CYBER CITY
PRIVACY POLICY

This Privacy Policy (the "Policy") describes how Cyber City protects privacy and personal data of its clients and website visitors.

Your personal data controller is Sparta, AB (registration code: 121730797, address: Švitrigailos st. 32, LT-03230 Vilnius) (“Cyber City”). This Policy does not address cases where your personal data is collected and otherwise processed by the tenants of Cyber City. You may find the list of Cyber City tenants available here.

If you have any questions regarding this Policy or if you have any requests related to processing of your personal data, you can reach out to us via our contact form at our website.

Grounds for data processing. We process your personal data on the following legal grounds:

• your consent, which is expressed by your active actions, i.e. addressing us with request, etc.;
• for conclusion and performance of a contracts with our tenants (as well as other clients;
• our legitimate interests or legitimate interests of our tenants, clients or third parties (e.g., to operate our website, to inform our clients about services offered, to ensure security of the premises etc.);
• to comply with the obligations imposed on us by legislation.

Contracting parties, partners and other persons. We process personal data of different categories of individuals – our tenants, business partners, suppliers, other contracting parties, including employees, representatives, agents. The data processed can include name, position, contact information as well as any other information related to the conclusion and performance of the contract.

Purposes: The data is collected and processed for the following purposes:

• development and creation of business, professional or other relations;
• conclusion and administration of transactions and agreements;
• defence of our legal interests, including lodging or enforcing legal claims;
• performance of our mandatory legal obligations.

Video surveillance. To ensure the security of property and safety of our tenants, employees, visitors and other persons, our premises and territory is under video surveillance.

We inform about video surveillance by virtue or notices / signs with a symbol of video camera, our details, purposes of processing and other information.

Video data is stored for a period of 14 days from the day of recording and is deleted afterwards. Under certain circumstances, when it is necessary for the protection of our interests or any third party (e.g., in case of insurance event and crime), the retention period may be extended.

When you contact us. If you contact us via email, our contact form, social media, etc. we process the data you provide us with (such as your name, email address, phone number, company you are from and other personal data you provided in your inquiry).

We process your data in these cases to handle the queries and complaints, to ensure the quality of the services we provide, to protect and defend our rights and legitimate interests. You provide your data to us on the basis of your consent.

Marketing. We may use your contact information (your name, email address, phone number) for offering you our services. We may contact you where we have your consent; where by law we are allowed to reach out to you based on our legitimate interest in marketing ourselves; on the grounds of our contractual relationship or on some other existing legal grounds. You can always opt-out of marketing communications by contacting us via our contact form at our website and/or by choosing the unsubscribe option in our email communications.

Website data processing and cookies. Our website, as in the case of most websites on the Internet, may collect log data (such as IP address, browser type, operating system) to operate our website and ensure its reliable performance.

Cookies are small text files (up to several KB) that your web browser places on your computer, tablet, or other smart device when visiting our website. Cookies are designed to ensure the efficient and safe operation of the site and to analyse your habits in order to make the site functioning convenient, efficient and meet your needs and expectations.

As standard on the Internet, we may use various types of cookies (including third-party cookies) so that we could make improvements on our website. You can choose whether to accept or block cookies through your browser settings. You could decide to delete cookies as well. All major browsers allow users to choose their cookie settings.

In the table below we present the main providers of the cookies used in our website, which help us track the number of visitors and the frequency of their visits to the website.

You can control the use of cookies by changing your browser settings and by using the cookie banner at the bottom of the page on the Cyber City website. For more information on how to remove cookies as well as other useful information related to the use of cookies, visit the website http://www.allaboutcookies.org/.

Social media widgets. We may use social media (Facebook, Instagram, etc.) sharing functions. Such social media widgets may collect certain information (e.g., your IP address or the type of device you are using) and transmit it to the respective social media organisations. For more information on how these organisations use personal data, please read their privacy policies. Here, we act based on our legitimate interest to market ourselves.

Data sharing. We use some third-party service providers (such as email, website analytics, data centres and communication technology services) for the data processing. They can access the data only as much as is needed for the provision of the services. When the service provider is based outside of the European Economic Area, we transfer the personal data only if, according to the European Commission’s adequacy decision, there is sufficient data protection in the respective country; or if data protection measures (e.g., standard contractual clauses) have been agreed upon with such a provider. We may disclose your personal data to a law enforcement agency, government authority or other organisation if we are required to do so to meet our legal obligations, or otherwise to protect our rights or the rights of anyone else.

Data storage. We keep the data only as long as necessary to provide you with our services and for legitimate and essential business purposes, such as complying with our legal obligations, and resolving disputes.

Your personal data processed for the purpose of direct marketing and newsletters will be kept for 2 years from the last communication with you (if a separate consent was obtained) or the date of fulfilment or expiry of the agreement.

Your personal data, in pursuit of our legitimate interest in collecting evidence about requests received, the replies to them, as well as the services provided and the contact we had, is retained, depending on the type of data and circumstances, as long as it is in line with the purposes for which it was collected.

A longer retention of your personal data than that previously indicated is performed when:

• it is necessary to be able to defend ourselves from any claims or lawsuits and to exercise our rights;
• in case there is a reasonable suspicion of illegal activity and an investigation is or is going to be conducted;
• your data is necessary for proper resolution of dispute or a complaint;
• for back-ups and other purposes related to the operation of information systems and maintaining and similar purposes;
• on other grounds set by other legal acts.

Your rights. You have the following rights with regards to your data processing:

• to get familiarise with your personal data and how it is processed;
• to demand correcting incorrect, inaccurate or incomplete data, erasing your personal data or restricting the processing of your personal data when personal data is processed without complying with legal requirements or when there is another legal basis;
• to demand transfer of your personal data to another data controller or provide it directly to you in a convenient form (applicable to that personal data that you submitted and that is processed by automated means based on an agreement or consent);
• to object to processing of your personal data if it is processed based on a legitimate interest, unless there are legitimate reasons for such processing or for the purpose of making, pursuing or defending legal claims;
• in cases where your personal data is processed on a separate consent basis, you have the right at any time to withdraw your consent.

If you would like to exercise any of your rights or have any questions, please reach out to us via our contact form at our website. We believe that if there are any issues, we can always solve them together, however, you could also contact the State Data Protection Inspection.

When we receive your application and successfully verify your identity, we will try to evaluate and answer your application no later than within one month from its receipt. If your application is complex or there are a number of applications we have to answer, we have a right to extend the answer period for another two months. If so, we will notify you no later than within one month from the receipt of your application, by indicating the reasons for such extension.

External links. Our website may contain links to and from other websites. These websites have their own privacy notices and/or terms of service. We do not accept any responsibility or liability for these other websites. Please make sure to check the above-mentioned documents before submitting any personal data to these websites.

Updates. We may update this Policy from time to time. This may be in relation to changes in the law, best practice, or changes in our services. Any changes will become effective when we post the revised Policy; thus, you should check here regularly. Below you can find the date of the last update.

2024-06-26