PRIVACY POLICY OF THE FINPRO GROUP OF COMPANIES

The Finpro group of companies, which includes the companies listed below in this privacy policy (hereinafter referred to as “we or Finpro“) take your privacy very seriously and attach great importance to your privacy and personal information. Therefore, we handle your personal information honestly, responsibly and legally, in compliance with this privacy policy, the EU General Data Protection Regulation (hereinafter referred to as GDPR), the Personal Legal Protection Law of the Republic of Lithuania and other legal acts regulating the security of personal data.

In this privacy policy (hereinafter – Privacy Policy) we provide information about what personal data we process and for what purpose, to whom we can transfer it and how long we keep it, what rights you as a data subject have and other important information related to your personal data handling.

Additional information about how we process your personal data can be provided in contracts and other documents related to the provision of our services.

The group of Finpro companies (data controllers) that will process your personal data, as specified in this Privacy Policy, consists of the following companies:

UAB Finpro group, legal entity code 305722002, M. Valančiaus str. 1A-601, Vilnius,

UAB Finpro LT, legal entity code 305435148, M. Valančiaus str. 1A, Vilnius,

Finpro LT 1 UAB, legal entity code 305826232, M. Valančiaus str. 1A, Vilnius,

Finpro LT 2 UAB, legal entity code 305880689, M. Valančiaus str. 1A, Vilnius,

Finpro rent UAB, legal entity code 305677308, M. Valančiaus str. 1A, Vilnius,

any of the above-mentioned companies may be referred to individually as Finpro company, and together as Finpro companies.

APPLICATION OF THE PRIVACY POLICY

This Privacy Policy is relevant for persons who visit our website www.finpro.lt (hereinafter – the website), use or want to use the services of the Finpro company, apply to any Finpro company specified in this Privacy Policy, provide it with security measures, represent other persons in the relationship of such persons with the Finpro company or there are managers, owners, shareholders, beneficiaries, including final beneficiaries, persons with voting rights of legal entities who use or intend to use the services of any Finpro company specified in the Privacy Policy.

By providing us with personal data on the website, browsing it, submitting a request, using the request form on the website, you confirm that you are familiar with the Privacy Policy and how we handle your personal data. We also ask for your confirmation that you have read the Privacy Policy in the documents submitted to us (e.g. applications, contracts, agreements, questionnaires concluded with any Finpro company).

The website may contain links to the websites of other companies, but the Privacy Policy does not apply to you when using the websites of other companies. Always read the privacy notices of other service providers and contact them directly regarding the use of your personal data.

We may change the Privacy Policy at any time in our sole discretion or as required by law. Before browsing the website, make sure you are familiar with the current version of the Privacy Policy.

WHERE AND WHAT INFORMATION DO WE GET ABOUT YOU

We receive your personal data directly from you when you submit inquiries to us, conclude or intend to conclude contracts with the Finpro company specified in the Privacy Policy, fill out applications for the provision of Finpro company services, questionnaires, other documents requested by the Finpro company, communicate with us on social networks.
When you intend to enter into or enter into contracts with the Finpro company, we process the following personal data:

• data related to identification: name(s), surname(s), personal code, date of birth, tax payer code, gender, citizenship, personal identification document data, digital identification data, if your identity is determined remotely ,
•  Your data as a representative of the company/person you represent: name(s), surname(s), personal identification number, personal identification document data, digital identification data, if you, as a company/person of the representative, the identity is determined remotely;
• contact details: address of place of residence, address for correspondence, telephone number, e-mail postal address,
• data related to the service: identification data of the property that you intend to rent (use by leasing)/ rent (use by leasing) or finance (are financed) in another way, information related to the security measures provided,
• financial information: Your salary, other income, source of income, financial obligations, data on concluded financing transactions, assets, debts, bank account number, credit history data, method of settlement with the company (cash or bank transfer),
• data related to your profession: information about your employer, positions held, participation in company management,
• data related to your marital status,
• website browsing data, your visit to social networks administered by the Finpro group of companies,
• other data: taking into account the measures of the money laundering and terrorist financing prevention policy implemented in the Finpro company, your presence as a politically vulnerable (affected) person, the risk class assigned to you, data related to the application of sanctions to you.

When you make inquiries or fill out applications for the provision of services on the website, you provide us with the personal data specified in the relevant inquiry or application form, such as: name, telephone number, e-mail address, the service you are applying for, company name and others.
We can receive information about you indirectly from organizations and persons that you represent, as well as, at your request as a potential client of ours, data can be provided to us by persons such as car dealers, we can also receive data from persons who intend to insure/insure you property intended to be rented (leased)/ leased (leased) or property that you intend to finance (are being financed) in another way or property that is the object of security measures.
When legal entities contact us regarding the provision of services, we may receive the following data from you as a representative, manager, legal entity owner, shareholder, shareholder, beneficiary, person with voting rights of such a legal entity:

• data related to identification: name(s), surname(s), personal identification number, date of birth, gender, citizenship, personal identification document data,
• contact details: address of place of residence, address for correspondence, telephone number, e-mail postal address,
• other data: taking into account the measures of the money laundering and terrorist financing prevention policy implemented in the Finpro company, your presence as a politically vulnerable (affected) person, the risk class assigned to you, data related to the application of sanctions to you, data on participation in legal entities, being the head of a legal entity or another person who holds the decisive voting right.

In addition, we may receive the same data indirectly from third parties as we request from you directly, as indicated above.
Indirectly, we can also receive information about you with a legitimate interest related to risk reduction, when at your request we make a decision on providing a service to you or provide you with services, from sources available to us: credit risk assessment persons, registers, companies, state organizations and we can collect information using Internet search engines.
Indirectly from asset location tracking service providers, if you or other persons to whom you have transferred the assets do not return the assets to us or we have reasonable suspicions that the assets transferred to you or financed by us or subject to collateral may be hidden, not returned, etc.
We may also indirectly receive information about you from state institutions, other persons about damage caused to individuals, property, non-compliance with the requirements of legal acts, your use of property, transferred to you under contracts concluded with Finpro company or the object of security measures provided to Finpro company or financed property .
If you provide us with information about another person, you must inform such person that you have provided us with their personal data, indicating that such person can familiarize themselves with the processing of their personal data in this Privacy Policy or by contacting us. By submitting another person’s data to us, you confirm to us that such other person has been familiarized with this Privacy Policy, the processing of his personal data, and that you have legally agreed to such processing and that such person has agreed to such processing of personal data.
You provide us with all data voluntarily. If you do not provide certain personal data, it is possible that we will not be able to perform certain actions, for example, we will not be able to provide you with the service you are applying for.

FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA

We generally process your personal data for the following purposes:

• the decision to enter into a service provision agreement and the conclusion of a service provision agreement,
• Your identification,
• Insurance of property intended to be transferred/transferred, financed or subject to security measures,
• administering, responding to your requests or seeking to solve problems that have arisen,
• in order to protect and defend their rights and legitimate interests, property,
• implementing the “know your customer” principle in Finpro companies,
• in compliance with the requirements of legislation, including those for the prevention of money laundering and terrorist financing,
• improving our services and developing our activities,
• internal administration,
• for business transfer and investment attraction purposes,
• accounting,
• fulfilling our obligations to third parties (such as owners of property transferred to you, persons providing us with property financing services),
• collecting and administering debts, submitting legal claims, seeking their fulfillment and defense, defending themselves against lawsuits and complaints,
• communications,
• when conducting direct marketing,
• statistical,
• receiving your opinion (feedback) about us.

For the purposes specified in this section, we process your personal data when we are required to do so by legal acts, a contract with you, our legitimate interest, when we seek to protect our, third parties’ or your property or interests, or if we have received your consent for the processing of personal data.

Processing of PERSONAL Data for the purpose of direct marketing

When processing your personal data for the purpose of direct marketing, we ask you to provide consent for such processing. If you do not give your consent, we will not process your personal data for this purpose. If you give your consent, you can withdraw it at any time by clicking on the corresponding unsubscribe link in the message sent to you or by contacting us by e-mail at info@finpro.lt.

For direct marketing purposes, we will process personal data for no longer than 3 years after receiving your consent or until you withdraw your consent to data processing for this purpose, whichever comes first.

PERSONAL DATA STORAGE PERIOD

We ensure that your personal data is processed no longer than is necessary to achieve the purposes of data processing, no longer than is provided for by legal acts.

Normally, we will store personal data during the performance of the contract and for 10 years from the last calendar day of the year in which the contract concluded with Finpro was executed, unless longer periods are necessary in order to submit legal claims, defend legal interests, or longer storage periods are required in the execution of documents requirements related to archiving or other requirements established by legal acts.

If the contract is not concluded, we will store personal data for 2 years from the date of receipt of your application for the provision of services, unless in compliance with the requirements of the legislation on the prevention of money laundering and terrorist financing, we will be required to store personal data for a longer period or if a longer period of personal data storage is necessary in order to protect our interests .

In compliance with the requirements of the money laundering and terrorist financing prevention legislation, we will store personal data for 8 years, and at the request of the competent authorities, the term of personal data storage can be extended for 2 years. In compliance with the requirements of the money laundering and terrorist financing prevention legislation, we will also protect the managers, representatives, shareholders, final beneficiaries, etc. of legal entities within the terms specified in this Privacy Policy section. personal data, even if such a person does not have any contracts with Finpro companies.

At the end of the retention period, we will either delete, destroy or anonymize the collected personal data. Some personal data stored in computer files may still be available for a certain period of time after their retention period has expired in data backup systems, but access to such personal data is strictly limited.

SECURITY OF PERSONAL DATA

Since we value the security of your personal data, we apply appropriate technical and administrative measures to protect the personal data collected by us from loss, unauthorized use and changes.

CONFIDENTIALITY

The security of your personal data is extremely important to us, so we process all personal data in strict accordance with the principle of confidentiality.

WHO WE TRANSFER YOUR PERSONAL DATA TO

Generally, we do not share your personal data with other persons. However, in order to fulfill our obligations, we may transfer personal data to property sellers, from whom Finpro company or a person selected by Finpro company will purchase the property intended to be leased (used by leasing)/rented (used by leasing) or the property intended to be financed (financed) in another way.
We may also transfer your personal data to the following recipients:

•  to persons providing legal services to us,
• to persons providing financial services to us,
• To the persons who provided the means to ensure the performance of your obligations,
• to the buyer of the property, who will buy the property after the end of the rental (leasing) services,
• To the owner of the property rented (leased) to you, if the Finpro company is not the owner of the property,
  persons providing accounting services, auditors, other consultants,
• for persons providing property insurance services,
• for persons providing asset location tracking services,
• payment service providers,
• for any company of the Finpro group to the extent necessary for the administration of requests for a specific service, the decision on the provision of a service or the purpose of providing a service, for the purposes of financial accounting, auditing, corporate management of the Finpro group of companies, as well as for the use of common information systems and equipment by the companies of the Finpro group,
• entities managing registers (including databases of financial obligations, joint files of debtors or other registers in which personal data are processed) or which mediate the provision of personal data from such registers,
• for individuals and companies performing debt collection, administration of insolvency proceedings, bailiffs, notaries,
• to the used data processors,
• to state institutions, law enforcement agencies and other persons in accordance with the procedure established by the legal acts of the Republic of Lithuania,
• other persons (including future business buyers of the Finpro company(ies), investors), as far as it relates to the sale, mergers, purchases of the business or part of the business of the Finpro company(ies),
• to other recipients specified in the contract concluded with the Finpro company or in other documents provided to you.

After receiving your consent, we will be able to provide personal data to other persons.
When transferring your personal data to other persons, we ensure the security of the transferred personal data.

PERSONAL Data Managers

In order to fulfill our obligations to you, as well as to ensure the activities of Finpro companies, we can use data processors who, according to our instructions and to the extent determined by us, will process personal data to the extent necessary to achieve the goals of personal data processing.

When choosing data processors, we require that the data processors have implemented appropriate organizational and technical security measures to ensure the security and confidentiality of personal data.

RIGHTS OF THE DATA SUBJECT

With this Privacy Policy, we also inform you about the rights you have as a data subject.
This Privacy Policy implements your right to know (to be informed) about the processing of your personal data. You can also exercise this right by contacting us at the address specified in the Privacy Policy, by e-mail.
You have the right to access your personal data processed and how it is processed. You can exercise this right by contacting us at the address specified in the Privacy Policy, by e-mail. At your request, we will provide information from where we received your personal data, the period of personal data storage, what personal data is collected, for what purpose we process it, to whom we provide it.
We will normally provide such information to you free of charge, unless your requests are manifestly unreasonable or disproportionate, in particular due to their repetitive content. In addition, if your requests are clearly unreasonable or disproportionate, we have the right to refuse to fulfill your request.
If you do not specify the form of information submission in your request, we will provide you with the information in the same form as the received request.
The right to request the correction of personal data and to stop the processing of personal data if the data is found to be incorrect, incomplete or inaccurate.
The right to demand the destruction of personal data or restriction of data processing actions, if it is determined that personal data is being processed illegally or unfairly.
The right to object to the processing of personal data, except in cases where these personal data are processed for our or a third party’s legitimate interest, if your interests are not more important.
You can exercise the right to withdraw your consent to data processing at any time by contacting us using the contacts specified in this Privacy Policy, and you can also withdraw your consent to the processing of personal data for marketing purposes by clicking on the corresponding unsubscribe link in the e-mail sent to you.
You can request the deletion of all data we have collected about you and thus exercise the right to be forgotten. We have the right to refuse to fulfill your request “to be forgotten” in the cases established by law.
You have the right to demand that the personal data provided by you, if they are processed on the basis of consent or contract, and if they are processed by automated means, be “transferred“, i.e. i.e. forward to another data controller or transfer to you in a structured, commonly used and computer-readable format, if this is technically possible.
You have the right to object to only automated data processing, including profiling.
As a general rule, we do not make decisions about you based on automated processing of personal data. If we do make such decisions, at your request, we will review the decision and evaluate all relevant data.
If you doubt the legality of our processing of your personal data or if you are not satisfied with the solution to the situation, you have the right to file a complaint regarding such processing of personal data with the State Data Protection Inspectorate (address L. Sapiegos st. 17, Vilnius, e-mail address ada@ ada.lt, website https://vdai.lrv.lt/ or to a competent court. You have the right to complain about our actions or inaction by yourself or through a duly authorized representative or a non-profit institution, organization or association that meets the requirements established by law.
If we have violated your rights as a data subject and you have suffered material or non-material damage, you have the right to compensation.

PROTECTION OF MINORS

We do not provide services to persons under the age of 18. If we learn that personal data has been obtained directly from persons under the age of 18, we will immediately destroy such personal data. If you are under 18 years of age, you must obtain the consent of your parent or other legal guardian before submitting information about yourself.

If you are the parent or legal guardian of a child and you believe that your child has provided us with personal data, please inform us immediately so that we can delete such data immediately.

Social media tools

We may have profiles on social media such as Facebook. If you intend to communicate with us on social media, please read the privacy notices of the operators of the social network and contact them directly regarding the use of your personal data.

Cookies

Cookies are used when you visit the website. The list of used cookies is provided in the Cookies Policy.

YOUR QUESTIONS

If you have any questions related to this Privacy Policy or other requests related to the protection of your data, please contact us at the following contacts:

UAB Finpro LT

Code: 305435148

Address: M. Valančius 1A, LT-03155, Vilnius

email p.: info@finpro.lt

www.finpro.lt

You can also contact the designated data protection officer by e-mail: e.strimaitis@vialex.lt.

We value all your questions, advice and opinions, so we will try to answer you as soon as possible.

Thank you for taking the time to read this Privacy Policy.

This Privacy Policy was last updated on 08/23/2023.

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Cookie management

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This Cookie Policy was last updated on 08/23/2023.