This Privacy Policy lays down information on the processing of personal data by data controller which is mandatory in accordance with the EU’s General Data Protection Regulation (hereinafter – the Regulation). This Privacy Policy is designated for people, whose multi-apartment buildings are administered by Civinity Group, who use the services provided by Civinity Group, are interested in employment opportunities at Civinity Group and / or visit the websites www.civinity.com, www.civinity.lt, civinitysmart.com or websites of other Civinity Group companies. For the purposes of this Privacy Policy, Civinity Group includes Civinity AB, legal entity code 302247881 and its directly and indirectly controlled legal entities, including UAB Civinity LT, legal entity code 304726371, Civinity Namai UAB, legal entity code 121452134, Civinity Namai Vilnius UAB, legal entity code 300510344, Civinity Namai Kaunas, UAB, legal entity code 132125543, Civinity Namai Klaipėda, UAB, legal entity code 140336910, Civinity Namai Vakarai, UAB, legal entity code 140597134, Civinity Namai Palanga, UAB, legal entity code 152429379, UAB Kretinga Būstas, legal entity code 300531826, UAB Debreceno Valda, legal entity code 140524652, Civinity Engineering, UAB, legal entity code 125169233, Civinity Solutions, UAB, legal entity code 300131675. The data controller may be any or several of the above-listed companies, depending on the actions of the data subject.

The information below covers the following purposes of data processing: (i) processing of data of persons using electronic customer system; (ii) processing of data on candidates participating in selection procedures; (iii) quality control and assurance of proper provision of services (call recording); (iv) administration of complaints, inquiries and feedback; (v) e-mail communication. This document also describes your rights as a data subject, provision of data to data recipients and other conditions for the processing of personal data applicable to all personal data processed for above purposes.

Processing personal data of persons using electronic customer system

We process data of persons using the electronic customer system in order to provide building administration and maintenance services and to issue invoices for the services electronically.

The use of the electronic customer system is voluntary – if you wish, you may not use this system and continue to get invoices by post. However, if you decide to use the electronic customer system, you will need to provide your personal data as requested during registration. If you do not provide such personal data, we will not be able to identify, to register you and to allow you to use the system.

We shall process your personal data on the basis of your consent, performance of the contract and discharge of obligations provided for by legal acts.

We shall store your personal data for 10 years after we stop providing the service.

Processing personal data of candidates taking part in selection procedures

If you sent your CV for a specific job position in response to a job ad posted on our website or on a specialized recruitment and job search website, we shall process your voluntarily submitted and other personal data listed below for employee selection purposes.

We shall process your personal data till the end of the selection procedure, i. e. until we will decide to hire a specific candidate, the end of his/ her trial period or until we will decide to end the selection without selecting any candidate. After the selection procedure, we shall destroy your personal data, unless you consent to continued storage of your data for future selections. If you consent to us storing your data after the selection procedure, please inform us thereof by e-mail or express your consent during our meeting. If you give such consent, we shall store your data for 6 years, and should we need to hire a new employee in our company during this period of time, we shall contact you. At the end of the 6-year period, we shall destroy your personal data.

We shall process your personal data on the basis of your consent to participate in selection procedures and to continue to store them, also on the basis of obligations and rights provided for in legal acts.

Please be informed that by exercising the right granted to us by legal acts regulating the protection of personal data, we may contact your previous employers and ask for their opinion on your qualifications, professional abilities and relevant skills. However, we shall not contact your current employer without your express prior consent thereto.

Quality control and assurance of proper provision of services (Call recording)

We shall record phone calls in order to control the quality of the provided services and to ensure their proper provision. Call recording shall be based on your consent – you shall be informed that the call will be recorded before starting the conversation, and you shall be asked to continue the conversation only if you consent to it being recorded. If you do not consent to recording the call, you can end the call and contact us by e-mail, mail or come to our office. Please be informed that we will be able to provide you with information falling within the category of personal data by e-mail or post only after identifying you or having your completed form confirming that the e-mail which you used to e-mail us actually belongs to you.

Call recordings shall be stored for a maximum of 45 days and will then be destroyed.

Administering complaints, inquirieS or feedback

If you have filed with the company a complaint, inquiry or feedback by e-mail or other means, we shall process your voluntarily provided personal data for the purpose of administration of this complaint, inquiry or feedback.

If your complaint relates to a potential dispute, potential damage, etc., your personal data may be stored for a maximum period of 10 years. If your personal data are not related to a potential dispute, we shall destroy them sooner than that.

The processing of your personal data shall be based on the expression of your free will, i.e. a consent, but in certain cases discharge of the obligations provided for in legal acts may become the basis for further storage of a complaint.

E-mail communication

According to the Regulation, the content of e-mail correspondence shall be considered personal data, even if the correspondence is between employees of legal entities. Therefore, we shall apply the rules on the processing of personal data required by the Regulation to the content of communication and to e-mail addresses.

The basis of the processing of your personal data shall be the expression of your free will to correspond and to provide certain data in the correspondence, i.e. your consent. Moreover, performance of the agreement and discharge of obligations provided for in legal acts may also be the basis of processing of data.

We shall process your e-mail address, content of correspondence and related data in accordance with the principle of proportionality. These data shall first of all be accessible by the employee with whom you communicate directly. However, in certain cases, other employees of our company may also read your correspondence for the purposes of, say, internal administration, investigation of possible violations of legal acts or internal rules, substitution of an employee and other related purposes.

Provision of personal data to data recipients

We shall provide your personal data to the following:

• IT, server, mail, archiving, marketing, accounting, debt recovery, call center, payment collection service providers;
• banks and payment institutions;
• subcontractors who carry out works related to the administration and maintenance of buildings on our behalf;
• companies of the same group;
• notaries, bailiffs, lawyers, consultants, auditors;
• law enforcement and supervisory authorities, courts, other dispute resolution institutions;
• potential or existing successors of our business or a part thereof, or their authorized consultants or persons;
• multi-apartment building community representatives, joint activity representatives.

Key principles of protection of personal data which we comply with

We shall follow the following principles when collecting and using personal data which you entrusted to us or which we legitimately received from other sources:

• Your personal data shall be processed in a lawful, fair and transparent manner (principle of lawfulness, fairness and transparency);
• Your personal data shall be collected for specified, clearly defined and legitimate purposes and shall not be further processed in a way incompatible with those purposes (principle of purpose limitation);
• Your personal data shall be adequate, relevant and only such, which are necessary in pursuit of the purposes of their processing (principle of data minimisation);
• The personal data processed shall be accurate and kept up to date, if necessary (principle of accuracy);
• Your personal data shall be stored in a form that allows identifying a person for no longer than is necessary for the purposes for which your personal data are processed (principle of storage limitation);
• Your personal data shall be processed in such a way as to ensure adequate security of personal data through application of respective technical or organizational measures, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage (principle of integrity and confidentiality).

Provision of administrative services and sending of invoices

Please be informed that when providing apartment building administration services, we can receive personal data necessary for the provision of these services not only directly from the data subject, but also from third parties. In cases where it is not possible to serve the account at the address of the real estate of the data subject, and we do not have other contact details, we receive the address of the declared place of residence of the data subject from the Public Institution Centre of Registers. The aforementioned personal data is needed in order to find out to which address and method to send invoices for the services provided.

Implementation of rights of the data subject

Please be informed that you have the following rights of the data subject: the right to access your data and know how they are processed; the right to request to rectify or, given the purposes of the processing of personal data, to supplement incomplete personal data; the right to request the destruction of your data or to suspend the processing of your data (except for storage); the right to request that the processing of your personal data is restricted; the right to data portability; the right to lodge a complaint with the State Data Protection Inspectorate; the right to withdraw your consent.

In order to exercise your data subject rights, we will have to identify you. Without identifying you, we will not know if the person contacting us is really the person whose personal data we process, and thus we will not be able to implement your rights.

We may refuse to process your request for the exercise of your rights, or we may charge a respective fee therefor, if the request is manifestly unfounded or excessive, also in other cases provided for by law.

If you want to exercise your data subject’s rights or have other questions regarding the processing of your personal data, please contact us by e-mail hello@civinitysmart.com.