CUSTOMER PRIVACY POLICY

Last update: 3 January 2023

UAB A5 investicijos is committed to protecting your information. We comply with the European Union’s General Data Protection Regulation (GDPR) and other laws protecting your information, which we collect, use and store in our Company.

1. HOW SHOULD THIS PRIVACY POLICY BE READ?

This Privacy Policy will answer important questions about how we collect, use and protect information about you. If you have any questions or if any part of this Privacy Policy is unclear, our Data Protection Coordinator will readily assist you as described in Section 8 of this Privacy Policy. Please note that any form of the word ‘we’ in this Privacy Policy refers to our Company as set out in Section 2 of this Privacy Policy.

2. WHO IS RESPONSIBLE FOR THE PROTECTION OF MY INFORMATION?

We are: UAB A5 investicijos; legal entity number: 306058312;

Address: Gynėjų g. 16, Vilnius;

3. WHY DO YOU COLLECT INFORMATION ABOUT ME? WHAT IS THE LEGAL BASIS FOR COLLECTING, USING AND STORING INFORMATION ABOUT ME?

Purpose of data collection, use and storageLegal basis for data collection, use and storage
Conclusion of a preliminary real estate sale/purchase agreement Your personal data are required for concluding a preliminary real estate sale/purchase agreement with you (Article 6(1)(b) GDPR);
Conclusion of a notarial real estate sale/purchase agreementYour personal data are required for concluding a notarial real estate and purchase agreement with you (Article 6(1)(b) GDPR);
Property valuation – If you need a property valuation to obtain financing for the purchase of the real estate, we can offer it to you as a giftA property valuation is offered as a gift when buying a home, i.e. even in the absence of a written gift agreement, if we carry out a valuation of the property you intend to buy, an oral gift agreement with you is deemed to be made (Article 6(1)(b) GDPR);
For us to be able to comply with legal obligations related to the performance of the service agreement and applicable to us in terms of taxation, accounting and archiving of documents Your personal data is required for the performance of our legal obligations (Article 6(1)(c) GDPR);
For us to be able to respond to your requests, enquiries and complaintsWe have a legitimate interest in administering and responding to requests, complaints and enquiries we receive (Article 6(1)(f) GDPR), and to the extent that such requests, enquiries and complaints are related to the performance of an agreement that you are about to enter into, or that has already been concluded, the administration of such requests, enquiries or complaints is necessary for the purpose of entering into or proper performance of the agreement (Article 6(1)(b) GDPR).

4. WHAT TYPE OF INFORMATION AM I REQUESTED TO PROVIDE?

In order to conclude a preliminary real estate sale/purchase agreement, you should provide us with the following information about yourself (and the other buyer, if you are buying the property jointly with another person), without which we would not be able to conclude this agreement:

  • identification data (name, surname, personal number);
  • contact details (phone number, e-mail address, address).

For us to carry out a property valuation of the home you are planning to buy, you are requested to provide us with the following information, which we will need to communicate to the company carrying out the valuation and without which we will not be able to complete the property valuation:

  • identification data (name, surname, personal number);
  • contact details (phone number, e-mail address, address);
  • credit institutions to which the property valuation report will be submitted.

In order to conclude a notarial property sale and purchase agreement, you are requested to provide us with the following information about yourself (and the other buyer, if you are buying the property jointly with another person), without which we would not be able to conclude this agreement:

  • identification data (name, surname, personal number);
  • contact details (phone number, e-mail address, address);
  • information about your children, if any;
  • information whether you are married, if you are buying the property with another person; which company will finance the sale and purchase agreement, if you take out a loan to buy the property.

5. DO YOU SHARE MY INFORMATION WITH OTHER ENTITIES?

When processing your personal data, we may transfer it to the following categories of recipients:

  • our service providers – providers of IT services, data warehouses, customer management platform, communication (e-mail) services, sales management, marketing services, accounting platform, who have statutory personal data protection obligations with regard to the confidentiality and security of personal data;
  • persons authorised to conclude agreements on our behalf;
  • property valuation service providers, if a property valuation is offered to you as a gift;
  • a notary public to the extent necessary for the conclusion of a notarial sale and purchase agreement;
  • service providers auditing our company (auditors) or state or municipal authorities carrying out inspections.

6. HOW LONG DO YOU KEEP INFORMATION ABOUT ME?

Your information will be stored for the data retention periods indicated below:

  • agreements concluded with you will be kept for ten (10) years after their expiry;
  • the agreement we have entered into with you for the gift – a property valuation – will be kept for ten (10) years after its expiry;
  • your requests, complaints and enquiries, together with the replies to them, will be kept for one (1) year from the date of the reply, and if they relate to the performance of our agreement – for ten (10) years.

7. WHAT ACTIONS CAN I TAKE WITH REGARD TO MY INFORMATION KEPT IN YOUR COMPANY?

If you wish to take the following actions, please contact us as defined in Section 8. Please note that these rights are subject to statutory conditions and exceptions:

  • to request access to the information we hold about you which allows us to identify you, if we process your personal data;
  • to request the rectification or completion of the information we hold about you;
  • to request erasure of information about you, where:
  • your data is processed by us unlawfully;
  • your data is processed on the basis of our legitimate interest and you contest our legitimate interest;
  • your data is no longer necessary for the purposes it was collected; or
  • we are under a legal obligation to erase information about you;
  • to request that we restrict the processing of information we hold about you, where you contest the accuracy of the data or object to the processing of the data, you object to the erasure of your data that are unlawfully processed, or you need the data to assert, exercise or defend legal claims;
  • to request the export of your data, if you have provided the data to us in a structured, commonly used format and have given your consent to the processing of such data, or if we need to process the data in order to perform an agreement with you;
  • to withdraw your consent to the collection, use and storage of your personal data at any time;
  • to lodge a complaint with the State Data Protection Inspectorate (further information is available at vdai.lrv.lt).

Please note that you cannot exercise your right to object to the processing of your personal data for this purpose, since this right can be exercised where the processing is based on legitimate interest (Article 6(1)(f) GDPR), meanwhile we will process your data on other legal grounds.

8. HOW CAN YOU HELP ME?

If you have any questions, comments or complaints as to how we collect, use and store information about you, we are here to help. If you need assistance in relation to the processing of your personal data, please contact us by e-mail: [email protected].