1. GENERAL INFORMATION
- how Companial collects, retains, processes, shares and transfers your personal data when you visit our website or use our services; and
- the legal rights that you have in connection with our collection and processing of your personal data.
When we refer to “Companial”, “we” or “us” in this policy, we mean UAB Companial, Companial B.V. and any other entity of the global group of Companial companies acting as Data Controllers. When we refer to “website” we mean our website at www.companial.com and our Business Portal.
Please contact us at ITsupport@companial.com if you have any questions about our privacy practices.
2. WHAT INFORMATION WE COLLECT ABOUT YOU
- Information about business contacts: your name, title, company details, postal address, e-mail address, other contact information, your business bank account and other information that enables us to maintain our business relationship with you and the company you represent. We also keep a record of the correspondence with our business contacts.
- Credit card information: if you choose to make a purchase or sign up for a paid subscription service on our websites, Companial will ask for credit card information in order to process your order.
- Automatically collected information: information about your browser, type of device, operating system, movements and behavior on our website, IP address, and other information that may be necessary for your use or improvement of our services, tools or websites.
- Images and recordings: images/footage captures on our video or CCTV systems when you visit our offices and business locations; image or voice recordings when you attend our webinar, online conference or training and choose “Camera On” and\or “Microphone On” settings. We may also use your photo or image for reference purposes or webinar recordings in our marketing communication and social media but only where and after you have provided us with a consent to do so.
We do not intentionally or knowingly collect any information of individuals younger than 16 years old. In addition, we do not seek to collect sensitive or special categories of personal data through this website, we may do so in certain cases where we have the legal right to do so, or where you have expressly consented to this.
3. HOW WE COLLECT AND PROCESS YOUR PERSONAL DATA
We collect and process your personal data in 3 ways: directly, indirectly or automatically.
- Directly: You will be requested to provide us with your personal data when you order or use our services, or tools, download marketing materials, register for a webinar, conference or event, become a registered user of our website or when you send any other query to Companial. Information is collected through an online form on our website or when you contact Companial by other means (e.g., you engage with us on social media, you contact our Support Services team online, over the phone or via web chat).
- Automatically. Certain information may be collected automatically when you interact with our websites. The webpage may also use certain analytics software that enables us to better understand the functionality used on the website so that we can continue to improve our website. You can find out more in section 9 (Additional Information We Collect)”.
4. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We may collect and process your personal data for the following purposes:
- To address your requests and inquiries for services or other information. For example, we may disclose the identity of Partner’s Admin User to the representatives of the same partner if access rights to the subsequent user accounts on the Partner Portal are requested.
- For providing our services, tools and materials as per your or your company’s request and in accordance with the agreement between you (or company you represent) and Companial.
- To process and execute online orders and downloads.
- For facilitating our communication with you in order to ensure business continuity; we may send certain communications, including, but not limited to, response to your requests, welcome letters, billing reminders, security announcements, requested password reset information, notifications of technical information, etc.
- To invite you to participate in surveys and ask for your feedback about our services;
- For marketing our services or tools and provide you with relevant sales information (unless you objected against such processing), so that we can ensure that we can conduct and increase our business.
- For providing you with tailored newsletters, relevant notifications and press releases to help you stay up to date with our services.
- To plan and host online forums or webinars.
- To apply analytics and monitor your use of our website for statistical analysis or to enable us to personalize or improve user experience.
- To improve business or service performance and otherwise to better meet the needs and preferences of our partners and their customers.
- For operating and managing our business operations and ensuring the proper functioning of our business.
- For access management purposes, to ensure that both us and you are protected when accessing our locations and offices.
- For keeping and maintaining internal business records.
- For improving the security and functioning of our websites, webpages, networks and information, to ensure that our networks and information are secure.
- For detecting, preventing and/or investigating security breaches or fraud.
- To assess and address risk management to avoid non-compliance and protecting of our reputation.
- To comply with applicable legislation or a court order.
5. LEGAL BASIS TO PROCESS YOUR PERSONAL DATA
- Because such personal data is necessary to enter into and perform a contract to which you and/or the company you represent are a party to.
- Because the processing is necessary for the purposes of the legitimate interests pursued by us, by yourself or by a third party, or.
- Where necessary in order to protect the vital interests of any person.
- Because we are required to do so for compliance with a legal or regulatory obligation to which we are subject to.
- Based on your prior consent, to the extent such consent is mandatory under applicable laws.
6. LOCATIONS OF WHERE WE COLLECT AND PROCESS INFORMATION
Except as may be required or permitted by laws, we do not disclose, sell, trade, or otherwise share your personal data with the third parties. This does not include our trusted third parties, with which we may share your personal data with, such as:
- service providers, such as Microsoft (see separate section beneath) and other service providers or subcontractors, who assist us in operating our website, conducting business, providing services to you or for storing, service or recruitment purposes;
- professional advisors, such as our lawyer offices, tax consultants, or auditors, and
- public authorities.
Any trusted party to whom your personal data are disclosed, are expected and required to protect the confidentiality and security of your personal data and may only use your personal data in compliance with applicable data privacy laws and applicable contractual obligations.
Your credit card information will not be sold, exchanged or otherwise transferred to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased service requested.
7. INFORMATION SHARED WITH MICROSOFT AND MICROSOFT PARTNERS
Partners and end-customers: We work exclusively through Microsoft partners and, in order to ensure clear ownership, communication lines and accountability, we may inform your Microsoft partner (if you have one and you are an end-user of Microsoft software) about your request for services, and such services will be provided through your Microsoft partner.
If you request Companial services and you are an end-user of Microsoft software, but you do not have a Microsoft partner, we are willing to help you find one and provide services through your Microsoft partner. However, we will contact you to get your prior consent to provide your information and request to potential Microsoft partner.
Microsoft initiated activities: Companial is a Microsoft partner (among other, an authorized ISV and CSP indirect provider), therefore, we may share with or receive from Microsoft information, for business and administration purposes only, such as name, contact details of partners and their respective end-customers, and feedback provided by partners or end-customers about certain Microsoft-initiated activities, programs, webinars, trainings, workshops or events.
8. HOW LONG WE KEEP YOUR PERSONAL DATA
We retain your personal data only for as long as is necessary. We delete personal data after a reasonable time according to the following retention criteria:
- We retain your personal data for as long as we have an ongoing relationship with you (in particular, if you have an account with us or use our services).
- We retain your personal data for as long as needed in order to comply with a legal requirements or contractual obligations to which Companial is subject to.
- We retain your personal data where this is advisable to safeguard or improve Companial’s legal position (for instance, in relation to statutes of limitations, litigation, or legal investigations).
This means that we may retain your personal data for a reasonable period after your last interaction with us. When the personal data that we collect is no longer required in this way, we will destroy, delete or anonymize it in a secure manner. Please note that some data may be required in order to comply with law.
9. ADDITIONAL INFORMATION WE COLLECT
Non-personally identifiable information
We use analytics tools to collect and use information in aggregate form to track the total number of visitors to our site, the number of visitors to each page of our site, time spent on each page, technologies used, and keywords to find our sites, traffic sources and other such technical information. This is technical information that does not by itself identify a specific individual. No personally identifiable information is available in this process. We use this data to better target our marketing efforts and improve our services.
On our sites we use a technology called “cookies”. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. The cookie may transmit information via your browser with a purpose of authenticating or identifying the computer (via e.g. the IP address) or the user. It enables our websites recognize your computer at recurring visits and contains information such as registration data and user preferences. Cookies can store many types of data and they help us in providing additional functionality to the site or help us analyze site usage more accurately.
10. MARKETING COMMUNICATION
The personal data that we collect and may use for marketing purposes relates to individuals representing our partners, customers, suppliers, and other companies with which we have a business relationship with. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant representative of a partner, supplier or other company.
We send e-mails to representatives of partners, customers, suppliers, or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages sometimes include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Companial we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from Companial include additional data privacy information if required by applicable laws.
You can exercise your right to prevent marketing communications by utilizing opt-out mechanisms on our website or in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you by contacting us at ITsupport@companial.com.
We are committed to ensuring that your personal data is secure. We protect your personal data in accordance with applicable data privacy laws. We have implemented appropriate organizational, physical and technical security measures to protect personal data against unauthorized or unlawful processing and/or against accidental or unlawful destruction, loss, alteration, or unauthorized disclosure.
We have controls and internal policies and procedures to ensure continuous protection of personal data considering the risks associated with the categories of personal data and the processing we undertake.
We store personal data on servers with limited access located in secured facilities, and our security measures are evaluated on an ongoing basis.
12. DATA SUBJECT RIGHTS
Please contact our Data Privacy team if you (i) have any questions or concerns about how Companial processes your personal data or (ii) want to exercise any of your rights in relation to your personal data.
You are entitled, in the circumstances and in accordance with the conditions and exceptions set out in applicable law to:
- Request access to the personal data we process about you: this right entitles you to know whether we hold personal data of you and, if so, obtain information on and a copy of such personal data.
- Request rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
- Object to the processing of your personal data: this right entitles you to request that we no longer process your personal data.
- Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
- Request the restriction of the processing of your personal data: this right entitles you to request that we only process your personal data in limited circumstances, including with your consent.
- Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to us, or request us to transmit such personal data to another data controller.
Please note that most of the personal data that we hold about you comes from information you completed, therefore, please ensure that you keep your information correct and up to date by updating your profile/information on the website or inform Companial of any material changes.
If you wish to exercise any of your rights in relation to your personal information please send your request to us at: ITsupport@companial.com. Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting us at ITsupport@companial.com. Please note that this will not affect our right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
13. HOW TO CONTACT US AND APPROPRIATE AUTHORITIES
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to reach out to us, Companial, to first to seek resolution of any complaint. Please contact ITsupport@companial.com or send a letter to Companial, Data Privacy Team, Sporto 7A, LT-03233 Vilnius, Lithuania.
Where you deem that data privacy law have been infringed, you have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Companial with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).
The contact details for State Data Protection Inspectorate, the supervisory data protection authority in Lithuania, are below:
Post: State Data Protection Inspectorate,
Sapiegos g. 17,
Phone: +370 5 271 28 04, +370 5 279 1445
You can find contact details of other competent authorities within EU, here:
14. OTHER IMPORTANT PRIVACY INFORMATION
Our services are intended for the use by companies and\or their representatives only, therefore your use of our websites or services might be subject to that company’s policies. We are not responsible for the privacy or security practices of your companies.
15. CONTACT DETAILS
You can exercise your rights and/or manage your information by contacting us using the details below:
Post: UAB “Companial”,
Sporto st. 7A, Vilnius, Lithuania.