When processing your personal data, we comply with the provisions of the General Data Protection Regulation (GDPR), the provisions of the Law on Legal Protection of Personal Data of the Republic of Lithuania, and the applicable requirements provided for in other legal acts.

1. General provisions

1.1. This Privacy Policy (hereinafter referred to as the Privacy Policy) sets out the Privacy Terms when you use our Website www.frontit.dk (the “Website”) as well as our accounts in social media.

1.2. Please read this Privacy Policy carefully to see how we process your personal data, where we receive it, and what rights you have.

1.3. The Privacy Policy applies to all persons who have visited our Website and social networks.

1.4. If you use the Site or our accounts on social networks, you have read and agreed to this Privacy Policy and the purposes, means and procedures for the processing of your personal data specified therein. If you do not agree with the Privacy Policy, you may not use the Site and our accounts on social networks.

1.5. The controller of your personal data is UAB “FrontIT”, legal entity code 300579778, Ukmergės st 126, LT-08100, Vilnius, e-mail info@frontit.dk (hereinafter referred to as “the Company” or “we”).

1.6. When you first visit the Website, you are presented with a cookie banner requesting your consent to the use of cookies, except for strictly necessary cookies, in accordance with this Privacy Policy and Cookie Policy.

1.7. We reserve the right to update this Privacy Policy at any time. The updated Privacy Policy takes effect from the date of its publication on the Website. We recommend you to periodically check the Privacy Policy, considering the update of the text.

2. On what grounds do we process your personal data?

2.1. The Company collects and processes personal data in accordance with EU and Republic of Lithuania legislation governing the protection of personal data.

2.2. The scope of the personal data processed depend on the services used and the information provided by the person who uses the services or browses our Website.

2.3. The Company processes the personal data on the following grounds:

2.3.1. consent, which is expressed by your active actions, i.e. referrals to us and the provision of personal data, or other active actions;

2.3.2. the exercise of our legitimate interests (e.g. management and administration of the Website, etc.);

2.3.3. performance of a contract to which you are a party or taking steps at your request prior to entering into a contract;

2.3.4. to fulfill the obligations imposed by law.

2.4. The Company seeks to ensure that personal data is processed accurately, fairly and lawfully, that it is processed only for the purposes for which data was collected, so that it is processed in accordance with the clear and transparent principles and requirements of the processing of personal data laid down in legal acts.

3. What personal data do we process and why?

3.1. Processing of personal data in cases of requests you have made

3.1.1. The Company also processes your data in cases where you contact us by e-mail, request, ask questions and provide any other information on our Website or social networks.

3.1.2. In such cases, the Company processes the following personal data: name, surname, e-mail address, telephone number, communication content, correspondence history, and any other personal data you voluntarily provide.

3.1.3. The Company processes your data in these cases in order to administer requests and complaints, to ensure the quality of the services it provides, and to protect your rights and legitimate interests. You provide your data to us based on consent, which is expressed by your active actions, i.e. by contacting us.

3.1.4. Personal data collected for this purpose is stored for as long as necessary to respond to your request and for a reasonable period thereafter to defend against possible legal claims.

3.2. Data processed for recruitment purposes

3.2.1. We process the following data: name, surname, place of residence or address of residence, e-mail address, telephone number, information on the candidate’s work experience (workplace, period of work, duties, responsibilities, achievements), information about the candidate’s education (educational institution, learning period, education and/or qualifications acquired), information on training (training received, certificates obtained), information on language skills, information technology, driving skills, other competencies, other information you provide in the CV, cover letter or other candidate documents, recommendations or feedbacks, contact details, content of recommendations or feedbacks, summary of interview with candidate, notes and opinions of the candidate, candidate’s test results.

3.2.2. We process your data with your consent as well as the Company’s legitimate interest in selecting the most suitable candidate for employment. Where applicable, personal data may also be processed for the purpose of taking steps prior to entering into an employment contract.

3.2.3. While we perform the selection to the workplace and 3 months after the end of the selection (as long as it is technically optimal to perform periodic data deletion).

3.2.4. After the expiry of the data retention period, your personal data will be deleted or securely destroyed.

3.2.5. We may also retain your consent and proof of it for a longer period, if necessary, to defend ourselves against claims, or any other legal actions initiated against us.

3.2.6. We may transfer your data to third parties who assist us in the selection of candidates or who provide us services related to selection, evaluation of candidates and internal administration: personnel selection and evaluation service providers, software providers, database providers, data centers, cloud service providers, etc.

3.2.7. In each case, we provide the processor only as much data as is necessary for the execution of a specific order or for providing a specific service.

3.2.8. We collect personal data directly from you when you respond to a job advertisement and submit your CV, candidate profile or other candidate documents (resume, cover letter, etc.).

3.2.9. We may also collect personal data from job search and recruitment agencies, employment agencies, job search portals, and professional social networks (e.g. LinkedIn).

3.2.10. We collect information from your previous employers or persons providing recommendations only with your consent to contact such persons.

3.3. Processing shareholders, members of management bodies, beneficiaries, customers, business partners, other persons data

3.3.1. We process personal data of our shareholders, members and beneficiaries of our management bodies, their representatives, authorized persons. The processed data may include name, surname, position, company affiliation, contact details, identification data, shareholding data, signature rights, and other data required by applicable laws. This data is obtained from legitimate sources (including public registers) or direct from data subjects and processed for compliance with legal obligations, corporate governance, financial accounting, tax obligations and other legal requirements applicable to the Company.

3.4. We also process the personal data of different categories of data subjects (customers, business partners, suppliers, other counterparties, as well as their employees, managers, shareholders, representatives and agents).

3.4.1. We process the following personal data categories: name, surname, position, contact details (e-mail address, telephone number), business contact information, contract-related information, payment and transaction data, communication data, and other data necessary for cooperation.

3.4.2. This personal data is processed for the following purposes and on the corresponding legal bases:

3.4.2.1. when the persons establish, maintain and develop business, professional and other legitimate relationships with us;

3.4.2.2. establishing, maintaining and developing business, professional and other legitimate relationships;

3.4.2.3. concluding, executing and administering contracts and transactions;

3.4.2.4. pursuing and protecting the legitimate interests of the Company and its affiliates;

3.4.2.5. defending against claims, and other legal actions initiated against us;

3.4.2.6. fulfilling legal obligations under applicable laws.

3.4.3. The Company may transfer personal data to competent authorities, public registers, auditors, legal advisors, IT service providers, and other recipients having a legal basis to receive such data.

3.4.4. Personal data is retained for as long as necessary to achieve the purposes for which it is processed, taking into account legal retention requirements, statutory limitation periods, and the necessity to defend legal claims.

3.5. Data processing in social accounts

3.5.1. We process personal data in our social media accounts, including the following data: username, profile name, comments on posts, shared content, “like” and “follow” actions, reactions to posts, private messages, message receipt time, message content, message attachments, replies to messages, reply time, and other information you provide when interacting with our social media accounts.

3.5.2. Personal data you provide through social media (including messages, “Like”, “Follow”, comments, and other interactions) is also processed by the operator of the respective social network.

3.5.3. We recommend that you review the privacy policies of the following social media providers and contact them directly regarding the processing of your personal data:

3.5.3.1. “Facebook” – privacy policy is provided https://www.facebook.com/policy.php

3.5.3.2. “LinkedIn” – privacy policy is provided https://www.linkedin.com/legal/privacy-policy

3.5.4. We process personal data in social media accounts for the purposes of communication, responding to inquiries, providing information about our services, marketing and improving our services, as well as protecting the Company’s legitimate interests.

3.5.5. The legal basis for such processing is your consent expressed through your interaction with our social media accounts, as well as the Company’s legitimate interest in communicating with clients or their representatives and promoting its services.

3.6. Processing personal data on the Website

3.6.1. When you use our Website, we may process the following personal data: IP address, device information, browser type, operating system, browsing behaviour, pages visited, time and duration of visit, referral source, and other technical information.

3.6.2. Personal data on the Website is processed for the purposes of ensuring Website functionality, improving user experience, ensuring security, and analysing Website traffic.

3.6.3. The legal basis for processing is consent (where required, e.g. cookies) and the Company’s legitimate interest in ensuring proper functioning and security of the Website.

4. From what sources do we collect your personal data?

4.1. We collect personal data directly from you when you use the Company’s services, contact us, or use the Website.

4.2. Data can be generated when you use services such as making phone calls, sending an instant message, e-mail, or visit the Website.

4.3. We may also collect personal data from publicly available sources, business partners, service providers, recruitment platforms, social networks, public registers, or other lawful sources where permitted by applicable legislation.

5. How long do we process and store your personal data?

5.1. We retain personal data for no longer than necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by applicable legislation.

5.2. If you contact/email us, we usually store e-mail in active e-mail for 24 months and up to 5 years in the inactive e-mail archive.

5.3. Longer storage of your personal information can only be carried out when:

5.3.1. there are reasonable suspicions of an unlawful act which is the subject of an investigation;

5.3.2. your data is necessary for the proper resolution of the dispute or the complaint;

5.3.3. complaints have been received regarding a visitor or user, or violations of terms have been identified;

5.3.4. personal data is necessary for the establishment, exercise or defence of legal claims;

5.3.5. other specific grounds, conditions or cases provided for in the legislation.

6. In what cases and for which third parties do we disclose your personal data?

6.1. The Company shall not transfer your personal data to any third parties without your prior consent, except in the cases described below or where required by applicable legislation.

6.2. We may transfer personal data to third parties who assist us in providing services and administering our activities. Such recipients may include IT service providers, database providers, hosting providers, cloud service providers, system maintenance providers, marketing service providers, consultants, and other service providers. In each case, we provide data processors only with the personal data necessary for the provision of a specific service.

6.3. Data processors cooperating with us may process personal data only in accordance with our instructions and must ensure appropriate technical and organisational measures to protect personal data in accordance with applicable legislation and contractual obligations.

6.4. Personal data may also be disclosed to competent authorities, supervisory institutions, law enforcement authorities, courts or other public bodies where required by applicable legislation or upon lawful request.

6.5. If we use the Website analytics service (e.g. Google Analytics), to determine how you use the information provided on our Website, we may exchange your anonymised data with third parties who rely on this information to evaluate the use of the Website.

7. In which territories and jurisdictions do we carry out data processing activities?

7.1. As a general rule, the Company processes personal data within the territory of the European Union and the European Economic Area (EEA). The Company does not intend to transfer personal data to third countries or international organisations unless appropriate safeguards are implemented in accordance with applicable data protection legislation.

7.2. Please be informed that certain technical data of your visit (IP address, cookies, technical information of the browser you use, other information related to browser activity and Website browsing) when browsing Website may be transferred or made available to entities operating both within and outside the European Economic Area for statistical, analytical and related purposes (e.g. through our use of the Google Analytics Service, such entity is operating in the United States). Please note that non-EEA Countries may provide less protection for personal data than in EEA Countries, but we will carefully assess the conditions under which such data will be processed and stored later after the transfer to the above-mentioned entities.

7.3. Where personal data is transferred outside the European Economic Area, the Company ensures that appropriate safeguards are implemented, such as:

7.3.1. adequacy decisions adopted by the European Commission;

7.3.2. standard contractual clauses approved by the European Commission;

7.3.3. other safeguards provided for under applicable data protection legislation.

7.4. The Company carefully assesses the conditions under which personal data is transferred and processed by recipients outside the European Economic Area and takes appropriate measures to ensure an adequate level of data protection.

8. How do we protect your personal data?

8.1. The Company implements and keeps up to date appropriate organisational and technical security measures to protect personal data against accidental or unlawful destruction, alteration, disclosure, as well as any other unlawful processing. Such measures may include, but are not limited to: access control and authentication measures, data encryption, IT system security and monitoring measures, data backup and recovery solutions, staff training and confidentiality obligations, contractual data protection obligations with service providers.

8.2. All service providers processing personal data on behalf of the Company are required to implement appropriate security measures and process personal data only in accordance with the Company’s instructions and applicable legal requirements.

9. Submission of requests and complaints

9.1. If you wish to submit a request or complaint regarding the processing of your personal data, you may contact us in writing using the contact details provided at the end of this Privacy Policy. Please include as much information as possible to allow us to properly assess and respond to your request.

9.2. If you believe that your rights have been violated in accordance with the GDPR, you can file a complaint with the State Data Protection Inspectorate at L. Sapiegos st. 17, Vilnius, or by e-mail ada@ada.lt.

10. What rights do you have?

10.1. Right of access. You have the right to obtain confirmation from us of whether we process your personal data, as well as the right to access your personal data and information about the purposes of the processing, the categories of data processed, categories of recipients, the period of processing, the sources of data acquisition.

10.2. Right to erasure. You have the right to request that we erase your personal data where personal data is processed unlawfully, the legal basis for processing no longer exists, you withdraw your consent (where processing is based on consent), or other grounds for erasure provided for in applicable data protection legislation apply.

10.3. Right to rectify personal data. You have the right to request that we correct inaccurate personal data or complete incomplete personal data concerning you. If the data you have provided has changed, or you believe that the information we process about you is inaccurate or incorrect, you have the right to request that such information be corrected or updated.

10.4. Right to withdraw consent. Where personal data is processed based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

10.5. Right to restrict of processing. You have the right to restrict the processing of your data when personal data is processed unlawfully, you dispute the accuracy of the data, you have objected to the processing on the basis of our legitimate interest, etc.

10.6. Right to data portability. You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another data controller, where processing is based on consent or contract and carried out by automated means.

10.7. Right to object. You have the right to object at any time to the processing of your personal data where such processing is based on the Company’s legitimate interests, including profiling, unless we demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms.

10.8. Right to complaint. If you believe that we are processing your data in breach of data protection law, please contact us directly and if you are not satisfied with the way in which we can resolve the problem, you have the right to file a complaint to the supervisory authority.

11. How to contact us?

11.1. If you have any questions, comments or requests regarding this Privacy Policy, if you wish to exercise your rights as a data subject, or if you would like to submit a complaint regarding the processing of your personal data, you may contact us using the contact details provided below: by e-mail info@frontit.dk.