PRIVACY & COOKIES NOTICE

INTRODUCTION

We are committed to protecting your personal data; your privacy matters to us. That is why we have developed this Privacy and Cookies Notice to explain how we collect, use, share and store your personal information when you use this website, and to inform you about how we will look after that information. This includes any information you may provide to us when you sign up to keep in touch with us or take part in any competitions that we might run.

It is important that you take some time to read and familiarize yourself with this Notice, together with our Website Terms and Conditions and any other privacy or fair processing notices that we may provide on specific occasions when we collect or process personal data about you. This will help you to be fully aware of how and why we are using your information.

If you do not agree with any term in this policy, please do not use the website or submit any personal information to or through it.

  • 1. CONTROLLER

    UAB Eugesta (Company Number 121539735) is the data controller responsible for your personal data.

    Our registered addresses:

    UAB Eugesta; Kibirkšties g. 8, LT-02242 Vilnius, Lithuania

    SIA EUGESTA; Tīraines iela 11, Zemgales priekšpilsēta, LV-1058 Rīga, Latvia

    OÜ EUGESTA; Rukki tee 5, Lehmja, 75306 Harju maakond, Estonia

    References to “our”, “us”, “we” or “Company” within this policy are deemed to refer to UAB Eugesta, its subsidiaries, affiliates and associates.

    Eugesta is operated on www.eugesta.com for all Baltic countries.

  • 2. CONTACT DETAILS

    Our contact details:

    UAB Eugesta, Kibirkšties g. 8, LT-02242 Vilnius, Lithuania

    SIA EUGESTA; Tīraines iela 11, Zemgales priekšpilsēta, LV-1058 Rīga, Latvia

    OÜ EUGESTA; Rukki tee 5, Lehmja, 75306 Harju maakond, Estonia

  • 3. CHANGES TO THE PRIVACY NOTICE & YOUR DUTY TO INFORM US OF CHANGES

    This Privacy Policy was last updated in September 2024; however, we keep this policy under review. We will post any updates on this web page. We recommend that you check this page regularly to ensure that you have read the most recent version.
    Please note, it is important that the personal data we hold about you is accurate and current. Please keep us informed if the personal data we hold about you changes during your relationship with us.

  • 4. THIRD-PARTY LINKS

    From time to time this website may contain links to third-party websites, plug-ins, platforms and applications. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or how they collect and use your personal information. When you leave our website, we strongly advise you to read the privacy notice of every website you visit before you submit any personal information.

  • 5. INFORMATION WE MAY COLLECT FROM YOU

    Personal data or personal information means any information about an individual by which that individual can be identified.

    The personal information we collect includes (a) information you provide to us; and (b) information we generate or collect automatically. We have provided more details about these types of information below:

    Information you provide to us – this type of information might include:

    • contact details (such as your name, postal addresses, phone numbers and e-mail addresses);
    • demographic information (such as your age or age range and gender);
    • competition entries or submissions; and in certain cases, your marketing preferences.

    Information we generate or collect automatically – this type of personal information may relate to your device (such as your PC, tablet or other mobile device), your use of our websites and apps, photographs and video recordings made by us or on our behalf and/or your personal preferences, interests or geographic location. Examples of this type of information might include:

    • name and age (or predicted age range);
    • information about your device, operating system, browser and IP address;
    • unique identifiers associated with your device;
    • details of web pages that you have visited;
    • how long you spend on certain areas of a website with the date and time of your visit/usage;
    • personal information contained within user-generated content (such as blogs and social media postings);
    • social media user name or ID;
    • social media profile photos and other social media profile information (such as number of followers);
    • photographs and video recordings.
  • 6. HOW WE COLLECT YOUR INFORMATION

    We use different methods to collect your personal data including through direct interaction with you, for example, when you:

    • visit and use our website;
    • contact us with an enquiry or other feedback;
    • enter any competition, promotion, prize draw or event that we run on this website;
    • inform us of your marketing preferences;
    • communicate with us via social media websites, third-party apps or similar technologies; and/or
    • attend events run by us or on our behalf.

    We may also collect your personal data through automated interaction, for example, when you browse or use our website, we use cookies and other similar technologies to automatically collect information from one or more of your connected devices. Cookies are explained in more detail in Section 8 below.

  • 7. INFORMATION YOU POST ON PUBLIC AREAS OF OUR WEBSITE AND SOCIAL MEDIA

    Information that you post on or through any public areas of the website (such as chat rooms, bulletin boards or discussion forums) and on any social media pages that we operate is publicly available information. This means that it is generally accessible to others and may be collected and used by others to send you unsolicited messages. We do not have control over whether or how other people may use this information, so you should exercise caution and take care not to disclose personal information when using public web areas or social media. We are not responsible for any postings you make with personal information in them.

  • 8. COOKIES

    We use cookies on this website. They allow us to provide you with the best possible experience on our website.

    This section contains information on the following:

    • What are cookies?
    • Why do we use cookies?
    • What cookies do we use?
    • How do I control cookies?

    WHAT ARE COOKIES?

    Cookies are small text files that are placed on your computer by websites that you visit. They cannot harm your computer. If you would like to read more about cookies, this website contains a lot of useful information that may be of interest to you: http://www.aboutcookies.org/default.aspx

    WHY DO WE USE COOKIES?

    We use cookies to distinguish you from other users of our website and to provide enhanced functionality on this site. This helps us to improve your experience of the website(s) and to deliver a better and more personalized service.

    We do not use cookies to collect personal information about you, but we do use encrypted information collected from them to:

    • estimate our audience size and usage patterns; and
    • recognize you when you return to the website(s).

    In order to make full use of the personalized features on our website(s), your computer, mobile phone or other device that you use to access the internet will need to accept cookies.

    WHAT COOKIES DO WE USE?

    Below is a list of the main cookies that may be sent to your device and what we use each cookie for. You can set your browser to reject cookies (see below for more information on how to do this), but if you do, certain personalized features of our website(s) may not be available to you.

    To support our website(s), we may occasionally embed content from other third-party websites such as Facebook, Twitter, Pinterest and YouTube. Pages with this embedded content may present you with cookies from these websites. We do not control the distribution of these cookies and you should check the relevant third-party website for more information about them.

    HOW DO I CONTROL COOKIES?

    You may refuse to accept cookies from us by: (a) not opting in to our use of cookies on the landing page of the website(s); or by (b) activating the setting on your browser which allows you to refuse the setting of cookies. Each web browser is different, so please refer to your browser’s Help section to determine how to update your particular cookie settings. The website http://www.allaboutcookies.org contains step-by-step guides which can assist you in adjusting your browser settings.

    To opt out of Google Analytics tracking across all websites, visit tools.google.com/dlpage/gaoptout.

    Please note that switching off cookies may reduce the functionality of, or prevent access to, certain websites.

  • 9. HOW WE USE YOUR PERSONAL DATA

    We will only use your personal data where the law allows us to do so and where it is fair do so. Most commonly, we will use your personal data in the following ways:

    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; for example, this is the basis on which we collect information which is necessary for us to understand our markets and consumers, to promote our services and to operate our business effectively; (This is the legal basis on which we may process your personal data where it has been collected for the purposes listed in paragraph 10 below)
    • Where we need to perform a contract that we are about to enter into or have entered into with you; (This is the legal basis on which we may process your personal data where it has been collected for the purposes listed in paragraph 10 below)
    • Where we need to comply with a legal or other regulatory obligation; (This is the legal basis on which we may process your personal data where it has been collected for the purposes listed in paragraph 10 below)
    • Where you have given us your consent to do so, for example, where you have given your consent to receive marketing or other information from us. Please note that you can withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of any marketing e-mail we send you. (This is the legal basis on which we may process your personal data where it has been collected for the purposes listed in paragraph 10 below)
  • 10. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA

    We use your personal information to:

    1. manage and improve this website to ensure that its content is presented in the most effective manner for you and for your computer and/or device;
    2. respond to any enquiry or feedback from you and implement any changes as needed;
    3. retain records of how we have dealt with feedback and/or complaints;
    4. monitor the nature and trends of any complaints we receive;
    5. allow you to participate in interactive features of the website(s) if you choose to do so;
    6. manage any competitions, prize draws or promotions that you enter on this website;
    7. administer any surveys you complete on this website;
    8. improve our products and services;
    9. comply with legal obligations and protect ourselves against legal claims or liability;
    10. target online advertising;
    11. authenticate and control access to parts or features of our website (including relative to your age and location);
    12. enable us to carry out marketing analysis of our products, services and campaigns;
    13. provide specific services that you request from us and additional services that may be of interest to you;
    14. maintain your accounts and manage transactions, such as payment card transactions, for any products you order from us or for the fulfilment of such transactions;
    15. diagnose service or technology problems reported by our users or engineers in connection with the use of our websites;
    16. celebrate or promote our values, products, brands, partnerships, culture, people or business. Please note that when you contact us, we may keep a copy of any resulting correspondence.
  • 11. HOW DO WE STORE YOUR PERSONAL INFORMATION?

    We will take all steps reasonably necessary to ensure the security of the personal information we collect and store about you. We will use all reasonable endeavors to protect your personal information from unauthorized disclosure and/or access. Unfortunately, the transmission of information over the internet is not completely secure and we have no control over the privacy of any communication while it is in transit to us. Although we will do our best to protect your personal information, we cannot guarantee the security of your information while it is being transmitted to our site. Accordingly, any such transmission is at your own risk.

    All information you provide to us is stored on securely managed servers and we will limit access to your personal data to our employees, agents, contractors and other third parties who have a business need to know. All payment transactions are encrypted using SSL technology and payment details are not kept after the transaction has been completed. Where we have given you or where you have chosen a password which enables you to access certain parts of the website(s), you are responsible for keeping this password confidential. You are responsible for controlling access to your account and for all activities that occur under your account and password. We therefore ask you not to share your password with anyone. We will not be liable for any loss or damage if you fail to comply with this obligation. To the extent required by law, we will notify you and any applicable data protection authority or other regulatory authority of any actual or suspected personal data breach involving your personal information.

  • 12. HOW LONG WILL YOU USE MY PERSONAL DATA?

    We will only keep your personal data for as long as is necessary to fulfill the purposes for which we collected it, including to comply with any legal, accounting or reporting obligations that we may have. We will only keep personal data for longer where there is a legal requirement for us to do so.

    To determine how long we should keep your information, we will consider the amount, type, and sensitivity of the personal information involved, as well as the potential risk of harm if it is lost or used or disclosed without authorization. We will also consider the purposes for which we process your personal data and whether we can achieve those purposes through other means without retaining your data.

    In some circumstances you can ask us to delete your data (see Section 15 below for more information).

    In some circumstances, we may also anonymize your personal data so that it can no longer be associated with you, for example for statistical purposes. Where we do this, we may use this information indefinitely without further notice to you.

  • 13. OPTING IN

    Sometimes we will give you the option to choose whether or not to receive information from us (e.g. by opting in to receive emails from us with news about our brands or promotional offers). However, sometimes we are required by law to collect information from you, or you may not have the option to opt out, such as when we are performing our obligations under a contract we have with you, or when we are processing a transaction requested by you, i.e. if you purchase products from us online. In some circumstances, if you choose not to provide certain information, we may be unable to provide you with a particular service or product.

  • 14. SHARING YOUR PERSONAL DATA WITH OTHERS

    We may share your personal information with any member of our group of companies – this includes any of our subsidiaries, our ultimate holding company and its subsidiaries.

    We may disclose your personal information to our suppliers, distributors (wholly or partly owned) and other contractors who are engaged by us to assist in the provision of products and services to you.

    We only use carefully selected third parties to help us deliver our services and products to you, and they are only allowed to use your personal information to deliver the services or products you have purchased, registered for or subscribed to. We do not allow them to use your personal data for their own purposes.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

    We will never share any of your personal data with anyone outside of our group of companies for third-party mailing or marketing purposes unless we have your consent to do so.

    As a global business, we may sometimes need to transfer personal data to a country outside the EEA. Where this is the case and your personal data is affected, we will ensure that an adequate level of protection is in place to protect your personal data.

  • 15. YOUR LEGAL RIGHTS

    In certain circumstances, you have rights under data protection laws in relation to your personal data. This includes the right to:

    • request access to your personal data; This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.
    • request that inaccurate personal data be corrected; This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of any new data you provide to us.
    • request that your personal data be erased; This enables you to ask us to delete or remove personal data that we no longer have a legitimate reason to process. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
    • object to the processing of your personal data or request that the processing be restricted;
    • withdraw your consent to our processing of your personal information.

    NO FEE USUALLY REQUIRED

    You will not have to pay a fee to access your personal data or to exercise any of your other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    WHAT WE MAY NEED FROM YOU

    We may need to request specific information from you to confirm your identity and to ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up our response.

    TIME LIMIT TO RESPOND

    We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than one month if your request is particularly complex or if you have made a number of requests. If this happens, we will notify you and keep you updated.

    If you wish to exercise any of the rights set out above, or if you have any concerns about how we are processing your information, please email us at www.eugesta.com so that we can investigate and hopefully resolve your concerns.

    If we are unable to resolve your concerns to your satisfaction, you have the right to lodge a complaint with the appropriate data protection authority.

  • 16. HOW TO UNSUBSCRIBE OR WITHDRAW YOUR CONSENT

    Where we have collected your personal information based on your consent and we have no other lawful basis for continuing to process your information, we will delete your personal information if you subsequently withdraw your consent.

    You can withdraw your consent, change your preferences, or opt out of receiving further communications from us by letting us know using the contact details set out in Section 2 of this Notice or by emailing us at www.eugesta.com.

    You can also ask us to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you.

    However, please note that if you unsubscribe from receiving marketing communications from us by email, we will keep a note of your email address to make sure that we do not send you any further marketing communications by email in the future.

Issue Date: September 2024