Privacy Policy

1. WHAT IS THIS DOCUMENT?

1.1. This Privacy Policy (hereinafter - Privacy Policy) shall determine the privacy conditions when using our Respo application (hereinafter – Respo app), contacting us by e-mail, telephone or other means of communication, as far as it concerns the processing of personal data by us and our Personal data processing rules (hereinafter referred to as the Rules).
1.2. Carefully read this Privacy Policy to understand what kind of practices we use to process your personal data. After reading this document, you will find out how we process your personal data, where we receive it and what rights you have as the personal data subject.
1.3. If you use Respo app, purchase our goods and services or are otherwise related to us UAB "BURBULIUKAS IR CO", legal entity code: 147952214, registered office address: 7, Pušaloto str., Panevėžys, contact details: info@respowater.com; tel. +370 45 448329, which means that you have read and agreed to this Privacy Policy and the purposes, methods and procedures for processing your personal data specified in it. If you do not agree with the Privacy Policy or its individual terms, we will unfortunately not be able to sell you all or any of the Company's goods or services, or to cooperate with you on business or other matters, and you will not be entitled to use the Respo app.
1.4. The term "personal data" used in this Privacy Policy shall mean any information that may help identify your identity, both directly and indirectly. Personal data shall consists of a surname, name, date of birth, postal or e-mail address, location data and Internet identifier, characteristics specific to you, etc.
1.5. The provisions of this Privacy Policy apply to our customers who have purchased, are purchasing or intend to purchase goods or services sold by us, our business partners (including their employees), and persons who contact us by making requests or claims directly or by means of remote communication (by telephone, email, social networking accounts, etc.). This Privacy Policy applies to all persons who visit the Respo app, regardless of whether you are our customer, and to actions you may take on the Site. The Privacy Policy also contains information about the processing of personal data of all other persons by us in the course of our business and the conclusion and performance of contracts.

2. WHO ARE WE?
2.1. This Respo app is managed and administered by UAB "BURBULIUKAS IR CO", legal entity code: 147952214, registered office address: registered office address: Pušaloto str. 7, Panevėžys, contact details: info@respowater.com; tel. +370 45 448329, the website: www.respowater.com (hereinafter – Company and/or Data Controller).

3. WHAT PRINCIPLES DO WE FOLLOW?
3.1. By processing your personal data we:
3.1.1. shall comply with the requirements of valid and applicable legal acts, including the GDPR;
3.1.2. shall process your personal data in a lawful, fair and transparent manner;
3.1.3. shall collect your personal data for specified, clearly defined and legitimate purposes and will not continue to process it in a way incompatible with those purposes, except to the extent permitted by law;
3.1.4. shall take all reasonable steps to ensure that personal data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, suspended or destroyed without delay;
3.1.5. shall keep them in such a form that your identity may be established for no longer than is necessary for the purposes for which the personal data are processed;
3.1.6. we shall not provide personal data to third parties and we shall not disclose it, except for the cases specified in the Privacy Policy, the Rules or in the cases established by legal acts;
3.1.7. shall ensure that your personal data is processed in such a way as to ensure the proper security of personal data, including protection against unauthorised processing or unlawful processing of data, and accidental loss, destruction or damage, by applying appropriate technical or organisational measures.

4. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
4.1. We shall process your personal data for the following purposes:
4.1.1. For the purpose of drawing up, executing (dispatching products) and accounting for contracts for the purchase and sale of goods (water ionizer devices). For this purpose, we shall process the following personal data: Customer's name, surname, phone number, email address, delivery address.
The Company may additionally process the following data of employees of legal entities (business partners of the Company): work telephone number, work e-mail address, workplace address, position held, authorisation (representation) data, name of workplace, correspondence with the Company on behalf of or in the interests of the business partner, or other data provided during the conclusion of a contract with the Company, during the performance of the contract (signing of documents, confirmation of orders, etc.), or on any other basis related to business relations.
Personal data shall be stored for the entire period of validity of the contract and/or cooperation and for 10 (ten) years from the end of the contract and/or cooperation, unless another period of storage of Personal data is provided for by the legislation of the Republic of Lithuania.
4.1.2. For the purpose of submitting and responding to an enquiry/question and for the purpose of resolving potential or arising disputes with data subjects. When you contact us (or we contact you following your enquiry), we process information from telephone, email, Respo app or other communications.
For this purpose, we process the following personal data about you: name, surname, email address, telephone number, the content of the complaint and/or enquiry, telephone number, date and time of contact with us, and the details of the communication.
For this purpose, we obtain your personal data: from you yourself, we may create personal data ourselves in the course of fulfilling a query or analysing a complaint (e.g., after receiving your complaint, we contact third parties about the facts and record them, etc.).
For this purpose, we keep your data for 3 years from the date of recording, unless there are grounds to believe that a crime or other illegal act has been recorded or an internal investigation has been launched, until the end of the relevant investigation and/or proceedings.
4.1.3. For the purpose of creating a Customer’s account and using the Respo app. For this purpose, we process your username, password, email address, date of birth, country of use.
For this purpose, we obtain your personal data from you.
We point out that when you log in to your account, cookies are stored on your device to save your login information and your screen settings. Login cookies are stored for 1 (one) year and display settings for 1 (one) year. However, if you tick the "Remember me" option, then your login information will be stored for 1 (one) year. When you log out of your account, the login cookies will be deleted immediately.
The Respo app remembers your passwords by default.
4.1.4. For direct marketing purposes. For this purpose we may process your name, surname, email address, data of customers (legal entities), representatives (employees) of business partners or other contact persons: work telephone number, work email address, workplace address, position held.
For this purpose, we obtain your personal data from you.
For this purpose, we keep your data for the duration of the consent and for 5 (five) years from the date of withdrawal of consent.
Consent may be withdrawn at any time.

5. HOW DO WE COLLECT AND PROCESS YOUR PERSONAL DATA?
5.1. We process your personal data obtained in the following ways:
5.1.1. When you submit it to us.
5.1.2. When you use the Respo app operated by us, certain information (such as Internet address (IP) or others) shall be collected automatically.
5.1.3. When we receive your personal data from other persons in accordance with the legal acts and/or this Privacy Policy.
5.2. You provide us with your personal data and other information by using the Respo app, actively participating in them, i.e. by writing to us or communicating with our team, making inquiries and/or submitting your complaints, orders, comments or otherwise when you subscribe to our newsletter. If you contact us in writing or by e-mail, we shall save the correspondence data.
5.3. The information you provide may include your or the person’s you represent name and surname, e-mail address and telephone number, the text of the message and other data.
5.4. When you use the Respo app, certain non-personal information (e.g. Internet address (IP), type of Internet browser used, number of visits, viewed website pages, time spent on the website, the Internet source from which you came, information about the device used, language, country, etc.) shall be collected automatically.
5.5. You shall always be able to request the correction of incorrect personal data and to exercise your other rights as a personal data subject as set out in this Privacy Policy and applicable law.

6. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING?
6.1. Yes, we may use your personal data for direct marketing purposes in order to provide you with offers and information about our services that we believe may be of interest to you. However, we shall only use your personal data for this purpose with your additional consent.
6.2. For this purpose, we shall process your personal data specified in Clause 4.1.4. of the Policy.
6.3. You may choose whether you allow us to use your personal data for direct marketing purposes. You may do this by giving your consent, which you may revoke at any time.
6.4. By granting the right to process data for the purpose of direct marketing, you also give permission for us to contact you for this purpose by means of communication (e.g. e-mail, telephone, text message (SMS)) or other means of communication (e.g. Facebook, LinkedIn, Skype, Viber etc.).
6.5. We may combine available information about you with the information available to third parties in order to provide you with offers.
6.6. If you give consent to use your personal data for direct marketing purposes, we may use your personal data to analyse and improve the effectiveness of our webpages, advertising and market research, and for other marketing and sales goals. In such case, we will use your depersonalised data.
6.7. Even if you have given consent to the processing of your personal data for direct marketing purposes, you may easily withdraw this consent at any time for all or part of the personal data processing activities. You may do this in the following ways:
6.7.1. notify of refusal by e-mail in the manner specified in the communications and/or offers received (e.g., by clicking on the unsubscribe link in the newsletter), or
6.7.2. Send us a request by e-mail – info@respowater.com Your name and surname and other registration data (if any) must be clearly indicated in the application. If you make a request to withdraw your consent in this way, we may ask for proof of identity.
6.8. The processing of your personal data for the purpose of direct marketing shall be terminated no later than within 3 days from the date of receipt of the request.
6.9. Withdrawal of consent shall not automatically oblige us to destroy your personal data or to provide you with information about the personal data we process, therefore, we require you to specify such a request separately for the performance of these actions.

7. HOW DO WE STORE YOUR PERSONAL DATA?
7.1. We warrant that your personal data will not be sold, provided or otherwise transferred to third parties without lawful basis, or used for purposes other than those for which the relevant personal data was collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy and the law. However, we reserve the right to disclose information about you if we are required to do so by law or if we are requested to do so by lawful authorities or prosecuting authorities
7.2.We may disclose the data we collect about you to the following third parties:
7.2.1. third party service providers (e.g. technical service providers in the performance of our contracts with these service providers, including the performance of services for sending newsletters or other marketing activities).
7.2.2. to third party service providers whose services we generally use for data storage, telecommunications and the Respo app hosting purposes.
7.3 The above service providers are limited in their ability to use your data and may not use it for purposes other than to provide services to us.

8. HOW DO WE PROTECT YOUR PERSONAL DATA?
8.1 The data we collect from you will be located within the EU, but may be transferred or stored outside the EU. It may also be processed by our or our suppliers' staff working outside the EU. When we transfer your data outside the EU, we will take all reasonable steps to ensure that your data is processed securely and in accordance with this Privacy Policy.
8.2 The OWASP Top 10 is a standard awareness document for developers and web application security.
8.3 Each password is encrypted, i.e. encoded.
8.4 In the unlikely event that we become aware of a breach of security of your personal data which may pose a significant threat to your rights or freedoms, we will inform you immediately upon becoming aware of it and identifying the information accessed.

9. WHAT RIGHTS DO YOU HAVE?
9.1. In processing personal data, we shall guarantee your rights under the GDPR and the Republic of Lithuania Law on Legal Protection of Personal Data. As a personal data subject, you shall have the following rights:
9.1.1. to know (to be informed) about the processing of your personal data;
9.1.2. to access your personal data that we process;
9.1.3. to demand the correction or supplementation, revision of incorrect, inaccurate, incomplete personal data;
9.1.4. to require the destruction of personal data where they are no longer needed for the purposes for which they were collected;
9.1.5. to demand the destruction of personal data if they are processed unlawfully or if you withdraw your consent to the processing of personal data or do not give such consent, which is necessary;
9.1.6. to object to the processing of personal data or to withdraw your consent given previously;
9.1.7. to request suspension (except storage) of your personal data processing operations, in the event of disputes or the need to verify the legality of the processing, the accuracy of the data, as well as in cases where we no longer need your personal data, but you do not want us to destroy it;
9.1.8. to request, if technically possible, the provision of your personal data in an easily readable format for your consent or for the purpose of performing the contract, or to request the transfer to another data controller.
9.2. We shall endeavour to guarantee the exercise of your rights as a person of the personal data subject and to create all conditions for the effective exercise of these rights, but we reserve the right not to comply with your requirements when it is necessary to ensure:
9.2.1. fulfilment of legal obligations imposed on us;
9.2.2. security or defence of the state;
9.2.3. public order, prevention, investigation, detection or prosecution of criminal offences;
9.2.4. important economic or financial interests of the state;
9.2.5. prevention, investigation and detection of violations of professional ethics;
9.2.6. protection of your or other person’s rights and freedoms.
9.3. You may provide us with the requirements related to the implementation of your rights in person, by post or by email. Upon receipt of your request, we may ask you to provide proof of identity, as well as any additional information related to the request which is necessary for us.
9.4. Upon receipt of your request, we shall respond to you within 30 calendar days of receipt of your request and of the date of submission of all necessary documents for submission of a response.
9.5. If we consider it necessary, we shall stop processing your data, except storage, until your request is resolved. If you have legally withdrawn your consent, we will terminate your personal data processing activities immediately, but not later than within 30 calendar days, except in the cases specified in this Privacy Policy, and in the cases provided for by law, i. e. when we are obliged to continue to process your data due to the legislation in force, due to our legal obligations, court decisions or binding instructions from the authorities.
9.6. If we refuse to comply with your request, we shall clearly indicate the reason for such refusal.
9.7. If you disagree with our actions or the response to your request, you may complain to competent public authority about our actions and decisions.

10. HOW CAN YOU FILE A COMPLAINT?
10.1. If you wish to make a complaint about our data processing, please submit it in writing, giving as much information as possible, using the contact details provided at the end of this Privacy Policy. We shall cooperate with you and try to resolve any issues immediately.
10.2. If you believe that your rights have been violated in accordance with the GDPR/other applicable acts regulating the protection of personal data, you may file a complaint with our supervisory authority – the State Data Protection Inspectorate of the Republic of Lithuania, you may find more information and contact details on the Inspectorate's website (https://vdai.lrv.lt/). Although, above all, we shall try to resolve all disputes together with you.

11. HOW WILL THIS PRIVACY POLICY BE CHANGED?
11.1. All changes to our Privacy Policy shall be posted on the Respo app. In case of significant changes and/or if needed, we shall notify you about them. The new terms of the Privacy Policy may also be presented on the Respo app, and you may need to read them and agree to them in order to continue using the Respo app and/or our services, purchase goods for sale, services provided.

12. COOKIES
12.1. The following cookies https://www.cookiebot.com/en/privacy-policy/

13. HOW CAN YOU CONTACT US?
13.1. Please send all documents related to this Privacy Policy or contact us directly by these contacts:
13.1. by post - UAB "BURBULIUKAS IR CO", legal entity code: 147952214, registered office address: registered office address: Pušaloto str. 7, Panevėžys
13.2. by email – info@respowater.com