Privacy Policy

UAB FORTEVENTO PRIVACY POLICY

This privacy policy (hereinafter referred to as the Privacy Policy) explains how UAB “Fortevento” (“Fortevento” or “we”), a legal entity registered and operating under the laws of the Republic of Lithuania, whose legal entity code is 302327313, registered address Lvivo g. 105A, Vilnius, Lithuania, as your personal data controller and the operator of the website www.fortevento.lt (hereinafter referred to as the Website), processes your personal data when you provide it to us.

When processing personal data, Fortevento follows and complies with 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, repealing Directive 95/46/EC (hereinafter referred to as GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable legal acts regulating the protection of personal data.

By using the Website, you have read and understood this Privacy Policy and the purposes, methods, and procedures for processing your personal data specified therein.

I. WHAT PRINCIPLES DO WE FOLLOW WHEN PROCESSING YOUR PERSONAL DATA?

When processing your personal data, we will:

Comply with the requirements of applicable and relevant legal acts, including GDPR;
Process your personal data in a lawful, fair, and transparent manner;
Collect your personal data for specified, clearly defined, and legitimate purposes and will not process it further in a manner incompatible with those purposes, except to the extent permitted by legal acts;
Take all reasonable measures to ensure that personal data that is inaccurate or incomplete, considering the purposes for which it is processed, is promptly corrected, supplemented, suspended from processing, or destroyed;
Keep it in a form that allows your identity to be determined no longer than necessary for the purposes for which the personal data is processed;
Not provide personal data to third parties and not disclose it, except in cases specified in the Privacy Policy or applicable legal acts;
Ensure that your personal data is processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

II. PROCESSING OF YOUR PERSONAL DATA

Fortevento processes the following personal data for the purposes specified below:

To contact you after you have filled out the inquiry form on the website.

a) Data categories: Name; surname; email address; your message text/inquiry.

b) Legal basis for data processing: We process this data:

At the request of the data subject before concluding a contract (GDPR Article 6(1)(b));
When it is necessary to process the data to fulfill a contract to which the data subject is a party.

c) Data processing term: As long as the contract is being executed, if such a contract is concluded, and for 1 year after the contract ends. If the data subject does not conclude a contract, the information provided in the inquiry is stored for 6 months.

d) Data received from: You.

e) Data provided or transferred to: Website database and email.

2. For the purpose of organizing and conducting our events (including remote events).

a) Data categories: Name, surname, workplace, email address, photos (if photographed), phone number.

b) Legal basis for data processing: Depending on the nature of the specific event, personal data may be processed on the following grounds:

Contract conclusion and execution (GDPR Article 6(1)(b)) or
Your consent (GDPR Article 6(1)(a)) and/or
Our legitimate interests (GDPR Article 6(1)(f)).

c) Data processing term: Personal data is stored for 1 year after each event.

d) Data received from: You; third parties.

e) Data provided or transferred to: Service providers (e.g., data storage services, marketing services, event organization services, etc.).

3. For the purpose of managing and administering our social media accounts (Facebook, Instagram, LinkedIn).

a) Data categories: Your social media account name, photo, reactions to Fortevento-generated content (likes, comments, shares, etc.), inquiries to us.

b) Legal basis for data processing: Your consent (GDPR Article 6(1)(a)).

c) Data processing term: Personal data is processed as long as our or the data subject’s social media account is active, unless the data subject expresses a desire to delete their data from our social media accounts earlier.

d) Data received from: You.

e) Data provided or transferred to: Companies providing data storage services; companies performing and providing internet browsing or online activity analysis services; companies providing advertising, marketing services; Meta Platforms Inc.; Google Inc.; LinkedIn Corporation.

4. For the purpose of direct marketing (including profiling).

a) Data categories: Name; surname; email address.

b) Legal basis for data processing: Your consent (GDPR Article 6(1)(a)).

c) Data processing term: Personal data is processed as long as the data subject’s consent is valid, but no longer than 2 years.

d) Data received from: You.

e) Data provided or transferred to: Companies providing direct marketing services; companies providing data storage services.

5. For the purpose of conducting candidate selection.

a) Data categories: Name; surname; email address.

b) Legal basis for data processing: Contract conclusion and execution (GDPR Article 6(1)(b)) or our legitimate interests (GDPR Article 6(1)(f)).

c) Data processing term: Data is stored for 4 months after the contract with the selected candidate is signed, if consent is expressed, we will store the data for 3 years from the date of receipt.

d) Data received from: You.

e) Data provided or transferred to: We may provide it to companies providing employee selection services.

III. TO WHOM CAN WE TRANSFER YOUR PERSONAL DATA?

We inform you that we do not transfer or otherwise disclose your personal data to third parties, except in the cases specified below:

If there is your consent;
To our employees, intermediaries, service providers, if reasonably necessary for the purposes specified in this Privacy Policy;
To data processors who process your personal data on our behalf and for the purposes specified in this Privacy Policy (e.g., IT, server service providers);
To law enforcement or other authorities, institutions, or other data recipients to whom data must be transferred according to legal requirements or to protect our rights and interests.

When Fortevento transfers data to data processors, Fortevento requires data processors to process the transferred data exclusively according to Fortevento’s instructions, for the purposes specified by Fortevento, and based on this Privacy Policy, the laws on legal protection of personal data, and the data processing agreements concluded between Fortevento and data processors.

Based on a legitimate basis and purpose, Fortevento may transfer your personal data to entities outside the European Economic Area (EEA) (e.g., if Fortevento’s data processors or personal data recipients are established outside the EEA). When personal data is transferred from the EEA to countries that the European Commission does not recognize as ensuring an adequate level of personal data protection, Fortevento takes all appropriate measures to protect your personal data (e.g., personal data transfer is based on the European Commission’s approved standard data transfer contract terms).

IV. WHAT RIGHTS DO YOU, AS A DATA SUBJECT, HAVE?

Jūs, kaip duomenų subjektas, turite šias teises:

The right to be informed about Fortevento’s processing of personal data. You have the right to receive information about the processed personal data, the sources of personal data, the purposes of processing, legal bases, retention periods, and persons, data recipients, or data processors, data subject rights, etc.
The right to access Fortevento’s processed personal data. You have the right to access the processed personal data and receive a copy of it.
The right to request correction of Fortevento’s processed personal data. You have the right to request correction of inaccurate or incorrect personal data processed by Fortevento.
The right to withdraw consent. You have the right to withdraw your given consent at any time, without affecting the lawfulness of data processing based on consent before its withdrawal.
The right to request data deletion. You have the right to request deletion of your personal data if it (i) is no longer necessary for the purpose for which it was collected; (ii) you have withdrawn consent to process your personal data if the data processing was based on your consent; (iii) your personal data is processed based on legitimate interest and you object to such processing and there are no overriding legitimate reasons to process the data; (iv) we must delete your personal data to comply with legal obligations or (v) your personal data was processed unlawfully.
The right to restrict data processing. You have the right to restrict Fortevento’s processing of your personal data: (i) if you dispute the accuracy of the data and Fortevento performs related verification; (ii) your personal data was processed unlawfully, but you do not agree to delete the data; (iii) if your personal data is no longer necessary for the purpose for which it was collected, but you need it to assert, execute, or defend legal claims; (iv) if you objected to data processing, as described below, until it is verified whether Fortevento’s legitimate reasons override your reasons.
The right to object to data processing. You have the right to object to Fortevento processing your personal data for direct marketing purposes, the right to object to your personal data being processed in the public interest or legitimate interests of Fortevento, unless these interests override your reasons for objection.
The right to data portability. You have the right to receive the personal data you provided to us or to request the transfer of this data to another data controller in a structured, commonly used, and machine-readable format, if your personal data processing is based on your consent or our mutual agreement and your personal data is processed by automated means.
The right to file a complaint. If you believe your rights have been violated, you can contact us by email at info@fortevento.lt or (and) file a complaint with the supervisory authority. In Lithuania, the supervisory authority is the State Data Protection Inspectorate (L. Sapiegos g. 17, LT-10312 Vilnius, email ada@ada.lt), other supervisory authorities you can contact based on your place of residence or Fortevento’s place of activity can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

To exercise your rights, you can contact Fortevento by email at info@fortevento.lt. Before exercising your right(s), Fortevento may ask you to provide proof of identity.

Fortevento hereby informs that the exercise of the above rights may depend on the specific conditions for exercising the right established in legal acts, therefore, in specific cases established by legal acts, Fortevento has the right to refuse to satisfy your request to exercise a specific right in a reasoned written form.

Upon receiving your request, Fortevento undertakes to implement your right as soon as possible, but in any case, no later than within one month from the date of receipt of your request or to refuse to implement it in a reasoned written form. Fortevento has the right to request a reasonable fee if your requests are clearly unfounded, repetitive, or excessive.

V. ENSURING THE SECURITY OF YOUR PERSONAL DATA

Fortevento processes your personal data responsibly and securely, considering the personal data security requirements established in legal acts. When determining personal data processing measures, as well as during data processing, Fortevento implements the technical and organizational measures established in legal acts to protect the processed personal data from accidental or unlawful destruction, damage, alteration, loss, disclosure, as well as from any other unlawful processing. Personal data security measures and their level are determined considering the risks arising from the processing of personal data.

Among other things, Fortevento employees who have access to personal data are familiar with personal data protection requirements and ensure the complete confidentiality of the processed personal data.

VI. COOKIES

Fortevento hereby informs that cookies are used on the Website.

Cookies are small text files sent to each person’s device visiting the Website, from which the Website is accessed, and temporarily stored on that device.

The information collected by cookies helps to recognize the Website visitor, save the browsing history, and adapt the content accordingly. The information collected by cookies allows us to ensure your ability to browse more conveniently, provide attractive offers, and learn more about visitor behavior, analyze trends, and improve the Website, customer service, and the services we provide.

When visiting the Website, you can express your consent if you want to use cookies. If you do not give consent to the use of cookies, cookies that are not necessary for the operation of the Website or are exclusively technical will not be recorded on your device.

We inform you that you can also manage and/or delete cookies according to your preferences by selecting the cookie management tool on the Website. Also, in the settings of the browser (“Microsoft Edge”, “Safari”, “Firefox”, “Chrome”, etc.), you can choose which cookies you want to accept and which to reject. You can delete all cookies already on your device, and most browsers can be set to prevent cookies from being recorded. The location of these settings depends on the browser you are using.

You can withdraw your consent to use cookies at any time by changing the settings and deleting the recorded cookies. If you choose to delete cookies, remember that all set options will also be removed, and the Website may not work or may not work properly. For these reasons, we do not recommend disabling cookies when using the Website.

To learn more about cookies and how to manage or delete them, you can visit: www.allaboutcookies.org.

On the Website, we use the cookies listed below.

Marketing Cookies:

ga# – Sends data about the visitor’s device and behavior to Google Analytics, enabling tracking across devices and marketing channels.
_ga – Sends data about the visitor’s device and behavior to Google Analytics, enabling tracking across devices and marketing channels.

Statistical Cookies:

_clck – Collects data on user browsing and behavior to generate statistical reports and heat maps for the Website owner.
_clsk – Records statistical data on user behavior for internal analysis by the Website owner.

Functional Cookies:

pll_language – Determines the visitor’s preferred language and sets the language accordingly on the Website.

Necessary Cookies:

CookieConsent – Stores the user’s cookie consent status for the current domain.
_GRECAPTCHA – Used by Google reCAPTCHA for spam protection and risk analysis, storing browsing device information.
wpEmojiSettingsSupports – Supports content delivery and display settings, including fonts, blog/image sliders, and color themes.
rc::a – Distinguishes between humans and bots to provide accurate Website usage reports.
rc::b – Distinguishes between humans and bots.
rc::c – Distinguishes between humans and bots.
rc::d-15# – Distinguishes between humans and bots.
rc::f – Distinguishes between humans and bots.
_grecaptcha – Distinguishes between humans and bots to ensure accurate Website usage reports.

VII. CHANGES TO THE PRIVACY POLICY

Fortevento has the right to change the conditions specified in this Privacy Policy. If the conditions specified in this Privacy Policy are changed, we will publish the updated version of the Privacy Policy on the Website.

Changes to the Privacy Policy were made and are effective from March 5, 2025.