DATA CONTROLLERS
MB ELTUVA, registered at Girios g. 114A, LT-47252 Kaunas, contact email [email protected], tel. no. +37064985903
This privacy policy (“Privacy Policy”) is intended for individuals who use the accommodation and water taxi services provided on the website www.mariosirjura.lt, as well as visitors to the website www.mariosirjura.lt.
TERMS USED IN THE PRIVACY POLICY
Personal Data – any information about a natural person whose identity is established or can be established (data subject); a natural person whose identity can be established is a person whose identity can be directly or indirectly identified, primarily by an identifier such as name and surname, personal identification number, location data, and internet identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. Data Subject – a person who uses the services provided on the website www.mariosirjura.lt, visits the website www.mariosirjura.lt, contacts MB ELTUVA for services/products, or for other purposes. Request – a data subject’s request to exercise their rights. Regulation – the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). Website – the MB ELTUVA website www.mariosirjura.lt
Other terms used in this Privacy Policy have the meaning as provided in the Regulation.
GENERAL PROVISIONS
This Privacy Policy is not considered an agreement with you regarding your data processing. Through this Privacy Policy, we inform you about the main principles of personal data processing and the exercise of the data subject’s rights. Additional information about the processing of your personal data may be provided in purchase-sale, service, and other agreements. By using the services of MB ELTUVA, providing your data, filling out inquiry or reservation forms, and continuing to browse the Website, you confirm that you have read this Privacy Policy and understand its provisions. This Privacy Policy does not apply when using other companies’ websites or services or other reservation systems, such as www.booking.com. We recommend reading the privacy notices of other service providers and contacting them directly regarding the processing of your personal data.
PRINCIPLES OF PERSONAL DATA PROCESSING
MB ELTUVA processes personal data in accordance with the laws of the European Union and the Republic of Lithuania regulating personal data processing. The scope of the processed personal data depends on the ordered or used services, the legal relationship of MB ELTUVA with the data subject or other persons, and the information provided by the person when ordering and/or using the services, visiting the Website, or contacting MB ELTUVA. We process your personal data only if there is a lawful basis for processing – to take action at your request before entering into a contract or to perform a contract; with your consent; when processing personal data is required by applicable laws; when personal data needs to be processed for the legitimate interest of us or a third party. We aim to process personal data accurately, fairly, and lawfully, only for the purposes for which it was collected, and to process it in compliance with the clear and transparent principles and requirements established in legal acts.
HOW WE OBTAIN PERSONAL DATA
We may obtain personal data directly from you when you: • Fill out inquiry or reservation forms on the Website; • Place an order for services provided by us; • Contact MB ELTUVA by other means; • Communicate with MB ELTUVA through social networks or simply follow MB ELTUVA activities on social networks; • Receive services from MB ELTUVA. We may also obtain your personal data indirectly: • Through the online reservation channel you use to make a reservation, such as www.booking.com and others; • From social media platforms or online reviews; • From MB ELTUVA data processors or other external sources. Personal data may be generated when you use the services or inquire about them, for example, by calling, sending a text message, email, ordering services, or visiting the Website. You are not obliged to provide us with any personal data, but without your personal data, we may not be able to perform certain actions, such as providing services or issuing invoices.
RECIPIENTS OF PERSONAL DATA Your privacy is important to us, so without your consent, we will not disclose your personal data to other persons, except for the following:
• In case of a dispute, to persons providing legal services to MB ELTUVA;
• Auditors, other consultants;
• Engaged data processors, reservation service providers;
• Operators of online reservation channels used by the data subject to make reservations, such as www.booking.com and others, for the purpose of service ordering and provision;
• State institutions, law enforcement agencies, and other persons as required by the laws of the Republic of Lithuania. If we disclose your personal data to other groups of data recipients not specified in this Privacy Policy, we will inform you no later than at the first time of disclosure, unless such information has already been provided to you earlier in other documents provided to you or concluded with you.
PURPOSES OF PERSONAL DATA PROCESSING
MB ELTUVA processes your personal data for the following purposes: service ordering and provision, direct marketing, customer service, apartment reservation, Website traffic statistics and monitoring, Website improvement, promotion of MB ELTUVA awareness, analysis of MB ELTUVA complex ratings and guest opinions, complaint handling, service improvement (including monitoring guest behavior), property and personal protection, internal administration, debt recovery and administration, legal claim submission, execution and defense, relationship maintenance with clients and partners, accounting, contract administration and execution, inquiry administration, and employee search purposes.
CATEGORIES OF PROCESSED PERSONAL DATA
The following main categories of personal data may be processed for the above purposes, but are not limited to:
• Data subject’s name, surname,
• Date of birth, age,
• Phone number,
• Address, country,
• Email,
• Purchased service/product,
• Check-in and check-out date,
• Information about co-residents,
• Data subject’s preferences,
• Discount code,
• Reservation number,
• Additional ordered services,
• Signature,
• IP address,
• Website browsing history and date,
• Other information necessary for service/product provision, relationship maintenance, invoice issuance, and contract administration, legal claim submission,
• Feedback and ratings of MB ELTUVA on social media,
• Data subject’s habits related to MB ELTUVA services,
• Data subject’s profile and other information on social media,
• Video recordings,
• Other data categories. Detailed information about other data categories is provided in separate sections of the Privacy Policy.
PERSONAL DATA RETENTION PERIOD
Personal data is processed no longer than necessary to achieve the purposes of data processing or as required by data subjects and/or provided by law. Generally, we will process data during the contract, service provision period, and for 10 years from the end of the contract, service provision, or relationship, complying with document archiving requirements established by law and to assert, execute, or defend legal claims of MB ELTUVA. Data collected during guest behavior monitoring for service improvement and customization purposes are processed for no longer than 3 years from the last contact with the data subject. Payment card data is retained for 1000 days. Your personal data, obtained through social media platforms or online reviews to address your complaints or respond to positive feedback about us, monitor our reputation online, to assess and improve our service quality through these means, is processed for no longer than 1 year from the date of data collection. If the data subject withdraws consent for data processing or the data processing period ends (when data is processed based on the data subject’s consent), only data confirming the fact of consent will be retained, but no longer than 10 years from the end of the consent period or withdrawal of consent, to assert, execute, or defend legal claims of MB ELTUVA.
DATA PROCESSORS
Your personal data may be processed by data processors providing accounting, legal, Website hosting, data center and/or server rental, IT maintenance, external audit, and other services to MB ELTUVA. Data processors have the right to process personal data only according to MB ELTUVA’s instructions and only to the extent necessary to properly fulfill the obligations established in the contract. MB ELTUVA, by engaging data processors, aims to ensure that data processors have implemented appropriate organizational and technical measures to ensure security and maintain personal data confidentiality.
YOUR RIGHTS RELATED TO PERSONAL DATA
As a data subject, you have the rights specified in this section below.
The right to know (be informed) about the processing of your personal data When we receive information directly from you about the processing of personal data, we inform you at the time of receiving the personal data:
- verbally (if we communicate with you only verbally, e.g., by phone);
- in writing (information sent to you by email is considered to be provided in writing).
If we obtain your data indirectly from you, we will inform you about the processing of your personal data verbally or in writing (as indicated above) no later than within one month from receiving the data, and if we use your personal data to maintain contact with you – no later than the first time we contact you.
The right to access your processed personal data and how it is processed
You have the right to receive information about the period of storage of personal data, information from which sources and what personal data was collected, for what purpose it is processed, to whom it is provided. Upon receiving your request, without delay, but in any case no later than within one month from the receipt of the request, we will check whether your personal data is processed by MB ELTUVA or not. After determining that we process your personal data, we will provide you with information about the processed personal data and a copy of the processed personal data in electronic format or paper medium.
We may extend the period for providing a response, if necessary, taking into account the complexity and number of your requests. We will inform you about this separately. If we decide to extend the period for providing a response, you have the right to appeal to the State Data Protection Inspectorate regarding such extension.
Usually, we will provide you with information free of charge. However, if your requests are clearly unfounded or disproportionate, especially due to their repetitive content, or if you wish to receive a copy of the processed personal data in a form other than the electronic or paper form prepared by MB ELTUVA, MB ELTUVA may charge a fee consisting of the administrative costs incurred by MB ELTUVA for providing information or notifications or actions requested.
Moreover, if your requests are clearly unfounded or disproportionate, we have the right to refuse to fulfill your request.
At your request, information may be provided verbally, by allowing access to the document, providing a certificate, document extract or paper copy of the document, electronic medium, access to the information file. If you do not specify the form of information provision in your request, we will provide you with information in the same form as the request was received.
Request to correct personal data and suspend such personal data processing actions, in case when, after familiarizing yourself with the personal data, you determine that the data is incorrect, incomplete or inaccurate
MB ELTUVA will immediately notify you about the correction, destruction or suspension of personal data processing actions performed or not performed at your request. We will also inform data recipients about personal data corrected or destroyed at your request, suspended personal data processing actions, except in cases where providing such information would be impossible or too difficult. In such a case, at your request, we will provide you with information about such data recipients.
The right to demand the destruction of personal data or to restrict data processing actions, in case when, after familiarizing yourself with your personal data, the data subject determines that the personal data is processed illegally or unfairly
MB ELTUVA will immediately notify you about the restriction of data processing performed or not performed at your request.
Personal data whose processing is restricted is stored. Before lifting the restriction, we will inform you about it by electronic means of communication. We will also inform data recipients about the data processing restricted at your request, unless this would be impossible or require disproportionate effort. In such a case, at your request, we will provide you with information about such data recipients.
The right to object to the processing of their personal data, except in cases where this personal data is processed for the legitimate interest pursued by the data controller or a third party to whom the personal data is provided, and if the data subject’s interests are not more important.
If you express objection to the processing of personal data, further data processing is carried out only if it is reasonably decided that the reasons for which personal data processing is carried out outweigh your interests, rights and freedoms, or if your personal data is necessary to submit, execute or defend legal claims.
The right to withdraw given consents for data processing
You have the right to withdraw all your consents for personal data processing at any time when the basis for processing your personal data is your consent provided to MB ELTUVA.
The right to request data erasure (right to be “forgotten”)
You have the right to request that MB ELTUVA erase personal data related to you for reasons provided in Part 1 of the Regulation.
We have the right to refuse to fulfill your request in cases established by legal acts, including, but not limited to, the cases discussed in Article 17(3) of the Regulation.
If we fulfill your request, and your personal data (deleted according to your request) has been transferred to data recipients, we will inform these data recipients about it, unless this would be impossible or require disproportionate effort. At your request, we will provide information about such data recipients. This right cannot be implemented if we are required to store personal data by law.
The right to personal data portability
You have the right to request that your provided personal data, if it is processed on the basis of consent or contract, and if it is processed by automated means, be transferred to another data controller or provided to you in a structured, commonly used and machine-readable format, if this is technically feasible. When contacting us regarding the implementation of the right to data portability, you must specify whether you want your personal data to be transferred to you or to another data controller.
If we fulfill your request and you wish the data to be transferred on a digital medium, we will provide you with your personal data processed by MB ELTUVA on a one-time recordable compact disc provided by you, or on a one-time recordable compact disc of MB ELTUVA, with you compensating for the purchase price of this medium.
You do not have the right to data portability for personal data that is processed by non-automated means in structured files, for example, paper files.
Personal data transferred at your request is not automatically deleted. If you wish so, you must contact MB ELTUVA regarding the implementation of the right to request data erasure (“right to be forgotten”).
The right to object to the application of only automated data processing to the data subject, including profiling
You have the right to know and be informed according to what logic personal data is processed automatically and what could be the consequences of such personal data processing when data is processed only in an automated manner.
If you contact us regarding the review of a decision based on automated data processing (if MB ELTUVA would make such decisions regarding you), we will conduct a comprehensive assessment of all relevant data, including the information you provided.
The right to submit a complaint to the State Data Protection Inspectorate or a competent court regarding the processing of personal data
You can appeal our actions or inaction related to the implementation of data subject rights to the State Data Protection Inspectorate, at the address A. Juozapavičius g. 6, Vilnius, email address [email protected], website www.ada.lt, as well as to a competent court of the Republic of Lithuania. You have the right to appeal MB ELTUVA’s actions or inaction yourself or through a duly authorized representative or a non-profit institution, organization or association that meets the requirements of Article 80 of the Regulation.
The right to compensation for damage suffered due to violation of data subject rights
If you have suffered material or non-material damage due to a violation of data subject rights, you have the right to compensation, for the award of which you have the right to apply to a competent court of the Republic of Lithuania.
PROCEDURE FOR CONTACTING MB ELTUVA WHEN IMPLEMENTING DATA SUBJECT RIGHTS
You have the right to contact us regarding the implementation of data subject rights verbally or in writing, by submitting a request in person, by mail or by electronic means using the contacts specified in this Privacy Policy. If you contact us verbally or the request is submitted in writing in person regarding the implementation of data subject rights, you must confirm your identity by presenting an identity document. Failure to do so will prevent us from accepting your requests and your data subject rights will not be implemented. This provision does not apply if you contact us for information about personal data processing according to Articles 13 and 14 of the Regulation. If you decide to contact us in writing regarding the implementation of data subject rights by submitting a request by mail, you must also submit a copy of an identity document certified by a notary or in another manner established by legal acts. If your personal data, such as name, surname, has changed, you must also submit copies of documents confirming the change of this data; if they are sent by mail, then the copies must be certified by a notary or in another manner established by legal acts.
If you decide to submit a request by electronic means, the request must be signed with a qualified electronic signature or it must be formed by electronic means that allow ensuring the integrity and immutability of the text. This provision does not apply if you contact us for information about personal data processing according to Articles 13 and 14 of the Regulation.
The request to implement data subject rights must be legible, signed, and must indicate your name, surname, address and/or other contact details for communication or which you wish to receive a response regarding the implementation of data subject rights.
You can implement your rights yourself or through a representative. If you decide to implement your rights through a representative, your representative must indicate in the request their name, surname, address and/or other contact details for communication, which your representative wishes to receive a response to, as well as your name, surname and indicate other data that are necessary for proper identification of the data subject and submit a document confirming the representation or a copy thereof.
If we have doubts about your identity, data, we have the right to request additional information necessary to ascertain it.
On all issues related to the processing of the data subject’s personal data and the exercise of their rights, you have the right to contact MB ELTUVA.
If you do not comply with the procedure specified in this section when contacting us, we will inform you about this no later than within 7 calendar days from the receipt of your request and indicate the shortcomings. If you do not correct the indicated shortcomings or do not inform MB ELTUVA about the reasons why the indicated shortcomings cannot be eliminated, we will not consider your request.
In the presence of objective circumstances due to which the indicated shortcomings cannot be eliminated, we may decide to accept your request and consider it after evaluating such circumstances.
We will not consider that your request has shortcomings if you did not comply with the request form specified in this section of the Privacy Policy when contacting us in writing.
ENSURING DATA SECURITY
Access to personal data is only available to those employees, service providers and authorized data processors who need it to perform their job functions or provide services.
MB ELTUVA ACCOUNTS ON SOCIAL MEDIA PLATFORMS
MB ELTUVA has created and manages accounts on social media platforms Instagram and Facebook. All information that you provide through the social media platforms Instagram and/or Facebook (including messages, use of “Like” and “Follow” fields, and other communication) or that is received when you visit MB ELTUVA accounts on social media platforms (including information received through cookies used by social network operators), is controlled by the social network operator. Therefore, we recommend reading the privacy notices of social network operators and contacting them directly regarding the use of your personal data.
As an administrator of Instagram and Facebook accounts, MB ELTUVA selects appropriate settings, taking into account its target audience and business management and promotion goals. The social network operator, by providing the opportunity to create MB ELTUVA account on the social network and administer it, may have limited the ability to change certain essential settings, and thus MB ELTUVA cannot influence what information about you the social network operator will collect when MB ELTUVA creates an account on the social network.
All such settings, both selected by MB ELTUVA and set by the social network operator, may affect the processing of your personal data when using social media tools, visiting MB ELTUVA account or reading MB ELTUVA messages on the social media network. Even if you just look at MB ELTUVA messages on social media platforms, the social network operator may receive certain personal information, such as what end device you are using and what your IP address is.
Usually, the social network operator processes your personal data (even those collected by MB ELTUVA selecting additional account settings) for purposes set by the social network operator, based on the social network operator’s privacy policy. However, when you use the social network, communicate with MB ELTUVA through the social network, visit MB ELTUVA account on the social network or view MB ELTUVA posts on it, MB ELTUVA receives information about you. The scope of data received by MB ELTUVA depends on the account settings selected by MB ELTUVA, agreements with the social network operator on ordering additional services, cookies set by the social network operator.
The operator of the Facebook social network collects information about what type of content you see, what you do on the Facebook social network, with whom you communicate, how often and how long you communicate with them, how active you are on the social network and other information, including information about your end device. To learn more about the privacy policy of the Facebook social network operator, click here https://www.facebook.com/policy.php.
RESERVATION SYSTEMS
You can book accommodation and other related services provided by MB ELTUVA not only by using our reservation system, but also by using external reservation systems, such as www.booking.com and others.
MB ELTUVA may receive your orders submitted through such external reservation systems, but the personal data you provide in external reservation systems is primarily processed by the controllers of these external reservation systems. We are not responsible for how your personal data is processed by the controllers of external reservation systems. Therefore, before submitting any data in external reservation systems, we recommend thoroughly familiarizing yourself with the personal data privacy policy of the controllers of external reservation systems.
COOKIES
To improve your visit, cookies are used – small pieces of textual information that are automatically created while browsing the Website and are stored on your computer or other end device.
The information collected by cookies allows us to ensure more convenient browsing on the Website, provide offers and learn more about the behavior of our Website users, analyze trends and improve both the Website and the services provided, save your completed or incomplete reservations so that you can return to them later. Cookies allow MB ELTUVA to provide services tailored to users’ needs (for example, by displaying only content that interests a specific user). If there are links to other websites on the MB ELTUVA Website (including external reservation systems or online reviews) that also use cookies, they are not described here.
When functional, tracking, advertising cookies and/or third-party cookies are recorded, we ask for your consent. When necessary cookies are recorded, we use them on the basis of legitimate interest and do not ask for your consent to record such cookies.
If we have obtained your consent, in the future when using the same cookie for the same purpose, we will not ask for consent again. This also applies to third-party cookies.
More detailed information about cookies used on Facebook and Instagram social networks is provided here https://www.facebook.com/policies/cookies/
If you do not agree that cookies should be recorded on your computer or other end device, in cases where we ask for your consent to record cookies, you can change your internet browser settings and turn off all cookies or turn on/off them one by one. However, please note that in some cases this may slow down your internet browsing speed, limit the functioning of certain Website features or block access to the Website. More detailed information is provided at AllAboutCookies.org or www.google.com/privacy_ads.html.
STATISTICS
Website visitor statistics are analyzed using Google Analytics. Information collected by Google Analytics cookies about your Website browsing history may be transferred and stored on servers located outside the European Union.
OTHER PROVISIONS
By contacting us, you express your will for MB ELTUVA to contact you regarding your inquiry.
Lithuanian Republic law applies to the implementation and interpretation of the Privacy Policy provisions. MB ELTUVA may, at its discretion, change this Privacy Policy, which comes into force from its publication on the Website www.mariosirjura.lt.
This Privacy Policy was updated on 2024-07-03.