Privacy policy

This privacy policy (hereinafter — the “Privacy Policy” or the “Policy”) explains how MB SEOMASTER (hereinafter — the “Company”, “we” or “us”) collects and uses information when you use any services offered on our website www.seomasters.lt (hereinafter — the “Website”) or any other services provided by us (hereinafter — the “Services”).

MB SEOMASTER is committed to processing your personal data responsibly and securely in its activities. Guided by this fundamental principle, we will always seek to ensure an adequate level of protection of your data and the protection of your rights. We process Personal Data in accordance with this Privacy Policy and applicable laws, including the General Data Protection Regulation (2016/679) (hereinafter — the “GDPR”) and applicable Lithuanian national data protection laws.

In this Policy, a reference to “Your Personal Data” means any information from which your identity can be determined (hereinafter — “Personal Data”).

We are the controller of Personal Data falling within the scope of this Policy.

We use your personal data in carrying out our activities and providing services to you. Our goal is to process only those personal data that you voluntarily provided to us after receiving comprehensive information about the purposes of data processing, and those data that are necessary for the performance of contracts with you, the implementation of legal requirements and the conduct of our business.

Please review this privacy policy to learn how we collect, use, transfer and store your personal data.

1. Collection and use of personal data

1.1 What information we collect

We process your personal data if you voluntarily provide it to us — for example, in the body of your e-mail to us, when ordering our services, filling out a form on the website or contacting us by phone/SMS. In certain cases we already process personal data you have previously provided — for example, if you are an existing or former client. We will process the personal data you provide in accordance with this Policy and applicable laws. Your personal data will not be used for purposes other than those defined at the time of collection, unless we obtain your additional consent or such use is provided for by law.

1.2 Legal basis for processing your personal data

Generally, we collect your personal data only to the extent necessary to provide services to you. EU law obliges us to inform persons whose data we process about the legal basis of processing. When processing your personal data, we rely on one of the following legal grounds:

Performance of a contract. Applies when processing your data is necessary to perform our obligations to you under a contract — for example, to issue you a loyal customer card or to make/receive payment for services.

Legal requirement. Applies when we are required by laws or other regulations to process your personal data — for example, for tax accounting purposes, or to provide data to public authorities or the police.

Consent. In certain cases we will process your personal data only if we have first obtained your consent. You can withdraw your consent to processing at any time by contacting us at info@seomasters.lt.

Legitimate interests. We will process your personal data in cases where we have a legitimate interest and such processing does not infringe on your interests or the protection of your rights.

Examples of the above legitimate interest include:

• Providing visitors of our website with information about the Company’s services or job offers;
• Trying to prevent fraud and crime, protect our property and the IT systems we use;
• Organizing and monitoring the advertising solutions we use;
• Seeking to ensure the performance of the Company’s corporate and public commitments;
• Ensuring the implementation of rights set out in Articles 16 and 17 of the Charter of Fundamental Rights of the European Union, including the freedom to conduct a business and the right to property.

In certain cases the personal data we process may also include special categories of personal data, i.e. personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, health data or data concerning a natural person’s sex life or sexual orientation. We process such data only with your consent or where such processing is provided for by law.

1.3 Automatic collection of personal data

In certain cases we or our service providers use cookies, web beacons and other smart technologies to automatically collect certain information about you when you visit our website or write to us by e-mail. Collecting this information helps adapt our website to your needs, increase the awareness, efficiency and usefulness of our information distribution and organize and track the effectiveness of the advertising solutions we use.

1.3.1 IP addresses

An IP address is a number assigned to your computer when you connect to the internet. It allows computers and servers to recognize each other and share data. When you visit our website, your IP address is recorded and used for system diagnostic and security purposes. The IP address is also used in compiling indicators that determine the traffic and usefulness of the website.

1.3.2 Cookies

Cookies will generally be stored on your computer or other device used to connect to the internet each time you connect to our website. This allows us to distinguish your device from others.

In certain cases, when visiting the website you will be presented with an information notice asking you to consent to the use of cookies. If you do not give consent, your computer or other device will not be specifically tracked for direct marketing purposes. Cookies necessary for the operation of the website (user-input cookies) will still be used to ensure the proper functioning of our website. Your choice regarding the use of cookies is saved in a separate cookie with a 90-day validity period. If you wish to withdraw consent, you can do so by clearing your browser’s cookies.

Most internet browsers automatically accept and allow cookies to be stored, but you can change your browser settings and block the use of cookies. These settings are usually stored in the browser menu under Tools or Preferences. You can also delete all cookies or specific cookies selectively at any time. If you decide not to accept cookies at all, the full functionality of our website may be unavailable to you. More information on how to manage cookie options in popular browsers can be found here: Internet Explorer, Chrome, Firefox, Safari, Opera.

In order to extend the functionality of our website, we sometimes use third-party tools and widgets. Usually, to ensure the operation of additional functionalities, these tools and widgets will save a cookie on your computer or device.

Cookies in themselves do not tell us your e-mail address or otherwise allow your identity to be identified. When evaluating website activity we use different identifiers, including IP addresses, but only to determine the number of unique website visitors and the geographic distribution of users, not to single out specific users.

BY BROWSING OUR WEBSITE YOU AGREE THAT COOKIES NECESSARY FOR THE OPERATION OF THE PAGE BE STORED ON YOUR COMPUTER OR OTHER DEVICE.

1.3.3 Web beacons

A web beacon is a small image file on a website that may be used to collect information about a visitor’s computer, including the IP address, time of visit, browser type and previously stored cookies from the same server. When using web beacons we strictly follow the requirements of legal acts.

We or our service providers will use web beacons to ensure the proper management of cookies and to determine the usefulness of services provided by third parties to us — for example, visitors attracted by information distribution, advertising or recruitment services.

You can limit the functionality of web beacons by disallowing the storage of cookies needed for their operation. In that case, the web beacon may still record an anonymous visit from a specific IP address, but cookie information will not be stored.

In some of our newsletters or other communications we monitor recipient actions, e.g. opening of an e-mail, using web beacons. We use the collected information to determine user interest and to increase user satisfaction in the future.

1.3.4 Location tools

When you use our services, we may collect information about the location of use of your computer or other device. We use this information to better adapt the services we provide to you.

1.4 Social media tools and applications

Our websites may have functionality allowing you to share information using third-party-operated social platforms, such as Facebook “like” and “share” functions. These social platforms may store data about your use of our website. The personal data you submit when using such social platforms can often also be transferred to other participants of the social platform. Such data transfer is regulated by the privacy policy of the social platform operator. We do not control how this personal data of yours is processed and therefore cannot accept any responsibility.

1.5 Children’s personal data

We understand how important it is to properly protect the privacy of children’s personal data. Our website and the services we provide are not adapted for children under the age of 16. We will never intentionally collect or store information about children under 16 unless this information is needed for providing our services to you.

2. Transfer of personal data to third parties

We do not share your personal data with third parties unless it is necessary to ensure the provision of services to you, fulfill your requests, our legitimate interests and business needs, or it is required by specific laws. You can see more information about the use of third parties by clicking this link.

We do not transfer your personal data to any third parties that could use this data for direct marketing purposes.

2.1. In the e-shop, payments are processed via the makecommerce.lt platform

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

3. Your choices

Generally, when you use our services we will not require you to provide personal data unless it is necessary for the provision of services — for example, for entering into a contract or maintaining contact with you. Upon receiving your request for information about the services we provide to you, we may ask you to provide additional personal data. In certain cases we may ask for your additional consent to process personal data, and you have the right to refuse to give consent for processing for these purposes. If you give consent to receive certain services or informational notices, we will give you the opportunity to withdraw this consent at any time. In the event of consent withdrawal, we will endeavour to discontinue the use of your personal data for the purposes specified in the consent as soon as possible.

As stated above in the “Cookies” section, if you wish to disallow tracking through cookies on our website, you can remove cookies from your browser and disallow further storage of such cookies. In that case, certain functionalities of our website may not work properly.

4. Your rights

If we process your personal data, you can exercise the following rights:

Access and rectification. You have the right to access the personal data we process about you. To access your personal data we process, you can submit a request to us. If, after evaluating your request, we decide that we are obliged to grant you such a right, we will provide the information free of charge. To ensure the protection of the rights of other persons and to respond to your request appropriately, before providing a response we may ask you to provide identity-verifying information and other information about your relationship with us. If your data we process is inaccurate, you have the right to request that this data be corrected.

Right to object to processing. You have the right to object to our processing of your personal data if we can no longer use them.

Other rights. If you believe that we should not process your personal data or are storing them too long, you have the right to request that your personal data be deleted or that their use be restricted. In certain cases you also have the right to request a copy of electronically stored information.

To exercise your rights you can contact us by e-mail at info@seomasters.lt. Upon receiving your request, in accordance with applicable laws and professional practice, we will make every reasonable effort to help implement your rights.

5. Data security and integrity

When processing your personal data we use organizational and technical data protection measures and procedures intended to protect your personal data from unauthorized loss, misuse, alteration or destruction. Despite all our efforts, it is not possible to take into account every possible threat or guarantee absolute security of personal data. To ensure maximum protection of personal data when processing your personal data, access to data is restricted to our employees on a “need to know” basis. Persons handling data are obliged to comply with strict personal data processing requirements.

We make every reasonable effort to ensure that your personal data is processed only:

• while this information is necessary for providing services to you or providing you with information;
• while we are required to retain this information in accordance with laws or business necessity, or
• until you ask us to destroy your personal data. The specific data retention period depends on the circumstances under which the information was collected and the purposes of its use, but, taking into account the requirements set out in I)–III) above, personal data will not be stored for longer than 2 years.

6. Links to other websites

Please be aware that our website contains links to other websites, including third-party-operated websites, to which this Privacy Policy does not apply and on which the privacy provisions may differ substantially. We encourage you to review the privacy policy of every such website before submitting any information that identifies you.

7. Changes to this policy

We may review and update this Privacy Policy taking into account our personal data protection measures. Each time the Privacy Policy is updated, we will update the “Last updated” field at the top of the Policy. You will be informed of changes to the Privacy Policy applicable to you through our usual means of communication between you and us.

8. Enforcement of the privacy policy

We are committed to ensuring the protection of your personal data. If you have questions or comments about the processing of your personal data, please contact us by e-mail at info@seomasters.lt. You can also submit any comments on this Privacy Policy at this address.

Upon receiving your request, we will confirm receipt within 14 days and will endeavour to provide a response within one month from the receipt of the request. If your request is complex or we have received a particularly large number of requests at the time, we may, after notifying you additionally, extend the response deadline up to three months from the receipt of the request.

Finally, you always have the right to submit a complaint about improper processing of your data to the State Data Protection Inspectorate.

Annex — Transfer of data to third parties

We do not share your personal data with third parties unless necessary for the provision of services to you, the execution of your requests, our reasonable business needs and/or where provided for by law. This includes:

Our service providers: We share your personal data with third parties that provide services to us — for example, our IT maintenance service providers, our website hosting providers, our accounting service providers, consultants, lawyers and other goods and service providers. We work with these third parties and pass them your personal data to process. We pass your personal data to such third parties only if they meet the strict personal data processing and security requirements we apply. We share your personal data only to the extent necessary to provide the services of these third parties.

If we or part of our business were to be sold, reorganized or transferred to another company: we would transfer the personal data related to the sale or reorganization to the extent directly related to the operation of the business being sold or transferred.

Pre-trial investigation institutions, courts or other state-authorized institutions: we will transfer personal data requested by courts, pre-trial investigation institutions or other authorized institutions where this is necessary to fulfill our legal obligations or where there is another data transfer ground provided for by law.

Audit: we will transfer personal data if it is needed to perform a financial, data privacy and security audit or to investigate and properly respond to a complaint or security threat.