Effective date: January 18, 2023

PRIVACY POLICY OF TeamBit, UAB

GENERAL PROVISIONS

The Controller – TeamBit, UAB, legal entity code 305954666, having its registered office address at K. Baršausko str. 47-13, Kaunas, the Republic of Lithuania, respects the privacy of the Website’s visitors, the Company's customers, partners/suppliers and/or their representatives and other persons who provide Personal data to the Company or the Company receives such data, including from third parties, with a lawful basis for obtaining and processing such Personal data (hereinafter, you, your or yours).

This Privacy Policy describes the principles of collection, use or otherwise processing of information we use on the Website, as well as other information about Personal data processed in Company's activity, policies and principles applied in order to ensure the protection of Personal data. Please note that additional and/or more detailed information about how we process your Personal data may be contained in contracts and other information and documents provided by the Company (e. g. consent forms).

By using the Website and/or by providing Personal data to us (unless we have to receive your explicit consent under applicable legal acts), you agree that Personal data that you submitted to the Company would be processed in accordance with this Privacy Policy.

Provision of your Personal data in cases described in the Website or otherwise requested by the Company is usually voluntary, but is necessary in order, for example, to respond to your inquiries, to test our services, to execute the agreement concluded with you or the person you represent and etc.

The Controller has the right to process Personal data in other cases and purposes not covered by this Privacy Policy, but in any case you will be informed about the processing of your Personal data in the manner prescribed by applicable legal acts (e.g. in the separate privacy notice dedicated to candidates).

We kindly ask you to familiarise with the information contained in this Privacy Policy your existing or future representatives (individuals, who represent you in relations with us, if you are, for example, our client or supplier), as well as other persons to whom this information may be relevant due to the fact that you submit their Personal data to us, and receive their consent for provision of data to us, if such is necessary.

DEFINITIONS

In the Privacy Policy definitions and expressions, 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 we, or us, or our

Teambit, UAB, legal entity code 305954666, having its registered office address at K. Baršausko str. 47-13, Kaunas, the Republic of Lithuania
You or your or yours

Any person, including who visits the Website and uses its functionalities (e. g., submits the inquiry) or is Company‘s client, partner/supplier and/or its representative and provide the Personal data to the Company or the Company, having legitimate ground for receive 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 establishes 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 device, 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://www.teambit.lt/ and the administrator 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 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 you could 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 manage our available financial and material resources, including Company‘s bookkeeping, invoicing clients, keeping accounting of incoming invoices, we process the Personal data of our clients or partners/suppliers and their representatives/employees.

Processed Personal data	Client’s or supplier’s/partner’s name, surname, address, details of individual activity, VAT payer’s code (if applicable), information about payables/receivables and when client/supplier/partner (natural or legal person) is represented by own representative/employee – his/her name, surname, e-mail address and (or) telephone number, position.
Legal basis for the processing of Personal data	Personal data of the client or supplier/partner are processed in order to perform the contract to which the Data subject is party, also to fulfil the legal obligation applicable to the Company to properly maintain accounting, and, when the Personal data of client’s or supplier’s/partner’s representative/employee are processed – on the basis of the Company’s legitimate interest to fulfil its contractual obligations with the client or supplier/partner and contact the representative/employee for accounting purposes.
Period of storage of Personal data	10 (ten) years from the relevant accounting operation and, in the case of processing of Personal data of the representative/employee of the Company's customer or supplier/partner's, 10 (ten) years from the proper performance of the contract.
Source of the Personal data	Personal data of client or supplier/partner are obtained from the Data subject and, when Personal data of its representative/employee are processed – it can be obtained from the employer of representative or other person being represented (client, partner/supplier of the Company).

Conclusion and performance of contracts

In order to conclude and properly perform contracts with our clients, partners/suppliers, including record concluded transactions, control its execution and payment, recover debts, we may process Personal data of clients or partners/suppliers and their representatives/employees.

Processed Personal data	Client’s or supplier’s/partner’s name, surname, address, telephone number, e-mail address, dates of occurrence, basis and amounts of debt/payments, date of birth or personal identification number, other information related to contractual obligations, and when Personal data of client’s or supplier’s/partner’s representative/employee are processed – his/her name, surname, telephone number, e-mail address, position.
Legal basis for the processing of Personal data	Personal data of the client or supplier/partner are processed in order to perform the contract to which the Data subject is party and, when Personal data of representative/employee of client or supplier/partner are processed – on the basis of the Company’s legitimate interest to identify representative and fulfil Company’s contractual obligations with the client or supplier/partner.
Period of storage of Personal data	10 (ten) years from proper execution of the contract.
Source of the Personal data	Personal data of supplier/partner are obtained from Data subject itself and when Personal data of its representative/employee are processed – they can be obtained from employer of representative or other representative (client, partner/supplier of the Company).

Administration of inquires, requests (including requests to try our services (DEMO)) or complaints received by Company‘s contacts (including by e-mail) or other functionalities available on the Website, including submission of responses

In order to ensure opportunity for you by using the means available on the Website (for example, form of inquiries/contacts) or by using contacts of the Company (for example, e-mail specified in the Website or this Privacy Policy) to submit for us the inquiries, requests or complaints, as well as to submit you the answers to your inquiries, requests or complaints, we can process your Personal data.

Processed Personal data	E-mail address, name, the content of the subject/message as well as any other Personal data voluntarily provided in the inquiry, request, complaint or further communication (e. g. telephone number, surname, the company you represent).
Legal basis for the processing of Personal data	Personal data are processed on the basis of the Data subject‘s consent, which may be expressed by submitting an appropriate inquiry, request or complaint to the Company. In the event you provide us with the data of other persons for this purpose (e.g. email address), you must inform such person and obtain their consent for provision of their data to us.
Period of storage of Personal data	1 (one) year from the date of submission of the relevant inquiry, request or complaint, unless we have legal basis to further process the data.
Source of the Personal data	Personal data are obtained from the Data subject.

Direct marketing and advertising of Company‘s products, solutions and etc.

When we obtain your separate consent or have other legitimate basis for Direct marketing, we may process your Personal data in order to offer you the Company's goods or services (products, tools) and/or to seek your opinion on the goods or services offered.

Your consent to the processing of Personal data for Direct marketing purposes is obtained in advance, i.e. prior to the processing of Personal data for Direct marketing purposes.

You are given the opportunity to object to the processing of Personal data for Direct marketing purposes and/or to withdraw your consent to the processing of Personal data for this purpose at any time.

Processed Personal data	Name, surname, telephone number and/or email address, details of the company you represent, other Personal data provided by you during communication.
Legal basis for the processing of Personal data	Personal data are processed on the basis of the Data subject‘s consent.
Period of storage of Personal data	3 (three) years from the date of consent (unless you revoke it earlier; in such case we store your data for this purpose until the moment you revoke your consent) or such other period as may be specified in the Data subject's consent. In addition, after the expiration or revocation of the consent, we will store the data about the fact that you gave us consent for another 1 (one) year based on our legitimate interest for the purpose of defending legal claims.
Source of the Personal data	Personal data are obtained from the Data subject.

Right to object

You are given the opportunity at any time to object to the processing of Personal data for Direct marketing purposes and/or to withdraw your consent to the processing of Personal data for this purpose (withdrawal of consent will not affect the lawfulness of consent-based processing of Personal data carried out by us prior to the withdrawal of your consent). Your refusal or non-consent will not prevent you from using the Company's services, but the Company will not be able to provide you with useful offers, information, etc.

You may withdraw your consent or exercise your right to object by informing the specific representative of the Company with whom you are communicating by telephone, by using the unsubscribe functionality in the emails sent to you, or by contacting the Company at the email address set out below in this Privacy Policy.

COOKIES

General provisions related to the Cookies and its usage on the Website

On the Website we use Cookies 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 may be “session cookies” that are used only while you are browsing the internet and are automatically deleted after closing the browser, “persistence cookies”, i.e. that are stored on you back device (computer, tablet, smartphone, etc.) until Cookie’s validity term ends or you refuse use of Cookie using one of the methods, described in this Privacy Policy, or “Third Party Cookies”, i.e. those that are used by the person, which is not the Website’s controller.

When you visit the Website, it displays a pop-up notification informing about the use of Cookies on the Website with link to this Privacy Policy. By making relevant choices in the pop-up notification, you consent that the Company will save relevant chosen Cookies on your back device (computer, tablet, smartphone, etc.) that are described in more detail below. You have a right to choose and accept or withdraw your consent on all or particular type of Cookies.

Despite your choice i.e. if you continue using the Website, the strictly necessary Cookies will be installed in all cases.

Please note that Cookies may also be used by the Company’s partners or other third parties that are not controlled by the Website’s controller. The Company may not be and is not responsible for the actions of such persons. By suspecting that, without your consent, the Company’s partners or other third parties, who are not controlled by the Website’s controller, use Cookies, you should contact the specific partner or other third party

Refusal of Cookies

If you disagree on instalment of Cookies on your back device, you can refrain from any actions expressing consent, also, you can always refuse all or specific Cookies by following the instructions below.

You can uninstall Cookies in the following ways:

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 internets 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

Strictly necessary cookies (these Cookies are essential for visitor to browse the Website, to identify him/her and for the functioning of the Website and the electronic services. These Cookies are always functional and do not require consent). Analytical (used for monitoring, collecting and analysing statistical (anonymous) data on the number of users visiting the Website, their origin, and their use of electronic services, as well as for improving the functioning of the Website).

List of and types of the cookies:

Name: bSession
Purpose and data used: Used to measure system efficiency.
Name: __cf_bm
Purpose and data used: This Cookie is used to distinguish between humans and robots. It is useful for the Website to produce valid reports on the use of the Website.
Name: _lfa
Purpose and data used: This Cookie is set by the service provider “Leadfeeder“ in order to identify the geographical location and the company of the devices that visit the Website (data is aggregated at company level).
Name: _gid
Purpose and data used: “Google Analytics” Cookie stores information on how visitors use a Website, while also creating an analytics report of the Website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
Name: _ga
Purpose and data used: “Google Analytics” Cookie, calculates visitor, session and campaign data and also keeps track of Website’s usage for the Website's analytics report. The Cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
Name: _gat_gtag_UA_2423660_4
Purpose and data used: This Cookie is part of “Google Analytics“ and is used to limit the number of requests (frequency of requests).

An alternative way to disable Google Analytics is to install a small plugin offered by Google, which can be found here. For more information on Google Analytics, click here.

STORAGE OF THE PERSONAL DATA

Your Personal data will be processed by the Company for the periods established in this Privacy Policy above. Please note that in some cases the longer period for the Personal data storage or our right to store the Personal data for the longer period may be established in applicable legal acts, e. g. in cases where the processing of Personal Data is necessary for compliance with a legal obligation to which the Company is subject and which requires the processing of Personal Data, or when the processing of Personal Data is necessary for the establishment, exercise or defence of legal claims.

In such cases we may process your Personal Data for a longer period, but only to the extent necessary for these purposes of the processing of Personal Data. Such Personal Data will be erased as soon as Personal data are no longer necessary in relation to the purposes for which they are processed.

DISCLOSURE OF THE 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 entities:

Service providers, who act as processors of the Personal Data and provide services to the Company related to IT, Website support and maintenance (e. g. to UAB Interneto vizija, which provide us web-hosting services), maintenance of applications used by the Company, provision of servers and its maintenance, other services (e. g. to group company iToGroup, UAB);
accounting services provider;
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;
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 reorganisation (including spin-off), transfer of business or acquisition, including to subjects carrying out legal due diligence.

TRANSFER OF PERSONAL DATA OUTSIDE THE EEA

Where the Company transfers Personal data outside the European Economic Area (e.g., by using a relevant processor), the Company shall ensure that Personal data is adequately protected and that the transfer complies with the GDPR. In this case, the Company shall transfer Personal data to countries for which the European Commission has issued an adequacy decision, or shall ensure and implement an adequate level of protection of Personal data by means of standard contractual clauses, other documents or measures in accordance with the GDPR.

YOUR (AS THE DATA SUBJECT) RIGHTS AND THEIR 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 (e.g. by informing of your objection the Company's representative with whom you are speaking by the phone or by email from which the offer was sent). 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 the access to your 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 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 the actual registered office, the address of which is set out at the bottom of the Privacy Policy).

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) 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) further months by informing you in advance.

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 given 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 on the Website, we draw your attention that at the time, when you press any mentioned element, you may leave the Website.

AMENDMENTS OF THE PRIVACY POLICY

The Company shall have the right at its own discretion to adjust (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 bottom 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 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 THE 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: dataprotection@itogroup.lt

Address: K. Baršausko str. 47-13, Kaunas, Lithuania

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).