PRIVACY POLICY

We recognize the special importance of the protection of your personal data, so we only collect and process your data that is necessary for the performance of our activities. We process personal data lawfully, transparently and fairly, for pre-determined purposes and only to the extent necessary to achieve the purposes of the processing. When we process personal data, we strive to ensure that it is accurate, secure, confidential, and properly stored and protected.

When processing your personal data, we adhere to the 2016 April 27 the requirements for the processing of personal data established by the General Personal Data Protection Regulation (EU) 2016/679 (hereinafter – GDPR), the Law on the Legal Protection of Personal Data of the Republic of Lithuania, as well as other legal acts and / or controlling authorities.

1. WHAT IS THIS DOCUMENT?

1.1. By reading this Privacy Policy (the “Privacy Policy”), you will learn how and for what purposes we process your personal data, where we obtain it, to whom it is provided and how we store it, and what your rights are as a data subject.
1.2. This privacy policy governs your use of our website https://www.1am.lt (the “Site”), our account on the social network LinkedIn https://www.linkedin.com/company/1-asset-management/ (the “Account”) ) and the terms of the provision of services (such as the use of the system accessible through the Customer Zone option on the Site) in connection with your use of the Site in relation to our processing of personal data and our privacy policy. Please read this Privacy Policy carefully, as each time you visit the Website and / or our Account, you agree to the terms of the Privacy Policy. If you do not agree to these terms, please do not visit our Website and / or our Account or use our services.
1.3. The term “personal data” used in this Privacy Policy means any information that identifies you – directly or indirectly – to identify you. Personal data includes, for example, last name, first name, e-mail. email address, phone number, location data and internet identifier, your unique characteristics and other personal data as defined in the GDPR.

2. WHO ARE WE?

2.1. We are UAB I Asset Management, headquartered in Liepyno str. 25A, Vilnius, code 304405305, tel. +370 655 57033, contact e-mail email info@1am.lt.
2.2. In accordance with the provisions of legal acts, we are the controller of your personal data in the cases and to the extent provided for in this Privacy Policy.

3. WHAT PRINCIPLES DO WE TAKE?

3.1. When processing your personal data, we:
(a) comply with applicable and applicable legislation, including GDPR;
b) we will process your personal data in a lawful, fair and transparent manner;
c) collect your personal data for specified, explicit and legitimate purposes and will not continue to process it in a way incompatible with those purposes, except to the extent permitted by law;

(d) take all reasonable steps to ensure that personal data which are inaccurate or incomplete, having regard to the purposes for which they are processed, are rectified, supplemented, suspended or destroyed without delay;
e) we will keep them in a form that allows you to be identified for no longer than is necessary for the purposes for which the personal data are processed;
f) we will not disclose or disclose personal data to third parties except as provided in the Privacy Policy or applicable law;
(g) we will ensure that your personal data is processed in such a way as to ensure the appropriate security of personal data through appropriate technical or organizational measures, including protection against unauthorized or unlawful processing of data and against unintentional loss, destruction or damage.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1. We process your personal data in the following ways:
a) When you provide them to us. You provide us with your personal data and other information by using the Site, visiting our Account, writing to us or communicating with our team, submitting your complaints and / or inquiries, and so on. Please be informed that if you contact us in writing or by e-mail. Email – We will save the correspondence.
b) When you use any of our Website and / or our Account. When you use the Website and / or visit our Account on social networks, certain information (such as your Internet address (IP), type of web browser used, number of visits, etc.) is collected automatically, as detailed in Section 6 of this Privacy Policy. .
c) When we receive your personal data from other persons in accordance with the law and / or this Privacy Policy. In cases where we receive data from non-data subjects, we require that data subjects be informed of the processing of the relevant personal data (purpose and other conditions and circumstances detailed in this Privacy Policy). In addition, in cases where we are provided with personal data other than our own, the data subject is required to be aware of this Privacy Policy.
4.2. We may combine personal data we receive from you through our Website, our Account, or any combination thereof, with data we collect from other public and / or accessible sources (e.g., we may combine personal data you provide with data). , obtained through the use of cookies on the Website, or with data lawfully obtained from third parties).
4.3. You will always be able to request the correction of incorrect personal data and to exercise your other rights under the Privacy Policy as set out in this Privacy Policy.

5. FOR WHAT PURPOSES AND HOW DO WE PROCESS YOUR PERSONAL DATA?

5.1. The exact amount of personal data and how we process it depends on the specific relationship between you and us. We may process your personal data for the following independent purposes:
a) In order to improve the Website, offer better services tailored to you. We use your personal data, including the personal data we receive from you to use our Website, when you visit our Account, in order to improve and develop the Website and to offer you better and more personalized services. For this purpose, we receive data from you (using cookies on the Website) and / or from other persons (including, but not limited to, social network operators through the cookies they use).

For more information about the categories and specifics of the processing of personal data processed for this purpose and how we use cookies and similar technologies, please read Chapter 6 of this Privacy Policy.
b) For the purpose of administration, identification and proper provision of services in the Self-Service Client Area of ​​the created individual profiles. You provide us with your personal information when you use the Website through your individual account (which provides a convenient and quick way to perform electronically the functions permitted by the Customer Zone option on the Website). We also process your personal data if you register on the Website or use it as a legal entity representative and / or contact person. Each account holder can view, edit and delete their personal data at any time (except for a nickname). Personal data may be processed for this purpose:

Data categories Name, surname, e-mail e-mail, password, login, related legal entity (position in it), collective investment undertaking in which the account holder or the legal entity represented by him is invested.
Legal basis for data processing Execution of your contract with the Management Company as a client (investor) of the Management Company
Deadline for data processing During the term of the above contract and for 10 years from the end of the contract, unless the (legal) dispute lasts longer (in this case, until the final decision of the competent authority takes effect)
We receive the data from you
We provide or transfer data to persons providing Website administration or other related services (eg, IT service providers, compliance service providers)
c) The purpose of quality control of our activities and ensuring the use of other functionalities of the Website and communication with us (handling of complaints and / or inquiries and communication submitted by you, including – storage). When you contact us (or we will contact you upon receipt of your request), we will process in writing, email. information received by e-mail, via the Website or otherwise, which may include personal data:

Data categories Date and time of application, subject of application, name, e-mail e-mail, telephone number, social network account name, social network photo, date of writing, details of the company involved, content of the complaint and / or inquiry, telephone number, date and time of the call, other communication information provided voluntarily by the applicant collected during the inquiry / complaint legal basis for data processing Enforcement of the terms of use of the 1AM Website as an agreement with you, as well as our legitimate interest in evaluating the feedback from our customers in order to improve the quality of our operations and services Term of data processing For this purpose, we store your data for 2 years from the date of their recording, unless: (i) existing reason to believe that a crime or other illegal activity has been recorded or initiated

(internal) investigation / dispute and data processing required before the final decision of the competent authority takes effect; or (ii) the relevant data relates to your contract with the Management Company as a client (investor) of the Management Company, in which case the data shall be kept for 10 years from the end of the dispute, unless the final decision of the competent authority takes effect. days)
We receive the data from you, we can create personal data ourselves by executing a request or analyzing a complaint (for example, after receiving your complaint, we contact our employees about the actual circumstances of the complaint, etc.), from third parties: distributors, compliance providers or kt. persons used for the performance of the activity
We provide or transfer data to persons providing Website administration services, persons providing legal services, and persons providing compliance services.
d) Candidates to join our team for selection purposes. If you contact us for the opportunity to join our team, we may process your personal data for this purpose:
Data categories Data specified in your CV or your completed questionnaire, data collected during communication, such as: name, surname, e-mail email, phone number, city, gender, date of birth, education, activities, information about professional (including volunteering) experience, professional projects completed, foreign languages ​​taught, link to LinkedIn social network account.
Legal basis for data processing The purpose of concluding an agreement (employment contract) to join your team
Deadline for data processing No later than 30 calendar days from the date on which the specific selection was completed and / or we informed you that it is not possible to join our team, unless we have obtained your separate consent to store the data for another purpose (ie Candidate Database Administration) longer – in this case, personal data is stored for the period specified at the time of obtaining consent (usually – 1 year from the date of giving your consent to us)
We receive data from you, from third parties (eg legal entities providing employment services, current or former employers on a legal basis)
We provide or transfer data to Legal Services and Compliance Services.

e) for other purposes set out in our Personal Data Processing Policy and / or other internal documents where your personal data is required to be processed by law or where there is a legitimate interest or other basis for lawful processing of personal data provided by law.

5.2. For the purposes of the processing of personal data detailed in this Privacy Policy, we do not solicit or disclose to you any special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as health data, genetic data, biometric data (to specifically identify you) and information about your sexual life.

6. HOW DO WE USE COOKIES?

6.1. We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device’s hard drive and allow you to identify you during other visits to the Site, social networks, save your browsing history, options, customize content, speed up searches, create a more convenient and friendly environment, and provide it more efficiently and reliably. . Cookies are common web browsing practices that make it easier to use the website.
6.2. By using the Website, we may collect the information specified in 5.1 of this Privacy Policy. (a) as detailed in 6.6. points.
6.3. We use the information we receive from cookies:
a) to ensure the functionality of the Website;
b) to enable us to improve and develop the Site to better meet your needs;
c) development of services and analysis of the use of the Website;
(d) targeted targeting of marketing solutions.
6.4. We may, without violating the law, combine information obtained through the use of cookies with information obtained about an individual through other means (such as information about your use of the Website with other personal data provided by you or obtained from other sources).
6.5. Please note that the Website and social networks may use cookies such as:
(a) “necessary (technical) cookies” means cookies that are necessary for the operation of websites;
(b) “functional cookies” means cookies which, although not necessary for the operation of websites, significantly improve their performance, quality and visitor experience;
(c) “analytical (statistical) cookies” means cookies used for the statistical analysis of navigation methods of website visitors; the data collected by these cookies is used anonymously;
(d) “targeted or promotional cookies” means cookies used to display offers or other information that may be of interest to you;
e) Social network cookies are cookies that are necessary for the use of website information in your social profile account.
6.6. Information about the cookies used on the Website, their purpose, validity and data used can be found here:

Place of use
Name (category)
Purpose
The moment of creation
Expiry date
Data used
Website https: // www
.1am.lt
_icl_current_l anguage
(required) Recognizes which language to display to the visitor. Visit the Website
moment 1 day The cookie does not collect personal data
Website https: // www
.1am.lt
cookie_notice
_accepted (technical) The cookie ensures that you do not have to do it again every time you visit us.
website. This cookie is not enabled until you submit it
consent. 1 year The cookie does not store any personal information.

Website https: // www
.1am.lt
_ga
(statistical) Google Analytics uses this cookie to evaluate the purpose of a user’s visit, generate website activity reports for website operators, and improve
customer experience. Time of visit to the site 2 years Unique random characters
identifier
Website https: // www
.1am.lt
_gat
(Statistical) An analytical cookie from Google Analytics that collects and stores information about user behavior on a website. Time of visit to the Website 1 minute Number
Website https: // www
.1am.lt
_gid
(statistical) An analytical cookie from Google Analytics that collects statistics
user information The data obtained is used to improve the performance of the website. The moment of visiting the Website 24
hours The cookie does not collect personal information, but gives each user an ID according to
your accounting
If you have an account or logged in to our website, we create:

Place of use
Name (category)
Purpose
The moment of creation
Expiry date
Data used
Website https: // www
.1am.lt
_icl_current_a dmin_languag e
(required) Identifies the online administrator of the site and displays the required language for the system management environment. The moment of visiting the Website Day 1 The cookie does not collect personal data
Website https: // www
.1am.lt
_icl_current_l anguage
(required) Recognizes sites
administrator and displays the required language of the system management environment Moment of visit to the Website 1 day Cookie does not collect personal data
Website https: // www
.1am.lt
wordpress_ [h ash]
(required) The secure ID cookie used by the user account
to keep your account secure. The moment of visiting the Website Until the end of the working session. The cookie does not collect personal data
Website https: // www
.1am.lt
wordpress_lo gged_in_ [has h]
(required) Login cookies are valid for 2 days. If you select the “Remember me” option, your login cookie will be valid for 2 weeks. When
you log out of your account, login cookies
deleted. Moment of Website Visit For identification
logged in user during the session. The cookie does not collect personal data
Website https: // www
.1am.lt
wp-settings- [hash], wp- settings-time- [hash]
(required) Used by the website
personalization of the structure according to the user. The moment of visiting the Website for 1 year The cookie does not collect personal data

6.7. You can consent to the use of cookies on our Website by clicking on the “I Agree” link in the link (bar) on the Website.
6.8. You can revoke your permission to use cookies at any time. You can do this by changing your web browser settings so that it does not accept cookies. How you do this depends on your operating system and web browser. You can find detailed information about cookies, their use, opt-out options at http://AllAboutCookies.org or http://google.com/privacy_ads.html.
6.9. In some cases, in particular, disabling, not accepting or deleting technical and functional cookies may slow down your Internet browsing, restrict the operation of certain features of the Website, and block access to the Website.
6.10. For more information about external sites (such as social networks), see Chapter 10 of this Privacy Policy.

7. WHO DO WE PROVIDE YOUR PERSONAL INFORMATION TO?

7.1. We guarantee that your personal data will not be provided or otherwise transferred to third parties without a legitimate basis, nor will it be used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than as required by law in accordance with this Privacy Policy. However, we reserve the right to provide information about you if we are required to do so by law or if required to do so by lawful authorities or prosecuting authorities.
7.2. We may transfer your personal data to partners who help us operate businesses. We require such entities to process your data only in accordance with the instructions given by us and the applicable data protection legislation. We enter into agreements with these individuals that impose strict obligations to protect personal data.
7.3. The use of your data by the above-mentioned service providers is limited – they may not use this data for purposes other than providing services to us.
7.4. A non-exhaustive list of individuals and their categories to whom we transfer your personal information is provided in Section 5.1 of this Privacy Policy. separately for each purpose of the use of personal data.

8. HOW LONG DOES WE STORE YOUR PERSONAL DATA?

8.1. We store your personal data for no longer than required by the purposes of the processing or as required by law, if they provide for a longer retention period.
8.2. We strive not to protect outdated, out-of-date personal data, so only up-to-date information is retained when it is updated (e.g., revised, changed, etc.). Historical information is protected if it is required by law or for the performance of our activities.
8.3. Privacy Policy 5.1. The terms of storage of your personal data are specified separately for each purpose of use of personal data.

9. HOW DO WE PROTECT YOUR PERSONAL DATA?

9.1. The data we collect from you will be within the EU, but may be transferred or stored outside the EU. They may also be handled by our own or our suppliers’ staff outside the EU. When transferring your data outside the EU, we will take all necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy.
9.2. Unfortunately, the transmission of information over the Internet is not completely secure. Although we make every effort to protect your personal data, we cannot guarantee the security of your data when you transfer data to the Website – you assume the risks associated with the transfer of data to the Website. When we receive your data, we will apply those legal procedures and security measures to protect your data from unauthorized access, unauthorized processing or disclosure, accidental loss, deletion, or destruction.
9.3. Should unlikely circumstances arise and we become aware of a breach of the security of your personal data which could seriously jeopardize your rights or freedoms, we will inform you immediately as soon as we become aware of it and determine what information has been accessed.
9.4. The site uses a Letsencrypt.org SSL certificate
a) Verified Website Identity (You are visiting the real domain owner’s website and not being redirected to a hacked server)
b) All data transmitted between the server and the browser is encrypted (network hackers can no longer read it).
c) Data integrity and originality guaranteed (routers on the way cannot correct or censor the information being transmitted).
d) More information at https://letsencrypt.org.

10. EXTERNAL SITES

10.1. The Site may contain links to external sites, such as our business partner sites or sites where we have accounts that promote our services. By following such links to any of the Sites, please note that these Sites and the services accessed through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data collected on or through these Sites, such as contact or location details. We encourage you to review these policies before submitting personal information on these sites or using any of our services.

11. WHAT RIGHTS DO YOU HAVE?

11.1. When processing personal data, we guarantee your rights in accordance with BDAR and the Law on the Legal Protection of Personal Data of the Republic of Lithuania. As a data subject, you have the following rights:
(a) be aware of the processing of their personal data;
b) access to our personal data that we process;
c) request the correction or supplementation, correction of incorrect, inaccurate, incomplete personal data;
(d) require the destruction of personal data where they are no longer needed for the purposes for which they were collected;
e) request the destruction of personal data if they are processed unlawfully or if you withdraw or do not give your consent to the processing of personal data, which is necessary;
(f) consent to the processing of personal data or the withdrawal of prior consent;
g) request the suspension (other than storage) of your personal data in the event of a dispute or verification of the lawfulness of the processing, the accuracy of the data, and in cases where we no longer need your personal data but you do not want us to destroy it;
h) require that, where technically possible, your personal data collected with your consent or for the performance of the contract be provided in an easy-to-read format or requested to be transferred to another controller.
11.2. We will endeavor to guarantee the exercise of your rights as a personal data subject and to create all conditions for the effective exercise of these rights, but we reserve the right not to comply with your requirements when it is necessary to ensure:
(a) the performance of our legal duties;
(b) national security or defense;
(c) public order, the prevention, investigation, detection or prosecution of criminal offenses;
(d) important economic or financial interests of the State;
(e) the prevention, investigation and detection of breaches of official or professional ethics;
f) Protecting the rights and freedoms of you or others.
11.3. You may submit claims related to the exercise of your rights to us in person, by post or by electronic means. Upon receipt of your request, we may ask you to provide proof of identity as well as any additional information we require regarding your request.
11.4. Upon receipt of your request, we will respond to you no later than 30 calendar days from date of receipt of your request and the submission of all documents required for a response.
11.5. If we deem it necessary, we will suspend the processing of your data, except for storage, until your request has been resolved. Upon lawful withdrawal of your consent, we will immediately, but not later than 30 calendar days, terminate the processing of your personal data, except as provided in Section 11.2 of this Privacy Policy. and cases provided for by law, i.e. y. when we are required to further process your data by applicable law, our legal obligations, court decisions or mandatory instructions from us.
11.6. If we refuse to comply with your request, we will clearly state the grounds for such refusal.
11.7. If you do not agree with our actions or the response to your request, you may appeal against our actions and decisions to the competent public authority.

12. TO WHOM CAN YOU MAKE A COMPLAINT?

12.1. If you wish to make a complaint about our processing of data, please submit it in writing, providing as much information as possible, using the contact details provided at the end of this policy. We will work with you and work to resolve any issues promptly.
12.2. If you think that your rights have been violated in accordance with the GDPR / other applicable personal data protection legislation, you can file a complaint with our supervisory authority, the State Data Protection Inspectorate of the Republic of Lithuania, more information and contact details can be found on the Inspectorate’s website (https://vdai.lrv .lt /). Although, above all, we strive to resolve all disputes with you promptly and peacefully.

13. HOW WILL THIS PRIVACY POLICY CHANGE?

13.1. All changes to our Privacy Policy will be posted on the Website. We will notify you of any material changes and / or needs. The new Terms of Privacy Policy may also be posted on the Website and you may need to read and agree to them in order to continue using the Website and / or our services.

14. HOW TO CONTACT US?

14.1. Please send all documents related to this Privacy Policy or contact us at the following contacts:
a) by sending mail – UAB I Asset Management, whose registered office is at Liepyno str. 25A, Vilnius;
b) by sending an e-mail – info@1am.lt;
c) contact telephone number – +370 655 57033.

Privacy Policy Release Date 2020 August 3

Download (private policy)

Other important documents:

Rules of IAM webpage

IAM webpage client zone rules

Procedures for examining applications and exercising rights