POLICY AND PRINCIPLES OF PERSONAL DATA MANAGEMENT OF GURU Group, UAB

The present Principles of Personal Data Management (hereinafter referred to as the Principles) provide the information on how GURU Group, UAB manages personal data.

The Principles shall be applied to the mutual relationship of GURU Group, UAB and the Clients that use, used, expressed their intention to use the services or are in any manner related with the services provided by GURU Group, UAB, including the relationship with the Clients, arising before the entry into force of the Principles.

1. Notions

The Client: any natural entity that uses, used, expressed their intention to use or is in any way related with the services provided by GURU Group, UAB.

The Personal Data: any information directly or indirectly related with the Client.

The Management: any operation performed with the Peronal Data (including collection, recording, storage, amendment, provision of access, submission of requests, transfer, etc.).

GURU Group, UAB: any other legal entity or a branch of a legal entity operating as the controller of Personal Data.

2. General Provisions

2.1 The Principles provide general provisions on how GURU Group, UAB manages the Personal Data. Additional information on management of the Personal Data may be submitted in service contracts and other documents related with services, order cards or website.

2.2 GURU Group, UAB ensures the confidentiality of the Personal Data in accordance with the requirements of the legislation in force and the implementation of proper technical and organisational measures necessary in order to protect the Personal Data from illegal access, reveal, accidental loss, change or distruction or other illegal management.

2.3 For the management of the Personal Data GURU Group, UAB may use processors. In such cases GURU Group, UAB shall take necessary measures in order to ensure that such processors manage the Personal Data following the indications of GURU Group, UAB and the legislation in force and shall request to implement the proper measures of safety of the Personal Data.

3. Categories of Personal Data

The Personal Data may be received directly from the Client, from the activity of the Client, as the later uses the services, and from external sources, such as registers controlled by the State and private entities, as well as other third parties. All the following data are stored and collected without violating personal privacy and privacy of the Personal Data. These data may not be revealed to unrelated third parties, except for the cases laid down in the legislation, following the laws of the Republic of Lithuania and in cases of non-performance of financial obligations of the Client.

Principle categories of the Personal Data that may be collected or are collected by GURU Group, UAB (but not limited to them) are the following:

Personal identity data, such as the name, surname, personal identification number, date of birth, and data of personal identity document (passport, ID).

Data for contacts, such as the address, telephone number, e-mail address, language of communication.

Personal Data of the Client filled in and indicated in the order card or in the form of website that are used for the provision of services of quality (in coordinating orders, providing services and offers, preparing invoices, etc.).

Data in relation with the profession, such as data on education and professional activity.

Data collected using network and other technical means, such as the data collected after the client has arrived to subdivisions of GURU Group, UAB (data of video surveillance and audio recording) or during the communication with GURU Group, UAB by telephone, video and/or audio recording tools, e-mail, notifications and other network means, such as social networks; data related with the Client‘s visits to websites of GURU Group, UAB or using other communication chanels of GURU Group, UAB.

Data of habits of behaviour, priorities and content of services, such as the data on activity using services, services provided to the Client, the Client‘s review on services, whether the Client is content with the services.

Data on participation in games and promotions organised by GURU Group, UAB, such as data on prizes won during games and promotions, given discounts, etc.

4. Policy and Rules of Use of Cookies

4.1 In order to improve the service of the website and in order to render the use of the website as simple as possible we have to be aware of certain information. It is related with the use of statistical data of website and behaviour of users: geographical indicators, what information is the most interesting to the visitors of our website, how many new visitors does the website receive per day, what is the number of repeated visits, what browsers do visitors use, with the help of what equipment our browser is read, etc. This information is collected using Google tool (Google Analytics). More information on the tool and the information collected by it is provided on the following address: https://support.google.com/analytics/answer/6004245?hl. In order for your browsing information not to be tracked and documented by the aforementioned tool, you have the possibility to use Google Analytics browser refusal add-on.

4.2 Cookies are small text data files; they are automatically created as you browse our website and are saved in your computer, tablet or mobile phone. Anonymous information is normally provided in a cookie. Cookie is sent from the server of the visited website to the Client’s computer, tablet or mobile phone.

4.3 Our website uses obligatory cookies that ensure the operation of the website and makes its use easier; functional cookies and analytical cookies recorded using the service of website analysis provided by Google Analytics (Google) helps analysing the use of this website. Our website also uses third party cookies when you reach us by e-mail, banners or when you visit our website. It allows us to recognise and calculate the number of visitors, to see the behaviour of visitors. Information received by cookies is stored by Google. Google shall have the right to transfer the information collected by Google Analytics to third parties when it is required in the order laid down by the legislation or when those third parties manage the information in the name of Google.

4.4 Our website uses cookies in order to improve the navigation of the Client on our website, to find out about the behaviour of users of our website, to analyse streams, and to improve our website. Cookies are used for no longer than necessary in order to implement the established goals. GURU Group, UAB shall retain the right to alter the rules of use of Cookies and their provisions by notifying it at the client service subdivision, on the website, by informing the Client by mail, e-mail, Internet bank message or in another way (e.g. by informing in the press) no later than 30 (thirty) calendar days before the entry into force of such changes.

4.5 If you require your behaviour not to be supervised, you may change the settings of your browser. In such a case, every time you will be informed on the cookies and every time you will be able to agree with them or to forbid them. For more information, please visit the following website: www.allaboutcookies.org.

5. Aims and Basis of Personal Data Management

5.1 Principle aims set by GURU Group, UAB in managing personal data are the maintenance of relationship with Clients, as well as creation and administration of possibilities to use services of GURU Group, UAB. Personal data of the Client are used only as much as necessary in order to ensure the provision of services of quality or preparation and submission of offers. Personal data are managed carefully, in good faith and only by employees related with the provision of a service of quality or related third parties.

5.2 Protection of interests of the Client and (or) GURU Group, UAB.

In order to protect the interests of the Client and (or) GURU Group, UAB, to implement the inspection of quality of services provided by the translation bureau, to provide the evidence of a commercial offer or other business communication (recording of conversations and video material), when it is obligatory in implementing the contract, and the ensurance of the quality of services.

5.2 GURU Group, UAB may manage Personal Data in order to improve the quality of electronic services provided to the Client, for example by adapting the offered services to a new device, also in trying to prepare personal offers for the Client. If the client has not obliged to the management of Personal Data for the purpose of direct marketing, GURU Group, UAB may manage the Personal Data in order to provide general and personal offers of services provided by GURU Group, UAB. Such marketing activity may be based on the services used by the Client and on the way in which the Client uses them and manages digital channels of GURU Group, UAB.

6. Receivers of personal data. Personal data may be transferred to the following receivers:

6.1 Public establishments and institutions, other entities performing functions assigned to them under the law (e.g. law enforcement institutions, judicial officers, notaries, institutions providing tax administration services).

6.8 Legal and natural entities ensuring proper implementation of client’s obligations to GURU Group, UAB.

6.9 Other entities related with the provision of services of GURU Group, UAB, such as providers of archiving and postal services, providers of services provided to the Client, for the services of which the Client orders electronic invoices and companies administering taxes and fines related with such property.

7. Geographical Territory of Management

7.1 Usually Personal Data are managed in the territory of the European Union/European Economic Area (EU/EEE); however, in certain cases they may be transferred and managed outside the territory of EU/EEE.

7.2 The Client that has submitted the application may receive more information on the transfer of the Personal Data outside the territory of EU/EEE.

8. Storage Period

8.1 The Personal Data shall be managed for no longer than necessary. Period of storage of the Personal Data shall be defined with regard to the kind of contracts concluded with the Client, the legal interest of GURU Group, UAB or the requirements of the legislation (e.g. regulating accounting requirements, etc.).

9. Rights of the Client (Data Subject) Guaranteed by the Legislation and Related with the Management of their Personal Data shall Include the Right:

9.1 To request to fix their Personal Data if they are wrong, undetailed or inaccurate.

9.2 To disagree with the management of their Personal Data, if the grounds for the management of the Personal Data are legal interests, including profiling for the purposes of direct marketing (e.g. reception of marketing proposals and participation in questionnaires).

9.3 To submit a written requirement to delete their Personal Data. This right shall not be applied if the Personal Data asked to be deleted are managed on other legal grounds, such as the management necessary for the implementation of the contract or if it is the implementation of the duty in accordance with the applied legislation.

9.4 To limit the management of their Personal Data in accordance with the applied legislation, e.g. for the period during which GURU Group, UAB shall assess whether the Client has the right to request the deletion of their Personal Data.

9.5 To receive information on whether GURU Group, UAB manages their Personal Data and if so, to be introduced to them.

9.9 To inform on the intention to submit an appeal concerning the management of the Personal Data to the State Data Protection Inspection, the website of which is www.ada.lt, if the Client shall believe that their Personal Data are Managed by violating their rights and legal interests in accordance with the applied legislation.

10. Validity and Changes of Principles

10.1 Clients may be introduced to the Principles at the client service subdivision of GURU Group, UAB.

10.2 GURU Group, UAB shall have the right to unilaterally amend these Principles at any time by informing the Client on changes by publishing the changes at GURU Group, UAB client service subdivision, on the website, by informing the Client by mail, e-mail, Internet bank message or in another way (e.g. publishing in press) no later than 30 (thirty) calendar days before the entry into force of such changes.