Primum Estetica UAB (hereinafter referred to as “the Clinic”) is committed to protecting the privacy of natural persons. This Privacy Policy sets out how we process your personal data (e.g. how we collect, use, disclose, store and protect your personal data). We also provide information about your rights as a data subject. The Clinic is a data controller and is responsible for the collection, use, disclosure, storage and protection of your personal information in accordance with the General Data Protection Regulation (“GDPR”), internal policies and rules, and applicable national law.
This notice is to inform you about our processing of personal data received from users (hereinafter collectively referred to as “Data Subjects”). Data subjects under the age of 18 (hereinafter referred to as the “Minors”) are not allowed to use our services and we ask that you do not provide any of your personal data to the Company if you are under the age of 16. Please note that this Privacy Policy applies only to the website https://primumestetica.lt/.
Please read this Privacy Policy together with the Primumestetica.lt website terms of use. This Privacy Policy governs your use of the Primum Estetica UAB website. This Privacy Policy contains information about how we collect, use, store and process your personal data, so please read this Privacy Policy carefully before using the services provided by Primumestetica.lt and the Clinic. If you do not agree to this Privacy Policy, we recommend that you do not use the website of Primum Estetica UAB.
We may revise this Privacy Policy at any time by updating the information posted here and we will obtain your consent to the changes if necessary. When this Privacy Policy was last modified is indicated in the “last updated” entry.
The Website is maintained and operated by Primum Estetica UAB (registered office: Pylimo g. 47, 01137 Vilnius, Lithuania; hereinafter referred to as “we”, “us”, “our”, “ours” or the “Company”).Information about the Clinic:
“Primum Estetica”, UAB
Legal entity code: 305045408
VAT code: LT100012621918
Registered office address: Pylimo g. 47, 01137 Vilnius
E-mail: info@primumestetica.lt Tel. +370 67099669
1. WHO WILL BE THE DATA CONTROLLER?
The data controller is the Clinic (“we”, “us”, “our” or “Company”).
2. WHAT IS THE PURPOSE OF THE PROCESSING?
We only collect and process your personal data that is sufficient and necessary to achieve the purposes for which it is processed. We process personal data in order to provide the services you have requested. The processing is carried out for the following purposes:
- To fulfill your orders, requests, consultations, inquiries or requirements submitted to the website (hereinafter referred to as the “Website”) by the methods and/or contact addresses you have provided.
- To help you contact your doctor.
- For direct marketing purposes.
- Cookies: we use cookies to obtain information about your use of our website https://primumestetica.lt/.
Cookies enable us to provide you with a simpler and more accessible website experience. Third-party cookies help us to improve the relevance of the advertisements used across different channels. The information generally does not include any data that would identify you as
a natural person.
2.1. Purchasing and processing your orders
We collect your personal data in order to receive, administer and fulfil your orders, including, but not limited to, processing payments, invoicing, communicating with you about, dealing with, resolving, etc:
Categories of personal data processed: your purchase data; your identification and contact data; communication data when and insofar as it relates to a specific order.
Legal basis: for the purpose of concluding and executing the sale and purchase agreement between you and Primum Estetica, UAB.
How long we keep the data: a specific order and the related data and documents are kept for 10 years after the order has been completed.
2.2. Personalisation of content and recommendations
To make your browsing and shopping experience even more convenient and faster, and to ensure that the content is relevant to your needs, we recommend products, services, features and content on Primumestetica.lt that may be relevant to you. In order to get to know you better and to provide you with content that is truly relevant to you, we process the following data about you: Categories of personal data processed: session ID; data recorded during the session of your browsing on the Primumestetica.lt website. All browsing data of an unregistered Customer is collected and processed on a personalised basis only and does not allow the identification of a specific person. In certain cases, the Primumestetica.lt system may recognize you as a returning user and associate the data collected during the previous browsing session(s) with the data of the new browsing session. However, in this case too, we cannot identify you as a specific person, as the browsing data is not linked to any other personal data and identifiers.
Legal basis: your consent, which you give by confirming your cookie choices.
How long we process the data: as long as your consent is valid, but no longer than two years. You can manage and withdraw your consent at any time by changing your cookie preferences as set out in the information on the cookies we use.
2.3. General and personalised direct marketing messages
At Primumestetica.lt you can subscribe to newsletters, information about Primumestetica.lt news, promotions, as well as offers tailored to you based on your purchase and browsing history. In order to provide you with such offers and information, we process the following data about you:
- Categories of personal data processed: your contact details; your purchase and browsing history on Primumestetica.lt, if you have opted to receive tailored offers; data about your viewing of newsletters and other communications.
- Legal basis: your consent provided by subscribing to Primumestetica.lt newsletters, general and/or tailored communications and offers. We process the data on the basis of our legitimate interest when you view newsletters and other communications. The collection and analysis of such data enables us to assess the relevance and effectiveness of our direct marketing campaigns, to ensure that our communications are interesting and relevant to you and that our direct marketing is effective.
- How long we process the data: as long as your consent is valid. You can withdraw your consent to receive newsletters, general and/or tailored communications and offers at any time by clicking the unsubscribe link in the email or by contacting us at info@primumestetica.lt or by phone +370 67099669.
2.4. Examination of requests, demands and other enquiries made by you
When you contact us for help, ask us questions, submit requests, feedback, complaints and similar actions, you are usually providing us with your personal data. Such data is used by us to enable us to process your request, claim or other enquiry in an appropriate and objective manner, to provide you with the information you have requested and/or need, to respond to your questions, and to resolve your requests and/or claims. We may also use the data from your requests, claims and other enquiries for the purpose of defending our rights and legitimate interests in the event that your request, claim or other enquiry gives rise to a legal dispute or the possibility of such a dispute:
- Categories of personal data processed: data relating to communication with you; your identification and contact details; other data necessary for the processing of your request, claim or enquiry.
- Legal basis: the performance of a contract where your request, claim or enquiry relates to the contract and/or its performance; the performance of our legal duty to respond to requests, claims and enquiries from Customers; our legitimate interest to protect our rights and interests when you contact us with a complaint or claim, or where a legal dispute is being initiated or is likely to arise.
- How long do we process the data: we process the data until we have dealt with the request, demand or other enquiry you have made, provided a response, and for a further 2 years after the resolution of such request, demand or other enquiry. If a legal dispute is initiated or is likely to be initiated as a result of a request, demand or other enquiry made by you, we may keep your data for a longer period of time – until the expiry of the statutory periods of limitation for lodging a complaint or bringing an action, and/or until the final decision has become final.
2.5. Analytics and statistics for the purpose of performance analysis, development and improvement
We aim to make the Primumestetica.lt website as convenient and easy to use as possible, and to ensure that the services we provide are useful and relevant to our Customers, so that they can have the best possible Customer experience. Therefore, in order to develop and improve our activities, we analyse how Customers use the Primumestetica.lt website and Primumestetica.lt services and process the following data. It should be noted at this point that, for the purposes of analytics and statistics, we process non-personalised aggregated data and do not process your contact details or other information that personalises you. In other words, the analytical and statistical data does not identify a specific user, is not linked to other data of an identified user, and is not combined into data sets on a per-user basis:
- Categories of personal data processed: aggregated Customer purchase data; aggregated browsing data on the Primumestetica.lt website; aggregated data on the viewing of newsletters and other communications; aggregated data on communications with Customers.
- Legal basis: we carry out the Statistics and Analytics and collect and process data for this purpose only on the basis of your consent. You can accept or reject analytical and statistical cookies at any time by changing the selection of these cookies accordingly.
- How long we process the data: we keep the data for as long as necessary for the purposes defined in this section.
- Notes: on the Primumestetica.lt website, we may use Google Analytics and/or other website analytics providers. Google Analytics and other analytics tools collect browsing data using cookies and similar technologies. However, in general, cookies from Google Analytics and/or other analytics tools on Primumestetica.lt act as cookies under our own (first party) control. We collect and use analytical and statistical data about your visit and use of the Primumestetica.lt website only on the basis of your consent, for the purpose of evaluating the performance of our services and/or marketing campaigns and to make important decisions on the development and improvement of our activities, such as the development of Primumestetica.lt services and the improvement of the website. However, if you object to the installation of analytical cookies, you can reject them in your web browser, as stated in the Cookie Policy.
2.6. Information on the processing of CCTV data
CCTV cameras are installed on the outside of the clinic building to capture and record images that come into the cameras’ field of view. The video recordings may only be viewed by responsible persons duly authorised by the Head of the Clinic, who are familiar with the requirements of the legislation on the protection of personal data and have undertaken to comply with them, either by signing a declaration or by any other means of proof of their familiarity with the legislation and their commitment.
CCTV recordings may be provided to those interested parties involved in the incident, such as law enforcement authorities and officials, insurance companies, visitors (where damage to their property or the incident involves bodily injury). In these cases, the data will only be provided once it has been established that there is an appropriate legal basis for providing the data. In order for the Clinic to exercise its legitimate interest in the safety, health and public order of individuals, we process the following data about you:
- Categories of personal data processed: your image as an individual.
- Legal basis: the need to pursue Our legitimate interests; the need to protect the health, safety, public order and property of persons in the Clinic (in accordance with Article 6(1 )(f) of GDPR).
- How long we process the data: video recordings are kept for up to 180 calendar days and are automatically deleted when new video recordings are stored on the storage medium, unless there are reasonable grounds to believe that a criminal offence is being committed, that an offence is being committed, or that other unlawful acts are being committed (pending the outcome of the relevant investigation and/or proceedings).
3. HOW DO WE USE YOUR DATA?
We process your personal data in accordance with the legal requirements set out in the Law on Personal Data Protection, the Law on Prevention of Money Laundering and Terrorist Financing and other applicable legislation.
We process your personal data in accordance with the legitimate interests of Primum Estetica UAB.
In accordance with our legitimate interest, we process your personal data in order to provide you with offers of our products and services that best meet your needs.
If you wish to opt-out of our direct marketing communications, please inform us at any time using the contact details provided that you do not wish your contact details to be used for direct marketing.
In all cases, we take into account your interests and rights under data protection legislation when processing your personal data in accordance with our legitimate interests. Your privacy rights are always guaranteed by safeguards and balanced with your rights and freedoms. You have the right to object to the processing of your personal data for the purpose of our legitimate interest. If you wish to object, please contact us using the contact details above. Please note that we may continue processing if, after assessing our legitimate interest, it is compatible with your freedoms and rights. If your objection is motivated, we may suspend the processing of your data for the reasons stated.
However, where personal data is processed for the purpose of concluding or performing a contract (e.g. your purchase order) and/or providing you with the desired Primumestetica.lt Service, you would not be able to place the purchase order or use the relevant Service if you did not provide the relevant personal data or did not authorise their processing. From time to time we may collect and process your data with your consent. Your consent is voluntary and is required for the related processing operations for the following purposes.
4. WHAT IS THE LAWFUL BASIS FOR PROCESSING?
Unless otherwise stated in this Privacy Policy, the processing of personal data is carried out on a voluntary basis and is based on your freely given consent. You have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal. Failure to provide the requested personal data may result in our inability to provide you with the Services.
5. WHAT PERSONAL DATA MAY WE COLLECT?
In the course of our business and for the purposes set out above, in relation to the services we provide to you and the use you make of Primumestetica.lt services, features and other interactions you have with us, we may process (collect) the following personal data:
| Data category | Collection and processing of personal data | Where the data comes from |
| Your identification, profile and contact details | Identifying data: your name; Contact details: email address, telephone number, residential address. Other profile data that you provide to us by choice: date of birth, gender, choice of language, company name and details if you are interacting with us on behalf of a company, other information you provide to us about yourself. | Received from you when you place an order with Primumestetica.lt and provide us with your data necessary for its execution, contact us with a request, enquiry, complaint or similar way. |
| Purchasing data | Your order details: the services or goods ordered, their quantity, prices, discounts given, gift vouchers used, date and time of order placement; Payment details: payment method, date and time, payment details (including but not limited to bank account number); Delivery details: delivery method and/or delivery address; Information about the status and progress of the order: whether the order is ready, dispatched, delivered, information about returns, etc. Communication data: information about communications and interactions with you on issues related to the order and its execution, your feedback and ratings, content of other communications. Other information: indication that you have read the Terms and Conditions of Sale and Purchase and/or Privacy Policy, date and time of reading. | Received from you when you place an order with Primumestetica.lt, make a payment for an order, contact us (or we contact you) about issues related to the order and its execution, when you request a return of goods, etc. Generated during the execution of the order. Collected by means of cookies and similar technologies when and to the extent that such information is necessary for the conclusion of the sales contract, the acceptance of the order and the processing of the order (e.g. cookies record that you have read the Terms and Conditions of Sale and Purchase and/or the Privacy Policy). |
| Your consent, communication and/or service management choices | Consents and communication choices: your consent to receive marketing and/or other communications, information about ordering and/or unsubscribing from communications; Service choices: information about the Primumestetica.lt services you use, ordering and/or unsubscribing from them. Your choices about cookies. | Obtained from you (and captured by automated means, including through cookies and similar technologies) when you check the relevant consents and/or choices, subscribe to or opt-out of the relevant communications and/or services. |
| Data about your browsing on the Primumestetica.lt website | Browsing data: pages viewed, services or products viewed, date and time of viewing, duration of browsing, items uploaded to the shopping cart, date and time of upload, other clicks and interest in the content, information about where users come to the website from, including but not limited to affiliate link statistics. Technical data: IP address, session ID, browser used, device type, resolution. | Collected by means of cookies and similar technologies when you browse the Primumestetica.lt website. Generated from your browsing data (e.g. statistical browsing information). |
| Other data that is generated when you use the relevant Primumestetica.lt services | Data that is generated when you use certain services or features of Primumestetica.lt: for example, when you save your language preference on the website, confirm your age of majority, etc. This information allows us to send you messages in languages that you understand, determine whether you can use the services, etc. | Received from you (and recorded by automated means, including cookies and similar technologies) when you use the relevant Primumestetica.lt service or feature. |
| Viewing data for newsletters and other communications | Information on the successful delivery of the message, information on the opening of the message and the date and time of the opening, clicks on the links contained in the message, information on the forwarding of the email (without recording the addressee), information on the unsubscription of messages (of the type concerned). | Collected by cookies and similar technologies when you receive and view newsletters and other email communications. |
| Communication data with you | When you contact us for help, ask us questions, give us feedback, make complaints and in other similar cases, we process records and copies of your communications with us, the documents and data you provide to us, as well as data collected by us when and to the extent that it is necessary for us to investigate and respond to your enquiry. | Received from you when you contact us with a request, feedback, complaint or other enquiry. Collected by us from data we already lawfully hold about you and/or obtained from third parties (e.g. public authorities, etc.) when and to the extent necessary to process and respond to your enquiry. |
| CCTV surveillance data | Video surveillance data: an image of you as a person. The Clinic has a legitimate interest in the safety, health and public order of persons and the security of the Clinic’s premises and property. In cases of theft, damage to property or other unlawful acts, video recordings provide an opportunity to observe, investigate and prove these incidents. | Received from you when you enter the Clinic premises, where the image is captured in the field of view of the cameras. |
6. WHAT COOKIES DO WE USE?
Our Website may use cookies to distinguish you from other users of the Website. This helps us to improve your browsing experience on the Website and to improve the Website.
A cookie is a small alphanumeric file that we store on your browser or on your computer’s hard drive, if you accept it. Cookies contain information that is transferred to your computer’s hard drive.
We may use the following cookies:
- strictly necessary cookies: these cookies are essential for the operation of the Website. They include, for example, cookies that allow you to access secure areas of our Website. This category of cookies cannot be disabled;
- analytical/performance cookies: these allow us to recognise and count visitors and to see how visitors navigate through the Website when using it. This helps us to improve the performance of the Website, for example by ensuring that users can easily find what they are looking for;
- functional cookies: these cookies are used to recognise you when you return to our Website. This allows us to personalise content for you, greet you by name and remember your preferences (e.g. your preferred language or region);
- targeting cookies: these cookies record your visit to the Website, the pages you visit and the links you click. We will use this information to better tailor the Website and the ads displayed on it to your interests. In addition, we may share this information with third parties for the same purpose.
- For more information on the individual cookies we use and the purposes for which we use them, please see the table below. You can block cookies by activating a setting in your browser that allows you to refuse the recording of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of the Website. For more information about cookies and how to disable them, please visit www.allaboutcookies.org.
- We may use the following cookies:
- strictly necessary cookies: these cookies are essential for the operation of the Website. They include, for example, cookies that allow you to access secure areas of our Website. This category of cookies cannot be disabled;
- analytical/performance cookies: these allow us to recognise and count visitors and to see how visitors navigate through the Website when using it. This helps us to improve the performance of the Website, for example by ensuring that users can easily find what they are looking for;
- functional cookies: these cookies are used to recognise you when you return to our Website. This allows us to personalise content for you, greet you by name and remember your preferences (e.g. your preferred language or region);
- targeting cookies: these cookies record your visit to the Website, the pages you visit and the links you click. We will use this information to better tailor the Website and the ads displayed on it to your interests. In addition, we may share this information with third parties for the same purpose.
- For more information on the individual cookies we use and the purposes for which we use them, please see the table below.
7. WHERE IS THE INFORMATION STORED AND WHO WILL SEE IT?
Access to your personal data is limited to those authorised persons and departments of the Clinic and the Clinic’s units in your country (if any) who need to have access to it in order to carry out their functions. We will not disclose your personal data to third parties, external bodies or organisations unless you have given your consent to the transfer of the data, or as required or permitted by law.
In cases of legal proceedings and other cases provided for by law, your personal data may be transferred to public authorities in accordance with the procedure established by the legislation of the Republic of Lithuania.
8. HOW LONG WILL PERSONAL DATA BE STORED?
We keep personal data for no longer than is necessary to achieve the purposes for which the personal data were processed (collected), unless we are specifically required by applicable law to keep the personal data longer.
The data retention periods for the individual purposes of data processing are detailed in Part 2 of this Privacy Policy. The storage of personal data for a longer period than set out in this Privacy Policy may only be carried out when:
- there are reasonable grounds for suspecting the unlawful activity under investigation;
- Your data is necessary for the proper resolution of a dispute or complaint;
- if the data is necessary to ensure the security of the Primumestetica.lt website, e.g. in the event of suspicious activities of a visitor or a Customer, etc.;
- on other specific grounds, conditions or in other cases provided for by law.
We will delete and remove personal data if:
- You withdraw the consent on which the processing is based and the other legal grounds for processing no longer exist;
- You object to processing and there are no legitimate grounds for processing that override your objection, or you object to processing for direct marketing purposes;
- personal data have been processed unlawfully;
- the personal data must be erased in order to comply with a legal obligation to which the Clinic is subject.
The data will not be erased to the extent necessary for compliance with a legal obligation under which the Company is required to process the data, or for the performance of tasks which are of public interest or in the exercise of official authority vested in the Clinic (if any); for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes; or for the purpose of asserting, exercising or defending the legal claims of the Clinic.
9. WHAT KIND OF INTERNATIONAL DATA TRANSFERS ARE MADE?
We do not transfer your personal data to countries or territories outside the European Economic Area unless that country or territory has an adequate level of protection or you have given your explicit consent to the transfer abroad.
10. HOW DO WE ENSURE DATA INTEGRITY?
Every reasonable and practicable step will be taken to ensure that the personal data we hold is accurate. Please update your personal data and notify us of any changes to the personal data you provide to us.
11. HOW DO WE PROTECT PERSONAL DATA?
We will take all necessary measures to ensure the security of personal data and to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, alteration, disposal, erasure or other unauthorised use of personal data.
Please note that the electronic transmission of information cannot be completely secure. We use Secure Sockets Layer (SSL) and password encryption to protect the security of the information we process. Please note that you have an active duty of care to keep your password secure and not to share this data with third parties.
12. WHAT ARE YOUR RIGHTS AND REMEDIES?
You have the right to have incomplete, incorrect, inappropriate or irrelevant personal data removed or rectified or restricted. If you believe that the personal data we hold about you is incomplete, incorrect or irrelevant, you may contact us and we will make the necessary corrections within twenty-five (25) days. All reasonable and practicable steps will be taken to ensure that the personal data we hold is accurate. We will restrict personal data if you dispute its accuracy or relevance and the accuracy of such assertion cannot be ascertained beyond reasonable doubt. You may request that we remove your personal data, but we may be under a legal obligation to keep such information secure and not to remove it (or to restrict its processing for a period of time, in which case we will only comply with a request to remove the data once we have complied with the above obligation). You have the right to be informed about the processing of your personal data. We will respond to requests for access to personal data as soon as possible, but no later than twenty-five (25) days from the date of the request. We may ask you to provide additional information necessary to confirm your identity. You also have the right to object to the processing of your personal data if the processing or transfer of your personal data is necessary for the performance of a contractual obligation, for the legitimate interests of us, the recipient or another third party (except where processing is mandatory), or where permitted by law. We will process such objections within fifteen (15) days from the date of submission. If you disagree with our decision on your objection, you have the right to initiate legal proceedings within thirty (30) days from the date of receipt of the decision rejecting your objection. You have the right to exercise the right to data portability under the conditions laid down by law.
This Website may contain links to third party websites. Such linked websites are not under our control and we are not responsible for their privacy practices. We note that this Privacy Policy does not apply to any third party applications, services or websites, even if you use or access them through the means indicated on Primumestetica.lt. This Privacy Policy does not apply to information provided or collected by third parties. Where this Privacy Policy does not apply, you should read the privacy policy and related terms and conditions posted on the relevant website or application that you are using, or that applies to other services that you are using, before submitting your personal information.
13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?
Data subjects’ enquiries and requests on data protection issues shall be received at the Company’s general email address info@primumestetica.lt.
Last update date: 17 February 2023