PRIVACY POLICY
1. WHAT IS THE PURPOSE OF THIS POLICY?
This privacy policy (hereinafter referred to as the "Policy") contains information on how VšĮ “Žalgirio krepšinio centras” (hereinafter referred to as the "Žalgiris Basketball") and VšĮ Futbolo klubas “Kauno Žalgiris” (hereinafter referred to as "Žalgiris Football") (collectively referred to in the Policy as "we") collect, use and store your personal data (hereinafter referred to as the "Data") and what rights you have under applicable data protection legislation.
We comply with the EU General Data Protection Regulation ("GDPR") and the requirements of other data protection legislation to protect your information. This policy is subject to change and we recommend that you check the latest version of this policy regularly.
2. WHO IS MY DATA CONTROLLER?
Your data controller depends on the specific data processing purpose, outlined in Part 3. The controller of your data may be either:
● VšĮ "Žalgirio krepšinio centras", company code 302811111, address: Karaliaus Mindaugo pr. 50, e-mail address:[email protected], or
● VšĮ Futbolo klubas "Kauno Žalgiris", company code 300054549, address: 50 Karaliaus Mindaugo pr., e-mail address: [email protected].
3. THE PURPOSES AND LEGAL BASIS FOR THE PROCESSING, THE CATEGORIES OF DATA CONCERNED
3.1. Provision of services and/or goods
When you purchase our goods or order our services, we will process your data as set out below in order to deliver the goods or services to you.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which company you are purchasing goods and/or services from, Žalgiris Basketball or Žalgiris Football |
● Contract (Article 6(1)(b) GDPR) ● Legal obligation where we are required by law to collect your address (Article 6(1)(c) GDPR) |
Name, email, phone number, account number, amount paid, product/service, purchase history, health data (if purchasing tickets for disabled person’s venues and/or requesting assistance from staff), address (where address collection is required by law) |
3.2. Administration of the Zalgiris mobile app, Insider membership and our websites
When you visit www.zalgiris.lt, www.koobin.zalgiris.lt, www.insider.zalgiris.lt, use the Zalgiris mobile app or register on the Zalgiris Insider platform, we will process your data as set out below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Žalgiris Basketball |
● Contract (Article 6(1)(b) GDPR) ● Consent (Article 6(1)(a) GDPR) ● Legitimate interest in processing data necessary for the security and proper functioning of the mobile app and websites (Article 6(1)(f) GDPR) |
Your device information, location data, your interaction with the app and with other app users, your prizes, guessing data, accumulated points, position, user ID (UUID), IP address, login time, username, email, password, photos you uploaded, comments, subscription information, any other information you provide If the Zalgiris Insider member is under 12 years of age: parent's or guardian's email address, child's name, age and club membership status (if new) |
3.3. Because we organise events and other activities
When you participate in games, promotions, quizzes (both on social media and at venues), projects such as Zalgiris - in your school and One Team, as well as various tournaments (e.g. 3x3, Euroleague U-18) or when you order a birthday greeting, we will process your data as set out below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which company’s event or activity you are participating in, Žalgiris Basketball or Žalgiris Football |
● Consent (Article 6(1)(a) GDPR) ● Contract (Article 6(1)(b) GDPR) |
Name, surname, contact details (email, phone number), social media reactions and comments, information on participation in events, ratings, photos or videos, date of birth, team, shirt size, address, photo, greeting text or other additional information, age, photo, personal greeting, any other information needed to organise the event or activity in the specific case If you are a minor Zalgiris ambassador at your school - name and contact details of your parents/guardians |
3.4. Managing our social media accounts
When you take active steps (such as responding to posts, posting a message) on our social media accounts, we will process your data as described below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which institution's social media account you are active on, Žalgiris Basketball or Žalgiris Football |
● Consent (Article 6(1)(a) GDPR) ● Contract (Article 6(1)(b) GDPR) |
Username, post comments, shares, reactions ("likes", "follow") and other information about posts, photos, content of messages, time of receipt and reply, attachments to messages, information about participation in events, ratings and other information you provide. |
3.5. Keeping you and us safe
When you have entered Žalgiris Arena on the basis of a prior visitor list or after passing through a security checkpoint, as well as when you have entered the field of view of the video cameras located in Žalgiris Arena, Žalgiris Basketball Centre or their territories, we will process your data as specified in the table below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Žalgiris Basketball |
Legitimate interest in ensuring your and our security (Article 6(1)(f) GDPR) |
Name, signature, organisation represented, event and date, video, place of visit/stay, behaviour, personal property, time and date. |
3.6. Taking and publishing photos and/or videos of competitions and other events we organise
When you are photographed or filmed during competitions or other events, we will process your data as set out below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which institution you are attending, Žalgiris Basketball or Žalgiris Football |
● Consent (Article 6(1)(a) GDPR) ● Legitimate interest in capturing and using for representational purposes images and/or video recordings of events organised by us (Article 6(1)(f) GDPR) |
Videos, photos and related information (e.g. event, date of event) |
3.7. Marketing
When you register on our website or mobile app, give us your consent or have a legitimate interest, we will provide you with relevant offers, information about our or our partners' services and goods and ask for your opinion about our services.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which institution is providing you with the information, Žalgiris Basketball or Žalgiris Football |
● Consent (Article 6(1)(a) GDPR) ● Legitimate interest in informing you about our goods and/or services (Article 6(1)(f) GDPR) |
Name, surname, email address, phone number, whether the email was opened, which active links were clicked and other statistics |
3.8. Analysis of your purchase history, habits and behaviour
When you use our websites or mobile app and purchase our goods or services, we analyse your purchasing habits and behaviour to continuously improve our products and services. For this purpose, we will process your data as described in the table below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Zalgiris Basketball Centre |
● Consent (Article 6(1)(a) GDPR) ● Legitimate interest to inform you about our goods and/or services (Article 6(1)(f) GDPR) |
Device information (ID), IP address, login time, location data, purchase history, actions you have taken on our websites or mobile app |
3.9. Dealing with your enquiries, requests or complaints
When you make an enquiry, request or complaint to us, we process your data as set out below.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which body you are making your enquiry, request or complaint to: Žalgiris Basketball or Žalgiris Football |
● Consent (Article 6(1)(a) GDPR) |
Name, e-mail, telephone number, address, enquiry, request or complaint, information relating to the enquiry, request or complaint |
3.10. Selection of potential staff
When you apply for a vacancy in our workplace or we contact you about a job opportunity, we process your data in connection with the recruitment process.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Depending on which body you are making your enquiry, request or complaint to: Žalgiris Basketball or Žalgiris Football |
● Consent (Article 6(1)(a) GDPR) ● Legitimate interest in contacting you about job opportunities with our company (GDPR Article 6(1)(f)) |
Name, surname, place of residence, email address, telephone number, work and education information (work experience, qualifications, language skills, IT and other competences), information provided in CV, cover letter or other application documents, references, interview summary, selection notes and test results |
3.11. Compliance with legal requirements
We will keep the data within the statutory limitation periods in order to protect our rights and legal interests should we need to do so. We need to keep some data to comply with legal requirements in the areas of record keeping, archiving and other areas. On rare occasions, where you become involved in a legal process to which we are a party, we will use this data for the purposes of that legal process.
|
Data Controller(s) |
Legal basis for the processing |
Categories of data concerned |
|
Zalgiris Basketball Centre or FK Kaunas Žalgiris |
● Legal obligation (Article 6(1)(c) GDPR) ● Legitimate interest to protect our rights and legal interests (Article 6(1)(f) GDPR) |
Name, surname, email address, contracts, documents and data of legal significance, communications, legal documents, pleadings, annexes, court documents, investigation information, information about convictions and criminal offences, information about IT and communication facilities provided by us, username, password, correspondence, information about the use of IT and communication facilities, logs, possible breaches and incidents, and any other data provided and collected |
4. HOW LONG DO YOU KEEP MY DATA?
We keep the data in a form which permits your identity to be established for no longer than is necessary for the purposes for which the data are processed and in accordance with the requirements of law:
● We keep photos and videos of competitions and events we organise for different periods. In general, we delete the data 10 years after the date of publication of the photo, but this period may be longer if you are a public figure and the photo or video is taken at the time of an award presentation to you. Shared shots and images of Žalgiris Arena are kept for 50 years.
● We keep video recordings and visitor lists for up to 6 weeks, unless there are grounds to believe that illegal activities have been recorded, until the end of the relevant investigation and/or proceedings.
● We keep your application data for 3 years after the end of the relevant selection process. If you give your consent or if we collect the data from professional social media platforms, we keep the data for 5 years.
● We protect the data necessary for the protection of our legal interests within the general limitation period of 10 years (Article 1.125(1) of the Civil Code of the Republic of Lithuania), calculated in accordance with the rules laid down in the aforementioned legal act.
5. WHAT INFORMATION SHOULD I GIVE YOU AND WHY?
Where we are under a legal obligation to collect, use or store your data, or where we need to collect, use or store your data in order to perform or enter into a contract with you (as described in paragraph 3 above), you are required to provide us with your personal data. If you do not provide such data, we will not be able to provide you with services and/or goods or fulfil our other obligations to you.
6. WHERE DO YOU COLLECT INFORMATION ABOUT ME?
Most of the information we collect comes from you. In addition, we may receive information from other sources for certain purposes, as indicated in the table below.
|
Source of origin of data |
Purpose of processing |
|
Other Žalgiris Group companies |
Providing you with information about our goods and/or services |
|
Social networking service providers |
Managing our social media accounts |
|
Recruitment service providers |
Finding potential job candidates |
|
Courts, law enforcement and other public authorities |
Performance of our statutory obligations and/or of our legal interests |
7. TO WHOM DO YOU PASS INFORMATION ABOUT ME?
Where necessary for the purposes described above and permitted by applicable law, we share your data with recipients both within and outside the European Economic Area (EEA).
|
Recipients or categories of recipients |
If the Data are to be transferred to a third country or an international organisation: |
|
|
Third country |
Safeguard measure or exemption allowing the transfer |
|
|
Interneto vizija UAB (website administration service provider) |
--- |
|
|
UAB Baltnetos komunikacijos (website administration service provider) |
--- |
|
|
Other Žalgiris Group companies, including Zalgiris Ventures UAB (provider of data optimisation and analysis services) |
--- |
|
|
Ekskomisarų biuras UAB (security service provider) |
--- |
|
|
UAB "Asistentai.lt" (visitor access management service provider) |
--- |
|
|
ChatMarketing UAB (marketing services provider) |
--- |
|
|
ManyChat UAB (marketing services provider) |
--- |
|
|
Euroleague Properties S.a. |
--- |
|
|
Koobin S.S.L. (ticketing platform provider) |
--- |
|
|
Typeform SL (provider of survey and quiz design services) |
--- |
|
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UAB „Synopticom“ (provider of marketing services) |
--- |
|
|
Lawyers, notaries, bailiffs, data protection officers, auditors, tax, business, HR and other consultants |
--- |
|
|
Providers of IT tools and services, electronic communications services, travel agencies, insurance companies, archiving and other services |
--- |
|
|
State labour, social security, tax, supervisory authorities, police, prosecutors, courts, law enforcement and other state and local authorities |
--- |
|
|
Stripe Inc. (payment processing service provider) |
USA |
|
|
ActiveCampaign, LLC. (marketing services provider) |
USA |
|
|
Facebook (Meta) (social networking service provider) |
USA |
|
|
LinkedIn (social networking service provider) |
USA |
|
|
Microsoft Cooropration (IT infrastructure and services provider) |
USA |
|
|
Potential or actual purchasers of the business or part of it and their authorised advisers or representatives |
Miscellaneous |
|
8. WHAT RIGHTS DO I HAVE?
Subject to the conditions, limitations and exceptions set out in data protection laws, you have the following rights:
|
My right |
When does this right apply to me? |
|
Right of access to data |
The right to obtain confirmation from us as to whether Data relating to you is being processed and, if such Data is being processed, the right to access the Data and information about the processing |
|
Right to request rectification |
The right to require us to correct inaccurate Data relating to you. |
|
The right to request erasure ("right to be forgotten") |
- when the Data is no longer necessary for the purposes for which it was collected or otherwise processed; - where you withdraw the consent on which the processing of the Data is based and there is no other legal basis for processing the Data; - where you object to the processing and there are no overriding legitimate reasons for processing the Data or where you object to the processing of the Data for direct marketing purposes; - where the processing has been unlawful; - where the Data must be erased to comply with a legal obligation; - where the Data was collected in connection with the direct offering of information society services directly and on the basis of consent. |
|
Right to restrict processing |
- when you dispute the accuracy of the Data; - where the processing of the Data is unlawful and you do not consent to its erasure and instead request that its use be restricted; - where we no longer need the Data for the purposes intended but need it to assert, exercise or defend legal claims against you; - where you have objected to the processing of the Data and until it is verified that our legitimate interests override yours. |
|
Right to data portability |
when you seek to obtain the Data you have provided to us or to transfer that Data to another Data Controller, and the processing is based on consent or contract and is carried out by automated means. |
|
Right to object |
when we collect and use Data on the basis of a task carried out in the public interest, under the authority of a public authority or in our legitimate interests or for direct marketing purposes. |
|
Right to withdraw consent |
where the Processing is based on consent and you seek to withdraw it at any time, without affecting the lawfulness of the Processing based on consent prior to its withdrawal. |
|
Right to lodge a complaint |
Right to lodge a complaint with a supervisory authority. |
9. ARE YOU PROFILING ME AND MAKING AUTOMATED DECISIONS?
We do not apply decisions based solely on automated processing, including profiling, which gives rise to legal consequences for you or similarly significantly affects you.
10. DO YOU USE COOKIES AND OTHER SIMILAR TECHNOLOGIES
When you visit our websites, we use cookies and similar technologies to ensure the quality of the content and features. Cookies are small text files of information stored in your browser or computer that help us to recognise you as a visitor to the website, to keep a record of your visit to the website and to personalise the content of the website, to make the use of faster and more convenient, to analyse your behaviour and to improve the services we provide. A list of the cookies we use can be found at: https://zalgiris.lt/slapuku-politika.
11. HOW CAN I CONTACT YOUR DATA PROTECTION OFFICERS?
You can contact our Data Protection Officer by email:
12. CAN THIS POLICY BE CHANGED?
We update this policy from time to time. The latest version of this policy can be found on our website.
Last update date: March 2025