This privacy policy (hereinafter referred to as Policy) establishes the terms for the processing of personal data while using the internet website of the closed joint-stock company "Dzūkijos agrokoncernas", code: 135738170, address: Laisvės al. 85B-2, LT-44297 Kaunas, which is part of the Royal Horse Resort service complex http://www.rhr.lt (hereinafter referred to as Website) and the Royal Horse Resort service complex.
The conditions set out in this privacy policy apply each time you log in to the Website, regardless of the device (computer, mobile phone, tablet, television, etc.) you use and each time you visit the Royal Horse Resort service delivery center.
Through this online privacy policy, we inform you of the information we collect about you when you visit the Website or the Royal Horse Resort service complex, how long we keep this information, and what rights data subjects have. Therefore, it is very important that you read this Policy carefully and assess the conditions with which you agree. If you do not agree with these conditions, please do not visit the Website, do not use our content and/or services.
The data subject, by providing their personal data (including data that is provided directly or indirectly by visiting the Website and using its services), agrees and does not object to the Data Controller managing and processing them in accordance with this Privacy Policy and for the purposes and procedures specified in the consent of the data subject and legal acts.
Personal data is processed in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as Regulation), as well as the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal acts regulating the protection of personal data.
KEY TERMS
Data Controller/Company – a legal or natural person who alone or in conjunction with others determines the purposes and means of processing personal data. Within the scope of this Policy, the Data Controller is the closed joint-stock company "Dzūkijos agrokoncernas", code:
135738170, address: Laisvės al. 85B-2, LT-44297 Kaunas.
Data Subject - in this Privacy Policy, it is considered any person who contacts the Data Controller with a request, enters into a service provision contract, an applicant, a caller, or any other natural person whose personal data is processed by the Data Controller.
Inquiring Person – an individual interested in the services provided by the Data Controller or wishing to contact the Data Controller on other issues.
Client - a person who has purchased goods or services from the Data Controller or has entered into a contract with the Data Controller for the purchase of goods and/or provision of services, or a person who arrives together with a person who has entered into the contract and to whom the Company will provide services.
Candidate - a person participating or intending to participate in the recruitment conducted by the Data Controller.
Caller – a person calling the contact phone number indicated on the Website regarding the services provided by the Data Controller and/or other issues.
Participant – a person participating or intending to participate in games, promotions, and/or contests organized by the Data Controller.
Personal Data – any information relating to an identified or identifiable natural person – the data subject, which is processed by the Data Controller and by which the person can be identified, including but not limited to: name, surname, email address, etc.
Data Processing – any operation or set of operations performed on personal data: collection, recording, accumulation, storage, alteration (enrichment or correction), provision, use, destruction or other action or set of actions.
Consent – a freely given, specific, informed, and unambiguous indication of the data subject’s wishes, by which he or she signifies agreement to the processing of personal data.
Privacy Policy – this document/procedure which sets forth the main rules for the collection, accumulation, processing, and storage of personal data.
Cookies – small files placed on your computer, phone, tablet, or other device that help the website recognize the device.
Website – the web page managed by the Company http://www.rhr.lt
Service Provision Complex – the Royal Horse Resort complex owned by the Company, located at Šilelio g. 2, Balkasodžio km., Alytaus r.
II. PRINCIPLES OF PERSONAL DATA PROCESSING
We collect and process the personal data specified in this Policy only on a lawful basis – your consent and/or our legitimate interest and/or the fulfillment of legal obligations applicable to us, and we will not process data in a way incompatible with this purpose, except as permitted by law.
We strive to ensure that personal data is processed accurately, fairly, and lawfully, that it is processed only for the purposes for which it is collected, and in compliance with the Regulation and other legal acts establishing clear and transparent principles and requirements of personal data processing.
We ensure that your Personal Data is processed in such a way that, taking appropriate technical or organizational measures, there is adequate security for personal data, including protection against unauthorized processing or unlawful processing of personal data and against accidental loss, destruction or damage.
We take all reasonable measures to ensure that personal data that is inaccurate or incomplete, considering the purposes of its processing, is promptly corrected, completed, its processing is suspended or is destroyed.
III. INFORMATION COLLECTED BY THE COMPANY
We collect information about you directly, obtaining the information from you while using the Website or in another way when purchasing services/goods from the Company.
Information about you may also be obtained by generating visit statistics.
With your consent, the Company may collect information about your device or your use of our website content.
The Company may also collect information about you from public and commercial sources (as permitted by applicable law) and from third-party social network services when you connect to them.
You may choose not to provide us with certain information; however, in that case, you may not be allowed to use the service we offer.
IV. PERSONAL DATA PROCESSING
The Company, as the Data Controller, collects personal data in compliance with applicable European Union and Republic of Lithuania legal requirements and instructions of relevant state institutions. The Data Subject applies all reasonable technical and administrative measures to protect the collected data about the Data Subject from unlawful loss or unauthorized use.
The Company, in order to provide services and carry out activities, must collect personal data of Data Subjects. Accordingly, this Policy informs about the purposes of the Company’s activities and service provision and how personal data is collected and processed.
4.1. For the purposes of submitting inquiries
On the Website http://www.rhr.lt there is an opportunity to send us a request.
At your choice and with your consent, for the purpose of submitting a request and receiving a response, we collect and process the following personal data:
1. Name;
2. Surname;
3. Email address;
4. Other personal data you voluntarily provide along with the content of the request.
You can also submit requests to the Company by phone or email, as well as on social media Facebook and Instagram accounts. The Data Subject processes the personal data of Inquiring Persons and/or Callers by phone:
1. Name;
2. Surname;
3. Phone number;
4. Email address.
The Company strives to ensure the quality of service provision by recording phone conversations. Callers are informed about this before the call begins. If the Caller does not agree to the recording of the call and the processing of the data, they must terminate the call.
Personal data collected for the purposes of inquiries and consultations is retained for 1 (one) year from the date of fulfillment of the inquiry.
If, following the submission of a request, the Data Subject has agreed to the provision of services by the Company, then the personal data is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.2. For the purposes of providing accommodation, SPA, and sports complex services
The Company, in providing accommodation, SPA, and sports complex services, collects and processes the following Customer data:
1. Name;
2. Surname;
3. Date of birth;
4. Residential address;
5. Phone number;
6. Email address;
7. Payment information for services rendered;
8. Car registration number, if the Client will use the Service Provision complex parking area;
9. Health data if necessary to provide SPA services;
10. Loyalty program member information;
11. Other information related to the purchased service/product if personal data is necessary for providing the service/product.
Personal data for the purpose of providing services is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.3. For the purposes of organizing conferences and events
The Company, in providing conference and event organization services, collects and processes the following personal data:
1. Name;
2. Surname;
3. Date of birth;
4. Email address;
5. Phone number;
6. Residential address;
7. Payment information for services rendered;
8. Car registration number(s), if the Client will use the Service Provision complex parking area;
9. Loyalty program member information;
10. Other information related to the purchased service/product if personal data is necessary for providing the service/product.
Personal data for the purpose of providing services is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.4. For the purposes of training and competitions with their horses
The Company, in providing training and competition services with its horses, collects and processes the following personal data:
1. Name;
2. Surname;
3. Date of birth;
4. Email address;
5. Phone number;
6. Residential address;
7. Payment information for services rendered;
8. Car registration number(s), if the Client will use the Service Provision complex parking area;
9. Loyalty program member information;
10. Health data and related information demonstrating that the Client meets the requirement to periodically check their health;
11. Other information related to the purchased service/product if personal data is necessary for providing the service/product.
Personal data for the purpose of providing services is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.5. For the purposes of organizing competitions
The Company, in providing services for organizing horse competitions, collects and processes the following personal data:
1. Name;
2. Surname;
3. Date of birth;
4. Email address;
5. Phone number;
6. Residential address;
7. Payment information for services rendered;
8. Car registration number(s), if the Client will use the Service Provision complex parking area;
9. Loyalty program member information;
10. Health data, including, but not limited to, medical examination results prior to competitions, doping test results, or data on other substances;
11. Other information related to the purchased service/product if personal data is necessary for providing the service/product.
Personal data for the purpose of providing services is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.6. For the purposes of organizing excursions
The Company, in providing excursion services in the Service Provision area, collects and processes the following personal data:
1. Name;
2. Surname;
3. Date of birth;
4. Residential address;
5. Phone number;
6. Email address;
7. Payment information for services rendered;
8. Car registration number(s), if the Client will use the Company’s parking area;
9. Other information related to the purchased service/product if personal data are necessary for providing the service/product.
Personal data for the purpose of providing services is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.7. For the purposes of organizing photo sessions
The Company, in providing photo session services in the Service Provision area, collects and processes the following personal data:
1. Name;
2. Surname;
3. Date of birth;
4. Residential address;
5. Phone number;
6. Email address;
7. Payment information for services rendered;
8. Car registration number(s), if the Client will use the Company’s parking area;
9. Other information related to the purchased service/product if personal data is necessary for providing the service/product.
Personal data for the purpose of providing services is retained for 10 (ten) years from the expiration of the contract. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subject and the requirements established by legal acts.
4.8. For the purposes of recruiting candidates for job positions
The Data Controller processes the personal data voluntarily provided by the Candidate for recruitment purposes to the extent that the personal data was submitted together with the CV and/or cover letter.
Candidate data is processed on the basis of consent expressed by providing their data and an intention to take action through the Candidate's tacit actions and/or request before entering into a contract.
Candidate personal data (CVs, cover letters, and other personal data submitted) are processed and retained for 2 (two) months from the date of hiring the Candidate. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subjects and the requirements established by legal acts.
4.9. For the purposes of organizing promotions, contests, and games
The Data Controller, with the consent of the Data Subject, processes personal data for the purposes of conducting contests or promotions. The Data Controller may collect the following personal data:
1. Name;
2. Surname;
3. Photographs;
4. Phone number;
5. Email address.
Data is obtained directly from Data Subjects participating in the games, promotions, and/or contests. This data is not disclosed to third parties, but may be publicly announced on the Data Subject's Website and/or on the Data Controller's social media accounts on Facebook or Instagram. The Data Controller may publish: name, surname, photograph.
Personal data is processed on the basis of consent expressed by providing their personal data and is retained for 1 (one) year from the date of fulfillment of the contest, game, or promotion. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subjects and the requirements established by legal acts.
4.10. For the purposes of direct marketing
The Data Controller, with a clearly expressed consent of the Data Subject, processes personal data for direct marketing purposes.
For the purposes of direct marketing, the following personal data is processed:
1. Name;
2. Surname;
3. Phone number;
4. Email address;
5. Information on participation in the loyalty program.
Through newsletters, the Data Controller aims to provide the Data Subject with relevant information regarding discounts, special offers, etc.
The Data Controller may collect statistical data about the Data Subject's behavior related to the use and content of the newsletter (for example, whether the newsletter was read, which links were opened by the Data Subject).
The Data Subject's email address may be used for advertising through Facebook, Instagram, Google, and other advertising platforms, tailoring advertisements to the target audience.
Based on the personal data you provided, profiling of your personal data may be carried out for the purpose of direct marketing to offer you individualized solutions and offers.
You can withdraw your consent to process personal data automatically, including profiling, at any time or object to such processing (if such a method is applied).
Personal data is collected directly from Data Subjects. The Data Controller may share personal data with third parties only if they provide specialized services to send emails and/or SMS with tailored offers or to order the nature of the advertising.
Personal data of Clients and other Data Subjects is processed on the basis of consent expressed by providing their data and agreeing to process personal data for direct marketing purposes.
The Data Subject has the right to refuse or withdraw their consent for the processing of their personal data for direct marketing purposes, including profiling, as far as it relates to such direct marketing, without stating the reasons for the refusal. To withdraw your consent to process personal data for direct marketing purposes, the Data Subject can open the newsletter and click on the existing link to "unsubscribe from the newsletter" at the end or send an email to the Data Controller: info@rhr.lt.
Personal data for the purposes of direct marketing is retained for 5 (five) years from the date of providing consent to process data for this purpose. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subjects and the requirements established by legal acts.
4.11. Video surveillance
Video surveillance is conducted in common areas of the service provision area to ensure the safety of Clients, employees, and their property.
Video data is recorded by the Data Controller’s video surveillance equipment while you are visiting the common areas of the Service Provision complex. Video data may only be transferred to law enforcement authorities in accordance with the procedures established by the legal acts of the Republic of Lithuania.
Personal data for the purpose of video surveillance is processed on the basis of the Data Controller's legitimate interest.
Personal data for video surveillance purposes is processed and stored for 60 (sixty) days. Upon expiration of the specified period, the data will be deleted in a manner that prevents restoration, unless the term has been extended as long as it does not infringe upon the rights of the Data Subjects and the requirements established by legal acts.
V. YOUR RIGHTS
In accordance with the Regulation, you, as a data subject with respect to whom data processing is performed, have the following rights:
1. The right to be informed about the processing of your data;
2. The right to access your data and how it is processed;
3. The right to request the correction of your personal data with respect to the purposes of processing, to complete incomplete personal data;
4. The right to be forgotten – to delete your personal data or suspend the processing of your data (except for storage);
5. The right to restrict the processing of data – to request that the Data Controller restrict the processing of data;
6. The right to data portability;
7. The right to object to the processing of your data for direct marketing purposes, including profiling, as far as it relates to direct marketing;
8. The right to lodge a complaint with the state supervisory authority;
9. Other rights specified in the Regulation.
The Data Subject, exercising the above rights, can submit any request or instruction to the Data Controller regarding the processing of personal data by writing to the email address: info@rhr.lt.
The Data Controller shall respond to such requests or instructions no later than one month from the date of the request and shall take actions specified in the request or refuse to perform them. If necessary, the specified period may be extended by another two months, considering the complexity and number of requests. In this case, the Data Controller will inform the Data Subject about such extension within one month from the date of receipt of the request, providing the reasons for the delay.
The Data Controller may not enable Data Subjects to exercise the rights listed above, except for objecting to the processing of personal data for direct marketing purposes when legally specified that it is necessary to ensure the prevention, investigation, and identification of crimes or violations of official or professional ethics, as well as to protect the rights and freedoms of the Data Subject, Data Controller, or other persons.
VI. TRANSFER OF DATA TO DATA PROCESSORS AND THIRD PARTIES
In order for the Company to properly provide services and effectively carry out the Contract, the Company has the right to involve other data processors for personal data processing.
Personal data collected for the purposes of promotions, contests, lotteries may be publicly announced on the Website or on the Instagram and/or Facebook accounts managed by the Company.
Photos taken during competitions or other events organized by the Company may be published on the Website and/or on the Company’s social networks.
For the purpose of providing services to the Data Subject, their data may be transferred to the Company's partners to the extent necessary to fulfill the service.
VII. THIRD PARTY SERVICES
The Company informs that there may be advertisements from third parties, links to their websites and services on the Website, which the Data Controller does not control, for example, a link to the Data Controller’s social media profile. The Data Controller is not responsible for the security and privacy of the information collected by third parties.
You should read the privacy policies applicable to third-party websites and services you use.
If you provided data about yourself through social networks, we understand that you agree that we can contact you using the provided contact phone number and email to offer services.
VIII. COOKIES
We are constantly improving our website to make it as easy and convenient to use as possible, and to ensure that the content and features presented meet your needs. In order to enhance your browsing and experience on the Website, we use the following cookies:
· Necessary cookies that are essential for the website to function properly and smoothly and help improve browsing quality. The following necessary cookies are used on the Website:
1) Wordpress session ID (WP_SESSION_COOKIE)
2) pll_language.
· Google analytics cookies analyze user behavior on the website.[KJ1]
What are cookies?
A cookie is a small set of data (file) stored on the user's computer or other device used for logging on to the service provider's websites. With the help of cookies, the website recognizes the user's device (for example, the next time the user visits this website), thus enabling easier user navigation on the website and/or providing certain information about the use of such a website to the website owner.
Why do we use cookies?
The information collected by these cookies allows us to ensure that you can browse more conveniently, learn more about the behavior of our website users, analyze traffic, trends, and improve the website. Cookies may also be used for direct corporate marketing, advertising, and/or remarketing based on user (consumer) lists. The aim of such marketing is to provide information about services to users who previously visited the website mentioned above. Our cookies do not allow us to identify you as a user of our website, the information collected is anonymous, and we do not provide it to third parties.
How to control cookies?
You can withdraw your consent for cookies at any time by changing your internet browser settings and deleting the cookies stored.
Please note that in some cases, deleting cookies may slow down online browsing, limit certain functionalities of the website, or block access to the website.
Our website may contain links to the websites of other individuals, companies, or organizations. Please note that the Data Controller is not responsible for the content of such websites or the privacy assurance principles they apply. Therefore, if you click a link from the Data Controller’s website and reach other websites, you should separately check their Privacy Policy.
To learn more about how to manage cookies, visit: http://www.allaboutcookies.org/manage-cookies/.
IX. FINAL PROVISIONS
The Company's manager or a designated person is responsible for data processing/deletion.
By contacting the Company by email at info@rhr.lt you can exercise your rights as a data subject established by personal data protection laws. You must submit your request for the implementation of your rights as a data subject in writing to the contacts of the Company specified in this Policy.
By browsing our website, providing data, etc. you agree that you are familiar with the applicable privacy policy.
By browsing our website, you agree to the recording of cookies on your computer or other device.
Amendments or changes to the privacy policy shall take effect from the day they are posted on the Website.
If, after the amendment or change of the Privacy Policy, the Data Subject uses the Website and/or the services provided by the Data Controller, it is deemed that the Data Subject does not object to such amendments and/or changes.
X. CONTACT US
If you have any questions regarding the information presented in this Privacy Policy, please feel free to contact us by any method convenient for you:
By phone: +37068599996
Email: info@rhr.lt
