Privacy policy

Privacy policy of VMG group companies for the processing and protection of personal data of candidates, business partners and website visitors

Privacy Policy of the VMG group companies for the processing and protection personal data of candidates, business partners and visitors of website www.vmg.eu (hereinafter – Website) is designed to familiarize the candidates applying to various positions in VMG group companies, business partners (customers) and visitors of Website with processing and use of their data at the same time providing them with information about their rights concerning data protection (hereinafter – Privacy Policy).

The Data Controller is UAB “Vakaru medienos grupe” (hereinafter – VMG), company code 142044723, address: Liepu Str. 68, Klaipeda, Lithuania, phone (8-46) 469 555, e-mail: info@vmg.eu

VMG group companies may be joint controllers for some purposes with respect to the processing of personal data, while for other ones may be separate controllers. We will inform you in any other convenient way about which Company is the data controller for what purpose.

The personal data of candidates, partners and visitors are processed by the VMG group companies in accordance with 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 (hereinafter – Regulation) as well as according to the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts, establishing processing, protection, compliance and implementation of personal data.

I. Processing of candidates’ personal data

I. Processing of candidates’ personal data

From which resources do we collect your personal data and under what legal basis?

Most often your data is received directly from you – when you apply responding to the VMG group companies job advertisements and (or) submit your CV and (or) Cover Letter and other candidate’s documents. The legal basis for the processing is your provided consent.

Information about your candidacy, your CV and / or other candidacy documents can also be obtained from other subjects: the employment agencies, providers of selection and / or mediation services, for example, the Lithuanian Labor Exchange, specialized career social networks (such as LinkedIn) or other career portals. The VMG group companies may collect certain information from third parties, for example, from referees, i. e. persons who are recommending you, existing or former employers, educational institutions, however, such information will be collected by the VMG group companies only in case if you provide a separate consent to apply to your previous employer and / or another person.

For what purposes will your data be used

After you having submitted your data according to advertisement, or after having filled out the website form and / or having submitted the request (application) for a job by your own initiative we will be protecting and processing your personal data in order to evaluate your candidacy for a particular position, perform the selection procedures and offer you a certain job position. This is necessary for our legitimate interest to select the most relevant, qualified and individually suitable candidates for specific position.
Contact details: e-mail personalas@vmg.eu, phone: (8-46) 469 434. If you have any inquiries regarding data protection please do not hesitate to contact by e-mail: duomenu.apsauga@vmg.eu

Who has the right to view your information?

Your data may be reviewed by staff responsible for staff selection and employment as well as by the Heads of those departments which carry out selection of personnel, also by engaged consultancy services in the field of personnel management, or involved data processors.

Department of Information technology (IT), as well as IT services companies, can maintain access to your data to the extent necessary to ensure the proper operation of the software, by supervising and ensuring the operation of the site and the computer software.

How much long do we keep your information?

If, according to your questionnaire, you will not be offered a position or practice, your personal data will be stored and processed for future selection up to 2 (two) years period from the date of receiving of the data. We will do this in line with the legitimate interest in simplifying future selections. Please be advised that at any time you can object for the processing of your data for future selections. In this case, your data will no longer be processed. You have the right at any time to withdraw your consent regarding your processing of candidate data by email: personalas@vmg.eu

What rights do you have?

You have the right to familiarize with your processed personal data, to edit, add or update by contacting e-mail: duomenu.apsauga@vmg.eu. You may also contact us for limitation of processing of your personal data if you have a legal basis for it.

You have the right to object to the further processing of your personal data submitted for the purpose of personnel selection, including storing data for future selections or transferring data to other VMG group companies and request to remove your data by submitting an application to e-mail address: duomenu.apsauga@vmg.eu

Where to apply on violation of your rights?

If you think that your personal data is being processed improperly and your right to privacy is violated, you can contact us by e-mail: duomenu.apsauga@vmg.eu or submit a complaint to the State Data Protection Authority for inspection which contact details can be found at address https://vdai.lrv.lt/ VMG group companies ensure that your personal data will remain confidential and will not be used for any other purpose than selection process.

II. Processing of business partners’ (customers’) personal data

The purpose and legal basis of personal data processing

  • The lawfulness of the processing and transfer of the data of the partner’s representatives, employees, subcontractor’s employees or other natural persons engaged in the conclusion and performance of the Contract is based on the necessity to execute the contract of the partner and his / her representative, employee or other natural person engaged in the performance of the Contract, to which the representative, employee or other natural person is a party, or the necessity for the partner to exercise the rights arising from such a Contract (e.g., to request from the employee to perform his / her job functions, or to request from the representative to ensure an adequate representation). (Article 6 (1) (b) of the Regulation)
  • The lawfulness of processing of the data of partners’ representatives, employees or other natural persons transferred to the VMG group companies is based on the necessity to pursue legitimate interests (to ensure proper and effective performance of the Contract and exercise of rights arising from the Contract). (Article 6 (1) (f) of the Regulation)
  • The legal basis for the processing operations of the personal data of partners’ representatives, employees or other natural persons transferred to any individual company of VMG group is also the performance of applicable legal obligations (e.g. execution of tax accounting and declaring). (Article 6 (1) (c) of the Regulation)
  • Where necessary, the data may be processed for the purpose of implementation of the legitimate interests of the VMG group companies (to submit, defend and enforce any legal requirements arising from the Contract). (Article 6 (1) (f) of the Regulation).

Period of data storage

To the extent necessary to fulfil the obligations of the Parties under the Contract. Upon expiry of the Contract, the data shall be processed and stored during the limitation period of the claim, unless public law requires a longer period of storage.

Categories of personal data

VMG grupės įmonėse gali būti tvarkomi šie verslo partnerių pateikti asmens duomenys:

  • vardas, pavardė;
  • kontaktiniai duomenys (darbo tel. Nr., darbo el. paštas, darbovietės adresas);
  • užimamos pareigos;
  • įgaliojimų (atstovavimo) duomenys;
  • asmens kodas (jeigu partneris yra fizinis asmuo), juridinio asmens kodas, PVM mokėtojo kodas, individualios veiklos numeris;
  • duomenys apie sutarties dalyką, sudarymo aplinkybes ir kt.;
  • VMG grupės įmonių vardu ar interesais vykdomas susirašinėjimas ar kiti duomenys suformuojami Sutarties vykdymo metu (dokumentų pasirašymas, užsakymų tvirtinimas, ir pan.).

Categories of personal data

The following personal data provided by business partners may be processed by VMG group companies:

  • name and surname;
  • contact details (work phone number, work e-mail address, workplace address);
  • position held;
  • authorisation (representation)-related data;
  • personal ID number (if partner is a natural person), code of legal entity, VAT payer number, Individual Activity Certificate number;
  • data on the subject matter of the contract, the circumstances of the conclusion thereof, etc.;
  • Correspondence carried out on behalf or in the interests of VMG group companies or other data formed during performance of the Contract (signature of documents, confirmation of orders, etc.).

Recipients of data

The following subjets may receive the data processed by VMG group companies:

  • employees of the VMG group companies that are responsible for the conclusion, administration and execution of the Contract, as well as the cooperation and maintenance of relations with partners, and those who perform functions of documents management, accounting, information system maintenance, business indicators analysis and business planning;
  • providers and supervisors of the information systems and data storage systems used by VMG group companies for management of relations with partners;
  • auditors;
  • the State Tax Inspectorate and other bodies and institutions where such provision of data is required by legal acts;
  • banks;
  • data processors engaged by VMG group companies and other entities related to the performance of the Contract;
  • entities involved in the enforcement of rights arising out of provisions of the Contract (the entities providing recovery and legal services, consultants, courts, etc.);
  • other legal entities (service providers) that act as independent data controllers when providing services to VMG group companies.

A part of the data recipients carry out activities in Belarus. The security of the data transmitted to Belarus is ensured by concluding of the agreements with the data recipients according to standard terms and conditions approved by the European Commission.

III. Processing of website visitors’ data

We inform you that your personal data is collected and processed in the website www.vmg.eu in order to fulfil your requests and help us understand in what ways the website may be useful for our operations and how it should be improved in the future to satisfy our clients’ expectations.

What data do we collect and for what purpose it is used

Server records

The server that contains our website is able to record inquiries that you submit to the server (the address of the website you open, your IP address, the time of connection, your email address). These data are used to ensure the proper and safe functioning of the website. If necessary, the data may also be used to investigate possible security breaches. The basis for processing of this data is our lawful interest to ensure the technical accessibility and safety of this website.

Statistics of attendance of website

We collect various data of the users of the website with the aim of improving our website and developing our activities. It is important for us to know what kind of information is interesting for the users of the website, how often they visit it, what browsers and devices they use, what kind of content they read most often, and which regions they are from. For these purposes, we collect relevant demographical and statistical data. The basis for processing of this data is our lawful interest to understand the needs and wishes of our clients in order we would be able to develop and expand our activities properly.

We collect this data by using the Google Analytics tool that allows us to record and analyse the data referred to above.

If you want to learn more about use of Google Analytics tool and what kind of information this tool allows us to collect and analyse, you can find additional information here:
https://support.google.com/analytics/answer/1012034?hl=lten&ref_topic=6157800

At any time you can switch off the function that allows us to collect your data by Google Analytics. See here to find out how: https://tools.google.com/dlpage/gaoptout/.

Data from your registration, questions and comments

In some places of website there are provided possibilities for users to register as well as ask questions and post comments. In such case, we process the data you have presented in order provide our services better, answer your questions, and respond to the opinions you have expressed. The legal basis for processing of this data is the necessity to carry out certain actions on your request before concluding a Contract (a reservation); to conclude and execute a Contract which party you are becoming or to carry out certain actions on your request before concluding such Contract; as well as our lawful interest to ensure the proper quality of our services.

Cookies

What are cookies?

A cookie is a small data file that the website saves on the device you are using when you visit a website. Most websites use cookies. Cookies allow the website to remember your actions and selected settings (e.g. language, font size) for some time. This ensures a more convenient use of the website because you do not have to choose the right settings every time you visit the website or search its different pages.

What type of cookies do we use and why?

The cookies that are used in our website record your IP address and information about your browsing, such as the websites you have visited and the time you spend in each website. It allows the website to remember your system and settings and thus ensures proper and convenient functioning of the website.

Other cookies allow us to monitor website traffic and users’ actions in the website. These cookies are installed in order to carry out users’ behaviour analysis referred to above and enhance users’ experience in the website. These cookies are installed and used with the help of the Google Analytics tool.

Social media cookies also may be used in our website. These cookies allow us to acquire information about what you were doing on the website, social media, or to log on to certain social media sites, e.g. Facebook, Twitter, or LinkedIn. For more information about these cookies please read the privacy policy of the relevant third parties.
Cookies are only installed in your device with your consent, with the exception of the cookies that are necessary to ensure the technical functioning of the website. If you do not give your consent to the use of cookies, some of the website’s functions may be partially or fully restricted. For this reason, we recommend you to agree with the use of cookies.

The use of technically essential cookies is based on our lawful interest to ensure proper functioning of our website.

How can you manage cookies?

You can delete all the cookies on your device at any time. Moreover, most browsers allow you to choose settings that block cookies. You can learn more about possibilities to manage cookies here: http://www.youronlinechoices.com/.

However, if you delete cookies, some services and functions may no longer work, and you may have to choose the right settings every time you visit the website.

Marketing

We also use the collected statistical data on our users as well as information about visits, interests, and demographical trends for the purpose of carrying out targeted marketing / direct marketing.

On the ground of the results of performed analysis we can assess which products you might be interested in. According to the traits we have identified, we group people and provide relevant advertisements for groups of similar people. This process, which enables you to see advertisements tailored on the basis of your behaviour online, is carried out with the help of profiling. The basis for this is our lawful interest to ensure effective advertising and business expansion.

If you have purchased our products / services or have demonstrated clear interest in doing so in some other way, we may use your contacts (email address) acquired in this way for the purpose of sending you similar offers. The basis for this is our lawful interest in advertising and developing our activities. You may choose to unsubscribe from getting these email offers at any time by pressing the option “unsubscribe” in the offer you have received or by informing us via email info@vmg.eu.

Who has access to your data

Data collected in this website can be accessed by our IT department employees who are responsible for the analysis of this data and the improvement of the website, as well as employees who perform functions related to marketing and the operation of the website.

Access to this data or the data themselves may also be shared with our partner companies that provide tools for the management of the website’s content, website hosting services, and marketing services. Please note that these subjects can only access and process your data to the extent that is needed to provide the services we request.
Google Inc., which provides the Google Analytics tool, is under agreement to comply with the EU‑USA Privacy Shield Principles, which ensure that the service provider meets the requirements of the EU privacy standards. The provider is also under contractual obligation to ensure privacy. To learn more, please see here:
https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20160909.html.

Access to cookies is provided to „Google“, „Facebook“, „Twitter“, „LinkedIn“.

How long your data are stored

We use and store the data collected on the website for up to 2 years.

Cookies are normally active for a short time, i.e. during your browsing session, but in some cases may be active for up to 2 years unless you delete them sooner.

We process the data provided during your registration, or when posting questions and comments, until we respond to your inquiries or provide the service for which you have registered.

Your rights and how to exercise them

In terms of your data being processed you have the right to familiarize with your personal data that is being processed; request to correct your data; request for your data to be deleted; express your disagreement to your data being processed for the purpose of direct marketing; withdraw your consent to use the cookies by deleting them, by choosing settings in your browser that block cookies, or by visiting the following sites:

You have the right to request that the processing of your data would be restricted, or express your disagreement on processing your data because of our lawful interest. However, this request might not be fulfilled if the specific situation does not meet all proper requirements. In this case, we will provide you with detailed information about the reasons why your request has not been fulfilled.

You can exercise your rights by contacting us via email info@vmg.eu.

 

The right to issue a complaint

If you think that your data is not being processed properly or your right to privacy has been violated, you may issue a complaint to the State Data Protection Authority. You can find its contact information here: https://vdai.lrv.lt/

 

Contact information

The data subject with questions regarding the processing of personal data, the provisions of the Privacy Policy or in order to exercise his / her rights may contact:
The Data Protection Officer of VMG group companies by e-mail: duomenu.apsauga@vmg.eu, address: Klaipeda, Liepu str. 68, Lithuania, phone (8-46) 433 052.
VMG address: Liepu Str. 68, Klaipeda, Lithuania, phone (8-46) 469 555, e-mail: info@vmg.eu

Requests for the exercise of data subject rights may also be submitted to the VMG office at Liepu str. 68, Klaipeda.

Mandatory

Essential (technical) cookies are used to ensure the proper provision of website services, allowing users to browse and use the website’s functions, i.e., ensuring the functionality of the website.

Cookie Name Cookie Description Expiration Time Cookie Not Stored if Declined
EW4SITE Session ID cookie used to ensure page functionality (e.g., returning to the last list position) Until the end of the session Not applicable
SITEXSRF141 Until the end of the session Not applicable
privacy_2 Remembers the visitor’s functional category choice in cookie policy. Possible values 0. 1 14 days Not applicable
privacy_3 Remembers the visitor’s functional category choice in cookie policy. Possible values 0. 1 14 days Not applicable
privacy_4 Remembers the visitor’s functional category choice in cookie policy. Possible values 0. 1 14 days Not applicable
privacy_verify Remembers that the visitor reviewed/selected the cookie policy 0. 1 14 days Not applicable
TS0* Until the end of the session Not applicable

 

Functional

Functional or technical cookies are used to remember user choices and settings (e.g., language or time zone). With the help of these cookies, users can avoid changes in settings every time they visit the website.

Currently, functional cookies are not being used.

 

Statistical

Tracking cookies from “Google Analytics.” These cookies allow the recognition and counting of website visitors, as well as tracking how visitors navigate through the website. This helps improve the performance of the website, ensuring that users can easily find what they are looking for.

 

Cookie name Provider Purpose Expiration Time Type
_ga Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 2 year HTTP Cookie
_gat Google Used by Google Analytics to throttle request rate 1 day HTTP Cookie
_gid Google Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 1 day HTTP Cookie

 

Marketing

Marketing or advertising cookies are used to collect information about how users use the website, ensuring the presentation of offers (advertisements) that best match users’ needs.

Currently, advertising cookies are not being used.