I. Terms:

1. Website – REFLECTUS website, available at www.reflectus.lt.
2. Platform – REFLECTUS platform, available at https://edu.reflectus.lt/
3. Applications – REFLECTUS mobile applications, downloadable and installed on mobile phones.
4. REFLECTUS – UAB Refleksija, a private limited liability company established in the Republic of Lithuania, legal entity code 304992411, registered office and office address – Gedimino pr. 27, LT-01105 Vilnius, data is collected and processed in the Register of Legal Entities of SE Centre of Registers, e-mail address – info@reflectus.lt, telephone number +370 676 16074.
5. User – any natural person and legal entity who uses the Website, Platform or Applications.
6. Cookie – a small file that is sent to a device when anyone visits the Website, the Platform or the Applications.
7. Browser – a program designed to display web pages (websites) on the web or on a personal computer.
8. Personal data – any information relating to a natural person – a data subject known or identifiable directly or indirectly by reference to such data as a personal identification number, one or more physical, physiological, psychological, economic, cultural or social characteristics of a person.
9. Recipient of personal data – a legal entity or a natural person to whom personal data is provided, including Partners.
10. Privacy Policy – this document, which sets out the basic rules for the collection, storage, processing and retention of personal data and other important information through the Website.
11. Law – the Republic of Lithuania Law on the Legal Protection of Personal Data.
12. General requirements – the General Data Protection Regulation of the European Union of 25 May 2018 (GDPR).
13. Website Administrator – a person responsible for the administration of the Website.
14. IP address – a unique number assigned to each computer connected to the Internet, known as an Internet Protocol (IP) address. Because these numbers are usually assigned by country blocks, an IP address can often be used to identify the country where your computer is connected to the Internet.

II. General Provisions

1. The Privacy Policy of the Website sets out the basic rules for the collection, storage and processing of personal data and other information of personal importance to the User when using the Website, Platform or Applications and ordering the Services provided therein.
2. The Privacy Policy is intended to secure and protect the personal and other data of the Users of the Website from unauthorized use.
3. Users are considered familiar with this Privacy Policy when they receive confirmation by e-mail after subscribing to the newsletter. You can get acquainted with this document at any time on the Website.
4. This Privacy Policy shall apply in all cases where REFLECTUS receives personal data due to the User subscribing to a newsletter through the Website or submitting his/her data on the Platform or Applications.

III. Collection and Storage of Personal Data

1. Some or all of the following Personal Data shall be collected and stored: name, surname, place of residence, place of work, telephone number, e-mail address, IP address, device parameters from which the connection was made.
2. The User of the Platform must obtain the consent of the minor’s parents/guardians before requesting minors to become users of the Application.
3. When using the Website, Platform or Applications, Cookies shall be stored on the User’s computer or mobile device for the purpose of collecting statistical traffic information, ensuring the quality of the Services and efficient use of the Website, Platform or Applications. Detailed information about Cookies: Cookie name, Purpose, Creation moment, Expiration date.
4. The User shall express his/her prior voluntary consent to allow REFLECTUS to save cookies on the Website or the Platform by clicking on the “I AGREE” button in the following way: “We use cookies to improve your experience on this website. Click “Confirm” that you have read and accept our cookie policy. You can block or disable the use of cookies in settings.”
5. You can delete or block all these Cookies in your browser or telephone settings, but in such a case, part of the Website may not work properly.

IV. Purposes of the Use of Personal Data

1. For the purpose of subscribing to the newsletter and informing about the REFLECTUS product.
2. In order to ensure the continuous improvement and development of the Website, the Platform and the Applications, REFLECTUS shall have the right to use the Personal Data for marketing purposes when the User expresses his/her consent (e.g. by subscribing to a newsletter, etc.).
3. REFLECTUS shall collect the following personal data for direct marketing purposes: e-mail. Consent to the use of Personal Data for marketing purposes shall be expressed by ticking the appropriate box.
4. All personal data collected for direct marketing and other purposes shall comply with the provisions of the Law and the General Requirements.
5. The User may revoke this consent at any time by sending an e-mail to the Website Administrator at info@reflectus.lt.
6. The Website Administrator may use the IP addresses of Users when administering the Website, Platform or Applications and diagnosing possible malfunctions.

V. Accounts

1. REFLECTUS Accounts shall be links to certain web pages that may contain the same information as the Website, Platform or Applications, as REFLECTUS is the manager of these Accounts.
2. REFLECTUS has Accounts on the following websites: @reflectus.lt – (social network Facebook; social network Linkedin).

VI. Provision of Personal Data

1. REFLECTUS hereby informs that it does not transfer Personal Data to third parties located in the Republic of Lithuania, European Union countries and other foreign countries, neither for a fee nor for a fee or otherwise, except in the following cases:

• if User consent has been provided;
• to law enforcement authorities in accordance with the procedure prescribed by the legislation of the Republic of Lithuania.

VII. Correction, Supplementation and Deletion of Personal Data

1. The User hereby grants REFLECTUS the right to collect, manage, process and store the User’s Personal Data to the extent and for the purposes set out in the Privacy Policy and other documents of the Website. The User shall have the right to revoke his/her permission to REFLECTUS to collect, manage and process his/her Personal Data, to demand the deletion of Personal Data at any time. The consent to the collection, management and processing of the User’s Personal Data shall be valid only in advance. REFLECTUS, upon receipt of such notice from the User, shall immediately suspend the processing of that Personal Data, but this does not mean that REFLECTUS must delete/destroy the Personal Data if it has grounds to store it.
2. The User shall have the right to access his/her personal data. In order to find out what personal data REFLECTUS has collected and from what sources, for what purposes they are processed, to which recipients they have been and are currently provided, the User must contact REFLECTUS in advance at the e-mail address specified in this Privacy Policy. REFLECTUS shall exercise the User’s right to access the processed Personal Data within 30 calendar days from the receipt of the User’s request.
3. If the User finds out that his/her Personal Data is incorrect, incomplete or inaccurate, he/she shall have the right to contact REFLECTUS by e-mail requesting the correction of incorrect, incomplete, inaccurate Personal Data and/or the suspension of the processing of such Personal Data. Personal Data shall be rectified and deleted or their processing shall be suspended on the basis of the identity of the data subject and the documents confirming his/her Personal Data. REFLECTUS shall exercise the User’s right to suspend the processing of Personal Data (or destroy Personal Data) within 5 business days from the receipt of the User’s request.
4. REFLECTUS shall retain Personal Data for 5 (five) years from the date of its submission, unless a different retention period is provided for in this Privacy Policy.
5. The User shall agree in advance that REFLECTUS has the right to keep his/her data indefinitely if his/her data has been used for illegal activity or identity theft or other violation, which has been or will be investigated by the relevant law enforcement authorities, if REFLECTUS has received complaints, related to the respective User, or if REFLECTUS has noticed violations of the Privacy Policy and/or the rules on the Website by the respective User or in case of other legitimate purposes to protect Personal Data.
6. When exercising the abovementioned rights, the User may apply to REFLECTUS by e-mail at info@reflectus.lt.

VIII. Protection of Personal Data

1. REFLECTUS ensures that the Personal Data provided by the User on the Website is protected from any illegal actions: unlawful alteration, disclosure or destruction of Personal Data, identity theft, fraud and ensure that the level of Personal Data protection would comply with the requirements of the legal acts of the Republic of Lithuania.
2. Personal Data is protected against loss, unauthorized use, and changes. The premises where the collected data shall be stored is physically protected from unauthorized access. The database that protects the User’s data of the Website is protected from unauthorized access via computer networks.

IX. Final Provisions

1. This Privacy Policy has been in force since 1 March 2020. Users shall be notified of any changes to the Privacy Policy on the Website and/or by e-mail.