UAB “Reefo,” legal entity code 305914091 (hereinafter referred to as the Company), understands that the protection of personal data is important to our clients, suppliers, partners, and other individuals whose personal data we process (hereinafter referred to as data subjects). Therefore, we take a particularly responsible and diligent approach to matters related to the protection of personal data and take all necessary measures to ensure the privacy and security of data subjects.
This privacy notice outlines how the Company processes the personal data of data subjects, including information on what personal data is processed, how it is collected and further processed, how long it is stored, to whom it is provided, what rights data subjects have, and where to address for their implementation or for other matters related to the processing of personal data.
The privacy notice is prepared based on the following legal acts:
How we collect your data depends on the services we provide to you or the nature of our collaboration. The company processes data:
Received directly from the Data Subject (you), for example, when you send us inquiries or messages using the provided contacts, or when you register for inspections on our website;
Generated when you use our services, for example, when you use our network and services, such as making phone calls, sending text messages (SMS), browsing the internet, visiting our websites, etc.;
Received from data registers when we need to prepare a contract for you.
| Data collection purpose | Legal basis for data collection | Description of categories of personal data | Data storage periods |
| Conclusion and execution of contracts with clients” | Execution of contract GDPR Article 6(1)(b | Name, surname, phone number, address, bank details, personal identification number, individual activity certificate number, personal code, VAT number, email, content of correspondence and information provided therein, data from the register center | 10 years after the end of the contract validity |
| Registration for property viewing purposes | Consent. GDPR Article 6(1)(a) | Name, phone number, message content | 2 years |
| Monitoring website visitor habits | Legitimate interest GDPR Article 6(1)(f) | Collected cookie information, registration data: name, surname, phone number, email | Until consent is withdrawn |
| Handling complaints and inquiries | Legitimate interest GDPR Article 6(1)(f) | Name, surname, email address, residential address, phone number, apartment address, inquiry content | 5 years after the complaint is resolved |
| Sending newsletters for direct marketing purposes | Consent GDPR Article 6(1)(a) | Email address, phone, name, surname | Until consent is withdrawn |
| Social networks administration | Legitimate interest, Article 6(1)(f) of the GDPR | Comments, messages, name, surname | The information is stored on social networks until the person deletes the data themselves. |
| Search for potential clients | Legitimate interest Article 6(1)(f) of the GDPR | Name, phone number and/or email | 2 years |
The Company engages only those data processors who ensure compliance with the GDPR and the same level of personal data security as specified in the Company’s data protection policy.
Here is a list of categories of data recipients engaged by the Company:
In case of the need for data provision to Third Countries by our partners, it is carried out based on the lawful grounds for data transfer provided in the General Data Protection Regulation.
We recommend familiarizing yourself with the privacy notices provided by our partners:
Privacy notices of social network administrators:
Facebook: https://lt-lt.facebook.com/privacy/explanation;
Facebook cookie policy: https://lt-lt.facebook.com/policies/cookies/;
Instagram data policy: https://help.instagram.com/155833707900388;
Privacy notices of message delivery and statistics tracking service providers:
Google Analytics: https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20160909.html
In order to ensure an appropriate level of security when processing data, the Company has implemented suitable technical and organizational measures. When selecting and implementing appropriate technical and organizational measures to ensure data processing security, the Company adheres to ENISA guidelines, good information security practices, guidelines prepared by the State Data Protection Inspectorate (VDAI), and recommendations.
According to the provisions of the GDPR, as a data subject, you have the following rights:
1. Right to access personal data. This means you can request information about whether your personal data is being processed, and if so, you have the right to access the personal data being processed.
2. Right to rectify personal data. This means you can request correction of your personal data if you find that the personal data we process is incorrect, incomplete, or inaccurate.
3. Right to erasure (right to be forgotten). This means you can request deletion of your personal data if you believe that your data is being processed unlawfully or unfairly.
4. Right to restrict data processing. This means you can request to restrict (suspend) the processing of your personal data, except for storage – for example, when you request correction of your personal data (while the accuracy of personal data is being verified and/or corrected), it is determined that personal data is being processed unlawfully and you do not consent to the deletion of data, you have objected to the processing of your personal data, etc.
5. Right to data portability. This means you can request the transfer of your personal data processed by automated means to you and/or another data controller in a structured, commonly used, and machine-readable format.
6. Right to object to data processing. This means you can object to the processing of personal data when data is processed by the Company on the legal basis of legitimate interest or public interest.
7. Right to demand that automated decision-making and profiling based on data processing that affects your legal rights or significantly affects you be excluded;
8. Right to withdraw consent given to us at any time for the processing of personal data – for example, you can unsubscribe from direct marketing messages at any time by clicking on the “Unsubscribe from the list” option.
9. You have the right to refuse to provide your personal data, but the provision of your personal data is necessary and essential for the purposes stated in this privacy notice. Therefore, if you do not provide your personal data, the Company may fail to achieve the stated purposes.
You can execute your rights by:
1. Sending us a free-form request to the email address hello@reefo.lt. The request must be signed with a valid electronic signature or accompanied by a copy of a notarized identity document to verify your identity.
2. Sending a request by registered mail to the address Švitrigailos g. 11K-212, Vilnius, indicating that the letter is addressed to the data protection officer. The request must be signed. A copy of your identity document must be attached to the request, certified by a notary.
The request must be in writing, signed, and include the data subject’s name, surname, place of residence, and other data necessary for communication in the desired format, information about which of the data subject’s rights and to what extent the data subject wishes to exercise.
In exceptional cases, if there are suspicions regarding the identity of the data subject, we reserve the right to request additional information to help verify the identity of the applicant, for example, by answering additional questions related to our cooperation, providing notarized documents, etc.
We will respond to your request no later than 30 (thirty) calendar days from the date of receipt of the request. In exceptional cases requiring additional time, we reserve the right to extend the deadline for the provision of requested data or the examination of other requirements specified in your request for up to 60 (sixty) calendar days from the date of your inquiry, after notifying you accordingly.
The Company reserves the right to refuse to consider a data subject’s request if it is found that the requests are obviously unfounded or disproportionate, especially due to their repetitive content.
If no solution can be reached together, you have the right to contact the State Data Protection Inspectorate (www.vdai.lrv.lt), which is responsible for the supervision and control of the legislation regulating the protection of personal data.
If you have any questions regarding the information provided in this privacy notice or the protection of your personal data and the exercise of your rights within the Company, including reports of observed personal data breaches, please feel free to contact the Company’s Data Protection Officer in any way convenient for you:
Email: hello@reefo.lt.
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List of cookies used on the website:
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| Google Analytics: identifies users | _ga | 2 years | Short randomly generated ID |
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| The Google Analytics cookie thats is necessary for connecting to a Google Analytics account | _utmt_UA_XXX | 6 months | |
| Google Analytics: stores information about where the user came from, which search engine was used, which link was clicked, and what keyword was used. | __utma, _utmb, _utmc | 2 years |
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