COOKIE POLICY

Annex to the General Data Processing Rules

1. GENERAL PROVISIONS

• A cookie is a small text file that a website stores on your computer or mobile device when you visit it. It allows a website to "remember" actions and preferences for a certain period of time.

• Cookies are used on the website to ensure the availability of the website's features, to improve them or to provide users with a better browsing experience and for other purposes. In addition to these technical, functional and session cookies, analytical cookies are set by third parties in order to monitor the user's experience on the website.

• Our website does not use web beacons or similar tracking technologies.

2. PURPOSES OF USING COOKIES

• Cookies are used when you visit the website to:

  • to make the website convenient, efficient, functional and responsive;

  • to ensure the smooth administration of the website;

  • provide relevant information;

  • enable us to carry out statistical and other analyses for:

    • marketing of the website;

    • the use of the website;

    • improving the content (information, services, etc.) of the website;

    • the development of the services provided on the website;

    • the use and development of other cookies used on the website;

    • improvement of the services we provide on the website;

  • Information relating to cookies is not used for identification purposes, and your fully personalised browsing data, which cannot be linked to you personally, may be passed on to our partners who provide advertising/marketing services.

3. TYPES OF PAGES

•  First party (our website) cookies:

First-party cookies are set by the website you are visiting and can only be read by that website, in this case, our website.

• Third party cookies:

Third party cookies are set and used by websites other than our website.

The presence, number and status of cookies may depend on your use of other websites before or during your visit to our website. You should check the social networking cookie policies of other websites you have visited.

Where we allow third-party cookies to be set on our website, these cookies are included in the cookies used on our website and are specifically identified in the section of this policy entitled "Cookies used on our website and their description".

4. COOKIES USED ON OUR WEBSITE AND THEIR DESCRIPTIONS

• Technical cookies:-

• Functional and session cookies:PHPSESSID: a cookie used to maintain a user's session.
  Validity period: until the website window is closed.

   cookie_notice_accepted – Indicates the user's acceptance of the privacy policy. Validity period - 2 months.

• Analytical cookies:

Google:

• _ga: This cookie collects information about user behaviour on the website and is used to store statistical information.
  Validity period: 2 years.

• _gat: Cookie used to distinguish the user.
  Validity period – 1 minute.

• _gid: - _cookie used to suppress the frequency of requests.
  Validity period: 24 hours.

• IDE – Used to improve advertising by identifying user interests. Validity period - 1 year and 7 months.

• CONSENT – Used to collect information on whether the user has agreed to the terms and conditions, valid for 20 years.

• NID – Stores information about a visitor's preferences. Validity period - 6 months.

5. AGREEMENT

• Unless you have selected the setting in your web browser not to accept all or certain types of cookies, cookies will be created on our website as soon as you visit our website and consent to the recording of cookies in the notification box (bar).

• In the absence of your consent, no cookies will be placed on our website, with the exception of cookies which are intended for the processing of technical storage or use data, where the sole purpose of such processing is the transmission of information over an electronic communications network, as well as, where necessary, the provision of information society services commissioned by the user of the electronic communications services (see Article 61(4) of the Law on Electronic Communications of the Republic of Lithuania).

• Information provided to the user when accessing a website where the user has not consented to the use of cookies:

This website uses cookies. If you agree to accept the use of all cookies, you will be able to use the website optimally. You can withdraw your consent at any time by changing your browser settings and/or deleting cookies. For more information on cookies and how to refuse them, please see the "Cookie Policy".

"Agree"; "Disagree", "Cookie Policy"

6. NON-CONSENT/MODIFICATION AND/OR WITHDRAWAL OF CONSENT

• You can control and/or delete cookies.

• Most internet browsers allow you to control cookies through their settings options. If you do not wish to accept cookies, you can select the setting in your browser to not accept all cookies or to send a warning when a cookie is created.

• For more information on how to manage the cookie options in web browsers, please consult the website of your web browser provider. For general information, please visit org.

• You can delete any cookies that are already on your computer, and you can set most browsers to prevent cookies from being stored on your device. In this case, you may need to manually change some options each time you visit the website and some services and features may not work.

• You may also withdraw your consent to the use of cookies at any time by submitting a request to us by emailing us at the email address set out in the Website Manager Details and Contact Us section of this Policy.

7. RIGHTS OF THE DATA SUBJECT AND HOW TO EXERCISE THEM

•  The rights of Data Subjects are listed in our General Rules for the Processing of Personal Data (Chapter 5), to which this Policy is an annex, and their implementation is discussed in our Procedure for the Implementation of the Rights of the Data Subject. These documents are publicly available on our website en.

8. CHANGES TO THE COOKIE POLICY

• This Policy may be amended by our unilateral decision.

• In the event that we change this policy, you will be notified when you visit our website by being asked to give your new consent to the use of cookies and provided with information relating to this.

9. DETAILS AND CONTACT DETAILS OF THE WEBSITE MANAGER

UAB "TCG TELECOM", legal entity code 304120498, registered office at Perkūnkiemio g. 7, LT-12131, Vilnius, Lithuania, e-mail: info@tcg.lt

POLICY ON THE PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES

(Annex to the General Data Processing Rules)

1. ABBREVIATIONS AND TERMS

• Abbreviations:

  • Company – UAB "TCG TELECOM", legal entity code 304120498, registered office at Perkūnkiemio g. 7, LT-12131, Vilnius, Lithuania.

  • Policy – this policy on the processing of personal data for direct marketing purposes.

  • Rules – the Company's general rules for the processing of personal data.

  • Description – the description of the Company's standard procedures for processing personal data.

  • GDPR – 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).

  • ADPA – means the Law on Legal Protection of Personal Data of the Republic of Lithuania.

  • EHR – Law on Electronic Communications of the Republic of Lithuania.

  • Employees of the Comoany – persons employed by the Company, with whom employment contracts have been concluded, as well as persons equivalent to them, acting on behalf and in the interests of the Company.

  • Company's website – www.tcg.lt.

• Definitions:

  • Direct marketing - activities designed to offer goods or services to persons by mail, telephone or other direct means and/or to seek their opinion on the goods or services offered; for the purposes of this Policy, this term also includes activities where persons who, on their own initiative or on behalf of another person, are interested in the Company's goods or services and/or express their opinion on the Company's goods or services; greeting cards, e-mails with content relating to the performance of contracts, debt reminders, etc. are not considered direct marketing offers, where the processing of personal data is based on at least one of the other criteria for lawful processing of personal data.

• Other terms are consistent with those used in the GDPR and the Rules.

2. SCOPE

• This Policy sets out the purposes and scope of the processing of personal data, the retention period and other related matters.

• This Policy applies only to the personal data and data subjects referred to herein.

• This Policy applies throughout the Company

3. PURPOSES OF PROCESSING PERSONAL DATA

• Purposes of processing personal data:

  • Direct marketing.

4. PERSONAL DATA

• The following personal data about data subjects are processed for the purposes set out in this policy:

  • Name

  • surname;

  • the person represented;

  • telephone number;

  • mobile phone number;

  • e-mail address;

  • information provided by the data subject;

  • the time and manner of communication with the Company and other relevant data, including data recorded by electronic means of communication (IP address, time, date and other information).

• Data subject group: persons who, on their own behalf or on behalf of another person, are interested in the goods or services offered by the Company and/or express an opinion on the goods or services offered by the Company, as well as persons to whom the Company offers its goods or services directly and/or asks for their opinion on the goods or services offered.

5. DATA COLLECTION, PROCESSING AND STORAGE

• In the course of its business, the Company shall receive, correct or otherwise process personal data provided or corrected by data subjects for direct marketing purposes, in order to inform data subjects about the goods and services provided by the Company and to provide related verbal and/or written information.

• The data is collected directly from data subjects who provide the Company with their consent to the processing of personal data.

• Data subject consent in cyberspace:

  • may be active, where it is expressed by ticking a special information box or by other active means, using the enquiry form on the Company's website, which implies an acknowledgement to receive direct marketing communications. A link to this Policy shall be provided at the relevant information time;

  • implicit, where a person, on his/her own initiative, directly contacts the Company through public or non-public means of communication published by the Company for the purpose of obtaining information about the Company's goods and services. In such cases, the data subject's request is of a one-off nature and the data subject may only be provided with the information requested by him or her or with other information directly related to the information requested. The Company shall provide the data subject with information about the processing of personal data (if the personal data will be collected and stored by the Company) and the applicable Policy and information that the Policy is published on the Company's website, as well as informing the data subject of his/her right to object to the processing of his/her personal data, and, if he/she consents, of his/her right to withdraw consent.

• The data subject's consent may be formalised by a written consent given in direct contact with the Company, which may be an integral part of another document (for example, a contract) or a separate document (consent). In this case, the data subject's written consent must be personal and signed by the data subject. The consent must contain a reference to this Policy and information that it is published on the Company's website.

• The data subject's consent may be implied when the data subject, on his/her own initiative, comes to the Company to inquire about the Company's goods and services. In such cases, the data subject's request shall be of a one-off nature and the data subject may only be provided with the information requested by him/her or with other information directly related to the information requested. The Company shall provide the data subject with information about the processing of personal data (if the personal data will be collected and stored by the Company) and the applicable Policy and information that the Policy is published on the Company's website, as well as informing the data subject of his/her right to object to the processing of his/her personal data, and, if he/she consents, of his/her right to withdraw consent.

• A direct marketing communication may only be sent to a natural person with the prior consent of the natural person, and to a legal person with the consent of the head of the legal person or his/her authorised representative.Tiesioginė rinkodara iš savo klientų gautais jų pačių kontaktais gali būti vykdoma tik panašių prekių ar paslaugų rinkodarai.

• Direct marketing by means of their own contacts obtained from their own customers may only be carried out for the marketing of similar goods or services.

• The data subject contacting the Company shall be responsible for the correctness of the personal data provided, and in the event of providing incorrect data, shall bear all the negative consequences thereof, including legal liability.

• Information on the data subject's right to object to the processing of his/her data must be included in the written consent (provided at the time of data collection).

• Period of retention of personal data:

  • Unless otherwise specified in the consent, personal data shall be processed for a period of 3 (three) months from the date on which the consent to the processing of the personal data was given;

  • Where a time limit is specified in the consent, the personal data shall be processed for the period specified in the consent.

• The processing of personal data shall be carried out by automated means.

6. FORM OF AGREEMENT

   • The consent is published on the Company's website in the form of an enquiry form:

     I agree to receive offers from TCG Telecom UAB at the telephone number and/or e-mail address I have provided. This consent is valid for 3 months, but can be withdrawn at any time by notifying us at info@tcg.lt. For more detailed information on the processing of your personal data, please refer to the Policy on the Processing of Personal Data for Direct Marketing Purposes, available at www.tcg.lt.

• The Company's documents use a written consent form (subject to modification):

  The SUBSCRIBER consents/does not consent to the processing of his/her data for 10 years for direct marketing purposes (including sending informative messages, informing the SUBSCRIBER about goods/services, asking his/her opinion on goods/services, and for this purpose using personal data, including e-mail address, telephone number or other direct means), as well as for inclusion in the list of subscribers of TCG TELECOM, which is available to the public. The SUBSCRIBER confirms that he/she has been informed of his/her right to object to the processing of his/her personal data for direct marketing purposes. The SUBSCRIBER has the right to withdraw his/her consent, in whole or in part, by notifying TCG TELECOM in writing by email to info@tcg.lt. More detailed information on the processing of your personal data is contained in the Policy on the Processing of Personal Data for Direct Marketing Purposes, available at www.tcg.lt.

7. CONFIDENTIALITY OF PERSONAL DATA

• Personal data shall not be made public, disseminated or disclosed to third parties, except as provided for in this Policy and by law.

• The processing of personal data referred to in this Policy shall be subject to the organisational and technical measures for the security of personal data established by the Company.

8. PERSONAL DATA PROCESSORS (SUBCONTRACTORS)

• The Company may use personal data processors (subcontractors) to process the personal data referred to in this Policy.

• The Company shall only provide personal data in strict compliance with the requirements for the protection of personal data, only in justified cases and only to recipients who undertake to adequately protect them. When the Company engages data processors, it shall take all necessary measures to ensure that they have implemented appropriate organisational and technical security measures and maintain the confidentiality of personal data.

• Foreseen processors/sub-processors:

  • To members of the Company's group of companies (companies, firms) - only to the extent permitted under the legislation on the protection of personal data and/or only to the extent necessary to achieve the purposes of the processing of personal data.

  • For data processors (subcontractors) - entities that provide services to the Company (perform work) and process personal data on behalf of the Company as the data controller. Processors have the right to process personal data only on the instructions of the Company and only to the extent necessary for the proper performance of the obligations set out in the contract concluded with the Company. The data processors used by the Company are active in the following main areas related to direct marketing: contractors performing installation and maintenance of electronic communications infrastructure; information technology service providers providing development, maintenance and other services for the Company's information systems; providers of communication, advertising and marketing services; partners distributing the Company's goods and services, etc.

9. DATA SUBJECT'S RIGHTS AND THE PROCEDURE FOR EXERCISING THEM

• The rights of Data Subjects are listed in our General Rules for the Processing of Personal Data (Chapter 5), to which this Policy is an annex, and their implementation is discussed in our Procedure for the Implementation of the Rights of the Data Subject. These documents are publicly available on our website tcg.lt.

• The Data Subject has the right to object to the processing of his/her personal data without providing reasons for the objection. The Company is obliged to immediately and free of charge terminate the processing of personal data, except in the cases provided for by law.

• The data subject may express his/her opposition to the processing of his/her personal data directly to the Company (in the case of e-mails, by clicking on the link contained in each e-mail sent).

10. CHANGES TO THE POLICY

    • This Policy may be amended by unilateral decision of the Company. In the event that this Policy is amended, it will only apply to the data subject if a new consent is obtained from the data subject. Otherwise, the personal data will be processed in accordance with the version of the Policy for which consent was given.