FPI BALTIC
PRIVACY POLICY
Date of last update: 22-05-2023
1. GENERAL INFORMATION
Your privacy and security of your Personal Data is our top concern, therefore in this Privacy Policy (hereinafter referred to as the “Privacy Policy“) we would like to explain to you how we process and protect your Personal Data, what rights you have as a data subject, and provide you with other important information about processing of your personal data.
The General Data Protection Regulation 2016/679 (EU) (hereinafter referred to as “GDPR“) sets out the basic principles and requirements for us and other data controllers regarding processing of Personal Data. When processing your Personal Data, we comply with requirements of the GDPR and other applicable law, as well as guidelines of supervising authorities.
Term “personal data” (hereinafter referred to as “Personal Data“) as used in this Privacy Policy corresponds to the definition set out in the GDPR and means, among other things, any information or set of data from which we can directly or indirectly identify you, including your name, surname, e-mail address, telephone number, etc.
This Privacy Policy will apply when you use Online Store and/or Customer Self Service Platform (hereinafter referred to as “Online Store“) operated by us, or when you visit our website accessible at www.fpibaltic.com or customer.fpibaltic.com (hereinafter referred to as “Website“), or when you contact us by telephone or other communication means. Information about products we sell is also published in our Internet accounts in social networks, such as Instagram (hereinafter referred to as “Accounts in social networks“), and information you provide in these social networks may also be processed.
We would like to note that the Online Store or the Website may contain links to other websites or social network accounts. Such websites or social network accounts are not covered by this Privacy Policy and you are recommended to review their privacy policies before submitting your Personal Data to such websites or accounts.
If you order goods from us, use our Online Store and Website, visit our Accounts in Social Networks, or contact us, subscribe to our newsletters, we assume that you have read and understood information in the Privacy Policy about processing of your Personal Data, purposes, methods and procedures for such processing.
We may change the Privacy Policy, so please visit the Website regularly and read the latest revision of the Privacy Policy published. In some cases, we may provide you with individual data privacy notes specific to certain services we provide. Such notes should be read in conjunction with this Privacy Policy.
2. WHO ARE WE?
We are UAB “FPI Baltic”, a private limited liability company incorporated in the Republic of Lithuania, legal entity code 300016801, address: 31, Liuksemburgo aklg., LT-46401, Kaunas, Lithuania (hereinafter referred to as “FPI Baltic” or “we“), and we are a controller of your Personal Data.
Data Controller sets up purposes and methods of Personal Data processing. Data Processor shall process Personal Data only on behalf of a Data Controller and for the purposes and in the manner determined by the Data Controller.
3. WHAT PERSONAL DATA DO WE PROCESS AND HOW DO WE OBTAIN IT?
We process your Personal Data obtained in the following ways:
- Registration information, which you provide when you create an account in the Online Store, when you order our products, contact us by e-mail or telephone, etc.;
- Information that you send to FPI Baltic when you use our messaging, chat, notification, photo hosting or other similar features;
- Information about your use of our Online Store, your account, Website, accounts in social networks, such as your service usage history, your IP address, Website visit history, preferences, URL links opened, etc;
- When your personal data is provided to us by your relatives or acquaintances with your consent, as well as when your data is provided by companies (your employers), for example, by providing your contact details for collection of goods, by naming you as a recipient or authorised person for the goods etc.;
- When we receive information from third parties, such as payment institutions about payments made, etc;
- When you provide information and participate in customer surveys organised by us, when you visit our physical stores, or when you call our customer support and service telephone numbers;
- We collect information through a variety of technologies such as cookies and application interfaces, including during your visits of our Website and Online Store using one or more devices, whether you are logged in or not.
We assume that a person providing Personal Data to us, whether by providing his/her own Personal Data or Personal Data about other persons (e.g., employees, agents), is responsible for accuracy, completeness and relevance of such Personal Data, and for obtaining consent from a person whose data is being provided to us. However, in certain cases, we may also take proportionate measures and ask for confirmation that an individual has the right to provide us with Personal Data (for example, by completing registration or merchandise forms). When necessary (for example, when an individual is inquiring about receiving his or her Personal Data), we will reveal provider of such data.
4. FOR WHAT PURPOSES AND ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR PERSONAL DATA?
Logging on in the Online Store and usage of registered user account
What Personal Data do we process?
In order to provide our services, to enable usage of registered user account in the Online Store and to identify a purchaser, we process the following Personal Data:
Your name, surname, username, email address, password, telephone number, address and/or delivery address, name, address, position, relationship with a represented legal entity, history of your use of the Online Store and your account, content and messages related to your order, services and account, and content of other users.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR);
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR).
How long will we process the Personal Data we collect?
We will process your Personal Data for the purposes set out above during the period of use of your account and for a period of 5 years from the last time you logged into your account.
Sale of goods, provision of services, including delivery of goods
What Personal Data do we process?
In order to enter into a contract with you and fulfil it, to ensure quality of the goods we sell and services we provide, we process the following Personal Data:
Your name, surname, personal identification number (if applicable), email address, telephone number, address and/or delivery address, name, address, position, relationship with a represented legal entity, payment account number, payment information, order information, shopping cart history and other information necessary for provision of services.
For processing of payments in the Online Store makecommerce.lt platform is used, and it is operated by Maksekeskus AS (Niine 11, Tallinn 10414, Estonia, reg. no.:12268475), and therefore your personal information necessary for the execution and confirmation of the payment will be transmitted to Maksekeskus AS.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR);
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR).
How long will we process the Personal Data we collect?
For a duration of the contract (execution of an order) and for 10 years after the end of the contract (execution of the order)
Warranty fulfilment, administration of product quality issues
What Personal Data do we process?
In order to ensure quality of the goods, fulfilment of warranty obligations, quality of the services we provide and quality of the sold goods, we process the following Personal Data:
Your name, surname, personal identification number (if applicable), email address, telephone number, address and/or delivery address, name, address, position, relationship with a legal entity represented, payment account number, payment information, order information and other information necessary for provision of after-sales service.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR);
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR).
How long will we process the Personal Data we collect?
We will process your Personal Data for the purposes set out above during the Warranty period and/or Quality supervision period and during 5 years following completion of the Warranty period and/or Quality supervision period.
Consultation on our products and services, request management
What Personal Data do we process?
In order to be able to provide you with the requested advice regarding our products and our Online Store, we process the following Personal Data:
Your name, surname, e-mail address, telephone number, relationship with a legal entity represented when you are contacting on behalf of a legal entity, content of a request and response to a request, ordering information and any other information necessary for provision of advisory services and management of requests.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR);
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR).
How long will we process the Personal Data we collect?
We will process your Personal Data for the above purpose during the period of request management and for 1 year period following end of request management, end of consultations or the last contact, but in any case, not longer than for a 2 years period.
FPI Baltic agreements with partners and service providers, their fulfilment and other in-house management
What Personal Data do we process?
In order to enter into agreements and fulfil agreements necessary for our activities, e.g., IT system support, delivery of goods and take other in-house management steps, we process the following Personal Data:
Your name, surname, telephone number, email address, job title, workplace name, address, relationship to a legal entity where a legal entity is represented, details of your individual activity certificate, other data necessary for cooperation.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR);
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR).
How long will we process the Personal Data we collect?
For the above purpose, we will process your Personal Data for the period of service provision and/or cooperation period and 5 year following end of provision and/or cooperation period.
Financial operations, bookkeeping, debt management
What Personal Data do we process?
In order to carry out financial transactions, bookkeeping and debt management, we process the following Personal Data:
Your name, surname, email address, telephone number, job title, workplace name, address, relationship to a legal entity represented, where a legal entity is represented, payment account number, financial institution, payment information, debt information, data transmitted by a company managing collection of debts, and confirmations of payment.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR);
- processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6(1)(c) of GDPR).
How long will we process the Personal Data we collect?
For the above purpose, we will process your Personal Data in accordance with the applicable legislation, including the General Guidelines for Document Retention Periods approved by Order No V-100 of the Chief Archivist of the Republic of Lithuania dated 9 March 2011.
When Personal Data is not covered by the aforementioned scope of retention, we will process it for the duration of the contract or cooperation between the parties and for 10 years after the end of a contract and/or relationship (last contact).
Assessment and selection of candidates for a proposed job
What Personal Data do we process?
In order to be able to assess the suitability of a candidate for a job we are offering or to make an offer for another job within 3 months, we process the following Personal Data:
Your name, surname, e-mail address, telephone number, address, education and activity/experience data, content of your CV, other information necessary for selection and/or evaluation of a candidate or information provided voluntarily by a candidate.
We will rely on the following legal bases:
- processing is necessary for the performance of a contract to which the data subject is party or in order to take steps (Article 6(1)(b) of GDPR) – when you apply for a position offered by us;
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 6(1)(a) of GDPR) – when you give your consent to retention of your data after selection.
How long will we process the Personal Data collected?
We will process your Personal Data for the above purpose during selection period and for 3 months after selection has ended, provided that a candidate’s consent to the post-selection retention has been obtained (unless such consent is withdrawn earlier).
When data is not received for a specific selection – for 3 months from the date of receipt.
Management of electronic information channels
What Personal Data do we process?
In order to ensure management, operation, security and quality of electronic data submission channels (websites, social network accounts), we process the following Personal Data:
Your IP address, data collected through cookies and settings, browser used, date and time of login, model and manufacturer of a mobile device, operating system of a mobile device (iOS, Android), password information, data collected through integration of social network accounts, e.g., analytical data.
We will rely on the following legal bases:
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR); or
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 6(1)(a) of GDPR) – when Personal Data is processed for the purposes of statistics, analytics and improvement of information delivery channels.
How long will we process the Personal Data we collect?
We will process your Personal Data for the purposes set out above as specified in the “Cookies and other tracking technologies” section of this Privacy Policy.
Website data that is not included in the cookie information is stored for a maximum of 1 year from the date of collection, unless a person withdraws his/her consent (where data is processed on a basis of consent). For social network accounts, information is stored in accordance with terms and conditions set by an owner of relevant social network.
Dispute and claim resolution
What Personal Data do we process?
In order to resolve disputes and handle and settle claims, we process the following Personal Data:
Your name, surname, name, address, position, relationship to a legal entity represented, telephone number, email address, content of a claim or other similar document, information and/or documents relating to a dispute and/or claim.
We will rely on the following legal bases:
- processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and for transfer of quality goods and provision of quality services (Article 6(1)(f) of the GDPR); or
- processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6(1)(c) of GDPR).
How long will we keep the Personal Data we collect?
We will process your Personal Data for the above purpose for the duration of a dispute and/or claim and for 3 years following end of extrajudicial dispute and/or claim settling and for 10 years after the end of a legal dispute.
5. SOCIAL MEDIA AND NETWORK ACCOUNTS
We use our social network accounts to publish information about our company and products and services we offer as well as related news. We may organise competitions, promotional campaigns, customer surveys, and share information regarding job vacancies.
It is important to remember that users of social network accounts are subject not only to this Privacy Policy, but also to the privacy policies, terms and conditions of use of operators of social networks where social accounts are located. When you contact and interact with us on via social network account, we may see certain information about you as an account user depending on the privacy settings you have selected for a social network, such as your profile name, image, gender, email address, location, if you have set this information to be publicly available. Information you post as a social network account user may, depending on privacy preferences you have chosen, be made publicly available (for example, displayed in our specific social network account) if you post information when you interact with us in social network accounts.
6. HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE FOLLOW?
We only collect and process Personal Data that is necessary to achieve our stated purposes for processing Personal Data.
In processing your Personal Data, we comply with requirements of applicable current legislation, including the GDPR:
- We collect your Personal Data for specified, clearly defined and legitimate purposes and do not process it in a way that is incompatible with those purposes, except to the extent permitted by law;
- We process your Personal Data in a lawful, fair and transparent manner;
- We take all reasonable steps to ensure that Personal Data that is not accurate or complete in relation to the purposes for which it is processed is promptly rectified, supplemented, suppressed or erased. You have the right to amend and update information you provide to us. In some cases (for example, in order to deliver goods to you), we need to have accurate and up-to-date information related to you, and we may ask you to confirm periodically that information we hold about you is correct;
- We keep them in a form that allows your identity to be established for no longer than is necessary for the purposes for which the Personal Data is processed;
- We do not disclose Personal Data to third parties and will not disclose it in other way than as set out in the Privacy Policy or applicable law;
- We ensure that your Personal Data is processed securely and is protected against loss, unauthorised use and alteration. We have set up physical and technical measures to protect the information we collect from accidental or unlawful destruction, damage, alteration, loss, disclosure or any other unauthorized processing. Security measures for Personal Data are selected taking into account risks involved in the processing of Personal Data;
- Our employees are under written obligation not to disclose or distribute your Personal Data to third parties.
7. TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?
Your Personal Data to other data controllers or processors we will transfer only as set out in this Privacy Policy.
Information published in the Website and/or social networks may be viewed by other users of services and/or visitors of social networks. We require from users of the Online Store services to comply with our terms of use. We also reserve the right to provide information about you if, in accordance with the applicable law, we are required to do so by law enforcement, prosecuting authorities or other authorities who have a right to request mandatory information provision.
We may transfer your Personal Data:
- To our partners or consultants, such as providers of server hosting, data centres, cloud, service, IT, payment, audit, legal, tax advisory services, claim management, debt collection, parcel delivery services. We require data processors to store, process and handle Personal Data as responsibly as we do and only according to our guidelines.
- We provide Personal Data to operators of social networking platforms in order to publish your content on our social networking accounts. We transfer Personal Data outside the European Economic Area to the following social network operators:
- Meta Platforms, Inc. (USA) (data is securely transferred to the service provider by signing the Standard Contractual Clauses for Data Transfers Outside the European Economic Area approved by the European Commission (EUR-Lex – 32021D0914 – EN – EUR-Lex (europa.eu)).
- We continuously undertake steps to improve our Online Store and Website as well as services we provide to ensure protection, security and confidentiality of the Personal Data we process, and to be able to perform certain business-related functions to make our E-Commerce and other services accessible and functional. For this reason, we transfer your Personal Data to service providers who provide cloud and hosting services, IT security, supervision, technical support and communication services.
- To law enforcement and pre-trial investigation authorities, courts and other dispute resolution authorities, state or local government bodies and institutions, and other persons performing functions mandated by law in accordance with applicable legal acts. We provide these entities with the information required by law or specified by the entities themselves;
- To other third parties such as financial institutions, payment institutions, etc;
- Where appropriate, to companies that would aim to buy or would buy FPI Baltic’s business or engage in joint activities or other forms of cooperation with us, as well as to companies established by us.
8. WHAT RIGHTS DO YOU HAVE?
As a data subject, you have the following rights relevant to your Personal Data:
Right to be informed
We inform you about processing of your Personal Data in this Privacy Policy, which we publish on the Website. In certain cases, we may also provide you with separate information notices to provide more detailed information about processing of your Personal Data.
Right to access your Personal Data processed by us
You have the right to ask us to provide you with a copy of your Personal Data we process. There are certain exceptions, for example, when we have to take due regard to the rights of others, so you may not always be able to receive all your Personal Data processed by us.
Right to correction of Personal Data
You can review and update your Personal Data through your account in the Online Store. You also have the right to ask us to correct information that you believe to be inaccurate. You also have the right to ask us to complete information that you believe is incomplete.
Right to removal of Personal Data
You have the right to ask us to erase your Personal Data in certain circumstances (right to erasure and right “to be forgotten”)
Right to restrict processing of Personal Data
You have the right to ask us to restrict processing of your Personal Data in certain circumstances. This means that your data can only be used for certain purposes, e.g., for compliance with our legal requirements or for implementation of our rights.
Right to object to Personal Data processing
You have the right to object to processing of your Personal Data if we process it on the basis of legitimate interest. If you object, we will continue to process your Personal Data only in case of compelling legitimate grounds which override your interests, rights and freedoms or aiming to declare, exercise or protect legal requirements.
Right to Personal Data migration
In certain circumstances, you have the right to request that we transfer Personal Data you have provided to us from one of our organisations to another or that we provide such information to you. This applies only in respect of Personal Data you have provided. This right will only be exercised if there are adequate grounds and measures in place ensuring that transfer of the requested Personal Data will not put the data of others at risk.
Right to withdraw consent to Personal Data processing
You have the right to withdraw your consent to processing of your Personal Data where such processing is carried out or intended to be carried out for the purposes of direct marketing, including profiling to the extent it is related to such direct marketing (based on the Personal Data you have provided to us, profiling for the purpose of direct marketing may be carried out in order to provide you with solutions and offers tailored to your needs. You may withdraw or object to processing of your Personal Data by automated processing, including profiling, at any time).
Implementation of the Rights
If you wish to exercise any of your rights set out above, you can contact us by email: info@fpifurniture.eu.
For security reasons, in some cases we may not be able to comply with your requests without verifying your identity, and we may ask you to provide proof of your identity, such as a personal document or other information. If we receive a request by email, depending on the content of the request, we may ask you to provide a request signed with a qualified electronic signature, to send the request by post, or to visit us.
You can exercise some of your rights as a data subject by changing settings and the information in your account in the Online Store. Please note that if you change your account settings or information you upload, the Online Store may not work or may malfunction.
We do not normally charge any fee for use of your rights. However, we are permitted by law to charge a reasonable fee or to refuse to comply with your request if it is clearly unjustified manifestly unfounded or excessive.
If you do not want your Personal Data to be processed for the purposes of direct marketing, competitions, surveys, including profiling, you may request your withdrawal from such processing without giving reasons for such withdrawal by sending an email to info@fpifurniture.eu or by any other means indicated in a message sent to you (e.g., by clicking on a relevant link in a newsletter).
Upon receipt of your request or instructions regarding processing of Personal Data, we will provide you with a response no later than 1 month following the date of the request and will undertake steps specified in your request or inform you why we refuse to do so. If necessary, the time limit may be extended by further 2 months depending on the complexity and number of requests. In this case, we will inform you of the extension within 1 month of receipt of the request.
9. NEWS AND DIRECT MARKETING
We may send our offers and information about our services (direct marketing notification) to your email address and/or telephone number if you have given us your consent to do so, or if you or an organisation you represent is our client. We may personalise direct marketing notification by using information about how you use our services, such as how often you use our Online Store and your account settings, what message / e-mail has been read, what links have been clicked on, etc. This information is collected in order to offer you relevant and more tailored news.
Your contact details may be passed on to our partners/processors who provide us with newsletters or quality assessment services.
If you no longer wish to receive direct marketing notifications, please click on the “Unsubscribe” link in the footer of one of our emails or unsubscribe by emailing us at info@fpifurniture.eu.
Withdrawing your consent does not automatically oblige us to destroy your Personal Data or to provide you with information about the Personal Data we process, so if you want us to do this as well, you shall make a separate request.
10. COOKIES AND OTHER TRACKING TECHNOLOGIES
A cookie is a small text file that a website stores on your computer or mobile device when you visit it. A cookie allows a website to “remember” your actions and preferences (such as your registration name, language, font size and other display options) for a certain period of time without you having to re-enter them each time you visit the website or browse through its various pages. Other technologies, including data we store in your browser or device, identifiers associated with your device and other software may be used for similar purposes. Cookies are used extensively to make websites work or work better and more efficiently. For the purposes of this Privacy Policy, all such technologies are referred to as “cookies”.
We use cookies to analyse information flows and user behaviours, to promote trust and ensure security, to ensure the proper functioning of the Website and/or Online Store, to improve it, to remember your preferences, to personalise content shown to you, to link the Website to your accounts in social networks.
You can choose whether to accept cookies or not. If you do not agree to cookies being placed on your computer or other device’s browser, you can tick the cookie consent bar, change the settings of a browser you are using and disable cookies (either all at once, or one at a time, or in groups). If you don’t want to accept cookies on your mobile device, you shall follow official instructions for such device. Please note that in some cases, non-accepted cookies may slow down your browsing speed, restrict functionality of certain websites or block access to a website.
For more information, please visit http://www.AllAboutCookies.org or https://www.google.com/privacy_ads.html. You can disable cookies used by third parties for advertising-related purposes by visiting “Digital Advertising Alliance” website at https://optout.aboutads.info/?c=2&lang=EN.
We may use mandatory cookies which are necessary for operation of the Website, analytical cookies, functional cookies which are designed to analyse traffic to the Website, to remember user preferences and to tailor them to the Website so that we can provide enhanced functionality, performance cookies, third party cookies which are used by third parties, advertising cookies which are designed to show you personalised and generic advertisements.
We use “Google Analytics”, a web analytics service, provided by Google LLC, which allows us to analyse your use of the Website, to compile reports based on this analysis, and to plan and predict performance of the Website and provision of Services. Data collected by “Google Analytics” is generally transmitted to and stored on a Google LLC server in the USA. We have implemented IP anonymization on the Site so that Google LLC will hide your IP address in EU member states and other countries that are signatories to the European Economic Area Agreement. You can change your browser settings to prevent “Google Analytics” from analysing your information. In this case, an opt-out cookie will be set for you. However, if you delete all cookies, the opt-out cookie may also be deleted. You can also prevent Google from capturing data generated by a cookie based on your use of the Website and from processing such data by downloading and installing a browser plug-in from https://tools.google.com/dlpage/gaoptout?hl=en.
More information about our use of cookies is available on the Website.
11. CONTACT US
If you have any questions about this Privacy Policy, you can always contact us using the contact details below:
Email: info@fpifurniture.eu
Address: Liuksemburgo aklg. 31, LT-46401, Kaunas, Lithuania
If you have a complaint or would like to make a formal complaint about the way we process your Personal Data, please contact us at the above email address with as much information as possible. We will cooperate with you and endeavour to resolve any issue promptly.
In addition, you can always lodge a complaint with our supervisory authority, the State Data Protection Inspectorate, for more information and contact details please visit the Inspectorate’s website (https://vdai.lrv.lt/). We aim to resolve all disputes promptly and amicably, so you are welcome to contact us first.