The protection of personal data is governed in Lituania, by the General Data Protection Regulation (Regulation (EU) 2016/679).
UAB POD Europe (hereinafter referred to as “we” or “us”) is registered under number 306713892, having its registered office at Vilnius, Žalgirio g. 88-101, LT-09303, in the person of its legal representatives domiciled in that capacity at the said registered office.
As data controller, we are committed to protecting the data of our customers and prospective customers (hereinafter referred to as “you”) that we process for the purposes of our business. This is why we are committed to respecting the principles and rules applicable to the protection of personal data.
This policy explains how we collect and process your personal data (hereinafter referred to as your “Data”) so that we can provide you with new services on a daily basis while respecting your rights.
1- What data do we process?
As part of our commercial relationship, we process the following Data in particular: your surname, first name, title, postal address, e-mail address, landline or mobile telephone number. When this information is essential for the provision of our services, it is indicated in the form or contact form by an asterisk. We also process Data when you purchase our products and use our services, in particular data relating to the amount and nature of your purchases, your bank details, your orders and your invoices.
When you browse our websites and mobile applications, we also process Data such as identification, connection and, where applicable, location data.
We collect your Data directly when you provide it to us. Your Data may also be communicated to us indirectly by partners.
2- When do we process your Data?
Your Data may be processed if you are one of our customers or if you are not yet one of our customers but receive our commercial offers as a prospect.
2-1 If you are a customer:
Your Data may be processed when you:
- visit our websites which may use cookies;
- subscribe to our newsletter and receive offers ;
- wish to benefit from our deferred payment offers;
- take part in satisfaction surveys or register for an event organized by us (competitions, commercial operations, etc.);
- interact with us on social networks.
For these processing operations, we rely on your consent. Please note that we have a legitimate interest in sending you information by SMS / e-mail for products or services similar to those for which your Data was collected. If you wish to object, please see the section below entitled “How to exercise your rights”.
Your Data may also be processed when you:
- create and use an account on our websites or mobile applications;
- buy our products online and have them delivered;
- contact our after-sales service.
This processing is necessary for the performance of our services (pre-contractual or contractual measures).
Your Data may also be processed when we:
- make statistical studies ;
- have to defend our interests (prevention and fight against fraud, litigation);
- working to improve our services.
Such processing is in our legitimate interest. If you do not wish to receive targeted advertising from us or our partners, please see the section below entitled “How to exercise your rights”.
Finally, your Data may be processed when you exercise your rights to your Data or to enable us to meet our legal obligations.
2-2 If you are not yet a customer (prospect)
Your Data may be processed when you :
- subscribe to our newsletter and receive offers ;
- visit our websites which may use cookies
- register for an event organized by us (competitions, sales operations, etc.);
- interact with us on social networks.
For these processing operations, we rely on your consent.
Your Data may also be processed when :
- we carry out statistical studies.
These processing operations are carried out in our legitimate interest.
Finally, your Data may be processed when you exercise your rights to your Data or to enable us to meet our legal obligations.
Whether you are a customer or a prospective customer, you may be asked to provide us with the data of a third party, particularly in the context of sponsorship operations. In this case, you guarantee that you have their consent and you must inform us as soon as they decide to withdraw it.
3- Who will receive your data?
We ensure that the persons who access your Data are authorized and subject to an obligation of confidentiality.
These recipients may be authorized personnel from departments responsible for handling commercial relations and support functions (communication, administrative and financial, legal and compliance, general services, security, technical and logistical services, information systems, etc.) of our company.
Your Data may be transmitted to certain partners and service providers specializing in payment and transaction services (e.g. banks, payment service providers), customer relationship management, product delivery (e.g. carriers), after-sales service, social or legal audits and due diligence, assistance in the event of litigation (e.g. lawyers, experts, consultants, etc.) as well as to IT support and security service providers.
In the case of deferred or instalment payment options, your Data may be transmitted to certain service providers specializing in payment and transaction services (e.g. banks). Eligibility for this scheme and its granting involves a credit risk analysis based on automated decision-making. You have the right to obtain human intervention, to express your point of view and to contest this decision (see section “How to exercise your rights?” or “Contact”).
Your Data is usually processed within the European Union. The processing of your Data may, in certain cases, give rise to a transfer outside the European Union. We ensure that appropriate safeguards are implemented for the protection and security of your Data. These guarantees may be the conclusion of a transfer agreement based on the standard contractual clauses adopted by the European Commission and/or any other mechanism approved by the supervisory authorities.
We may be required to disclose your Data in response to requests from public authorities, in particular to meet national security, anti-fraud or law enforcement requirements. In such a case, we are not responsible for the conditions under which the staff of these authorities process your Data.
4- How long will your data be kept?
Your Data is processed according to the following retention rules:
| Goals | Storage rules |
| Commercial prospecting | 3 years maximum after last contact |
| Statistical studies | 3 years maximum after last contact |
| Customer account management | 3 years maximum after last contact |
| Purchasing and order management | 5 years from invoice date |
| Customer relations and after-sales service management | Maximum 3 years after last contact / processing of request |
| Managing requests to exercise rights | 6 years maximum from processing of request |
| Cookies | Click here to consult our Cookie Policy |
At the end of these periods, we may archive your Data, in particular to comply with legal and judicial requirements. Your Data is then either deleted or anonymized, it being specified that these operations are irreversible and that we are not subsequently able to restore them.
5- Our commitment to security and confidentiality
We take great care to protect the confidentiality and security of your data.
Appropriate organizational and technical security measures are in place to protect your Data against the risks of malicious intrusion, loss, alteration or disclosure to unauthorized third parties. The implementation of such measures may justify the assistance of any third party of our choice, in particular to carry out vulnerability audits or penetration tests. These measures are reviewed and updated as necessary.
We take care to ensure that personal data protection principles are taken into account right from the design stage. For example, we may pseudonymize or anonymize your Data whenever possible or necessary.
We also encourage you to be vigilant and protect your terminals (computer, smartphone, tablet) against any unauthorized access.
We advise you to choose a password:
- complex, i.e. containing several different characters and types (lowercase, uppercase, digit, special character);
- “that says nothing about you, your preferences or your habits;
- for your different online accounts.
6- How to exercise your rights
In order to allow you to control our use of your Data, you have the right to:
- to be informed about the use we make of your Data. This is the purpose of the present document;
- to obtain confirmation that your data is being processed and, if necessary, to request a copy from us, it being understood that we will be entitled to charge you for any additional copies;
- obtain rectification of any data concerning you that may be inaccurate, obsolete or incomplete;
- to withdraw your consent or, where such processing is based on our legitimate interests, to object to the processing of your Data on grounds relating to your particular situation.
For example, with regard to commercial prospecting:
- by email, you can unsubscribe by clicking on “unsubscribe” in each newsletter or by logging into your customer account;
- to request **the limitation of the processing of your Data. This right only applies under certain conditions (contesting the accuracy of your Data, doubting the lawfulness of processing, exercising your legal rights).
- exercise your right to portability of your Data. This right applies only under certain cumulative conditions (you yourself have communicated your Data to us on our online service and for purposes based on your consent or the performance of a contract).
- request the deletion of your Data. This right applies only under certain conditions (withdrawal of the consent on which the processing is based, your Data is no longer necessary with regard to the initial purposes of processing, opposition to the processing of your Data, doubt as to the lawfulness of the processing).
- Formulate specific and general post-mortem directives on the retention and communication of your Data. Without a directive, your heirs can send us any request.
In general, to exercise your rights, you can :
- Go to your customer account.
- Send us your request :
*By e-mail: DPO[a]partofdream.io
Proof of identity may be requested in case of doubt.
We provide you with answers to your questions as quickly as possible and in compliance with our legal obligations.
You have the right to lodge a complaint with a supervisory authority, in Lituania the State Data Protection Inspectorate (‘VDAI’), i.e. the Lithuanian data protection authority (are available in Lithuanian here).
7- Contacts
You can contact our Data Protection Officer (DPO) at the following address: dpo[a]partofdream.io
This policy will be updated as necessary.
June 2024 version 1.0