1. What is provided in this Privacy Notice and who is it intended for?

UAB “EPSO-G” (hereinafter – the Company or we), in carrying out its activities, processes (collects, stores, etc.) your personal data. In processing this information, the Company follows the General Data Protection Regulation (GDPR) of the European Union and other legal acts regulating personal data protection.

In this Privacy Notice intended for you (hereinafter – Privacy Notice), we provide basic information about the processing of your personal data by the Company – where we obtain your personal data and to whom we may provide them, for what purposes and on what grounds we process them, what rights you have, how you can exercise them, and other relevant information. Please carefully review this important information and visit our website at https://epsog.lt/privatumo-pranesimas from time to time to read the latest version of the Privacy Notice published there.

To find out when the Privacy Notice was last updated, you can look at the date “Last updated”.

2. Who is responsible for the protection of your personal data?

UAB “EPSO-G”, legal entity code: 302826889, registered office address: Laisvės pr. 10, Vilnius, email: , phone no. +370 685 84866

3. Why and what personal data do we collect?

No.Why do we collect information about You?What information do we collect about You?Why do we have the right to collect the information You provided?How long do we use or store information about You?

3.1.

We select candidates to become members of our collegiate bodies or those of our group companies (which are directly controlled by us).

Name, surname, date of birth, telephone number, place of work, e-mail address, place of residence (address), education, date of receipt of curriculum vitae, personal qualities, work experience, knowledge of foreign languages, ability to work with computer programs, other information contained in the curriculum vitae, letter of recommendation and/or cover letter, signature, the data contained in the candidate's application for participation in the selection procedure and in the declaration of integrity and declaration of interests, and the records of the interviews/voice of the candidates for the membership of the collegial organs of the subsidiaries.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR). We have Your consent (Article 6(1) clause a of the GDPR)

1 year after the end of the selection.

3.2.

We carry out a verification of the reliability of candidates seeking to perform their duties

Name, surname, position applied for, date of submission and/or revocation of consent for security clearance, signature, personal data referred to in Article 16 of the Law on Prevention of Corruption of the Republic of Lithuania and/or Article 17 of the Law on the Protection of Objects of Importance to Ensuring National Security of the Republic of Lithuania (the scope of the personal data shall depend on the information provided by the relevant authorities to the Company). For this purpose, special categories of personal data may also be processed if they have been provided to us by the authorities carrying out the screening of the candidate (the State Security Department of the Republic of Lithuania, Special Investigation Service of the Republic of Lithuania, the Ministry of the Interior of the Republic of Lithuania).

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR). We have Your consent (Article 6(1) clause a of the GDPR)

When the selection process provides information leading to a decision not to appoint a person to a position, the personal data will be kept for 3 months after the end of the selection process. When a candidate's verification provides information that leads to an employment decision, the candidate's personal data (obtained prior to the conclusion of the employment contract) is stored for the duration of the employment contract and for 1 year after the termination of the employment relationship.

3.3.

We organize and conduct public procurement

Name, surname, personal code or date of birth, address, telephone number, position, other personal data may be required depending on the object of the contract and the qualification requirements (criminal record check, tax obligations related to the object of the contract, qualification requirements as specified in the contract documents), name, surname, personal code or date of birth, address, telephone number, position, bank account number, copy of the certificate of sole proprietorship, copy of the business certificate. The successful supplier may be asked for: curriculum vitae, copies of diplomas, certificates obtained, the number of contracts completed, criminal record, payment records with the State Tax Inspectorate, SoDra etc.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

During the period of validity of the contract and 5 years after the expiry of the contract. When the contract was not concluded, 5 years after the end of the procurement.

3.4.

We draw up and execute contracts with You, and comply with related tax obligations

Name, surname, personal code or date of birth, telephone number, e-mail address, bank account number, signature, basis of representation (power of attorney, statutes, etc.), number of the power of attorney, term, duties, billing information, settlement period, other information relevant to the conclusion and performance of the contract, depending on the nature of the contract.

We conclude a contract with You and fulfil our contractual obligations (Article 6(1) clause b of GDPR)

During the period of validity of the contract and 5 years after the expiry of the contract.

3.5.

We carry out internal and external communications to publicise the Company’s activities

In the case of media representatives, name, surname, position, telephone number and e-mail address. In the case of instructors, other invitees, name, surname and position.

We have a legitimate interest in processing Your personal data (to publicise the Company's activities by informing You about ongoing news) (Article 6(1) clause f of GDPR)

Media representatives (e.g. journalists in charge) - protected for as long as they are actually working for the media outlet or the department. 5 years after the end of the contract.

3.6.

We administer the internal reporting channel (Trust line) and carry out internal investigations on the basis of the information received

In case the information is not provided anonymously, the data collected will be the data provided by the person himself or herself - name, surname, telephone number, personal code, e-mail address, the circumstances of the notification, the date of the notification, the decision to inform about the actions taken and the decisions taken.

We have a legitimate interest in the processing of Your personal data (to prevent fraud, corruption, other criminal acts, violations of law, other violations -to prevent acts being committed, to take measures to prevent acts being committed in the future, etc.)(Article 6(1) clause f of GDPR). We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

If an infringement has been found after examination of the information received - 5 years after the end of the investigation. If the examination of the information received did not lead to the finding of an infringement - 3 years after the end of the investigation carried out.

3.7.

We deal with complaints, suggestions or requests submitted by You

Name, surname, e-mail address, telephone number, signature, date of application, application number (registration number) and the information contained therein, the outcome of the proceedings, if the person making the application, complaint or proposal has been communicated with by e-mail, the personal data recorded in that communication.

We have a legitimate interest in processing your personal data (to deal with your applications, requests or complaints) (Article 6(1) clause f of GDPR)

3 years from the date of receipt of the application, complaint or offer.

3.8.

We administer lists of persons with inside information in accordance with the requirements of the Market Abuse Regulation[1]

Name, surname acquired at birth, work/personal telephone number, date of birth, personal code, home address, reason for inclusion in the list, date and time of inclusion, date and time of removal from the list.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

5 years from the last update date of the list

3.9.

We administer the list of persons in the management positions of the company and closely related to them, implementing the requirements of the Market Abuse Regulation

Personal data of persons closely related to the Company's heads/managers (spouses, partners, persons treated as spouses in accordance with the procedure established by the legislation), children or stepchildren (16 years of age or older, living together with the them), relatives who have been living together with them for 1 year prior to the date of conclusion of the transaction in question) - name, surname, nature of the relationship with him/her.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of GDPR).

1 year after the person has completed his/her duties.

3.10.

We carry out internal audits of the Company and the Group companies

Personal data recorded in documents, including but not limited to emails, etc., of employees of Group companies and representatives of counterparties, which are provided for internal auditing.

We have a legitimate interest in the processing of Your personal data (ensuring proper risk management and internal control, improving the management of Group companies) (Article 6(1) clause f of GDPR).

10 years after the approval of the internal report.

3.11.

We develop, coordinate and control the activities of the Group companies and their development

Name, surname, date of birth or personal code, work e-mail address, work telephone number, information on the employee's curriculum vitae, information on remuneration and transfer of other benefits, investigation material on accidents at work, breaches of work duties, other breaches of work-related obligations, information on private interests and other data obtained for the purpose of development, coordination and control of the Group companies' operations.

We have a legitimate interest in processing Your personal data (to coordinate the activities of the Group companies, ensuring their development) (Article 6(1) clause f of GDPR).

Personal data is stored for 3 years.

3.12.

We provide services to our Group companies

Name, surname, position, telephone number, e-mail address, any other personal data recorded in the course of providing management or other advisory services, number of hours spent on the consultation, area of consultation, category, description.

We have a legitimate interest in the processing of Your personal data (to ensure the quality of the services provided and the efficiency of the activities) (Article 6(1) clause f of GDPR).

Personal data is stored for 5 years.

3.13.

We strive to ensure the efficient and safe operation of our website (we use technical cookies to support the user session)

Unique identifier

We have a legitimate interest in processing Your personal data (to ensure that the Company's website operates in a high quality, secure manner) (Article 6(1) clause f of GDPR)

Until the closing of the website window (information is automatically deleted after the browser is turned off)

3.14

We implement economic or financial sanctions, embargoes or other restrictive measures imposed or administered by the EU or other relevant institutions. Managing risks associated with business partners

Name, surname, date of birth, nationality, place of residence, address of registration, country of residence, percentage of shares held, information on links with politically exposed persons, information on investigations carried out in relation to corruption, competition, anti-money laundering, terrorist financing, occupational health and safety violations, information on business partners, clients. Personal data of shareholders of the partner of activity, beneficiaries (name, surname, date of birth, nationality, place of residence) Name, surname, position, e-mail address of the representative of the business partner. Other information provided in the questionnaire by the business partner, his representative.

We are obliged to collect information in accordance with the law (Article 6(1) clause c of the GDPR), we have a legitimate interest (to ensure the compliance of our business partners with the requirements of the Group's Supplier Code of Conduct and the management of potential financial and reputational risks) (Article 6(1) clause f of the GDPR)

5 years after the end of the contractual relationship.

4. Where do we obtain your personal data?

Most of the information is provided by you, but we may also obtain certain personal data from:

4.1. legal entities where you work (e.g., companies of the UAB “EPSO-G” group) or which you represent (e.g., suppliers with whom we enter into contracts).

When we receive personal data from you, we ask that you only provide the information necessary to achieve the purposes specified in point 3. Other information, such as political views, nationality, religion, etc., should not be provided.

5. What personal data must you provide us and why?

Please review the answer to point 3 above – you must provide the information about you that is necessary for us to:

5.1. enter into contracts with you and fulfill contractual obligations;

5.2. enter into contracts with the persons you represent and fulfill contractual obligations;

If you do not provide the specified information, we will not be able to enter into contracts with you and/or the persons you represent and fulfill contractual obligations.

6. To whom can we transfer your personal data?

We may transfer information related to you to our partners, service providers, as well as to the entities listed below only to the extent necessary to achieve the purposes specified in point 3 and as permitted by applicable laws:

6.1. banks conducting payment operations (data is transferred for the purpose specified in point 3.4);

6.2. courts, supervisory, law enforcement, and other state institutions (data may be transferred for all purposes specified in point 3);

6.3. lawyers, notaries, bailiffs, auditors, consultants, companies providing data center, hosting, cloud, website administration, and related services, software development, maintenance, and development companies, companies providing information technology infrastructure services, communication service providers, insurance companies, archiving services, and other services to the Company (data may be transferred for all purposes specified in point 3)

Please note that when the Company transfers personal data to other third parties as engaged data processors, it ensures that these persons apply appropriate technical and organizational measures to ensure the secure processing of personal data and an adequate level of data protection in accordance with applicable European Union legislation.

7. Will your personal data be transferred outside the European Economic Area?

In most cases, personal data is processed and transferred within the European Union and the European Economic Area (EEA[2]) territory.

If necessary for the provision of certain services, data may also be transferred and processed outside the mentioned territories, provided that an adequate level of personal data protection is maintained. Where permitted by law and necessary for the reasons specified in point 6 of this Privacy Notice, we disclose information about you:

7.1. based on a decision of the European Commission on adequacy, meaning that the European Commission has recognized the country in which the third party is established and/or operates as ensuring an adequate level of personal data protection;

7.2. we have signed a contract with the third party based on the Standard Contractual Clauses approved by the European Commission;

7.3. we have obtained permission from the State Data Protection Inspectorate;

7.4. using, if possible, other possible personal data protection measures and provisions allowing deviations.

8. How do we protect your personal data?

To ensure that information about you is protected from unauthorized access, disclosure, accidental loss, alteration, or destruction, or other unlawful processing, we have implemented and apply appropriate technical and organizational measures for the security of your personal data.

9. What rights do you have?

GDPR and other legal acts grant you rights, specify the cases when you can exercise them, the procedure you must follow, as well as exceptions in cases where you cannot exercise the granted rights. Where permitted by law, you may:

9.1. access your personal data, i.e., receive a notification confirming whether the Company processes your personal data, and if it does, request access to the processed data and related information;

9.2. submit a request to us to correct inaccurate, incorrect personal data or to supplement them when they are incomplete;

9.3. submit a request to us to delete your personal data that we have, if this can be justified by one of the reasons specified in Article 17(1) of the GDPR;

9.4. submit a request to us to restrict the processing of your personal data we hold, when one of the cases specified in Article 18(1) of the GDPR applies;

9.5. object to the use of your data when we process your data for the legitimate interests of the Company and/or third parties;

9.6. submit a request to us to transfer (receive) the data you provided to us under a contract or consent for data processing and which we process by automated means in a commonly used electronic format;

9.7. object to being subject to a decision made solely on automated processing, including profiling, if such decision-making may have legal consequences or similarly significant effects on you;

9.8. withdraw your consent for us to process your personal data when we use the data based on your provided consent;

9.9. file a complaint with the supervisory authority, primarily in the member state where your permanent residence is located or where the suspected GDPR violation occurred, and seek judicial remedies. In the Republic of Lithuania, the supervisory authority is the State Data Protection Inspectorate (L. Sapiegos g. 17, Vilnius; email: ), but we recommend that you first contact us, and we will try to resolve all your requests together with you.

10. How can you exercise your rights?

To exercise your rights specified in point 9 of this Privacy Notice, you must:

10.1. personally deliver a request to exercise data subject rights (hereinafter – Request) to the Company’s headquarters at Laisvės pr. 10, LT-04215, Vilnius (along with the Request, you need to provide an identity document for review);

10.2. send the Request to the Company or the Data Protection Expert by email at or (the Request submitted by email must be signed with a secure electronic signature);

10.3. submit the Request to the Company or the Data Protection Expert by mail to Laisvės pr. 10, LT-04215, Vilnius (a copy of the identity document, certified by a notary or in accordance with the procedure established by law, must be attached to the Request).

When submitting a request through a representative, a document confirming the representation or its certified copy must also be attached to the request in accordance with the procedure established by law.

11. How will we inform you about changes to this notice?

We may update or change this Privacy Notice at any time. Such updated or changed Privacy Notice will take effect from the day it is published on our website.

After updating the Privacy Notice, we will inform you about what we consider to be significant changes by publishing them on the website. You can check the date “Update date” indicated above to find out when the Privacy Notice was last updated.

12. How to contact the Company or the Data Protection Expert?

If you have questions, comments, or complaints about how we collect, use, and store information about you, or if you want to exercise your rights as a data subject, you can contact:

12.1. the Company at: Laisvės pr. 10, Vilnius, phone No.: +370 685 84866, email: ;

12.2. the Company’s Data Protection Expert, email:

[1] Regulation (EU) No. 596/2014 of the European Parliament and of the Council of April 16, 2014, on market abuse (Market Abuse Regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC, and 2004/72/EC

[2]The EEA or European Economic Area consists of the member states of the European Union and Iceland, Norway, and Liechtenstein.