Paskutinį kartą atnaujinta: 2026-07-14
1. INTRODUCTION
This Privacy Policy (hereinafter – the Policy) provides information on how and what personal data is processed by the company UAB “IGLU TECH” (hereinafter – the Company), which is considered the data controller, based on personal data protection legislation, including but not limited to the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and 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 – GDPR).
Company data:
Name: UAB “IGLU TECH”
Company code: 304400087
Registered address: Ukmergės St. 364-6, LT-14188 Vilnius
Tel.: +370 660 95488
Email for GDPR-related requests:duomenuapsauga@iglutech.eu
The purpose of the policy is to inform about the Company’s assurance of Data Subjects’ privacy protection, explain how the Company protects Data Subjects’ data, and help understand how and what Data Subjects’ data is processed, what the rights of Data Subjects are, and how they can be exercised.
2. DEFINITIONS
Personal data | Any information related to a natural person – the Data Subject, whose identity is known or can be directly or indirectly determined using relevant data. |
Data subject | A person whose Personal data is processed for specified purposes and by specified means. In this Policy, a Data subject is considered to be a visitor, client, partner, candidate, or any other individual whose Personal data is processed by the Company. https://iglutech.eu/ – visitor, client, partner, candidate, or any other individual whose Personal data is processed by the Company. |
Data processing | Any operation or sequence of operations performed on Personal data or sets of Personal data, whether by automated or non-automated means, such as collection, recording, sorting, systematization, storage, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or otherwise making available, as well as alignment or combination with other data, restriction, erasure or destruction. |
Cookies | Small text files with unique identification numbers that are transferred from www.igluheatpumps.com to the user’s computer. Cookies may be used to recognize the user, save website settings, as server-side session identifiers, or in any other way if it is possible to achieve by storing text data. More information about cookies can be found in the Cookie Policy. |
3. PRINCIPLES OF PERSONAL DATA PROTECTION PROCESSING
Principle of lawfulness, fairness, and transparency | Personal data is processed lawfully, fairly, and transparently. |
Purpose limitation principle | Personal data is collected for specified, explicit, and legitimate purposes and not processed in a manner incompatible with those purposes. |
Data minimization principle | Personal data is adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. |
Accuracy principle | Personal data must be accurate and, where necessary, kept up to date. The company takes all reasonable steps to ensure that inaccurate or incomplete personal data, considering the purposes for which they are processed, are promptly corrected, supplemented, or deleted. |
Principle of storage limitation | Personal data is kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. |
Principle of integrity and confidentiality | Personal data is processed in such a way that appropriate technical or organizational measures ensure proper security of Personal Data, including protection against unauthorized or unlawful Data processing and against accidental loss, destruction, or damage. |
Principle of accountability | The Data Controller is responsible for ensuring compliance with the principles related to Personal Data processing and must be able to demonstrate that they are being followed. |
4. METHODS OF OBTAINING PERSONAL DATA
The Company collects and processes Personal Data in the following ways:
Personal data for direct marketing purposes (including sending newsletters and providing personalized offers) is collected and processed only with the explicit consent of the Data Subject.
Detailed information about the purposes of Personal Data processing, data categories, legal grounds, and retention periods is provided in section 5.
5. PURPOSES, LEGAL BASES, AND RETENTION PERIODS FOR PERSONAL DATA PROCESSING
The Company processes Personal Data only for legitimate purposes, in accordance with the requirements of the GDPR and other applicable legal acts. Depending on the purpose of Data Processing, one or more legal grounds may apply.
Purpose of processing | Processed personal data | Legal basis (GDPR Article 6) | Retention period |
Website administration and operation assurance | IP address, device type, browser, visit statistics, technical data | Legitimate interest (Article 6, Section 1, Point f) | According to Cookie Settings |
Direct marketing (including newsletters and personalized offers) | Email address, phone number, name (if provided) | Data subject’s consent (Art. 6(1)(a)) | Until consent is withdrawn |
Administration of service, maintenance, or sales inquiries | Name, surname, email address, phone number, inquiry content | Actions prior to contract formation / legitimate interest (Art. 6(1)(b) and (f)) | 3 years from the last contact |
Contract formation and execution (clients, partners) | Name, surname, contact details, contract details, payment information | Contract execution and legal obligation (Article 6, Section 1, points b and c) | 10 years from the end of the contract, unless legislation specifies a longer period |
Registration and use of the Partner Portal | Name, surname, email address, phone number, position, login details | Contract / pre-contract actions (Article 6, Section 1, Clause b) | During the portal usage period and 3 years after its end |
Communication with an AI-based chatbot | Content of the conversation, voluntarily provided contact details | Consent or legitimate interest (Article 6(1)(a) or (f)) | Up to 6 months from the end of the conversation, unless necessary for longer |
Candidate selection through the website | Name, surname, email address, phone number, CV, cover letter, information about education and work experience | Legitimate interest (Article 6, Section 1, Point f) | Until the end of the selection process |
Storage of candidate data for future selections | Name, surname, contact details, CV, cover letter | Data subject’s consent (Art. 6(1)(a)) | Up to 1 year from the end of the selection process or until consent is withdrawn |
Handling of inquiries, requests, and complaints | Content of the inquiry, contact details, related information | Legitimate interest (Article 6, Section 1, Point f) | Until the inquiry is reviewed and 1 year after its completion |
Assertion, enforcement, or defense of legal claims | All personal data related to the dispute | Legitimate interest (Article 6, Section 1, Point f) | Until the final resolution of the dispute and the expiration of limitation periods |
In cases where Personal Data is processed on the basis of the Data Subject’s consent, the Data Subject has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of Data processing carried out before the withdrawal.
During the use of the AI chatbot, when the Data Subject provides personal data, it is considered that they have given consent for the processing of such data.
6. DATA TRANSFER TO THIRD PARTIES
Personal data may be disclosed to other parties if necessary for the conclusion or execution of a contract with the client, or for other legitimate reasons. Information may also be provided to other parties based on your request.
We may also provide your data to data processors who provide services (perform tasks) for us and process your data on behalf of our Company as the data controller. Data processors have the right to process Personal Data only according to our instructions and only to the extent necessary to properly fulfill the obligations set out in the contract.
Data may also be transferred to other parties when required by law or necessary to protect our legitimate interests.
In certain cases, Personal Data may be transferred outside the European Union, ensuring the appropriate safeguards established by the GDPR.
7. SECURITY
The company applies technical and organizational measures to ensure data security, including access control, encryption, and contractual requirements for subcontractors.
8. DATA SUBJECT RIGHTS
The data subject has the following rights:
In cases where the Company processes the Data Subject’s Personal Data on the basis of their consent, the Data Subject has the right to withdraw their consent at any time, and the data processing based on this consent will be immediately terminated. The withdrawal of consent does not affect the legality of the Data Subject’s Data processing carried out before such withdrawal.
The Data Subject also has the right to file a complaint regarding Personal Data processing with the State Data Protection Inspectorate (address – A. Juozapavičiaus g. 6, 09310 Vilnius, website address –www.ada.lt), if the Data Subject believes that their Personal Data is being processed in violation of their rights and legitimate interests according to applicable laws.
To respond and resolve issues related to GDPR application as quickly as possible, we kindly ask you to first contact the Company.
9. PROCEDURE FOR HANDLING REQUESTS
The Data Subject must submit a request for the exercise of the specified rights to the Personal Data Controller, i.e., the Company.
You can submit requests related to the exercise of your rights to us in person by visiting the Company, by mail, or via electronic communication means (email: duomenuapsauga@iglutech.eu). Upon receiving your request, we may ask you to provide identity verification documents, as well as any other additional information related to the request that we may need.
Upon receiving the Data Subject’s request, the Company provides a response without undue delay, but no later than one month from the date of receipt of the request. Depending on the complexity of the request and the number of requests being processed, this period may be extended by an additional two months, with the Data Subject being informed of the extension within one month of receiving the request, stating the reasons for the extension.
10. VALIDITY AND AMENDMENTS OF THE POLICY
The policy takes effect on 2026-01-01.
We may update or change this Policy at any time. Such updated or changed Policy will take effect from the date it is posted on our website, indicating the update date.
If you access the website after such an update/change, it is considered that you are familiar with the updated Policy.
CONTACT INFORMATION
UAB “IGLU TECH”
Company code: 304400087
Address: Ukmergės g. 364-6, LT-14188 Vilnius
Tel.: +370 660 95488
Email: duomenuapsauga@iglutech.eu