Privacy Policy

This Privacy Policy refers to personal data processed by the Lewben Group. You can find a list of companies belonging to the Lewben Group on the following websites: www.lewben.com, www.lewbenwealth.com (hereinafter referred to as the “Company” or “Lewben Group”).

This Policy applies to all persons who use, have used, or are going to use our services, as well as those who are indirectly related (e.g. business representatives or other employees), persons who have any contractual relationship with us, or whose personal data have become known to us, as well as to anyone who visits our websites (hereinafter referred to as “You” or the “Customer”).

Our goal is to ensure the protection of personal data. In pursuing this goal, we consistently adhere to the requirements of the European Union and national legislation. The basic legal acts governing the processing of personal data are the national legislation and the General Data Protection Regulation (2016/679) (hereinafter referred to as the “GDPR”). The GDPR applies to the processing of personal data relating to citizens of the European Union (natural persons) which is carried out by a natural person, a company, or other organisation for business and other non-personal purposes. The reference to “personal data” in this Policy refers to any information which could be  reasonably used to identify you as one of the above persons (hereinafter referred to as “Personal Data”).

The Policy provides a general overview of how we process personal data. Additional information on the processing of personal data may be provided in service contracts and in other documents.

We ensure the confidentiality of personal data in accordance with the requirements of the applicable law and we have appropriate technical and organisational measures in place to protect personal data from unauthorised access, disclosure, accidental loss, alteration, destruction, or any other unlawful processing.

We can use data processors to process personal data. In such cases, we will take the necessary steps to ensure that such data processors process personal data in accordance with our instructions and applicable laws, and require the implementation of appropriate personal data security measures. We ensure that we make every effort to guarantee the confidentiality and integrity of the personal data of our current, future, and past Customers.

Your personal data controller is the Lewben Group company to which you have either submitted your personal data concerning any contractual or pre-contractual relationship that you are bound to, or whose  Services  you (or the legal entity or entity to which you are the ultimate real owner) are going to use.

POLICY OBJECTIVES

In the Policy we describe how we process personal data in dealing with all matters related to all our Customers (existing or former), potential Customers, sending newsletters and marketing information, recruitment processes, cookies used on our websites, all our legal obligations set by the GDPR, any relevant laws on data protection, as well as any other applicable laws and regulations (including the obligations relating to prevention processes against money laundering).

PERSONAL DATA CATEGORIES

Depending on the service provided or the nature of our cooperation, we process different categories of personal data. In each case, we ensure that we process only the data that are necessary. The main categories of personal data include but are not limited to:

Identification data:  name, surname, nickname, personal code (national personal code), photo.

Contact details: address (correspondence/residential), telephone number, e-mail address;

Professional details: data on education and professional activity.

Data relating to relations with legal entities: data provided by you or obtained from public registries or third party transactions for the purpose of forming a third party transaction with the corresponding legal entity.

Financial data: data on invoices, accounts, property held, transactions, loans, income, liabilities that arise when the Customer chooses and provides accounting or asset and welfare management services.

Data we need to meet applicable compliance requirements, e.g. data needed for implementing measures to prevent money laundering and  terrorist financing, such as date of birth, country of birth, sex, nationality, passport details, photo, information on people involved in politics.

Data related to your participation in our events: position title, workplace.

Data about the authors and their copyright work: title of the work, author.

Depending on the services provided, we may also process your other personal data.

We are responsible for the accuracy of your data, so we would appreciate if you could assist us in fulfilling this obligation by informing us about  any change in regards to  your personal data.

PURPOSE AND BASIS OF PERSONAL DATA PROCESSING

We use the information provided by you to send you information about the latest events, services provided, as well as any planned events that may be of interest to you, including training sessions, seminars, art events, breakfast-briefings  on relevant topics, etc. You can find more information about the use of your personal data for marketing purposes in our Marketing Privacy Policy.

We use cookies on our websites.

We will use the personal data you provided to us by  sending your CV or a cover letter. We will keep the data you provide for as long as the recruitment process lasts, or for a longer period only with your consent to save your CV in the database of potential employees of the Company.

We collect the information necessary for us to do business, sign contracts or start any business relationship with you. Such personal data collection is strictly necessary to fulfil our obligations to you as well as for the provision of services to current and future Customers. In certain cases, we may receive your data from other sources.

Discharge of legal obligations and identification. Some of the Companies are subject to the obligations under the Law on Money Laundering and Terrorist Financing Prevention (hereinafter referred to as the “Law”). By providing the services, we process personal data in order to fulfil our obligations in regards to  anti-money laundering (AML) and know-your-customer control (KYC).

 

BASIS FOR DATA PROCESSING

Agreement – a contract between us and you, which provides the basis  for processing your personal data;

 

Consent – the consent given by you through which you have granted us the right to process your personal data for the purposes stated in your consent and only for such purposes;

 

Legitimate interest – in some cases, in order to be able to perform the tasks arising from our activities, we process data on the basis of a legitimate interest. Before we begin to process personal data on this basis, we  verify that legitimate interests do not have a significant impact on the rights and freedoms of those persons.

 

Legal obligation – this obligation is imposed on us by the European Union and national legislation, such as the Law.

 

Most of the time, we receive your personal data from you, our data subjects, but in some cases we may also receive personal data from third parties. For example, personal data are provided to us by a representative of a potential Customer, when we sign various agreements containing the representatives’ data, and others cases.

 

PERSONAL DATA RECIPIENTS

Lewben Group companies (for the purposes of administration,  anti-money laundering obligations, learning more about customers, and marketing );

Partners with whom we jointly provide services or products;

State institutions and authorities, other persons performing functions delegated to them by law (for example, law enforcement agencies, tax administration and financial crime investigation institutions).

Financial institutions, third parties (such as banks), auditors, legal and financial advisers; our authorised data processors, third parties, managing various registers (including loan registers, the Population Register, the Register of Legal Entities or other registers in which personal data are processed) or other persons, who has right to provide personal data from such registers.

Other persons who provide services to us, such as IT maintenance companies, communication and postal services providers, third parties, whose services we use to perform our Customer contracts or in the performance of administrative functions.

All service providers to whom we transmit your personal data must follow our instructions on how they process your personal data. Your personal data transfer is governed by the data processing agreements we have concluded with independent service providers. All independent service providers are considered  data processors and must guarantee that your personal data  is processed with the same level of accuracy and care  that we apply, and they will be held legally responsible for the non-performance of such guarantees. All service providers must have technical and organisational measures in place to ensure the same  level of data protection as we do..

TRANSFER OF PERSONAL DATA TO THIRD PARTIES

As a general rule, personal data are processed within the territory of the European Union/European Economic Area (EU/EEA), but may, in certain cases, be transmitted and processed outside the EU/EEA.

Personal data may be transmitted and processed outside the EU/EEA where the transfer is necessary for the conclusion and execution of a contract where personal data may be stored using data storage solutions whose servers are outside the European Economic Area or the Customer has given their consent, and if there are adequate safeguards in place.

YOUR RIGHTS AS A DATA SUBJECT

Right to access – you have the right to request access to any of your personal data that may be stored, including, for example, the right to know whether we process your personal data, which categories of personal data we process, and  the purposes for which we process the data.

Right to  rectification – you have the right to request that we correct any of your personal data that you believe to be inaccurate or incomplete.

Right to disagree – you have the right to disagree with the corresponding processing of your personal data, including, for example, the processing of your personal data for marketing purposes or, data processing based on the legal interest.

Right to erasure – you may also request that your personal data are deleted if they are no longer required for the purposes for which they were collected, or if you consider that the processing is illegal, or that personal data must be deleted in order not to violate the legal requirement. In certain cases, under statutory regulation, where the laws of the relevant jurisdiction prohibit us from deleting our stored and processed data, we will not be able to fulfil such an obligation, evenupon your request , but we will inform you if any such  obligation  applies to us.

Right to data transfer – if your personal data are processed automatically with your consent or on the basis of mutual contractual relations, you may request that we provide such personal data in a structured, commonly used and electronic form. You can also request that personal data be transferred to another controller. Please note that this can only be done where technically possible.

Right to withdraw your consent – in cases where the data are processed with your consent, you have the right to withdraw your consent for  data processing at any time .

Right to refuse marketing messages –you can opt out of our outgoing communications, in which we  provide the information about our events or any other material that we think may be of interest to you, at any time. You can  express your refusal at any time by contacting us.

If you are concerned about a potential violation of privacy laws or any other violation of statutory obligations , please contact us by e-mail at privacy@lewben.com or get in touch with any of our employees. The responsible person will investigate and transfer your complaint to the responsible employee, and will provide information regarding further handling of the complaint.

If you are not satisfied with the investigation of the complaint, you have the right to file a complaint with your country’s data protection authority. You also have the right to apply to the court of competent jurisdiction. Information about the authorities responsible for the enforcement of personal data protection legislation:

Lithuania:

The State Data Protection Inspectorate

Žygimantų g. 11-6a

011042 Vilnius

Tel. + 370 5 279 14 45

E-mail: ada@ada.lt

http://www.ada.lt/

 

The Netherlands

Personal Data Authority (Autoriteit Persoonsgegevens)

Prins Clauslaan 60

P.O. Box 93374

2509 AJ Den Haag/The Hague

Tel. +31 70 888 8500

info@autoriteitpersoonsgegevens.nl

https://autoriteitpersoonsgegevens.nl/nl

 

Cyprus

Commissioner for Personal Data Protection

1 Iasonos Street,

1082 Nicosia

P.O. Box 23378, CY-1682 Nicosia

Tel. +357 22 818 456

Fax +357 22,304,565

E-mail: commissioner@dataprotection.gov.cy

Website: http://www.dataprotection.gov.cy/

 

WHERE TO GET INFORMATION

You have the right to contact us in order to submit inquiries, cancel your issued permissions, and submit requests  to exercise your rights as a data subject and complaints regarding the processing of personal data.

Our contact details are available on the websites listed at the top of the Policy, and you can also contact us by e-mail at privacy@lewben.com.

POLICY CHANGES

This Policy may be changed or updated. The latest version of it will always be published on our websites, so we invite you to familiarise yourself with the latest version from time to time.

SOCIAL NETWORKS AND OTHER WEBSITES

All information that you provide to us via social media (including messages,  Like and Follow button clicks, and other communications) is controlled by the social network. We currently have Facebook and LinkedIn accounts .

We may be linked to third-party sites; links can be made to and from such websites. We have not reviewed, have no influence, and are not responsible for the content or privacy practices of websites that we may be linked to. We do not support third-party sites and we are not responsible for  any information, software or other products or materials contained therein as well as the results obtained through the use of such websites. We suggest that you always verify the information obtained through third party websites before acting upon it.

COOKIES

We use cookies on our website. A cookie is a small text element that a website saves on your computer or mobile device when you visit a website. This allows the site to remember your actions and settings (such as login name, language, alphanumeric settings, and other image settings) for some time, so that you do not need to enter them every time you re-visit the website or browse through individual websites.

Our site uses the Google Analytics service provided by Google, Inc. (hereinafter referred to as “Google”). This means that cookie information about your use of this website (including your IP address) will be transferred to the Google server in the US and stored there. Google uses this information to evaluate your use of the website by developing website activity reports and providing other services related to the site’s activities and Internet usage. Google may also transfer this information to third parties, if required by law, or to the extent that third parties process that data on behalf of Google. Google will never associate your IP address with any other data available to Google. You can refuse to download cookies by choosing the relevant settings in your browser; however, please note that in this case you may not be able to benefit from all the features of the site. By using this site, you agree that Google will process the data associated with you in the manner and for the purposes described above.

How to manage cookies?

You can manage and/or delete cookies at any time – here’s how: http://www.youronlinechoices.com/. You can delete all cookies that are already on your device. In addition, in most browsers, you can change the settings to block cookies. However, if you do this, you may need to manually enter your preferred settings each time you visit the website. In addition, some services and features may not work.

For more information about Google Analytics cookies, please click on this link. (https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage).

An alternative way to turn off Google Analytics is to install a small plugin that Google offers for the main browsers (https://tools.google.com/dlpage/gaoptout?hl=en).

14. Cookies

Revoke cookies

Below is a list of our cookies and their descriptions:

Website Cookie name Type/ Purpose Creation time Validity term Data uses
www.lewben.com _ga Stored on the computer/ Identifies unique visitor in Google Analytics system. Upon the entry to the website  2 years  Unique ID
www.lewben.com _gat Not stored on the computer/ Helps Google Analytics system track the time that visitor spent on the website. Upon the entry to the website Until the web page is closed  Time, duration
www.lewben.com _gid Not stored on the computer/ Identifies a unique website visitor in the Google Analytics system. Upon the entry to the website Until the web page is closed  Unique ID
www.lewben.com collect Not stored on the computer / Created and used only by Google Analytics system. Helps Google Analytics system identify unique website visitor. Upon the entry to the website Until the web page is closed  General information about visitor‘s search engine (name, version).
www.lewben.com pll_language Stored on the computer / Stores information about visitor‘s preferred language. Upon the entry to the website 1 year Website language selection.
www.lewbenwealth.com _ga Stored on the computer / Identifies unique visitor in the Google Analytics system. Upon the entry to the website 2 years  Unique ID
www.lewbenwealth.com _gat Not stored on the computer / Helps Google Analytics system track the time that visitor spent on the website. Upon the entry to the website Until the web page is closed Time, duration
www.lewbenwealth.com _gid Not stored on the computer/ Identifies unique website visitor in the Google Analytics system. Upon the entry to the website Until the web page is closed  Unique ID
www.lewbenwealth.com collect Not stored on the computer/ Created and used only by Google Analytics system. Helps Google Analytics system identify unique website visitor. Upon the entry to the website Until the web page is closed General information about visitor’s search engine and device (name, version).
www.lewbenwealth.com qtrans_front_language Stored on the computer / Stores information about visitor‘s preferred language. Upon the entry to the website 1 year Website language selection.
www.nordgain.com _ga Stored on the computer / Identifies unique visitor in the Google Analytics system. Upon the entry to the website 2 years  Unique ID
www.nordgain.com _gat Not stored on the computer / Helps Google Analytics system track the time that visitor spent on the website. Upon the entry to the website Until the web page is closed Time, duration
www.nordgain.com _gid Not stored on the computer/ Identifies unique website visitor in the Google Analytics system. Upon the entry to the website Until the web page is closed  Unique ID
www.nordgain.com catAccCookies Stored on the computer / Remembers visitor’s website cookie settings. Upon the entry to the website 1 month Entry value: yes (1)/ no (0)
www.nordgain.com collect Not stored on the computer / Created and used only by Google Analytics system. Helps Google Analytics system identify unique website visitor. Upon the entry to the website Until the web page is closed General information about visitor’s search engine and device (name, version).
www.nordgain.com em_cdn_uid Stored on the computer / Identifies unique website visitor. Upon the entry to the website 1 year  Unique ID
www.nordgain.com qtrans_front_language Stored on the computer / Stores information about visitor‘s preferred language. Upon the entry to the website 1 year Website language selection.
www.nordgain.com slaask-message-XXXXXXX…. Stored on the computer / If a visitor starts a conversation with a Nordgain representative on Slaask plug-in, the conversation is stored for one day so that the visitor could resume it upon returning to the website. Upon the entry to the website 1 day Correspondence text
www.nordgain.com slaask-token-XXXX… Stored on the computer / Slaask plug-in identifies visitor. Upon the entry to the website 2 years  Unique ID
www.nordgain.lt __cfduid Stored on the computer / Slaask plug-in identifies visitor for own purposes. Upon the entry to the website 1 year  Unique ID
www.nordgain.lt __cfduid Stored on the computer / Slaask plug-in identifies visitor for own purposes. Upon the entry to the website 1 year  Unique ID
www.nordgain.lt _dc_gtm_UA-XXXXXX… Not stored on the computer / Identifies website in the Google Analytics system. Upon the entry to the website Until the web page is closed  Unique ID
www.nordgain.lt _ga Stored on the computer / Identifies unique visitor in the Google Analytics system. Upon the entry to the website 2 years  Unique ID
www.nordgain.lt _gat Not stored on the computer/ Helps Google Analytics system track the time that visitor spent on the website. Upon the entry to the website Until the web page is closed Time, duration
www.nordgain.lt _gid Not stored on the computer / Identifies unique website visitor in the Google Analytics system. Upon the entry to the website Until the web page is closed  Unique ID
www.nordgain.lt catAccCookies Stored on the computer / Remembers visitor’s website cookie settings. Upon the entry to the website 1 month Entry value: yes (1)/ no (0)
www.nordgain.lt collect Not stored on the computer / Created and used only by Google Analytics system. Helps Google Analytics system identify unique website visitor. Upon the entry to the website Until the web page is closed General information about visitor’s search engine and device (name, version).
www.nordgain.lt em_cdn_uid Stored on the computer / Identifies unique website visitor. Upon the entry to the website 1 year  Unique ID
www.nordgain.lt slaask-message-XXXXXXX…. Stored on the computer / If a visitor starts a conversation with a Nordgain representative on Slaask plug-in, the conversation is stored for one day so that the visitor could resume it upon returning to the website. Upon the entry to the website 1 day Correspondence text
www.nordgain.lt slaask-token-XXXX… Stored on the computer / Slaask plug-in identifies visitor. Upon the entry to the website 2 years  Unique ID
http://www.lewbenart.com PHPSESSID  Standard, non-optional session cookie. Upon the entry to the website Until the web page is closed  Unique ID
http://www.lewbenart.com p_popup_uh Used to store information about user’s reviewed and disabled pop-ups. Upon the first entry to the website 1 year  Unique ID
http://www.lewbenart.com _ga  This cookie is used by Google Analytics to evaluate visitor’s use of the website, compile reports on website activity for website operators and enhance customer experience while using the website. Upon the entry to the website 2 years  Unique ID
http://www.lewbenart.com _gat This cookie is used by Google Analytics to evaluate visitor’s use of the website, compile reports on website activity for website operators and enhance customer experience while using the website. Upon the entry to the website 2 years  Unique ID
http://www.lewbenart.com _gid This cookie is used by Google Analytics to evaluate visitor’s use of the website, compile reports on website activity for website operators and enhance customer experience while using the website. Upon the entry to the website 2 years  Unique ID
www.strategylabs.lt XSRF-TOKEN Not stored on the computer, non-optional / This cookie is necessary to prevent XSRF type cyber-attacks. Upon the entry to the website Until the web page is closed Random sequence of letters.
www.strategylabs.lt laravel_session Not stored on the computer, non-optional / Identifies unique website visitor. Upon the entry to the website Until the web page is closed  Unique ID
ru lt Website by ENTER!