PRIVACY POLICY

If you have sent your CV, cover letter and/or other documents or data in order to participate in a published selection process, the personal data you voluntarily provided and the other personal data listed below will be processed for the purpose of employee selection.

For the purpose of conducting the selection, we will process your personal data until we decide to hire a specific candidate and his or her probationary period ends or we decide to terminate the selection process without selecting a candidate, but for no longer than six months of receiving the data. 

If you give your consent, after the end of the selection process, we will store your CV and other data submitted for one year for the purpose of administration of the candidate database, so that if we need a new employee, we can contact you with a job offer or invite you to participate in a new selection process. If you have expressed a preference that our company does not offer you job opportunities in the future, we will keep your name, surname, and information about the preference not to receive job offers for 3 years.

We will process your personal data on the basis of your consent to participate in the selection process or your consent to store your data in the candidate database. Providing your personal data in order to participate in the selection process is voluntary, but if you do not provide the data requested, we will not be able to assess the suitability of your candidacy.

Please be informed that by exercising the right granted by personal data protection legislation, your previous employers may be contacted to ask for their opinion on your qualifications and professional abilities and qualities. However, your current employer will not be contacted without your consent.

We may transfer your data for processing to third parties who help us carry out the selection of candidates or who provide us with services related to the selection process, candidate assessment and internal administration. In each case, we only provide the data processor with as much data as is necessary to fulfil the specific assignment or provide the specific service. The data processors we use can only process your personal data according to our instructions and cannot use them for any other purposes. In addition, they are required to ensure the security of your data in accordance with applicable legislation and the data processing agreements concluded with us.

For the purpose of ensuring the safety of property and persons, the company uses video surveillance. Video surveillance is carried out on the basis of a legitimate interest. Videos are stored for a period of 15 days. Access to the videos is given to the security company.

If you are a customer of the Company or have expressed your consent to receive direct marketing materials, your contact details will be used so that we can provide you with information about our goods and services, news or other direct marketing information.

If you are a customer of the Company, direct marketing may be sent to you on the basis of the right granted by the legislation. You can object to such marketing by noting it in the agreement you sign with our company or by using the contact details specified in this Privacy Policy.

Your personal data will be processed for the purpose of direct marketing for five years from the date of consent or the end of the Company’s relationship with you.

Each e-mail sent to you will include a link to opt out of direct marketing communications. You can also opt out or withdraw your consent by contacting the Company using the contact details provided.

If you have submitted a complaint, enquiry or feedback to our Company, the personal data you voluntarily provided will be processed for the purpose of their administration.

If your complaint is related to a potential dispute, possible damage, or the discharge of other legal obligations, your personal data may be stored for a maximum period of 10 years, until the general statute of limitations expires. If the personal data are not related to a possible dispute or the discharge of a legal obligation, they will be deleted after responding to your letter.

The processing of your personal data will be based on the expression of your free will (i.e. consent), but in certain cases, a legal act may become the basis for further storage of the complaint.

The basis for the processing of your personal data provided in the course of electronic communication is the expression of your free will to communicate by e-mail and to provide certain data thereby, i.e. consent. If you communicate with the Companies as employees of companies with which we have or may have contractual relations, the basis for the processing of the data you provide during electronic communication may be a legitimate interest. In addition, the basis for individual data processing actions, such as tax returns, may also be the discharge of obligations provided for in legislation.

In addition to the purpose of concluding and performing the agreement, your data are also processed for the purpose of internal administration.

Your e-mail address, the content of your correspondence and related data are processed in accordance with the principle of proportionality. These data will first and foremost be visible to the person with whom you communicate directly by e-mail. However, in certain cases, your correspondence may be read and processed by other employees, for example, for electronic monitoring of the workplace, investigation of possible violations of legislation or internal rules, implementation of internal rules, replacement of an employee and related purposes, and other similar situations.

We will store personal data processed for the purpose of concluding and performing agreements with natural persons for 10 years from the end of the contractual relationship. We will process your personal data on the basis of the performance of an agreement to which you are a party, as well as in order to take action at your request before concluding the agreement. We may ask for your consent to perform certain individual actions, and we may also be required to comply with legal obligations, for example, provided for in legislation regulating the payment of taxes. For the stated purpose, we will process the personal data that you provide directly before concluding the agreement and during performance of the agreement. If you do not provide this data, we will not be able to conclude and execute the agreement.

For the purpose of concluding and performing agreements with legal entities, we will store the personal data of employees and representatives of the other party for 10 years from the end of the contractual relationship. The basis for processing is a legitimate interest. Without processing the personal data of the party’s representatives, we would not be able to conclude and perform an agreement with the legal entity they represent.

Your personal data processed for the purposes of processing specified in this Privacy Policy may be provided to:

• IT, server, mail, archiving, reporting, accounting and other service providers and subcontractors;
• notaries, judicial officers, attorneys, lawyers, consultants, auditors, debt collection companies and debt buyers and assignees;
• law enforcement and supervisory authorities, courts, other institutions handling disputes and other persons performing the functions assigned to them by law;
• potential or existing successors of our business or part thereof or their authorised consultants or persons, and other reorganisation participants.

The Company belongs to the TMV Capital group, so we may transfer your data to other group companies for the purpose of internal administration on the basis of a legitimate interest.

We would like to inform you that personal data is entered into a project management system owned and licensed by a company based in the United States. Consequently, the data entered into the system is transferred to the mentioned country. Standard contractual clauses and certification under the EU-US Privacy Shield framework are used to ensure the security and compliance of data transfers with the Regulation.

When collecting and using the personal data of yours that you provide or that are obtained from other sources, we adhere to the following principles:

• your personal data are processed lawfully, fairly and in a transparent manner (‘lawfulness, fairness and transparency’);
• your personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
• your personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
• the personal data processed are accurate and, where necessary, kept up to date (‘accuracy’);
• your personal data are kept in a form which permits identification for no longer than is necessary for the purposes for which your personal data are processed (‘storage limitation’);
• your personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

Please be informed that you have the following data subject rights: 

• the right of access to your personal data and how they are being processed; 
• the right to rectify inaccuracies in the data we hold; 
• the right to ask that your personal data be deleted. This right shall be exercised in the cases provided for in Article 17 of the Regulation;
• the right to ask that the processing of personal data be restricted or that the data not be processed; 
• the right to portability of the data that are being processed by automated means and which we received from you with your consent or for the purpose of concluding an agreement;
• the right to object to your personal data being processed, as provided for in Article 21 of the Regulation, especially in the case when the data are being processed on the basis of a legitimate interest;
• the right to withdraw consent to the processing of personal data if you have given such consent;
• the right to lodge a complaint with the State Data Protection Inspectorate (L. Sapiegos g. 17, 10312 Vilnius).

In order to be able to implement your rights as the data subject, your identity must be established. If your identity is not established, it will not be possible to make sure that the person who is applying is really the person whose personal data are being processed, so it will not be possible to exercise your rights.

A request received from you regarding the exercise of rights may be refused to be examined or an appropriate fee may be asked for this if the request is clearly unfounded or excessive, as well as in other cases established by legislation.

If you would like to exercise your rights as a data subject or have other questions regarding the processing of your personal data, you can contact the Company using the contact details given at the beginning of this Privacy Policy.

Taking into account changes in legislation, as well as changes in the activities of the Companies, we have the right to update this Privacy Policy. We recommend that data subjects visit the www.tmvcapital.com website regularly and get acquainted with the latest version of the Privacy Policy. 

Updated: 15 December 2023