We recognize the critical importance of protecting your personal data and hence we only collect and process the data that is necessary for our operations. We handle personal data lawfully, transparently, and fairly, setting clear purposes in advance and limiting the scope to what is required to achieve these purposes. In managing personal data, we strive to ensure it is accurate, secure, confidential, properly stored, and protected.
Our data processing practices adhere to the General Data Protection Regulation (GDPR), the Republic of Lithuania's Law on Legal Protection of Personal Data, and other legal requirements related to personal data.
1.1. This privacy policy (hereinafter – Privacy Policy) defines the conditions of privacy for your use of the Website. In this Privacy Policy, "Website" refers to the internet site www.zuikio.com and/or the ZUIKIO mobile application, which can be downloaded from the "Apple App Store" and "Google Play".
1.2. Please read this Privacy Policy carefully to learn how we process your personal data, where we obtain it from, and your rights as a subject of personal data.
1.3. If you use the Website, you have read and agreed to this Privacy Policy and the processing of your personal data as described herein. If you disagree with the Privacy Policy, you are not authorized to use the Website.
1.4. The term "personal data" used in this Privacy Policy refers to any information which can be used to identify you, either directly or indirectly. Personal data includes your surname, first name, date of birth, postal or email address, location data, internet identifiers, characteristics unique to you, and more.
1.5. The Privacy Policy applies to all individuals who visit the Website, as well as to actions you may perform on the Website.
2.1. The website is managed and administered by us. The contact email address for the person responsible for personal data protection is: [email protected].
2.2. In accordance with legislative provisions, we are the controller of your personal data.
3.1. In processing your personal data, we:
a) shall comply with applicable legal acts, including the GDPR requirements;
b) shall process your personal data in a lawful, fair, and transparent manner;
c) shall collect your personal data for specified, explicit, and legitimate purposes and not further process them in a way incompatible with those purposes unless permitted by law;
d) shall take all reasonable steps to ensure that personal data which are inaccurate or incomplete, in relation to the purposes of their processing, are promptly rectified, complemented, processing is halted, or they are destroyed;
e) shall keep it in a form that allows your identification for no longer than necessary for the purposes for which the personal data is processed;
f) shall not provide personal data to third parties or disclose them, except in cases outlined in the Privacy Policy or applicable laws;
g) shall ensure that your personal data is processed in a manner that using appropriate technical or organisational measures assures proper security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
4.1. We process your personal data obtained by the following means:
a) when you provide us with your personal data. You supply us with your personal data and other information by using our Website, writing to us, or communicating with our customer service team by phone or email, submitting your complaints and/or inquiries, subscribing to our newsletter, etc.;
b) when you use the Website. When you use the Website, certain information (e.g., type of web browser used, number of visits to the Website, pages viewed, etc.) is automatically collected;
c) when we receive your personal data from other parties in accordance with the law and/or the procedures outlined in this Privacy Policy.
4.2. We may combine the personal data we receive from you when you use the Website with:
a) your data obtained when you use other websites and mobile applications that we manage and administer;
b) data we have collected ourselves from other public or available sources (for instance, the personal data you provide may be combined with data collected using Website cookies, or with data obtained legally from third parties).
5.1. We will process your personal data for the following purposes:
a) To improve the Website(s), mobile application, and offer better and tailored services and (or) products to you. We use your personal data, including the data we collect when you use our Website(s), visit our account(s), and (or) use our mobile application, to enhance and develop the Website and offer better and more personalized services and (or) products to you. Personal data processed for this purpose:
For detailed information about personal data processing for this purpose and how we use cookies and similar technologies, please read Section 7 of this Privacy Policy.
b) For direct marketing purposes (including the execution of direct marketing games, quizzes, contests). Upon obtaining your consent and in order to present you with newsletters, offers, including personalized ones, and information about our, our affiliates' and partners' services and (or) products, or other information, improving our services, we process your personal data. If you have consented to the use of your data for this purpose, in order to get to know you better and tailor offers to your needs, offer other benefits designed specifically for you, we will process not only the data identifying you but also analyze your behavior on the Website(s), account(s), and (or) mobile application, the history of service orders. For this purpose, we use automated data analysis and decision-making, including profiling, which, by grouping the data identifying you and (or) data about the ordered services, products, your behavior, we can provide you with relevant, interesting, and useful offers and other information. Personal data processed for this purpose:
For more detailed information about personal data processing for direct marketing, please read Section 6 of this Privacy Policy.
c) For the administration and identification of visitor-created individual profiles, ensuring proper service provision. You provide us with your personal data when you use the Website(s), mobile application, register (create an individual account), post your content (e.g., upload advertisements, their descriptions, photos, write comments, correspond, etc.), and use our services (e.g., play games, communicate with other visitors, use the email service, etc.). We also process your personal data when you register on the Website(s) or use it as a representative and (or) contact person of a legal entity (e.g., when you register to (co)advertise your business activity on our Website). Personal data processed for this purpose (if you provide it to us):
d) For ordering paid services, payment, accounting, control of settlements, debt management, and debt recovery purposes. You provide us with your personal data when you order our paid services. Personal data processed for this purpose:
e) For quality control of our activities and ensuring the use of other Website(s) account(s), mobile application functionalities, and communication with us (including the management (and or) processing of complaints and (or) your inquiries, comments and communication (including – storage)). When you contact us (or when we contact you upon receiving your inquiry), we process the information received during the communication that took place by writing, email, phone, through the Website, or by other means, which may include personal data:
g) For other purposes specified in our Personal Data Processing Rules and (or) other internal documents when legal acts obligate us to process your data, or there is a legitimate interest or other lawful basis.
5.2. We do not request your special category personal data that reveal your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, nor any details about your health, genetic data, biometric data (to uniquely identify you) or information concerning your sex life. In the event that you provide such data when using our Website(s), account(s), mobile application, or by any other means (in writing, by email, by phone), it will be considered that the data was provided consciously, with your consent. Accordingly, we will process these data along with the other data you have provided for the purposes and methods specified in Section 5.1 of the Privacy Policy, if these data cannot be separated or such separation would require disproportionately large efforts.
6.1. With your consent, we may use your personal data for direct marketing purposes to provide you with newsletters, offers, personalized promotions, as well as information about our services and/or products, those of associated individuals and partners that we believe might be of interest to you. However, we will only use your personal data for this purpose if you have given us additional consent to do so.
6.2. For this purpose, we process your personal data as specified in Privacy Policy Section 5.1. (b).
You can choose whether to allow us to use your personal data for direct marketing purposes. This can be done when registering on the Website(s) by checking the box to indicate your consent for the processing of personal data for direct marketing purposes.
6.3. By granting permission to process data for direct marketing, you also allow us to contact you through appropriate communication methods (e.g., email, phone, short message service (SMS)) or other communication tools (e.g., Viber, etc.) for this purpose.
6.4. We may combine the information we have about you with information obtained from third parties.
6.5. If you give consent for the use of your personal data for direct marketing purposes, we may use your personal data to analyze and improve the effectiveness of our websites, advertising, and market research, as well as for other company marketing and sales purposes. In such cases, we will use anonymized data.
6.6. Even if you have given consent for the processing of your personal data for direct marketing purposes, you may withdraw this consent easily at any time for all or part of the data processing activities by:
- indicating your refusal in the manner specified in the email newsletters or offers received (for example, by clicking a link stating “If you do not wish to receive similar kinds of emails, click here.” or similar), or when replying to received SMS messages by sending a message with the text "Unsubscribe"; or
- by sending a request to us by email at [email protected]. In your request, clearly indicate your registration email address and any other registration details (if any). If you choose to withdraw your consent in this manner, we may require you to provide identification documents.
6.7. If you withdraw your consent, we will endeavor to stop processing your personal data for direct marketing purposes as quickly as possible.
6.8. Revoking your consent does not automatically obligate us to destroy your personal data or to provide you with information about the personal data we process, so if you wish for us to perform these actions, you must indicate this in a separate request.
7.1. We collect information about you using cookies and similar technologies. Cookies are small files that are temporarily stored on your device's hard drive, allowing us to recognize you during subsequent visits to our Website(s), social networks, mobile applications, save your browsing history and preferences, tailor content, speed up searches, and create a comfortable and friendly environment to present it more efficiently and reliably. The use of cookies is a common web browsing practice that facilitates user experience.
7.2. Cookies enable us to collect the information specified in section 5.1. (a) of this Privacy Policy, as detailed in section 7.6.
7.3. We use the information obtained through cookies to:
- Ensure the functionality of the Website(s), mobile applications (e.g., to enable personalization features);
- Improve and develop the Website(s), mobile application so it better meets your needs;
- Develop services and analyze the usage of the Website(s), mobile applications;
- Target marketing efforts more effectively.
7.4. We may, without violating applicable law, combine the information obtained through cookies with information obtained about an individual by other means (e.g., information about the use of the Website(s), mobile applications with data you have provided or obtained from other sources).
7.5. We inform you that the following types of cookies may be used on the Website(s), mobile application, and social networks:
- Technical cookies – necessary for the operation of websites;
- Functional cookies – not necessary for the operation of websites but significantly improve their functionality, quality, and user experience;
- Analytical cookies – used to prepare statistical analyses of web navigation methods by website visitors; the data collected by these cookies is used anonymously;
- Targeting or advertising cookies – used to present offers or other information that might be of interest to you;
- Social network cookies – necessary to use website information in your social profile account.
7.6. Detailed information about the cookies we use on our own Website(s), mobile application, their purpose, validity, and the data they use can be found here.
7.7. You can give consent to use cookies on our Website by:
- Not deleting them and/or not changing your web browser settings to reject cookies;
- Clicking the "I Agree" button in the cookie banner provided on the Website.
7.8. You may revoke your consent to our use of cookies at any time. You can do this by changing your internet browser settings so that it does not accept cookies. How to do this depends on your operating system and web browser used. Detailed information about cookies, their use, and how to opt out can be found at http://AllAboutCookies.org or http://google.com/privacy_ads.html.
7.9. In some cases, especially when disabling technical and functional cookies, refusing cookies, or deleting them may slow down internet browsing speed, limit the functionality of certain website features, or block access to the website.
7.10. For more about external sites (such as social networks), please read section 11 of this Privacy Policy.
8.1. We assure you that your personal data will not be sold, disclosed, or otherwise transferred to third parties without legitimate reason, nor will it be used for purposes other than those for which it was collected. Your personal data will not be transferred in any way other than in accordance with this Privacy Policy or applicable legal regulations. However, we reserve the right to disclose information about you if we are required to do so by law or if legitimate law enforcement or criminal prosecution authorities demand it from us.
8.2. We may transfer your personal data to companies that help us to conduct our business, including direct marketing. We require these partners to process your data only according to our instructions and in compliance with legal regulations protecting your data. We enter into contracts with these entities that oblige them to strictly adhere to personal data protection requirements.
8.3. The data we collect about you may be disclosed solely in strict compliance with personal data protection requirements, only in justified cases, and only to third parties who commit to adequately protect them:
a) to third-party service providers (e.g., technical services providers for executing our contracts with these service providers, including courier services integrated on the website or services for sending newsletters or performing other marketing activities), which are entitled to process personal data solely in accordance with the website's instructions and only to the extent necessary to properly fulfill the obligations set out in the respective contract with the third party;
b) to third-party service providers commonly used for data storage, telecommunications, and website hosting purposes.
8.4. The aforementioned service provider's ability to use your data is limited – they cannot use this data for purposes other than providing services to us.
8.5. A list of individuals and categories of individuals to whom we transfer your personal data is provided separately for each purpose of personal data use in section 5.1. of this Privacy Policy (the list is not exhaustive).
9.1. We retain your personal data no longer than required for the purposes of data processing or as prescribed by law if such laws stipulate a longer data retention period.
9.2. We aim not to retain outdated or irrelevant personal data, thus we only keep current information upon updating. Historical information is preserved if necessary as per legal requirements or for the execution of our activities.
10.1. The data we collect from you will be within the territory of the European Union (EU), but may also be transferred to or stored outside the EU. Our staff or the staff of our suppliers, working outside the EU, may also process it. When transferring your data outside the EU, we will take all necessary steps to ensure that your data is handled securely and in accordance with this Privacy Policy.
10.2. Unfortunately, the transmission of information via the internet is not completely secure. While we make every effort to protect your personal data, we cannot guarantee the security of your data transmitted to the Website – you assume any risk associated with data transmission to the Website. Once we receive your data, we will apply strict procedures and security measures to prevent unauthorized access.
10.3. Should the unlikely event of a breach in the security of your personal data occur, which could pose a significant threat to your rights or freedoms, we will inform you without delay as soon as we become aware and determine which information was accessed.
11.1. The Website may contain links to external websites – sites of our business partners or sites that advertise our services and/or products. When following links to any of these websites, please be aware that these sites have their own separate privacy policies, and we do not accept responsibility or liability for these policies or for the personal data collected through these sites or services, such as contact or location data. Check these policies before submitting any personal data to these websites or using any services.
12.1. In processing personal data, we ensure your rights according to the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a data subject, you have the following rights:
a) to be informed about the processing of your personal data;
b) to access your personal data that we process;
c) to request the correction or completion of your incorrect, inaccurate, or incomplete personal data;
d) to request the deletion of personal data that is no longer necessary for the purposes for which they were collected;
e) to demand the deletion of personal data if they are processed unlawfully or if you withdraw your consent for the processing of personal data or do not give such consent when necessary;
f) to object to the processing of personal data or withdraw previously given consent and request the deletion of your data being processed and independently delete your account;
g) to request the suspension (except for storage) of your personal data processing activities if disputes are occurring, or there is a need to verify the legality of data processing, the accuracy of the data, or in cases where we no longer need your personal data but you do not wish us to destroy them;
h) to request the provision of, if technically feasible, your personal data collected with your consent or for the purposes of executing a contract, in an easily readable format, or to ask for them to be transferred to another data controller.
12.2. We will endeavor to guarantee the implementation of your rights as a data subject and provide all conditions for the effective exercise of these rights; however, we reserve the right not to fulfill your requests when it is necessary to ensure:
a) the performance of legal obligations set for us;
b) national security or defense;
c) public order, the prevention, investigation, detection, or prosecution of criminal activities;
d) vital state economic or financial interests;
e) the prevention, investigation, and detection of breaches of official or professional ethics;
f) the protection of rights and freedoms of you or other persons.
12.3. You may submit requests related to the implementation of your rights to us in person, by mail, or by means of electronic communication. Upon receiving your request, we may ask for identity verification documents and other additional information related to the request.
12.4. Upon receiving your request, we will respond no later than within 30 calendar days from the date of receipt of your request and all documents necessary for the response.
12.5. If necessary, we will suspend the processing of your data, except for storage, until your request is resolved. If you legally withdraw your consent, we will immediately, but not later than within 30 calendar days, cease your personal data processing activities, except in the cases set out in point 12.2 of this Privacy Policy and other cases provided by law, i.e., when legal acts obligate us to continue processing your data, our legal obligations, court orders, or mandatory instructions from authorities.
12.6. Should we refuse to comply with your request, we will clearly state the reason for the refusal.
12.7. If you disagree with our actions or the response to your request, you may appeal our decisions to the competent state authority.
13.1. If you wish to submit a complaint regarding our data processing, provide it in writing with as much information as possible using the contact details provided at the end of this policy. We will cooperate with you and strive to resolve all issues promptly.
13.2. If you believe that your rights have been violated under the GDPR, you can lodge a complaint with our supervisory authority – the State Data Protection Inspectorate. For more information and contact details, please visit the Inspectorate's website (www.ada.lt). However, we first seek to resolve disputes amicably and swiftly with you.
14.1. Any changes to our Privacy Policy will be posted on the Website. If necessary, you will be notified of them. The new Privacy Policy conditions may also be presented on the Website, and you may need to read and agree with them to continue using the Website and/or our services.
15.1. Send all documents related to this Privacy Policy or contact us using the following contact information:
a) by sending an email to – [email protected]
