Privacy Policy

This Privacy Notice (the “Notice”) provides information on how (Naglio Ausmano IV, the “Company”) handles personal data.

The provisions of the Notification apply to natural persons whose data are processed by the Company:

i) customers who use, have used, have expressed an intention to use or are in any other way related to the services provided by the Company (hereinafter – the Customers);

ii) to persons who address requests to the Company directly or by distance communication, including telephone, e-mail. by post, etc .;

iii) persons who visit the Company’s Internet and self-service websites, etc.

This Notice sets out the basic provisions for the processing of personal data. Additional information on how the Company handles personal data may be provided in the Company’s agreements, other documents, on the website, on the self-service website or through remote Customer service channels (telephone, e-mail, etc.).

The Company will announce changes to this Notice by posting on the Company’s website. In certain cases, the Company may also notify individuals of changes by mail, e-mail. by post or other means (eg publication in the press).


Terms and abbreviations used in this Privacy Notice have the following meanings:

  • Personal data – any information relating to an identified or unidentified natural person (eg name, contact details, etc.).
  • Person – a natural person (data subject) whose data is processed (eg the Company’s Customers, persons who apply to the Company by submitting requests, requirements, users of the Company’s website or self-service website, etc.).
  • Data processing – any activity performed with Personal Data (eg collection, recording, storage, granting of access, transmission, etc.).
  • Services – any goods and services provided by the Company.

Other terms used in the Notice shall be understood as defined in the legal acts regulating the protection of personal data (General Data Protection Regulation (EU) 2016/679, Law on the Legal Protection of Personal Data of the Republic of Lithuania and others).

Purpose and legal basis of the processing of personal data

The Company processes Personal Data only for specific purposes in accordance with the legal bases established by legal acts – when the processing is necessary for concluding and/or performing a contract with a person, the person has consented to the processing of personal data for one or more specific purposes, the Company must process Personal Data in compliance with the requirements of legal acts or Personal Data must be processed in the legitimate interest of the Company.

The main objectives pursued by the Company in processing Personal Data are:

  • Provision of services, conclusion, and performance of contracts. The Company processes Personal Data to ensure proper conclusion and performance of contracts with Clients, provision of contracted services or goods to Clients, including proper informing of the Client about issues related to goods, services and contract in accordance with the contract or legal requirements.
  • Settlement administration. The Company processes Personal Data related to the payment for the provided Services on the basis of the requirements of the agreement and legal acts.
  • Debt management. In the case of debt, the Company processes Personal Data related to indebtedness and performs recovery actions in accordance with the agreement, legal requirements, and legitimate interest.
  • Addressing the issues raised. The company processes personal data in the course of examining and resolving questions, complaints in accordance with the requirements of the contract, consent, or legal requirements.
  • Quality control of service provision and clarification of opinion. In order to ensure the quality of the provided Services, the Company may send inquiries asking for an opinion on the provided Services and record telephone conversations when the Clients contact the Customer service channels or the Company’s employees call the Clients on the basis of contract, consent or legitimate interest.
  • Direct marketing. The Company may process Personal Data by submitting offers, news about the provided Services, information about ongoing events with the consent of the person.
  • Credit and risk assessment. Before concluding a transaction, the Company may process Personal Data in order to determine which Services and under what conditions may be offered to the Customer on the basis of a contract, consent, or legitimate interest.
  • Other purposes. The Company may process Personal Data for other purposes as well, if it has obtained the consent of the individual, must process the Personal Data in compliance with the requirements of legal acts or has the right to process the data due to a legitimate interest.

In all of the above cases, the Company will process Personal Data only to the extent necessary to achieve the relevant clearly defined and legitimate purposes, taking into account the requirements of personal data protection.

Volume of Personal Data processed (categories)

The main categories of Personal Data and data processed by the Company for the above purposes and legal bases:

  • Identity data – name, surname, personal identification code, date of birth, etc.
  • Contact details – address, telephone number, e-mail address, etc.
  • Data related to the provision of Services, conclusion and performance of concluded agreements – information about the provided Services, contract data, ordering and consumption data, data received by the Company in communication with persons directly or by remote means (telephone, e-mail), etc.
  • Payment details – amounts due, outstanding debts, payment history, etc.
  • Audio data – audio data recorded during communication with persons, etc.
  • Cookie data – information about a person’s location in the accuracy of the city, a person’s hobbies, his behavior on the Company’s website or self-service, interests, etc. (More information in the “Cookies and their use” section).
  • Other data processed by the Company in accordance with the legal bases established by legal acts.

Receipt of personal data

The Company processes Personal Data provided by individuals or obtained by the Company from other sources, such as registers maintained by the state or private individuals, to the extent necessary in accordance with the agreement, consent, legal acts or the Company’s legitimate interest.

Provision of personal data

The Company may, in accordance with the requirements of legal acts, transfer the processed Personal Data to the following categories of data recipients:

  • For service providers. The Company may transfer the processed Personal Data to third parties providing Company customer service, software maintenance, accounting and other services to third parties acting on behalf and / or on its behalf in order to ensure the proper provision, management and development of the Company Services. In such cases, the Company shall take the necessary measures to ensure that the used service providers (data processors) process the provided Personal Data only for the purposes for which they were provided with appropriate technical and organizational security measures in accordance with the Company’s instructions and applicable legislation.
  • Institutions and supervisors. The Company may provide the processed Personal Data to government or law enforcement agencies, the police or supervisory authorities when required by applicable law or to ensure the Company’s rights or the security of the Company’s Customers, employees and property.
  • Debt management companies. If the Customer fails to make proper payments for more than 30 days, the Company, having informed the Customer in writing or electronically, has the right to provide the Customer’s personal data to joint debtors’ file managers, financial services companies and institutions, debt management and collection companies. for recovery purposes from credit history systems or other databases.
  • Other third parties. The Company may provide Personal Data to other data recipients on the legal basis defined by law.

Data storage

The Company processes Personal Data for no longer than required by the stated purposes of data processing or provided by the applicable legal acts, if they provide for a longer data retention period.

To determine the data retention period, the Company applies criteria that comply with the obligations specified in legal acts, as well as taking into account the rights provided by the person, e.g. provides for a data retention period during which claims related to the performance of the contract may be submitted, should such arise, etc.

Security measures in place

The Company ensures the confidentiality of Personal Data in accordance with the requirements of applicable legislation and the implementation of appropriate technical and organizational measures to protect Personal Data from unauthorized access, disclosure, accidental loss, alteration or destruction or other unlawful processing.

Rights of individuals

A person who has contacted the Company in writing and has established the identity of the Company has the right to:

a) to get acquainted with the Personal Data processed by the Company;

b) correct incorrect, incomplete, inaccurate personal data;

c) request the destruction of Personal Data or the suspension, except for storage, of the processing of Personal Data, if this is done in violation of the requirements of the applicable legislation;

(d) to receive personal data relating to him or her which he or she has provided in a structured, commonly used and computer-readable format;

e) request the deletion of Personal Data processed by the Company when the Personal Data is processed in violation of the requirements of applicable legislation or when the Personal Data is no longer necessary to achieve the purposes for which it was collected or otherwise processed;

f) restrict the processing of your Personal Data in accordance with applicable law, e.g. the period during which the Company will assess whether the person has the right to request that his / her Personal Data be deleted;

g) to object to the processing of your Personal Data and / or, in the case of processing of Personal Data on the basis of consent, to withdraw the consent given to the processing of your Personal Data, without prejudice to the lawfulness of consent-based processing prior to withdrawal.

Individuals may apply for this Notice or the Company’s processing of personal data by email.

If the issues related to the Company’s processing of personal data and (or) personal rights cannot be resolved, the person also has the right to apply and submit a complaint to the State Data Protection Inspectorate.

Duties of individuals

By submitting their personal data to the Company, the persons confirm that they are properly acquainted with the conditions of personal data processing provided in this Notice, do not object to the processing of personal data provided by persons, the data and information provided by persons are accurate and correct and the Company is not responsible for and processing if such data is provided to the Company by a person through negligence.

The Person undertakes to inform the Company about changes in the submitted data or other related information.

Cookies and their use

The company uses cookies to make the use of this and the self-service website faster and more convenient. Cookies are a small file that is sent and installed on a visitor’s computer. The Company uses the installed information to identify the person and monitor the website traffic statistics.

There are three types of cookies used on a company’s website:

  • Required: These cookies are necessary for a person to browse the website and use its features, such as access to secure areas of the website.
  • Performance: These cookies collect information about how visitors use a particular website, such as which pages they visit most often and whether visitors receive error messages from the website. These cookies do not collect information that allows the website visitor to be identified. All information collected by these cookies is of a general nature and therefore anonymous. It is only used to improve the performance of the site.
  • Functional: These cookies allow the website to remember the things you choose (such as your name, language or region) and to offer enhanced features that are personalized to you. These cookies cannot track your browsing activity on other websites.

Cookies on websites are used when a person agrees to the use of cookies while browsing the website. A person may revoke their consent at any time by changing their web browser settings, in which case certain features of the website may not work.