This policy describes what information can be collected about you through our website www.lewben.com, for what purposes, and how it is processed.
By using any of our services on our website or by providing us with any information about yourself, you are consenting to the use of that information as set out in this policy. Please do not send us any information about yourself if you do not want that information to be used in this way.
Information collected through our website about you will be controlled by UAB LEWBEN that is registered at A. Tumėno str. 4, Vilnius, LT-01109 Lithuania (‘us’ or ‘we’).
Information about you will be collected, if provided by you through certain facilities on our website, for example, the newsletter subscription facility and our e-mail queries facilities. The purpose of these facilities is apparent at the point where you provide your personal information and we only use your information for those purposes.
For the purpose of delivery of informational newsletters to you, we collect the following information about you: name, surname, e-mail address, organization, position, country, subscribed informational newsletters and access thereto. The said information will be stored until you unsubscribe to the informational newsletters.
For the purposes of handling your e-mail queries, we collect the following information about you: name, surname, e-mail address, subject matter and text of your query. The said information will be stored for 2 (two) years following the receipt of your query.
Any information that you provide to us may be shared with and processed by LEWBEN GROUP BV, which is registered at Herengracht 493, 1017BT, Amsterdam, the Netherlands; LEWBEN LONDON LIMITED which is registered at 7 Grosvenor Gardens, London, SW1W 0BD, United Kingdom, LEWBEN CYPRUS LIMITED, which is registered at Georgiou Griva Digeni Avenue 81-83, 1090, Nicosia, Cyprus, Jacovides Tower, 1st floor, offices 125-126, LEWBEN UAB which is registered at A. Tumeno str. 4, LT-01109, Vilnius, Lithuania, Lewben New York LLC which is registered office in the State of Delaware is located at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex and other Lewben Group companies as well as third parties which provide us with services and act on their behalf. If expressly required by law, information about you can also be shared with competent public authorities.
We implement appropriate technical and organizational measures to protect information about you against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
You have rights to access the information we process about you, to have such information corrected, erased or blocked, and to object to the information processing activities. To exercise these rights, you should make a written request as described below.
1. Who can see your data?
Lewben group refers to one or more companies of Lewben group, each of which is a separate legal entity. All information about Lewben group companies you can find on our websites www.lewben.com and http://lewbenwealth.com.
The entity that is managing the Contact databases for the Lewben group companies in Lithuania and other countries is “Lewben“, UAB, registration number 302299013, registered office A. Tumėno str. 4, Vilnius, the Republic of Lithuania.
The personal data stored in our Contact databases is available to all companies of Lewben group. Each company of Lewben group is the controller for its own contact data stored in the Contact databases.
2. Why do we need information?
The Contact databases are client’s/contact’s relationship management tools of Lewben group, that support the marketing operations of companies of Lewben group. We use this information for sending invitations to seminars, workshops and other events as well as newsletters, surveys or other direct marketing communications related to the various services offered by companies of Lewben group in the Republic of Lithuania and other countries.
Personal data processed in the Contact databases is used for the purposes of sales and marketing. Processing your contact information allows us to communicate with you via electronic mailings, text messages or via phone.
Lewben group relies on the following basis to legitimize the processing of personal data in its Contact databases:
– Lewben group has obtained individual’s consent for the processing of personal data in the Contact databases systems; or
– when its permitted by applicable law (example: to provide related services).
3. What type of personal data is processed?
The Contact databases process personal data of former, current and prospective customers (including individuals within a corporate client) of Lewben group. The Contact databases also contain data of other business contacts (such as consultants, regulators, etc.) as well as data of employees (former and current).
The following data categories are processed in the Contact databases:
4. Sensitive Personal Data
Sensitive personal data reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation.
Lewben does not intentionally collect any sensitive personal data from you to store in its Contact databases.
5. Who can access your information?
Access to your personal data is limited by need. All marketing and sales employees of companies of Lewben group in the Republic of Lithuania and other countries have access to your contact information.
We will only disclose your personal data to third parties:
– If such third party is engaged by Lewben group to facilitate, maintain or support its Contact databases (for example, to provide information technology and other administrative support services);
– When explicitly requested by you;
– When it is required by applicable law.
6. International transfer of data
Ordinarily, Lewben group will not transfer your data to countries outside the European Economic Area. In some cases, personal data can be saved on storage solutions that have servers outside the European Economic Area (EEA), [for example, Dropbox or Google]. Only those storage solutions that provide secure services with adequate relevant safeguards will be employed.
Transfers of personal data to third countries, in principle, will only be allowed if an adequate level of protection is ensured in the recipient country and in accordance with applicable law. Lewben Group undertakes to ensure the compliance with security requirements
7. Data retention
Data of contacts who have been out of active use for more than 5 years will be deleted from our Contact databases, unless you will agree to renew your consent. Data in opt-out list will be delated after 12 months after the date when we received your request to delete your information from our Contact databases.
If you want to have your data deleted from our Contact databases or if you wish to object to the processing of your personal data for direct marketing purposes, please contact us via e-mail email@example.com.
Lewben group is committed to making sure your personal data is secure. To prevent unauthorized access or disclosure, Lewben group has technical and organizational measures to safeguard and secure your personal data. All Lewben group employees and third parties that Lewben group engages to process your personal data are obliged to respect your data’s confidentiality. Obligation of confidentiality ensures that the Lewben group employees shall process all the Personal Data with respect of strict confidentiality
9. Data transfer to third parties
Lewben group will not transfer your personal data to third parties (other than any external parties referred to in section 5 above) unless we have your permission or its required by law.
10. Your rights
At any time, you can contact us with request:
after you get acquainted with your personal data, you are entitled to:
After the receiving of such request, we will give you an answer in your preferred way.
11. Rectification, erasure, restriction of processing or data portability
In order to confirm that your personal data is accurate and current or to request rectification, erasure, restriction of processing or a readily portable copy of your personal data, you can contact us by sending an e-mail firstname.lastname@example.org.
If you are concerned about an alleged breach of privacy law or any other regulation, contact us via e-mail email@example.com, by phone +370 (5) 2 644741, by post A. Tumėno str. 4, East entrance, 10 floor, Vilnius, the Republic of Lithuania. You can also contact any of our employees. Responsible person will investigate your complaint and provide information how it will be handled.
If you are not satisfied with how we resolved your complaint, you have the right to complain to your country’s data protection authority. You can also refer the matter to a court of competent jurisdiction.
13. Other question
If you have any questions or concerns, contact us by e-mail firstname.lastname@example.org.