Our Privacy Policy

1. GENERAL INFORMATION

UAB “Hostline” (hereinafter – the Data Controller or the Company) establishes the terms and conditions for the processing of personal data in this privacy policy (hereinafter – the Privacy Policy) when using the website managed by the Data Controller at www.vpsforfx.com (hereinafter – the Website), or by providing personal data to the Company in other ways. The Privacy Policy describes the personal data we collect, how we obtain it, the basis and purposes for using your personal data, how we use it, how long we retain your personal data, with whom we share it, how we take care of the protection of your personal data, and what your rights are. We respect your privacy and strive to protect your personal data.

The conditions set out in the Privacy Policy apply each time you access our provided content and/or services, regardless of the device (computer, mobile phone, tablet, TV, or other) you use.

Data Controller’s details:

Name: UAB Hostline

Office address: Dariaus ir Girėno g. 42a, 02189 Vilnius, Republic of Lithuania

Phone number: +370 700 22899

Email address: [email protected]

It is very important that you read the Privacy Policy carefully, as each time you visit the Website or otherwise provide personal data to the Company, you agree to the terms described in this Privacy Policy. By using the Website or otherwise providing personal data to the Company, you legally commit to complying with the provisions of this Privacy Policy. If you do not agree with these terms, you should not provide your personal data to the Company.

We confirm that the Company will process your personal data in accordance with the applicable requirements of the European Union and the Republic of Lithuania legal acts, including Regulation (EU) No 2016/679 (General Data Protection Regulation, hereinafter – GDPR) and other applicable data protection legal acts and the instructions of competent authorities. The terms used in the rules are understood as defined in the GDPR.

2. PERSONAL DATA

Personal data is any information related to a living individual whose identity is or can be identified. Separate pieces of information which together can also help identify a specific person also constitute personal data.

Please do not send any personal data to the Company, especially sensitive personal data, if you do not want such information to be used in any way.

The Website and the provision of personal data to the Company can only be used by individuals who are at least 18 years old. If you are between 14 and 18 years old, please read this Privacy Policy carefully together with one of your parents or guardians to understand and comply with it.

The Company does not collect personal data from individuals under the age of 14, so if you are under 14 years old, you should not use the Website and/or provide your personal data to the Company.

3. WHAT PERSONAL DATA DOES THE COMPANY COLLECT?

The Company processes your personal data for the following purposes and in accordance with the related legal bases:

3.1. EMPLOYEE RECRUITMENT

Purpose: Processing personal data of candidates wishing to be employed by the Company.
Data subjects: Candidates wishing to work at the Company.
Personal data: – Name and surname;
– Email address;
– Phone number;
– Our correspondence text;
– LinkedIn profile and the information provided therein as much as needed to determine the candidate’s suitability for specific positions;
– Information about your education (qualification), work experience, foreign language proficiency, and other information you provide in your resume and/or other documents.
Legal basis: We process personal data based on our legitimate interest in finding new employees (GDPR Article 6(1)(f)) and to take steps at your request prior to entering into an employment contract with you (GDPR Article 6(1)(b)).
If you do not provide the data specified in this section, you will unfortunately not be able to participate in the selection process or enter into an employment contract with the Company.
Storage: Your personal data is stored for the duration of the selection process for the specific position and for an additional 6 months after the end of the selection process, unless otherwise agreed upon / the data subject agrees to a longer period.

3.2. SOCIAL MEDIA ADMINISTRATION

Purpose: Managing and operating the Company’s social media accounts (Facebook, LinkedIn, Instagram, YouTube) and communicating with social media users.
Data subjects: Users of social media (Facebook, LinkedIn, Instagram, YouTube) who interact with the Company’s accounts.
Personal data: – Social media profile name;
– Profile picture;
– Public comments and other interactions with the Company’s social media accounts;
– The subject and text of your inquiries, if any.
Legal basis: Our legitimate interest in communicating with our social media users on our accounts (GDPR Article 6(1)(f)).
Storage: Considering that the Company does not administer the aforementioned social media platforms, but only its own accounts on them, and acts as a joint data controller together with the companies administering these social networks, we invite you to familiarize yourself with the information about the storage of your personal data in the privacy documents of these social networks:
Facebook and Instagram: Facebook Data Policy
LinkedIn: LinkedIn Privacy Policy
YouTube: YouTube Privacy Policy

3.3. INQUIRIES

Purpose: Administration of your inquiries submitted to the Company by email, phone, or using forms or features available on the Website.
Data subjects: Individuals submitting inquiries to the Company by email, phone, or using forms or features available on the Website (e.g., regarding product quality).
Personal data: – Name and surname;
– Represented organization;
– Email address;
– Phone number;
– Subject and text of the inquiry.

Please note that the amount of personal data you provide and we process may vary depending on the method you choose to submit your inquiry. Therefore, the actual scope of personal data processed may be smaller than indicated above.
Legal basis: Your consent (GDPR Article 6(1)(a));
Contract formation with you (or actions necessary at your request prior to entering into a contract) (GDPR Article 6(1)(b));
Our legitimate interest in processing your inquiry and providing you with accurate and comprehensive information about our services and activities (GDPR Article 6(1)(f)).
Storage: Data is stored for 2 years after receiving your inquiry. In certain cases, in accordance with applicable legal requirements, your personal data may be stored for a longer period.
If you do not provide your personal data, we may be unable to properly review your inquiry and provide you with the requested information.

3.4. ENSURING LEGAL CLAIMS AND DISPUTE RESOLUTION

All of the personal data mentioned above may be processed by the Company for the purpose of asserting, enforcing, or defending legal claims. For this purpose, personal data will be processed based on our legitimate interest in asserting, enforcing, or defending legal claims (GDPR Article 6(1)(f)). We will process this data until the relevant legal proceedings are concluded (e.g., until a claim is reviewed, a court or arbitration decision becomes final).

4. TO WHOM DO WE DISCLOSE YOUR INFORMATION?

The Company may share your personal data with third parties (data processors) who provide services to the Company and act on its behalf (e.g., companies providing marketing/advertising services, data center services, IT service providers, accounting service providers, etc.). The Company ensures that the processing of personal data by such third parties is carried out only in accordance with the Company’s lawful instructions and in compliance with the GDPR and other applicable legal requirements. Personal data is transferred to them only when and to the extent necessary for the provision of respective services. Additionally, personal data may be transferred to relevant data recipients/independent third parties, i.e., independent data controllers.

The Company may share personal data with the following categories of third parties (data processors, data recipients, or independent data controllers) when necessary:

  • Courts, arbitrators, mediators, opposing parties and their attorneys (if required for judicial processes);
  • Police, law enforcement agencies, tax authorities, other state or municipal institutions (if expressly required by applicable laws) or other persons performing official duties (e.g., notaries, debt collection companies);
  • Other professional advisors, such as lawyers, consultants, auditors, or accountants (if needed to protect our legitimate interests);
  • Service providers providing information technology, cloud computing, and system administration services, marketing, accounting, postal or courier, and other services – only to the extent necessary for the proper provision of services;
  • Other entities within the same corporate group if needed for reporting on company activities, clients, accounting, in the context of business reorganization or group restructuring, system support, and data hosting;
  • Other natural or legal persons, only if necessary to ensure the highest efficiency of the services provided to you.

The Company may also share personal data in the course of business transactions, i.e.: i) if a financial or legal audit (due diligence) is performed or any other inspection of the Company – with the persons performing such audit/inspection; ii) if the Company’s shares (or any part thereof) or the Company as a business (or any part thereof) are intended to be transferred – with potential acquirers (their representatives), iii) in the case of reorganization, merger, acquisition, joint venture, or business establishment (also if related to bankruptcy or other similar procedures). In such cases, the Company ensures the confidentiality of personal data.

Third Parties. The Company does not transfer your personal data to third countries (outside the EU/EEA) unless it is deemed necessary. The Company may transfer your personal data outside the EU/EEA if it has obtained your explicit consent or if it is necessary and appropriate safeguards are in place under the GDPR, such as an adequacy decision or standard contractual clauses. The Company makes every effort to ensure that the transfer of data in this manner complies with the GDPR requirements and implements appropriate measures to ensure the security of your personal data. You can obtain more information about such measures by contacting us directly via the above-mentioned phone number or email address.

5. MEASURES FOR THE PROTECTION OF PERSONAL DATA

The Company implements appropriate technical and organizational measures compliant with GDPR requirements to protect your personal data from accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or use, as well as from all other unlawful forms of processing.

While the Company strives to protect the personal data it processes, please understand that the Company cannot ensure or guarantee the security of any information you transmit to us, as no method of transmission or storage is 100% secure these days.

6. YOUR RIGHTS

You have the following rights regarding the processing of your personal data by us:

Right to be Informed and Right to Access Personal Data

You have the right to receive information about the processing of your personal data in a transparent, understandable, and easily accessible form, in clear and simple language. This is provided in this Privacy Policy. If any part of this Privacy Policy is unclear to you, please feel free to contact us at the above-mentioned contacts.

You also have the right to receive confirmation from the Company whether your personal data is being processed, and if such data is being processed, to access information about how we process your personal data.

Moreover, you have the right to receive a copy of your personal data that we hold. We have the right to charge a reasonable fee based on administrative costs for any additional copies you request.

Right to Rectify Personal Data

You have the right to request the Company to rectify inaccurate or incomplete personal data about you.

Right to Erasure of Personal Data (“Right to be Forgotten”)

You have the right to request us to delete or remove personal data if there is no valid reason for us to continue processing it, such as if the personal data is no longer needed for the purposes for which it was collected or processed, if you withdraw your consent on which the processing is based and there is no other legal basis for processing, or for other reasons set out in Article 17 of the GDPR.

Please note that Article 17(3) of the GDPR provides exceptions to the above cases when data processing is necessary. If such exceptions apply to your case, we will inform you accordingly.

Right to Restrict the Processing of Personal Data

You have the right to request the Company to restrict (or suspend) the processing of your personal data if:

  • You contest the accuracy of the personal data – until its accuracy is verified;
  • The processing is unlawful, and you object to the erasure of the personal data and request the restriction of its use instead;
  • We no longer need the personal data for processing purposes, but you need it to establish, exercise, or defend legal claims;
  • You object to the processing of your personal data on the grounds of legitimate interests, pending the verification whether our legitimate grounds override your interests.

If processing is restricted, such personal data, with the exception of storage, will only be processed with your consent or to establish, exercise, or defend legal claims, to protect the rights of another natural or legal person, or for reasons of important public interest.

Right to Data Portability

You have the right to receive the personal data you provided to the Company in a structured, commonly used, and machine-readable format, and the right to transmit those data to another controller if:

  • The data is processed on the basis of consent or a contract; and
  • The data is processed by automated means.

You also have the right to request that the Company transmit your personal data directly to another controller if technically feasible.

Right to Object

You have the right to object at any time to the processing of your personal data processed for the performance of a task carried out in the public interest or for the purposes of legitimate interests.

In such a case, the Company will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or if the processing is for the establishment, exercise, or defense of legal claims.

When personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing and your data will no longer be processed for this purpose.

Right to Withdraw Consent

If your personal data is processed based on your consent, you have the right to withdraw such consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint with a Supervisory Authority

If you believe that your personal data processing violates GDPR provisions, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or the place where the alleged infringement took place.

The supervisory authority in Lithuania is the State Data Protection Inspectorate, located at L. Sapiegos g. 17, 10312 Vilnius, Lithuania, email [email protected], website https://vdai.lrv.lt/.

Before lodging a complaint with the supervisory authority, we would appreciate it if you would contact us first to express your concerns. We will make every effort to promptly and carefully resolve your issue.

To exercise these rights, please send a written request to [email protected]. The Company will review your request within 30 days. If the request is very complex or if a large number of requests are received, this period may be extended to 60 days. In such a case, we will inform you of the extended period and the reasons for the extension within 30 days of receiving your request. To ensure data protection and to allow you to exercise your rights, the Company has the right to request additional information necessary to confirm your identity.

7. CHANGES

The Company reserves the right to change this Privacy Policy at its discretion. Notice of such changes will be published on the Website. In the event of significant changes to the Privacy Policy, the Company will inform you separately.

This Privacy Policy was last updated on 2024-04-01.

8. LIABILITY

The Website may contain links to websites owned and operated by third parties, such as social media platforms. The Company assumes no responsibility for the accuracy or reliability of such third-party websites. If you have any questions about how such other parties with whom you interact use your personal data, we recommend reviewing their privacy policies.

9. INTELLECTUAL PROPERTY

The Website, its content, code, design, domain name, all copyrights, trademarks, databases, business names, and other intellectual property or property related to the Website and/or its content belong fully to the Company, except for intellectual property objects (trademarks, logos, etc.) related to the Company’s partners or suppliers, and are protected by national and international intellectual property laws and other applicable laws.

Without clear permission from the Company, you do not have the right to copy, record in any form, reproduce in any form or manner, present, publish, transmit, sell, process, deliver, license, modify, re-publish, edit, broadcast, re-broadcast, publicly display or demonstrate, adapt, distribute, or use in any other way the Website or the content thereof, including their code or any part thereof, nor create derivative works based on them.

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