, also when the legal acts’ requirements or third parties rights’ are infringed.
AMENDMENTS OF THE PRIVACY POLICY
The Company shall have the right at its own discretion to amend (including change, edit, supplement, cancel, annul) this Privacy Policy or any part thereof and any related information.
The updated Privacy Policy will be posted on the Website and will take effect from the date of its publication (the link "Valid from" at the top of the Privacy Policy indicates when the Privacy Policy was last updated).
At the moment of visiting the Website or its functionality, we recommend You to check the Privacy Policy and its updates and make sure that You are satisfied with the current version of the Privacy Policy. If You use the Website or any other functionality after publishing an updated Privacy Policy, You agree to the updated Privacy Policy.
FINAL PROVISIONS AND CONTACT DETAILS
This Privacy Policy is governed by the laws of the Republic of Lithuania.
Any disagreement over the implementation of this Privacy Policy shall be resolved by negotiation. If the parties are unable to agree, disagreements shall be resolved in the manner prescribed by the laws of the Republic of Lithuania.
If you have any questions, claims or need our help with the interpretation or application of the Privacy Policy, or if you wish to exercise your rights as the Data subject, please contact the Company using the following contacts:
E-mail: vilnius@liv-in.lt
Phone No.: +370 614 59 599
Address: Rinktinės st. 5, Vilnius, Lietuvos Respublika
We will try to respond to all your requests regarding this Privacy Policy and submitted in a written form immediately (we shall respond to all your requests related to the implementation of your, as the Personal Data subject, rights no later than within 1 (one) month from the receipt of the request, except for the exceptions specified in the legal acts or this Privacy Policy).
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