BACK 2021 Jul 24

Privacy Policy

UAB Sanobiotec provides you with the following information in accordance 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 (the “GDPR”) (“the Regulation”), and the Law on the Protection of Personal Data (“the Act”).

Pursuant to this Privacy policy (“the Privacy policy”), the controller of your personal data is UAB Sanobiotec.

Contact information with regard to data processing matters:

Address: Mokslininkų str. 12, Vilnius, Lithuania.
Contact phone. No.: +370 608 33823
E-mail address: info@sanobiotec.com

THE FOLLOWING TERMS ARE USED IN THIS PRIVACY POLICY:

Personal data – means any information relating to an identified or identifiable natural person.
Person / Data subject – means natural person (data subject) whose data is processed.

Data processing – means any operation or sequence of operations performed by automated or non-automated means on personal data or sets of personal data.

Data processor – means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; for the purposes of this Privacy policy, the data processor is the service provider engaged by UAB Sanobiotec and acting on behalf of UAB Sanobiotec.

Data controller – means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Privacy policy, the data controller is Sanobiotec UAB, legal entity code 305534922.

Regulation – means 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 (General Data Protection Regulation).

HOW DOES UAB SANOBIOTEC COLLECT YOUR PERSONAL DATA?

UAB Sanobiotec receives your Personal data in the following manner:

by contacting you in writing, by email or by telephone, the content of the correspondence or conversations may be stored;
when negotiating with you and/or entering into contracts with you, when you order goods or services from UAB Sanobiotec;
when you provide certain data on the UAB Sanobiotec website (“the Website”);
while you use the Website;
when you visit UAB Sanobiotec’s office premises.

HOW DOES UAB SANOBIOTEC PROCESS YOUR PERSONAL DATA?

Purpose of processing of Personal data	Personal data processed	Time limits for processing Personal data	Legal basis for processing Personal data	Data recipients
Direct marketing, sending newsletters.	Email address, address, name, surname, phone number.	A period of 3 years or until the Data subject withdraws consent.	The Data subject’s consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to a company providing direct marketing services, a company providing information technology services.
Implementation of remote meeting booking functionality on the Website.	Email address, name, surname, phone number, meeting time details.	No longer than period of 6 months after the date of the relevant remote meeting or until the Data subject withdraws consent.	The Data subject’s consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to the company providing information technology services, to the company providing Website development and maintenance services, to the provider of the Calendly booking tool and to the persons engaged by it.
Implementation of enquiry form functionality on the Website.	Name, surname, email, phone number, company name, country, data related to the order request, other information provided by the data subject.	No longer than 6 months from the receipt of the order, but no longer than until the Data subject withdraws his or her consent.	The Data subject’s consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to the company providing information technology services, to the company providing website development and maintenance services, to the company administering the order form tool, and to persons engaged by it.
Website management and administration.	Information regarding cookies used on the Website.	Depending on the data retention period set by the cookie in question, which is indicated on the Website.	The Data subject’s consent to such processing (Article 6 part 1(a) of the GDPR). The processing is necessary for the legitimate interests of the controller (Article 6 part 1(f) of the GDPR).	Access to Personal data may be granted to a company providing information technology services, website development and maintenance services.
Customer service and service quality improvement.	Audio recording and the data captured during the recording.	No longer than one month from the date of the conversation in question.	The Data subject’s consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to a company providing information technology services.
Conclusion and performance of contracts.	If the contracting party is a natural person – name, surname, contact details (phone number, email address, address), personal identification number, signature, financial details (data required for invoicing and bookkeeping (such as VAT number, bank account number, payment information). If the contracting party is a legal entity – name, surname, job position.	During the term of the agreement and up to 10 years after the expiry date.	The processing is necessary for the performance of a contract to which the data subject is a party or in order to take action at the request of the data subject prior to the conclusion of the contract (Article 6 part 1 (b) of the GDPR). The processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6 Part 1(c) of the GDPR).	Access to Personal data may be granted to legal advisers.
Ensuring the security of property and persons on the premises through video surveillance.	Image.	14 days from the date of data recording, unless a longer retention period is provided for by law.	The processing is necessary for the legitimate interests of the controller (Article 6 part 1(f) of the GDPR).	Access to Personal data may be granted to a company providing information technology services, the joint controller UAB Sanobiotec R&D (company code 304832983, address: Vilnius, Mokslininkų g. 12, LT-08412).

In addition to the above: access to Personal data may also be granted to law enforcement or other authorities, as well as to companies of the UAB Sanobiotec Group; if the Personal data is used or is to be used as evidence in a case or investigation, or if the Personal data is transferred to law enforcement authorities, or in any other case provided for by law, the Personal data may be retained for the period of time required to fulfil the purposes of the processing of the Personal data, and shall be deleted as soon as it no longer is required.

In the case of transfers of Personal data, UAB Sanobiotec will take the necessary measures to ensure that the service providers (Data processors) would use the Personal data provided only for the purposes for which it was provided, ensuring appropriate technical and organisational security measures, in accordance with UAB Sanobiotec’s instructions and the requirements of the applicable legislation.

Personal data managed by UAB Sanobiotec is provided to data recipients outside the European economic area only after an adequate level of legal protection of Personal data has been ensured (e.g., on the basis of the EU Standard contractual clauses, the Privacy Shield system, the European commission’s decisions on adequate protection of Personal data, or otherwise), or, in the absence of any other justification, after obtaining the authorization of the State data protection inspectorate, or with the consent of the Data subject.

In all of the above cases, UAB Sanobiotec processes Personal data only to the extent necessary for the achievement of the relevant clearly defined and legitimate purposes.

NEWSLETTERS (WEBSITE)

By entering your email address in the box provided on the UAB Sanobiotec Website, you will be able to subscribe to newsletters regarding UAB Sanobiotec products and services.

Entering your e-mail data in the box provided for this purpose shall be deemed to be your expressed consent to the processing of the Personal data provided by you in accordance with the terms and conditions set out in this Privacy policy.

You can unsubscribe from newsletters by providing UAB Sanobiotec with a free-form notice expressing your will to unsubscribe from the newsletter or by clicking on the unsubscribe link in the newsletter you have received (if the newsletter has the above functionality).

Subscription to the newsletter is free of charge.

ENQUIRY FORMS (WEBSITE)

By completing the enquiry form on the UAB Sanobiotec Website, you will be submitting an enquiry to UAB Sanobiotec (including the Personal data you provide) regarding the goods and services offered by UAB Sanobiotec.

Completion of the enquiry form shall be deemed to be your expressed consent to the processing of the Personal data provided by you in accordance with the terms and conditions set out in this Privacy policy.

You may refuse the request (including the processing of the Personal data contained therein) by providing UAB Sanobiotec with a free-form notice expressing your will to refuse the request.

Information on the processing of personal data by the operator of the functionality is contained in the respective Privacy policy of the operator, at: https://policies.google.com/privacy?hl=en

The enquiry function is free of charge.

BOOKING A REMOTE MEETING (WEBSITE)

By completing the remote meeting booking form on the UAB Sanobiotec Website, you will make a remote meeting booking and provide UAB Sanobiotec with the relevant Personal data.

Completion of the booking form constitutes your consent to the processing of the data provided in accordance with this Privacy policy.

You may cancel your reservation (including the processing of the Personal data provided in relation thereto) by providing UAB Sanobiotec with a free-form notice expressing your wish to cancel your reservation.

Information on the processing of personal data by the operator of the functionality is contained in the respective Privacy policy of the operator, at: https://calendly.com/legal/privacy-notice

The booking function is free of charge.

COOKIES (WEBSITE)

UAB Sanobiotec informs you that cookies are used on this Website.

UAB Sanobiotec uses cookies that comply with the general legal framework for the protection of personal data, the General Data Protection Regulation (GDPR) No.679/2016 applicable in the European Union.

Full information regarding UAB Sanobiotec’s use of cookies is available at: https://sanobiotec.com/Privacy policy/

PROCESSING OF TELEPHONE CALL RECORDS

UAB Sanobiotec, when recording telephone conversations and processing Personal data, complies with the Regulation, the law on electronic communications of the Republic of Lithuania, UAB Sanobiotec’s internal procedures and other legal acts regulating the processing of Personal data and the protection of privacy.

In order to ensure the improvement of customer service and the quality of service provision, telephone conversations between you and an employee of UAB Sanobiotec (generally, UAB Sanobiotec’s sales managers) may be recorded in certain cases.

You will be informed regarding the recording of the content of the telephone conversation at the beginning of the telephone conversation, as soon as the telephone conversation has commenced, by asking a UAB Sanobiotec employee to confirm your consent to the recording of the audio recording of the telephone conversation. Recordings of telephone conversations are made only with your consent (Article 6 part 1(a) of the GDPR) in accordance with the procedures and under the conditions set out in this Privacy policy.

Please note that you have the right to object to the recording and processing of the audio recording of a telephone conversation. In this case, the conversation will be continued without audio recording or the telephone conversation will be terminated by asking you to contact us by other means of communication (by e-mail or by visiting the address of UAB Sanobiotec).

The audio recording of the telephone conversation shall record the voices of the participants in the telephone conversation and the Personal data provided by the individuals or by an employee of UAB Sanobiotec during the telephone conversation.

SECURITY MEASURES

Technical security measures:

Personal data is stored in a secure system protected by firewalls, antivirus and other technical measures to prevent unauthorised access to the system;
Sanobiotec UAB premises and territory have appropriate controls in place to protect the information and information technology equipment held or stored therein;
Sanobiotec UAB premises and territory where information and/or information technology equipment is stored, shall be provided with an appropriate level of physical security and shall be organised in such a way that appropriate access control systems are implemented and that access is restricted to authorised persons only;
only authorised persons have access to Personal data, and the ability of unauthorised persons to read, copy, alter or otherwise modify Personal data is restricted;
other additional technical security measures stipulated in UAB Sanobiotec’s internal procedures have been duly implemented.

Organisational security measures:

UAB Sanobiotec employees who process Personal data are obliged to comply with UAB Sanobiotec internal rules, procedures and policies governing and regulating the protection of personal data and the protection of information and information technologies;
information, access to information, its use, processing, storage and other processes related to information shall be carried out in strict compliance with the requirements and standards set by UAB Sanobiotec;
access control is based on the need (necessity) of the activities and functions performed. Access control is based on the assumption that everything is generally prohibited except as necessary for the performance of the assigned function, specifically authorised in advance and approved;
access to Personal data is limited to a limited number of persons, and no unauthorised persons are allowed access to the Personal data processed;
UAB Sanobiotec has a policy whereby computers are switched off and access is protected by passwords when leaving the workplace, and information containing Personal Data is stored in a place inaccessible to third parties;
other additional organizational security measures stipulated in UAB Sanobiotec’s internal procedures have been duly implemented.

RIGHTS OF DATA SUBJECTS

You have the following rights in relation to your Personal data:

the right of access to data – you have the right to obtain confirmation as to whether or not Personal data relating to you are being processed, as well as access to your Personal data processed by UAB Sanobiotec;

the right to rectification – your Personal data must be accurate and, where necessary, kept up to date;

the right to erasure – you have the right to request the erasure of the data relating to you if the data is no longer necessary for the purposes for which it was collected or processed for other purposes, if you withdraw your consent and there is no other legal basis for the processing of your personal data, if you do not consent to the processing of the data, if the processing is carried out for the legitimate interests of UAB Sanobiotec and there are no overriding legitimate grounds for the processing of the data, or if the processing of your personal data was unlawful;

the right to restrict processing – you have the right to request the restriction of the processing of your Personal data until UAB Sanobiotec verifies the accuracy of your Personal data processed. If you object to the processing where the processing is carried out for the legitimate interests of UAB Sanobiotec, you have the right to request the restriction of the processing of your Personal data for a period of time until it has been verified that UAB Sanobiotec’s legitimate reasons override your reasons. You have the right to request the restriction of the processing of your Personal data if, in the event of unlawful processing, you do not consent to the erasure of your data and instead request the restriction of its use, as well as if UAB Sanobiotec no longer needs the Personal data for the purposes of processing, but the data is necessary for the establishment, exercise or defence of legal claims;

the right to object to processing – you have the right to object to the processing of personal data where the processing is carried out for the purposes of the legitimate interests of UAB Sanobiotec, except where the processing is carried out for legitimate reasons which override your interests, rights and freedoms, or for the establishment, exercise or defence of lawful claims and interests;

the right to data portability – if personal data of individuals are processed by UAB Sanobiotec by automated means, you have the right to receive the Personal data relating to you that you have provided to UAB Sanobiotec in a format that is structured, commonly used and computer-readable;

the right to lodge a complaint with the State data protection inspectorate – you have the right to lodge a complaint with the State Data Protection Inspectorate in accordance with the procedure set out in the Law on Legal protection of personal data.

UAB Sanobiotec has the right to make changes to this Privacy policy.

COOKIE POLICY