1.1 Personal data – all information relating to a natural person who can be identified, directly or indirectly, using personally identifiable data (name, surname, address, personal identification number, etc.) or according to factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
1.2 Processing of personal data – all actions performed on personal data or on sets of personal data, whether or not by automated means (for example, collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, and any combination of these actions).
1.3 Data subject – a natural person whose personal data is processed by UAB Julianus Inkaso.
1.4 Regulation – Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
2. General provisions
2.2 UAB Julianus Inkaso shall ensure the confidentiality of personal data in accordance with the requirements of applicable legislation and the implementation of appropriate technical and organisational measures to protect personal data from unauthorised access, disclosure, accidental loss, alteration or destruction, or other unlawful processing.
2.4 Where there is a legitimate purpose and basis for the processing of personal data, UAB Julianus Inkaso may collect personal data from public state registers of the Republic of Lithuania and other official sources.
3. Categories of personal data
Personal data is obtained from data subjects, creditors on the basis of assignment or recovery agreements, and external sources, such as public and private registers (SE Centre of Registers, SE Regitra, the Population Register Office, the electronic services portal of Lithuanian courts, the Republic of Lithuania Judicial Officer Database, etc.). UAB Julianus Inkaso collects and processes the following data:
3.1 Identification data such as name, surname, middle name, hypocorism, identification number (national identification number, customer number, employee number) date of birth, country of birth, gender, citizenship;
3.2 Contact details such as home address or correspondence address, postal address, telephone number, e-mail address, language of communication.
3.3 Digital identification data, such as social media or Skype name.
3.4 Financial data such as assets, income, liabilities.
3.5 Professional data, such as data on education, professional activities, positions held.
3.6 Data obtained from public and private registers;
3.7 Data provided by the data subject.
4. Basis for the processing of personal data
UAB Julianus Inkaso may only collect personal data in accordance with the grounds for lawful processing specified in legislation:
4.1 Contractual basis (conclusion and performance of a contract) – initial agreement with the creditor, recovery agreement, assignment of claim agreement;
4.2 Compliance with a legal obligation – liability and consequences of obligations assumed;
4.3 The legitimate interests of UAB Julianus Inkaso;
4.4 Consent of the data subject.
5. Purposes of processing
In order to ensure transparency and the responsible processing of personal data, UAB Julianus Inkaso processes personal data for the following purposes:
5.1 Debt management (pre-trial debt collection), performance of legal obligations under recovery and assignment of claim agreements;
5.2 Judicial debt collection and the provision of legal services
(filing, enforcing and defending legal claims);
5.3 Protection of the interests of the data subject and/or UAB Julianus Inkaso;
5.4 Data subject consulting, provision of services;
5.5 Management of day-to-day operations;
5.6 Provision of services remotely.
6. Profiling and automated decision-making
6.1 UAB Julianus Inkaso only uses partial profiling and automated decision-making. This is based on the legitimate interests of UAB Julianus Inkaso, the fulfilment of a legal obligation, the performance of a contract or the consent of the data subject.
6.2 The data subject has the right not to be subject to a decision based solely on automated data processing, including profiling, if this has legal effects concerning the data subject.
7. Personal data recipients
Where there is a legitimate basis and purpose for providing personal data, the data may be transferred to recipients such as:
7.1 State bodies and institutions, and other persons performing the functions assigned to them by law (for example, law enforcement authorities, judicial officers, notaries, or institutions carrying out tax administration or financial crime investigation activities).
7.2 Entities providing legal, financial, archiving, mailing or information technology services – data processors authorised by UAB Julianus Inkaso;
7.3 UAB Julianus Inkaso customers;
7.4 Other third parties with a legitimate interest.
8. Rights of the data subject
UAB Julianus Inkaso strives to ensure that personal data processing activities are fair and transparent, and that all the rights of individuals provided for in applicable laws are guaranteed at all times. The data subject has the following rights:
8.1 To access the personal data processed by UAB Julianus Inkaso;
8.2 To have personal data rectified if they are incorrect, incomplete or inaccurate;
8.3 To object to the processing of personal data if only legitimate interests are the basis for the processing of personal data;
8.4 To demand the deletion of personal data which are only processed with the consent of the data subject if he or she withdraws the consent. This right does not apply if the personal data requested to be deleted are also processed on another legal basis, such as processing which is necessary for the performance of a contract or fulfilment of an obligation under applicable legislation;
8.5 To restrict the processing of personal data in accordance with applicable legislation, for example, for the period during which UAB Julianus Inkaso will assess whether the data subject has the right to request that personal data be deleted;
8.6 To receive in writing, including in commonly used electronic form, personal data provided by the data subject which is processed on the basis of his or her consent or performance of a contract, and, if possible, to transfer this data to another service provider (data portability);
8.7 To withdraw consent to the processing of personal data (except in cases when the basis of data processing is compliance with a legal obligation; conclusion and performance of a contract);
8.8 To object to a fully automated decision being used, including profiling, if said decision-making has legal effects concerning the data subject or similarly significantly affects him or her. This right does not apply in the event that this decision-making is necessary for the purpose of concluding or performing a contract or is permitted under applicable legislation, of if the data subject has given his or her explicit consent thereto;
8.9 To lodge a complaint regarding the processing of personal data with the State Data Protection Inspectorate (www.ada.lt) if the data subject considers that his or her personal data is being processed in violation of his or her rights and legitimate interests under applicable legislation.
9. Personal data retention period
9.1 Personal data is stored in accordance with applicable law and for no longer than is necessary to fulfil the purpose. Personal data retention periods are set by UAB Julianus Inkaso and they depend on the terms of the specific agreement and the basis for the processing of personal data. The personal data retention period may also be defined taking the legitimate interest of UAB Julianus Inkaso or legislative requirements into account (for example, a limitation period, for archiving purposes, in accordance with time limits laid down by legislation). It should be noted that cases where the purpose is debt recovery, when the data subject complies with the legal obligation in full, UAB Julianus Inkaso has the right to store the data for 30 calendar days for the purpose of informing the data subject and reporting.
9.2 If no legitimate purpose for the processing of personal data is left, the personal data is destroyed.
10. Principles of personal data protection
When collecting the personal data of data subjects, UAB Julianus Inkaso follows the following principles:
10.1 lawfulness, fairness and transparency (personal data are processed lawfully, fairly and in a transparent manner);
10.2 purpose limitation (personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes);
10.3 the principle of data minimisation (personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed);
10.4 accuracy (personal data are accurate and, where necessary, kept up to date);
10.5 storage limitation (personal data are kept in a form which permits identification of the person for no longer than is necessary for the purposes for which the personal data are processed);
10.6 integrity and confidentiality (personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures).
11. Measures taken for data security
11.1 In order to protect the personal data of data subjects from unauthorised access, unlawful processing or disclosure, accidental loss, alteration or destruction, UAB Julianus Inkaso shall take the necessary measures in accordance with the requirements of the applicable laws. These measures include technical measures such as the selection and assembly of appropriate computer systems, the protection of important connections, and the protection of data and files. They also include organisational measures – restriction of access to the UAB Julianus Inkaso system, files and documents.
11.2 Despite the fact that UAB Julianus Inkaso uses various security technologies and procedures to protect the personal information of data subjects from unauthorised access, use or disclosure, the security of information transmission via the Internet, e-mail or mobile communications may not always be guaranteed for reasons beyond the control of UAB Julianus Inkaso, so data subjects should be careful when providing confidential information.
12. Geographical area of personal data processing
12.1 Personal data are processed in the territory of the European Union/European Economic Area (EU/EEA).
12.2 Personal data may be transferred and processed outside the EU/EEA when the transfer is necessary for the conclusion and performance of a contract or when the data subject has given his or her consent, as well as if appropriate safeguards are in place.
13. Data protection officer
13.2 The data subject may submit requests to the data protection officer for the exercise of the above rights, as well as complaints and notifications related to data protection.
13.3 A response to the data subject’s request will be provided within thirty (30) calendar days of receipt of the request. In exceptional cases which require additional time, UAB Julianus Inkaso, having notified thereof, has the right to extend the time limit for submission of the requested data or examination of the other claims specified in the request to sixty (60) calendar days from the date of the data subject’s application.