PRIVACY POLICY
This Privacy Policy (hereinafter – the “Policy”) provides information on how Universal Management Systems, UAB (hereinafter in this Policy also referred to as “UVS” or “we”) processes the personal data of its clients (hereinafter in this Policy also referred to as Clients, Data Subjects, or You). In the context of this Policy, Universal Management Systems, UAB acts as the controller of personal data. This Policy applies to us and our Clients who use, have used, intend to use, or are otherwise connected with our products or services. When providing services to our Clients, we aim to ensure a high level of personal data privacy and protection. In the spirit of transparency, this Policy explains the rules and provisions we follow in processing and protecting Clients’ personal data. All personal data is processed in accordance with the EU General Data Protection Regulation (2016/679) and other EU or national laws supplementing personal data protection requirements.
Definitions used in the Policy
“Client” – any natural person who uses, has used, has expressed an intention to use, or is otherwise connected with the products (services, goods) provided by Universal Management Systems, UAB. This may also include suppliers in relation to UVS products/services (hereinafter may also be referred to as a Client – natural person). Employees or other authorized representatives of UVS clients who are legal entities may also be considered Clients (hereinafter may be referred to as a Client – employee of a legal entity or other authorized representative).
“Personal Data” – any information relating directly or indirectly to a Client that can be used to identify the Client.
“Processing of personal data” – any action performed with personal data: collection, recording, organization, storage, modification (addition or correction), access, provision, use, deletion, destruction, or any other action or set of actions.
Principles and legal bases for processing your personal data
We process your data in accordance with the following data processing principles:
- We process personal data lawfully, fairly, and transparently;
- We collect and process personal data only for specified, explicit, and legitimate purposes;
- We ensure that data is collected only to achieve the specified purposes;
- We take steps to ensure that personal data is accurate and, where necessary, updated or corrected;
- We store personal data no longer than necessary to achieve the purposes for which it was collected;
- We process personal data ensuring its confidentiality and security, including protection against unauthorized or unlawful processing and/or access. We also ensure protection against accidental disclosure, loss, destruction, or damage.
We process Clients’ personal data only when the processing is lawful, i.e., if it meets at least one of the following conditions:
- You have given consent to process your personal data for specific purposes (consent);
- Personal data is processed to conclude a contract or fulfill contractual obligations (contractual obligations);
- Processing is necessary to comply with a legal obligation (legal obligation);
- Processing is necessary to pursue our legitimate interests as a data controller and service provider, except when your interests override those interests (legitimate interest).
Purposes of processing your personal data
Maintaining client relationships and providing access to products:
- Contract conclusion and execution;
- Updating data to ensure accuracy, using information provided by the Client, external, and internal registers.
Risk assessment:
- Evaluating conditions and products we can offer;
- Performing duties related to business risk assessment;
- Managing debt obligations;
- Internal analysis necessary for contract execution or UVS’s legitimate interests.
Protection of legitimate interests:
- Protection of Client and/or UVS interests;
- Monitoring service quality;
- Recording conversations, storing electronic correspondence, preventing unauthorized use of products;
- Employee training and ensuring product quality.
Security:
- Video and/or audio recording to protect clients, employees, visitors, and property.
Additional products and marketing:
- Offering products based on consent or legitimate interest;
- Surveys, market research, and providing discounts.
Identity verification:
- For contract execution, legal obligations, or organizational management.
Legal requirements:
- Filing, executing, defending, or transferring claims.
How we obtain your personal data
We may receive personal data:
- Directly from you;
- From your use of our services;
- From external sources (government or private registers, third parties).
Types of personal data we process
Natural persons:
- Name, surname;
- Address, phone numbers, email;
- Data on your business activities, points of sale, turnover;
- Bank account information;
- Data on debts to the state or damage caused to UVS;
- Data from institutions (law enforcement, tax authorities, etc.);
- Residence, personal identification number;
- Video recordings, conversation recordings, electronic correspondence;
- Other data related to contract execution.
Representatives of legal entities:
- Name, surname;
- Contact information;
- Position, job description;
- Data from registers or transactions;
- Video recordings, communication data;
- Other data according to contracts.
All data is processed within the EU/EEA territory.
Direct marketing
If you have given consent:
- We may send general or personalized offers;
- We may offer tailored solutions based on your used equipment.
You can withdraw consent at any time by notifying us using the contact details below.
To whom we may disclose your personal data
Data may be disclosed to:
- Government authorities (law enforcement, tax administrators, etc.);
- IT service providers;
- Auditors, lawyers, consultants;
- Register managers;
- Debt collection companies, courts, bankruptcy administrators;
- Recruitment service providers;
- Other service providers related to our activities.
How long we keep your data
- As long as necessary to achieve contractual or legal purposes;
- No longer than required by laws or processing purposes.
Your rights
You have the right to:
- Know whether we process your data;
- Request correction of your data;
- Request deletion of your data;
- Restrict processing;
- Receive data in a structured format;
- Object to processing;
- Withdraw consent;
- File a complaint with the State Data Protection Inspectorate.
How to contact us
By registered mail or email indicated on the website.
You may need to provide an identity document or visit the office.
Policy validity
Universal Management Systems, UAB continuously reviews and updates this Policy. Changes take effect once published on the website.