PRIVACY POLICY

Editorial 2023 - 02 - 07


We are aware of the particular importance we attach to the protection of your personal data, and we only collect and process your data that is necessary for the performance of our activities. We process personal data lawfully, transparently and fairly, for predefined purposes and only to the extent necessary to achieve those purposes. When we process personal data, we aim to keep it accurate, secure, confidential, properly stored and protected.

When processing your personal data, we comply with the requirements of the General Data Protection Regulation (GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as the requirements for the processing of personal data set out in other legal acts.

1. WHAT IS THIS DOCUMENT?

1.1 This privacy policy ("Privacy Policy") sets out the privacy conditions for your use of the Website and provides information about the processing of personal data obtained from third parties, such as vehicle databases, ad portals, etc., which are necessary for the provision of our services. For the purposes of this Privacy Policy, the "Website" refers to the website autoistorija.lt.

1.2 Please read this Privacy Policy carefully to find out how we process your personal data, where we obtain it from and what your rights are as a personal data subject.

1.3 If you use the Website, it means that you have read and understood this Privacy Policy and the purposes, methods and procedures for processing your personal data as set out therein. 

1.4 As used in this Privacy Policy, "personal data" means any information from which you can be identified, whether directly or indirectly. Personal data includes name, surname, date of birth, postal or e-mail address, location data and internet identifier, characteristics specific to you, etc.

1.5 The Privacy Policy applies to all persons who visit the Website, to persons whose personal data is used in the provision of services by us and to actions that you may perform on the Website.

2. WHO ARE WE?

2.1 The Website is managed and administered by UAB "Diginet LTU", legal entity code 126222639, address Saltoniškių g. 9B-1, Vilnius. E-mail address of the person responsible for the protection of personal data: [email protected] 

2.2 In accordance with the provisions of the legislation, we are the controller of your personal data.

3. WHAT PRINCIPLES DO WE FOLLOW?

3.1 In processing your personal data, we:

 a) we will comply with the requirements of current and applicable legislation, including the GDPR;

 (b) we will process your personal data in a lawful, fair and transparent manner;

 (c) we will collect your personal data for specified, explicit and legitimate purposes and will not further process it in a way that is incompatible with those purposes, except to the extent permitted by law;

 (d) we will take all reasonable steps to ensure that personal data which are not accurate or complete in relation to the purposes for which they are processed are rectified, supplemented, suppressed or erased without delay;

 (e) we will keep them in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;

 (f) we will not disclose personal data to third parties or make them public, except as provided in the Privacy Policy or applicable law;

 (g) we will ensure that your personal data is processed in such a way that appropriate technical or organisational measures are taken to ensure adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1 We process your personal data received in the following ways:

 (a) when you provide personal data to us.  You provide us with your personal data and other information by using the Website, by writing to us or communicating with our customer service team by phone or email, by submitting your complaints and/or queries, or otherwise;

 (b) when you use the Website.  When you use the Site, certain information (e.g. the type of web browser you use, the number of times you visit the Site, the pages you view on the Site, etc.) is collected automatically;

 c) when we receive your personal data from other persons in accordance with the procedure established by legal acts and/or this Privacy Policy.

4.2 To the extent permitted by applicable law, we may combine the personal data we have obtained from you through your use of the Website with:

 a) Your data that we have received when you use other websites that we manage and administer (autoplius.lt, skelbiu.lt, cvbankas.lt, aruodas.lt, ntzemelapis.lt, kainos.lt, services.lt) or the mobile applications of these websites;

 (b) data collected by us from other public or lawfully available sources (e.g., we may combine the personal data you provide with data obtained through the use of cookies on the Site or with data lawfully obtained from third parties).

5. WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?

5.1 We process your personal data for the following purposes:

(a) for the purpose of registration, identification and provision of services. You provide us with your personal data when you use the Website, register with us (create an account). We also process your personal data when you register on or use the Website as a representative and/or contact person of a legal entity. Personal data processed for this purpose include:

Data categories

Name, email address, phone number, place of residence (city), IP address, mobile phone number.

Legal basis for processing

Agreement (Terms of Use)

Time limit for data processing

5 years from the date of the last login to your account.

We get our data from

by you, including through your use of the Website.

We provide or transfer data

We do not provide this data to third parties

 (b) for the provision of paid services, payment, accounting and billing control, debt management and debt recovery.  You provide us with your personal data when you subscribe to our paid services on the Website. Personal data is processed for this purpose:

Data categories

Name, surname, e-mail address, telephone number, VAT number, details of the provision of services (e.g. start date, end date, duration, status, etc.), details of the services ordered and used and the charges for them, details of the invoices issued, and details of payments (e.g. e.g. services provided, date, number of invoice, amount due or paid, method of billing and payment of invoice, date of payment, status of payment, data relating to debt (e.g. date of incurrence of debt, amount of debt, type of debt, etc).

Legal basis for processing

Agreement (Terms of Use)

Time limit for data processing

5 years from the date of the last login to your account

We get our data from

from yourself; from third parties: your mobile operator, bank or electronic money institution where you have an account

We provide or transfer data

to your mobile operator, bank or electronic money institution with which you have an account, where we transmit data necessary for the payment of the service, where it is necessary to identify you as a user of the Website subscribing to a paid service on the Website; to debt collection companies that mediate with us in the recovery of a debt and only to the extent necessary to initiate and pursue the recovery of the debt.

(c) for quality assurance and communication purposes.  You provide us with your personal data by writing to us, emailing us or contacting our customer service team by telephone with your complaints, queries about the Website or our services. Personal data is processed for this purpose:

Data categories

Name, surname, e-mail address, telephone number, place of residence (address), content of the complaint and/or request made in writing (e.g. date and content of the letter, etc.), by e-mail (e.g. date and content of the e-mail, etc.), by telephone (e.g. telephone number, record of the telephone conversation, date, time and duration of the call, details given during the call, etc.)

Legal basis for processing

Agreement (Terms of Use), as well as our legitimate interest in evaluating feedback from our customers in order to improve the quality of our operations and services

Time limit for data processing

2 years from the date of your enquiry to us where you make the enquiry in writing;2 years from the date of your enquiry to us where you make the enquiry in writing by email;2 years from the date of your enquiry to us where you make the enquiry by telephone

We get our data from

Your own; 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 our staff about the actual circumstances of the complaint and record them, etc.); from third parties

We provide or transfer data

Mobile operators, banks and payment institutions, payment intermediaries

(d) for the purpose of providing the services of a vehicle history check system. In order to ensure the quality of our vehicle history check services, we obtain data on specific vehicles based on the unique VIN number of the vehicle from third parties (vehicle registration, roadworthiness tests, advertising portals and other sources).

We make every effort to minimise the amount of personal data of former owners, sellers or users of the vehicle that we receive together before receiving vehicle data from third parties, and to collect only the data necessary for the provision of our services.

Data categories

The content uploaded by the seller of a vehicle to a for-sale advertisement, the details of the advertisement, such as photos and the technical details of the car, motorcycle or other vehicle, such as mileage information, technical parameters.

Information on the vehicle's history, including but not limited to mileage records, information on past registrations, damage records, and servicing performed. 

Vehicle technical data available in public registers.

Legal basis for processing

It is in our legitimate interest to collect all relevant information on the history of the vehicle at different stages of its use and to prepare the Report. It is in the legitimate interest of the purchasers of the Reports to have access to the historical technical data of the vehicle of interest, to ascertain the accuracy of its technical condition, accidents or mileage data.

We get our data from

Managers of vehicle history check databases.

Vehicle inspection companies and associations.

Vehicle registers.

Vehicle manufacturers' service history managers.

Stolen vehicle registers.

We provide or transfer data

We do not provide this data to third parties

(e) for direct marketing purposes.  We process your personal data with your consent in order to provide you with newsletters, offers, including personalised offers, and information about our services and/or products, services of our affiliates and partners, or other information to improve our services. 

If you have consented to the use of your data for this purpose when registering or using the Website (e.g. by checking your car history), we will process not only your personal data for this purpose, but also analyse your behaviour on the Website and your order history in order to get to know you better and to tailor our offers according to your needs and to provide you with other tailored benefits. 

Personal data processed for this purpose:

Data categories

Name, telephone number, email address, details of services ordered on the Website (e.g. date and time of services ordered, name of services, quantity of services, type of services ordered), history of personal offers made to you and information about the use made of them

Legal basis for processing

Your consent to receive newsletters, offers, including personalised offers, and information

Time limit for data processing

2 years from the date of your consent to receive newsletters, offers, including personalised offers, and information

We get our data from

by you, including through your use of the Website.

We provide or transfer data

For companies providing newsletter services, business management information systems, and administration of the Website itself.

For this purpose, we use automated data analysis and decision-making, including profiling, which enables us to provide you with relevant, interesting and useful offers and other information by grouping together data that identifies you and/or data about the services you have ordered on the Website, your behaviour on the Website.

We note that where we provide you with certain offers or other information on the basis of automated data processing, including profiling, we aim to implement appropriate measures to protect your rights and freedoms and legitimate interests. Specifically, in such cases, you have the right to request human intervention from us, to express your views and to contest the relevant decision.

For more information on the processing of personal data for direct marketing purposes, please refer to Section 6 of this Privacy Policy.

(e) for the purpose of ensuring the functionality of the Website, improving it and offering you better and more tailored services.  We process your personal data, including personal data and cookies that we receive when you use our Website, on the basis of legitimate interest, in order to improve and develop the Website and to offer you better and more tailored services.

For this purpose, we use personal data obtained from you, generated by your use of the Website and/or lawfully obtained from other persons.

Please see section 7 of this Privacy Policy for more information on how we use cookies and similar technologies.

(f) for other purposes where we are required to process your personal data by law or where there is a legitimate interest.

5.2 We do not ask for or process special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or data concerning your health or data concerning your sex life and sexual orientation. In the event that you provide us with special categories of data through the Website or otherwise (in writing, by email, by telephone), we will consider that this data has been provided with your consent. Where the special category personal data you have provided us with can be distinguished and would not require disproportionate effort on our part, we will promptly remove it.

6. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING?

6.1 We may use your personal data for the purpose of direct marketing to provide you with newsletters, offers, including personalised offers, and information about our, our affiliates' and our partners' services and/or products that we think may be of interest to you, after obtaining your freely given consent.

6.2 For this purpose, we process your personal data specified in section 5.1 (d) of the Privacy Policy.

6.3 You can choose whether you allow us to use your personal data for direct marketing purposes. You can do this by:

a) by ticking the consent text "I agree to receive newsletters, offers and offers by email" in the Settings/Information Notifications section of your account, or by not ticking it at any time after registration, when registering on the Website, when ordering a car history report or at any time after registration;

(b) by ticking the consent text "I agree to receive newsletters, telephone offers" in the Settings/Information Notifications section of your account, or by not ticking the consent text "I agree to receive newsletters, telephone offers" when registering on the Website, ordering a car history report or at any time after registration;

6.4 By granting us the right to process your data for the purpose of direct marketing, you authorise us to contact you for this purpose by appropriate means of communication (e.g., depending on the direct marketing method(s) chosen, by email or telephone, by SMS or other means of communication (e.g., WhatsApp, Viber, etc.).

6.5 If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyse and improve the effectiveness of our Website, advertising and market research, and for other corporate marketing and sales purposes. In this case, we will use your personalised data.

6.6 You can easily withdraw your consent to the processing of your data for direct marketing purposes at any time. Your refusal to receive offers and newsletters will not prevent you from using our services, but it will mean that we will not be able to provide you with useful offers. You can withdraw your consent by:

 a) in the Settings/Information Notifications section of the Website, change the settings to indicate that you no longer wish your personal data to be used for direct marketing purposes and untick the boxes next to "I agree to receive newsletters, offers by email" or "I agree to receive newsletters, offers by telephone" or

 (b) to notify the opt-out in the manner specified in the newsletters, offers received by e-mail (e.g. by clicking on the "Unsubscribe" link in the newsletters, offers, etc.) or by replying to the SMS received by telephone with the text "Unsubscribe"; or

 c) send us a request by email to [email protected]. The request must clearly state your name and other registration details (if any). If you wish to withdraw your consent in this way, we may ask you to provide proof of identity.

6.7 Withdrawal of consent shall not affect the lawfulness of the processing of your personal data based on consent carried out prior to the withdrawal of consent.

6.8 Where we have received your email contact details in the course of selling goods and services to you (e.g. after you have purchased a car history report), we may use them to market similar goods and services, such as car adverts, on the basis of legitimate interest rather than consent. In this case, we will always provide you with a clear, free and easy-to-use opportunity to object to or opt-out of such use of your contact data for direct marketing purposes. 

7. HOW DO WE USE COOKIES?

7.1 When you use the Website, we collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device's hard drive and allow us to recognise you on subsequent visits to the Site, save your browsing history, preferences, customise the content, speed up searches on the Site, create a user-friendly and friendly Site environment, and make the Site more efficient and reliable. Cookies are a common practice on websites that make it easier to use the website.

7.2 We may collect the following information by means of cookies: the IP address, the type of web browser used, the number of visits to the Site, the pages viewed on the Site, the time spent on the Site, demographic data and, if you have come to the Site from a third-party website, the URL link of the page.

7.3 We use the information we receive through cookies for the following purposes:

 (a) to ensure the functionality of the Site (e.g. to enable you to use the Site's personalisation);

 (b) to improve and develop the Website to better meet your needs;

 (c) for the development of services and analysis of the use of the Website;

 (d) targeted marketing guidance.

7.4 We may, without prejudice to the law, combine information obtained through the use of cookies with information obtained about you by other means (e.g. combining information about your use of the Website with personal data that you have provided).

7.5 The following types of cookies may be used on the Website:

 a) technical cookies - these are cookies that are necessary for the operation of the Website;

 b) Functional cookies - these are cookies that, although not essential to the operation of the Website, significantly improve its performance, quality and user experience;

 c) analytical cookies - these are cookies that are used to compile a statistical analysis of the navigation methods of visitors to the Website; the data collected by these cookies is used anonymously;

 (d) Targeting or promotional cookies - these are cookies that are used to show you offers or other information that may be of interest to you;

 e) social network cookies - these are cookies that are necessary for you to use the Site information in your social profile account.

7.6 Detailed information about the cookies used on the Site, their purpose and expiry date can be found in the cookie notice and consent section by clicking on the "Manage options" tag when you first visit the Sites or by selecting the "Cookie Settings" link at the bottom of the Site.

7.7 You can give your consent to the use of cookies by clicking "I agree" on the link (bar) about cookies on the Site.

7.8 You may withdraw your permission for us to use cookies at any time. You can do this by changing the settings on your web browser so that it does not accept cookies. How you do this depends on the operating system and web browser you are using:

 a) Cookie settings in Internet Explorer

 b) Cookie settings in Mozilla Firefox

 c) Cookie settings in Google Chrome

For detailed information on cookies, their use and the possibility to refuse them, please visit http://AllAboutCookies.org or http://google.com/privacy_ads.html .

7.9 Your consent is not required for us to use technical cookies, i.e. those cookies that are strictly necessary for the operation of the Website and the provision of our services to you. We use technical cookies on the basis of legitimate interest.

8. WHO DO WE PROVIDE YOUR PERSONAL DATA TO?

8.1 We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without legitimate grounds, or used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy or applicable 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 law enforcement authorities or prosecuting authorities.

8.2 We may transfer your personal data to companies that assist us in our business activities, including direct marketing and other companies within the Baltic Classifieds Group. We require such partners to process your data only in accordance with the instructions we have given them and the applicable data protection legislation. We enter into contracts with these individuals which oblige the parties to strictly comply with the requirements for the protection of personal data.

8.3 We may disclose the data we collect about you to the following third parties:

 (a) 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);

 (b) third-party service providers whose services we generally use for data storage, telecommunications and website hosting purposes;

 c) other companies in the Baltic Classifieds Group group of companies, insofar as this does not conflict with the requirements of mandatory legislation applicable to us.

 d) Payments on the Website are processed through the makecommerce.lt platform, which is operated by Maksekeskus AS (Niine 11, Tallinn 10414, Estonia, reg. no.:12268475), and therefore your personal information necessary for the execution and confirmation of the payment will be transmitted to Maksekeskus AS.

8.4 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.

8.5 A list (non-exhaustive) of the persons and categories of persons to whom we transfer your personal data is set out in clause 5.1 of this Privacy Policy, separately for each purpose for which we use personal data.

9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

9.1 We shall not keep your personal data for longer than the purposes of processing or the law requires, unless a longer retention period is specified in the law.

9.2 We aim not to store outdated, irrelevant personal data, so that only relevant information is stored when it is updated. Historical information is retained where it is necessary for the purposes of the law or for the conduct of our business, or where the data is necessary for the protection of our legitimate interests before judicial or other authorities.

9.3 Section 5.1 of the Privacy Policy specifies the retention periods for each purpose of use of personal data.

10. HOW DO WE PROTECT YOUR PERSONAL DATA?

10.1 The data we collect from you will be located in the territory of the European Economic Area (EEA) and in the countries for which the European Commission has adopted an adequacy decision (Safe Countries), but may also be transferred to, or stored in, countries outside the EEA and the Safe Countries. In exceptional cases, they may also be processed by our, the Baltic Classifieds Group's group of companies' or our suppliers' personnel outside the EEA or the safe countries. When we transfer your data outside the EEA or safe countries, we will take all necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy.

10.2 When we receive your data, we have strict technical and organisational measures in place to protect your data from unauthorised access. On the other hand, the transmission of information over the internet is not completely secure. Although we take great care to protect your personal data, we cannot guarantee the security of the data when you transmit data to the Website - you bear the risks associated with the transmission of data to the Website. 

10.3 In the unlikely event that we become aware of a breach of security of your personal data which may pose a serious threat to your rights or freedoms, we will inform you immediately upon becoming aware of it and identifying the information accessed.

11. EXTERNAL WEBSITES

11.1 The Website may contain links to external websites, such as our business partners' websites or websites advertising our services and/or goods. If you follow such links to any of these sites, please note that these sites and the services available through them have their own separate privacy policies and we do not accept any responsibility or liability for these policies or for the personal data, such as contact or location data, collected on these sites or through these services. Please review these policies before submitting personal data to these websites or using any services.

12. WHAT RIGHTS DO YOU HAVE?

12.1 When processing personal data, we ensure your rights in accordance with the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a personal data subject you have the following rights:

 (a) to know (be informed) about the processing of their personal data;

 (b) to have access to your personal data that we process;

 (c) to request the rectification or completion, clarification of inaccurate, incomplete or incorrect personal data;

 (d) require the destruction of personal data when they are no longer necessary for the purposes for which they were collected;

 (e) require the destruction of personal data where the processing is unlawful or where you withdraw or withhold your consent to the processing of personal data, which is necessary;

 (f) to object to the processing of personal data or to withdraw consent previously given;

 (g) to request the suspension (other than storage) of the processing of your personal data in the event of disputes or to verify the lawfulness of the processing, the accuracy of the data, or where we no longer need your personal data, but you do not want us to delete them;

 (h) require the provision, where technically feasible, of your personal data collected pursuant to your consent or for the purposes of the performance of a contract, in an easily readable format, or request that it be transmitted to another controller.

12.2 We will endeavour to guarantee the exercise of your rights as a data subject and to provide all the conditions for the effective exercise of those rights, but we reserve the right not to comply with your requests where it is necessary to ensure:

 (a) fulfilling the legal obligations imposed on us;

 (b) national security or defence;

 (c) public policy, the prevention, investigation, detection or prosecution of criminal offences;

 (d) important economic or financial interests of the State;

 (e) the prevention, investigation and detection of breaches of official or professional ethics;

 (f) the protection of your rights and freedoms or the rights and freedoms of other persons.

12.3 You may submit claims relating to the exercise of your rights to us in person, by post or by electronic communication. Upon receipt of your request, we may ask you to provide proof of identity as well as other additional information we require in connection with your request.

12.4 Upon receipt of your request, we will respond to you no later than 30 calendar days from the date of receipt of your request and the date of submission of all the documents required to provide the response.

12.5 If we deem it necessary, we will suspend the processing of your data, except for storage, until your request is resolved. If you lawfully withdraw your consent, we will cease processing your personal data immediately, but no later than 30 calendar days, except in the cases set out in clause 12.2 of this Privacy Policy and as required by law, i.e. where we are obliged to continue to process your personal data by applicable law, by a legal obligation incumbent on us, or by a judicial decision or a binding instruction from an authority.

12.6 If we refuse to comply with your request, we will inform you of the grounds for such refusal and of the possibility of lodging a complaint with the supervisory authority and of seeking a remedy.

13. WHO CAN YOU COMPLAIN TO?

13.1 If you wish to make a complaint about our processing of your data, please submit it in writing, providing as much information as possible, using the contact details at the end of this Privacy Policy. We will co-operate with you and endeavour to resolve any issues promptly. We will respond to your complaint no later than 30 calendar days from the date of receipt of your complaint and the submission of all documents necessary to respond.

13.2 If you believe that your rights under the GDPR have been infringed, you may lodge a complaint with our supervisory authority, the State Data Protection Inspectorate, for more information and contact details please visit the Inspectorate's website (https://vdai.lrv.lt/). We aim to resolve all disputes promptly and amicably with you, so we recommend that you always contact us directly in the first instance.

14. HOW WILL THIS PRIVACY POLICY BE AMENDED?

14.1 Any changes to our Privacy Policy will be posted on the Website. We will notify you of such changes by a separate notice where necessary. The new terms of our Privacy Policy may also be posted on the Site and you may be required to read and agree to them in order to continue using the Site and/or our services.

15. HOW TO CONTACT US?

15.1 Please send all documents relating to this Privacy Policy to or contact us at the following contact details:

 a) by post - UAB "Diginet LTU", address Saltoniškių g. 9B, LT - 08105 Vilnius;

 b) by email - [email protected] 

Date of publication of the Privacy Policy 7 February 2023