1. What Does This Privacy Policy Mean?
This privacy policy (hereinafter the Privacy Policy) provides information on the processing by VšĮ „Northtown Vilnius“, code 125967014, registered address Vismaliukų st. 34, Vilnius, Republic of Lithuania (hereinafter the Institution), contact email for personal data protection info@northtownvilnius.lt, of your personal data that are obtained in: concluding and executing contracts concluded with the Agency; executing public procurement; performing direct marketing activities by the Institution; participating in the events of the Institution; participating in the selection of the Institution’s staff; making an inquiry to us; When you are active in the Institution’s social media accounts; ensuring the safety of employees and other persons and the protection of property (video surveillance); when you visit the websites www.northtownvilnius.lt and vciip.com (hereinafter – the Websites).
Hereinafter all indicated persons whose data are processed by the Institution shall be referred to as Persons or you.
2. What Personal Data we do process?
Personal data are any information about you collected by the Institution that may be used for your identification and is stored electronically or in any other manner.
Personal data include any information, including your name, surname, address and IP address, which is collected by the Institution about you for the purposes indicated in this Privacy Policy or for the purposes indicated in the consent provided by you or in the agreement concluded with the Institution.
The data shall also include your publicly available personal information accessed by the Institution when you contact the Institution via any social media networks or perform active actions in social media accounts of the Institution.
3. Personal Data Processed When the Customer Purchases Goods on Website
The Institution processes your personal data, which you or your employer or the person you represent provide when applying to the Institution for the opportunity to establish in the Vilnius City Innovation Industrial Park, for participation in projects and initiatives promoting entrepreneurship, for assistance in creating and commercializing research results and for providing consultations.
As the Institution concludes such contracts only with legal entities, we process your personal data on the basis of our legitimate interest (to ensure the proper conclusion and execution of contracts).
The institution may process the following personal data of you for the above purpose: name, surname, basis of representation, position, signature, e-mail, postal address, telephone number, content of the communication, date, data provided in the contract application, data related to the performance of the contract, any other personal data you submit on your own initiative or we receive them in the performance of a contract. This data is necessary, without it we will not be able to conclude and execute contracts.
We will process the data for the above purpose during the term of the contract.
If the law imposes such an obligation on us, we may also collect information about your criminal record (in order to check the investor’s compliance). In this case, the basis for data processing is a legal obligation and Article 10 of the General Data Protection Regulation (hereinafter – GDPR). We will keep the criminal record for the duration of the contract or for the period specified in the relevant legal act.
We also have a legitimate interest in the processing of your personal data after the end of the contract in order to protect our rights and interests. Such data is enshrined in the contract itself (name, surname, contacts, signature) or related to the performance of the contract (correspondence, other communication data). For this purpose, the data is stored for 10 years from the date of execution (termination) of the contract.
4. Personal data processed for the purpose of concluding and executing contracts with the Institution (the Institution purchases goods or services)
The Institution processes personal data of employees of suppliers or service providers (legal persons) and data of suppliers or service providers (natural persons) in order to perform the agreement concluded between the Institution and the aforementioned persons. In such case, the Institution will process the following personal data belonging to you: name, surname, date of birth, phone, e-mail address, communication content, date, number of individual activity, personal code, data related to payments, and other data related to the performance of the agreement.
The basis for the processing of data of employees of service providers or suppliers of the Institution is the legitimate interest of the Institution (prepare and properly execute the contract).
If you provide services or sell goods as a natural person, the Institution will process your personal data on the basis of performance of the agreement. The data is necessary for the execution of the contract.
The personal data referred to in this paragraph shall be processed for the duration of the contract.
We also have a legitimate interest in the processing of your personal data after the end of the contract in order to protect our rights and interests. Such data is included in the contract itself (name, surname, contacts, identification data, signature) or related to the performance of the contract (correspondence, data related to payments, other communication data). For this purpose, the data is stored for 10 years from the date of performance (termination) of the contract.
5. Execution of public procurement
The Institution publishes and executes public procurements during which the following personal data is processed: name, surname, position, personal identification code, date of birth, signature, address, telephone number, e-mail address, qualification, education, work experience, information provided in CVs, copies of certificates, median monthly salary, other information provided in the supplier ‘s offer. This data is processed on the basis of a legal obligation and is necessary to achieve the above purpose. If it is not processed, the Institution would not be able to carry out public procurement procedures.
Planning and preparation documents, procurement documents, tenders, tenders and their examination and evaluation documents, commission decision-making, negotiation, dialogue or other minutes, correspondence with suppliers, other documents related to the procurement shall be kept for 4 years from the end of the procurement, preliminary contracts, procurement contracts, their amendments and documents related to their execution – 4 years from the performance of the procurement contract.
6. Direct Marketing
We will send offers for the sale of goods and provision of services of the Institution, newsletters and other advertising material to persons, who have provided their contact details and have expressed a wish to receive information about the services offered by the Institution via electronic communication means (e-mail), also ask for their opinion on provided services. The Institution will process the following personal data for direct marketing purposes: name, surname, e-mail address (data necessary in order to be able to send you direct marketing messages).
Your data will be used for direct marketing purposes for 3 (three) years as of the receipt of your consent.
The data contained in the consent will be stored for a further 2 years after its expiry in order to protect our rights and interests on the basis of our legitimate interest.
You have the right to refuse direct marketing at any time by contacting us via e-mail on info@northtownvilnius.lt.
7. Contact Us
There are several ways how you can contact the Institution: by phone, e-mail, via social media accounts. We personally accept, review and reply to all messages. If you contact us, we can process the following data belonging to you: name, surname, e-mail address, phone number, date, your nickname used in social media networks, and text of messages.
Such data will be processed in order to answer to your questions on the basis of your consent. If you do not provide your contact details, we will not be able to contact you.
Electronic messages will be stored for 1 (one) year as of the receipt of the message except for information that must be stored for other terms pursuant to the Privacy Policy or legal acts.
Please note that we may have to contact you by post, e-mail or phone. Please notify us of any changes of your personal data.
8. Social Media
Currently, we have the following accounts:
– „Facebook“, which privicy notice is available at https://www.facebook.com/privacy/explanation;
– „Twitter“, which privicy notice is available at
https://twitter.com/en/privacy;
– „LinkedIn“, which privicy notice is available at https://www.linkedin.com/legal/privacy-policy.
The information you provide to us on social media (including messages, the use of the Like and Follow fields, and other communications) is controlled by the social network manager. We recommend reading the privacy statements of third parties and contact service providers directly if you have any questions about the ways they use your personal data.
9. Participation in the Events of the Institution
If you grant your consent, the fact of your participation, name, surname, photo, video recordings will be used to notify the public about the Institution events, increase the visibility of the Institution. We promise not to damage your reputation and dignity by using such photos. With your consent, your photos can be published in the Institution‘s social media accounts and on its website.
Mass media representatives can publish your photos only in compliance with the legal requirements applicable to them; however, the Institution will not be responsible for the actions of mass media representatives.
Photos will be published and stored for 5 years from the event or provision of consent (whichever happens later), except in cases permitted by laws.
10. Participation in the Selections
We collect and process your CVs and/or motivation letters, and/or other information submitted by you at the time of participation in the selection for the purpose of recruitment and on the basis of your consent which you give to us or to the recruitment company by sending your curriculum vitae.
If you do not submit your curriculum vitae and/or motivation letter, we will not be able to assess your suitability for the offered position.
In the event that you have not granted your separate consent to the processing of your personal data after the completion of this selection process, we undertake to erase and/or destroy your personal data within after 2 days as of the day of conclusion of employment contract with the selected candidate or as of the decision to terminate the recruitment procedure.
11. Ensuring security of Persons, protection of property (video surveillance)
In order to ensure the security of the persons entering the field of video surveillance, to ensure the protection of property, as well as to record and preserve evidence of incidents (property damage, thefts, wrongdoings, accidents of employee injuries, other accidents, etc.), to investigate such cases (video surveillance), the Institution process the video data of persons entering the field of video surveillance on the grounds of legitimate interest. The data will be stored for 1 (one) week.
12. Cookies
A cookie is a small text file in alphanumeric format that we place with your consent on your browser or hard disk. We use different cookies for different purposes. Cookies also help us to differentiate you from other users of the Websites, thus providing a more pleasant experience of using the Websites and allowing us to improve the Websites.
Most browsers allow you to reject all cookies, and some browsers allow you to reject only third-party cookies. So you can take advantage of these opportunities. However, please note that blocking all cookies will have a negative effect on the use of the Websites, and without cookies you will not be able to use all the services provided on the Websites. More information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.
We may use the cookies described below, for a detailed list of which you will find HERE.
(a) Cookies are absolutely necessary.
These cookies are necessary for our websites to work. The basis of the data processed by such cookies is our legitimate interest to ensure the quality and safety of your visit.
(b) Analytical and / or performance cookies.
These cookies allow us to identify and count visitors to our website and to track how visitors navigate our website. This helps us improve the performance of the site, such as ensuring that users can easily find what they are looking for. The basis for the processing of the data collected by these cookies is your consent.
(c) Functional cookies.
These cookies are used to identify you when you return to our websites so that we can tailor the content provided to your needs, remember the information relevant to you. The basis for the processing of the data collected by these cookies is your consent.
(d) Commercial cookies.
We use our own and third-party cookies to display personalized advertising on our own and other websites. This is called “remarketing,” which is based on browsing activity, such as the products you search for and view. Please read the privacy policies of the relevant third parties.
13. Disclosure of Data
We can disclose information about you to our service providers such as debt administration or recovery companies, persons or subcontractors providing marketing and IT services, if the same is reasonably required for the respective purposes, as indicated in this Privacy Policy.
Moreover, we can disclose information about you:
- if we must do this under the law;
- in order to protect our rights or interests (including the provision of your data to third parties in order to recover debts to us);
Your personal data will not be transferred to third countries and/or international organisations.
The list of recipients and categories of recipients provided in the Privacy Policy may change; therefore, if you wish to be notified of any changes to the recipients of your personal data, please inform us via e-mail provided in this Privacy Policy indicating in the e-mail as follows: “I wish to receive information on the changes to the recipients of my personal data, name, surname”.
14. Your Rights
This section contains information about your rights related to the processing of your personal data carried out by us and cases where you can exercise these rights. If you would like to receive more information on your rights or to exercise them, please contact us via e-mail indicated in this Privacy Policy.
The Institution will provide information on actions taken on a request with regard to implementation of your rights without undue delay and in any event within 1 (one) month of receipt of the request. In consideration of the request complexity and the number of received requests, the aforementioned term may be extended for 2 (two) further months. In this case, we will notify you of such term extension and reasons for it within 1 (one) month as of the receipt of request. The Institution will refuse to implement your rights only in cases provided for in the legal acts.
Right to consent withdrawal. If you have given us your explicit consent to the processing of your data, you can withdraw it at any time.
Right to access your personal data. you can contact us at any time and ask if we process any of your personal data. If we store or use your personal data in any way, you have the right to access them. If you wish to do this, please submit a written request to us at the address indicated in this Privacy Policy and confirm your identity. Please comply to the fairness and reasonableness principles when submitting such request.
Right to request more information. If you have any questions about the use of your personal data, we will be happy to answer them or will provide you with all additional information that we can disclose. If you have any specific questions or did not understand the provided information, please contact us.
Right to data rectification. you have the right to request us to rectify any inaccuracies of data held by us.
Right to be forgotten. You have the right to ask us to erase your personal data. This right will be implemented in cases provided in Article 17 of the General Data Protection Regulation (EU) 2016/679.
Right to data processing restriction. You have the right to ask us to restrict the processing of your personal data or to object to their processing:
- during the period required for us to verify the accuracy of your personal data when you submit claims with regard to data accuracy;
- in cases of unlawful collection, storage or use of your personal data where you decide not to request the erasure of data;
- when we do not need your personal data anymore, but you need them for the establishment, exercise or defence of legal claims;
- during the period required to determine if we have an overriding legal basis to continue processing your personal data if you exercise your right to object to the processing of your personal data.
Right to data portability. You have the right to the portability of data obtained by us under your consent or for the purpose of agreement conclusion. If you exercise this right, we will transfer a copy of the data provided by you.
Right to object. You have the right to object to use of your personal data by us:
- in cases where we use such data in order to implement our legitimate interests, but we do not have an overriding legal basis to continue using your personal data; or
- at any time when we use your personal data to send newsletters or for direct marketing purposes. In such case, the data will not be used for these purposes anymore; however, they may be used for other legitimate purposes.
15. Complaints
If you believe that your rights of the data subject have been and/or may be violated, please promptly contact us via e-mail indicated in this Privacy Policy. We ensure that as soon as we receive your complaint, we will contact you within the reasonable period and inform you about the complaint handling process, and then about its result.
If the handling results are unsatisfactory to you, you will be able to submit a claim to the supervisory authority – the State Data Protection Inspectorate (www.vdai.lrv.lt).
16. Amendments to the Privacy Policy
We may update or amend this Privacy Policy at any time. Such updated or amended Privacy Policy will come into effect as of its publication on our Websites. You should check it from time to time and make sure that you find the current version of Privacy Policy acceptable.
After making an update to the Privacy Policy, we will notify you about any changes that we consider material by publishing them on the Websites. ‘Updated on’ date indicated below shows the date of the latest update to the Privacy Policy.
The latest update to the Privacy Policy was made on [2021-12-15].