PRIVACY POLICY
Last revision date: January 17, 2023
1. WHAT CAN I FIND IN THIS PRIVACY POLICY?
This Privacy Policy (hereinafter referred to as the Policy) contains information on how Public Institution Žalgiris Basketball Center (hereinafter referred to as Žalgiris Basketball Center) and Public Institution Kaunas Žalgiris Football Club (hereinafter referred to as Kaunas Žalgiris FC), together hereinafter referred to as We, collect, use and store your personal data and what your legal rights are in accordance with the applicable personal data protection laws.
We follow the requirements of the General Data protection Regulation of the European Union (hereinafter referred to as the GDPR) and other legal norms regulating personal data protection to ensure the privacy and security of your personal data. This policy may be amended; therefore, we recommend to visit our website regularly in order to access the newest version of the Policy.
2. WHO IS RESPONSIBLE FOR THE PROTECTION OF MY PERSONAL DATA?
As indicated in Section 3 of this Policy, in the Information about Personal Data Table below, your data processor is the following, respectively:
- Public Institution Žalgiris Basketball Center, enterprise number 302811111, address: Karaliaus Mindaugo Pr. 50, E-mail: [email protected], or
- Public Institution Kaunas Žalgiris Football Club, enterprise number 300054549, address: Karaliaus Mindaugo Pr. 50, E-mail: [email protected]
3. HOW DO YOU USE MY PERSONAL DATA AND WHY?
3.1. For the purposes of the sales of goods and/or provision of services
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you store my personal data? |
When you purchase our goods and/or services | Depending on the institution where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | Your first name, family name, e-mail, phone number, account number, amount paid, product/service, purchase history, health data (when purchasing tickets to the seats for people with disabilities and/or staff assistance is requested), address (when required by the laws) | Agreement (Clause (b) of Paragraph 1 of Article 6 of the GDPR) Legal obligation when your address must be collected according to the laws (Clause (c) of Paragraph 1 of Article 6 of the GDPR) | 3 years following the last purchase The address is stored for 10 years from invoicing |
3.2. For the purpose of managing Žalgiris mobile app (including Žalgiris Insider platform)
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you subscribe to our paid content on our mobile app (including Žalgiris Insider platform) | Žalgiris Basketball Center | Your device information, location data, your interactions with the mobile app as well as interactions with other users, user ID (UUID), username, email, password, your uploaded images, comments, subscription details, any other information you have provided | Agreement (Clause (b) of Paragraph 1 of Article 6 of the GDPR) Legitimate interest in processing data necessary for the security and proper functioning of the mobile app (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | For as long as you use the app and up to 3 years after your inactivity |
3.3. For the purpose of holding events and other leisure activities
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you participate in games, promotions and quizzes (on social networks and/or during events held by us) | Depending on the institution, where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | Your first name, family name, post comments, post shares, information on “like” and “follow” clicks on the social network account, information about reactions to posts, photos, messages, time, contents, attachments, replies of the messages, time of replying to the messages, information about participation in the events, information about the given rating, photos or video recordings, if intended for the competition as one of the conditions of participation. | Consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | 1 year after announcement of the winner |
When your photos were taken during an event | Depending on the institution, where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | Your image as seen on the photograph, image and/or audio recording in video, event, date of event | Legal interest to record and use images and/or video recordings from our events for representational purposes (GDPR 6 str. 1 d. f p.) Your consent when posing for photos (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | 5 years from publishing the photo and/or video recording |
You are the school ambassador in the “Žalgiris in Your School” project | Žalgiris Basketball Center | First name and contact details submitted by you (e-mail or a Facebook account) If you are a minor: first name, family name and contact details of one of your parents (guardians) If you are of lawful age and give your full consent, you will also submit your last name and photograph | Consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | For the duration of serving as the school ambassador in the Žalgiris in Your School project and for 1 year after that |
You have taken part in our friendly tournaments (e.g., 3X3, Euroleague U18, etc.) | Žalgiris Basketball Center | First name, family name, date of birth, represented team, phone number, e-mail, t-shirt size. | Agreement (Clause (b) of Paragraph 1 of Article 6 of the GDPR) | 30 days from the end of the tournament |
When you take part in the “One Team” project | Žalgiris Basketball Center | First name, family name, date of birth, address, phone number, your image on the photo, image and/or sound recording in video | Legal interest (Clause (f) of Paragraph 1 of Article 6 of the GDPR) Your consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | 3 years from the end of the project |
When you order a birthday greeting | Žalgiris Basketball Center | First name and additional information, if you decide to share it: last name, age, photo, personalized message | Agreement (Clause (b) of Paragraph 1 of Article 6 of the GDPR) | 30 days from rendering the services |
3.4. For the purpose of managing our social network accounts
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you carry out any active steps on our social networks | Depending on the institution, where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | User name, comments under a post, shares of posts, information on “like” and “follow” clicks on our social network account, information about reactions to posts, photos, messages, time, content, attachments, replies of the messages, time of replying to the messages, information about participation in events, information about the given rating and any other similar information that you may provide | Consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | 10 years after taking any active steps on our social networks |
3.5. For the purpose of ensuring ours and your safety
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
You have entered Žalgirio Arena according to the preapproved visitor list | Žalgiris Basketball Center | First name, family name, represented organization, event, event date, signature | Legal interest to ensure yours and our safety (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | 30 days from visiting Žalgirio Arena |
You have entered Žalgirio Arena through the security post | Žalgiris Basketball Center | First name, family name, signature, date | Legal interest to ensure yours and our safety (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | Up to 60 days from visiting Žalgirio Arena |
You have visited the premises at Naglio St. 4A which are under video surveillance | Žalgiris Basketball Center | Image, visit/stay location, behavior, personal belongings, time and date | Legal interest to ensure yours and our safety (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | Up to 60 calendar days from being filmed, except in cases of a reason to believe that a transgression or other illegal action has occurred (until the end of the respective investigation and/or closing of the case) |
3.6. For the purpose of publishing photos and/or video recordings from our events
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? | |
When your photos were taken and/or you were filmed during an event and the photos/ videos were made public | Depending on the institution, where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | Image on the photo, image and/or sound recording in the video, event, event date | Legal interest to record and use images and/or video recordings from our events for representational purposes GDPR 6 str. 1 d. f p. Your consent when posing for photos (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | 5 years from publishing the photo and/or video recording | |
3.7. For the purpose of provision of information pertaining to our products and/or services
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When we provide you with information about our products and/or services | Depending on the institution, where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | Your first name, family name, e-mail, phone number, address, enquiry, request or complaint and any other related information | Your consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) Legal interest to inform you about our products and/or services (Clause (f) of Paragraph 1 of Article 6 of the GDPR) Paragraph 2 of Article 81 of the Law on Electronic Communications of the Republic of Lithuania | 3 years from provision of information, unless you have revoked your consent to receive information about our products and/or services earlier than this term |
3.8. For the purpose of website and mobile app administration
| When is this important to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you visit us at www.zalgiris.lt, www.koobin.zalgiris.lt, www.insider.zalgiris.lt or use our zalgiris.lt mobile app | Žalgiris Basketball Center | Device information (ID), IP address, sign-in time, location data | Legal interest to manage our websites and mobile app (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | 1 year from browsing our websites or using our mobile app |
3.9. For the purpose of analyzing your purchase history, habits and interests
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you purchase goods and/or services from Žalgiris Group members | Žalgiris Basketball Center | Device information (ID), IP address, sign-in time, location data, purchase history | Legal interest to organize the data processed by us (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | 3 years |
3.10. For the purpose of analyzing your inquiries, requests and complaints
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you submit an inquiry, request or complaint | Depending on the institution, where you address the enquiry, request or complaint, either Žalgiris Basketball Center or Kaunas Žalgiris FC | First name and family name, e-mail, phone number, address, inquiry, request or complaint, information related to the submitted inquiry, request or complaint | Your consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) | 1 year from the submitted inquiry, request or complaint |
3.11. For the purpose of employee recruitment and selection
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you are a candidate to an open position with us or we evaluate you as a potential candidate | Depending on the institution, where you wish to work or which evaluates you as a potential candidate, either Žalgiris Basketball Center or Kaunas Žalgiris FC | First name and family name, date of birth, address, phone number, e-mail, workplace, education, desired position, date of receiving your CV, personal qualities, work experience, last workplace, professional experience in years, position in the last workplace, other work experience, language, foreign language skills, reading, writing and speaking skill levels, computer skills, other information, motivation to work with us, desired salary) and/or other information submitted by you during the selection process, and information from your social networks | Your consent (Clause (a) of Paragraph 1 of Article 6 of the GDPR) Agreement (Clause (b) of Paragraph 1 of Article 6 of the GDPR) Legal interest to contact you when you upload information on your professional social network platforms (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | 3 years after the end of the employment process 5 years after your consent or after we collect information from professional social network platforms |
3.12. For the purpose of accounting as set forth in the laws
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you order our products and/or services | Depending on the institution, where you purchase goods and/or services, either Žalgiris Basketball Center or Kaunas Žalgiris FC | First name and family name, address, e-mail, phone, personal identification document data, information about rendered services, signature, amount due for the services, invoice for the rendered services, bank account number, accounting documents | Legal obligation to collect data (Clause (c) of Paragraph 1 of Article 6 of the GDPR) | 10 years from ordering the products and/or services |
3.13. For the purpose of protecting our rights and legal interests
| When is this relevant to me? | Who is my data controller? | What information do you collect about me? | Why do you have the right to collect my personal data? | How long do you use or store my personal data? |
When you become a party of lawsuits or other legal proceedings you are related to | Depending on the institution, which will be a party of the lawsuit, either Žalgiris Basketball Center or Kaunas Žalgiris FC | All of the above-mentioned information related to other purposes, documents and annexes sent to you, documents and annexes submitted by you, procedural documents, court decisions, decrees, information about crimes and convictions | Legal interest to defend our rights in legal proceedings (Clause (f) of Paragraph 1 of Article 6 of the GDPR) | 3 (three) years from the day the court or institution decision came into force or the legally binding decision was implemented |
4. WHICH INFORMATION SHOULD I SUBMIT TO YOU AND WHY?
You must submit your personal data to us when we are legally obligated to collect, use and store your personal data or when such data collection, use and storage is necessary to execute or conclude an agreement with you (as described in Section 3 hereof). If you cannot provide the said data, we will be unable to render services and/or sell products to you or fulfill other obligations.
5. WHERE DO YOU GET INFORMATION ABOUT ME?
The majority of information is collected from you. We can also receive information from other sources as indicated below:
| Information source | Goal of information collection |
Other members of Žalgiris Group | Provision of information about our products and/or services |
Providers of social network services | Administration of our social network accounts |
Providers of HR recruitment services | Looking for potential new employees |
Courts, law enforcement and other state enterprises | Fulfilling legal obligations and/or protecting our legal interests |
6. WHO DO YOU RELAY MY PERSONAL DATA TO?
Your personal data may be relayed for the purposes laid out above to the recipients both within the European Economic Area (EEA) and beyond it, provided that such disclosure of personal data is obligatory and permitted in accordance with the laws.
| No. | Recipients or categories of recipients of personal data | State of recipient ofpersonal data | Legal basis for transferring my personal data beyond the EEA |
| 6.1. | Interneto Vizija UAB (provider of website administration services) | Lithuania | Not applicable |
| 6.2. | Baltnetos Komunikacijos UAB (provider of website administration services) | Lithuania | Not applicable |
| 6.3. | Other members of Žalgiris Group, including Žalgiris Ventures UAB (provider of data optimization services) | Lithuania | Not applicable |
| 6.4. | Ekskomisarų Biuras UAB (provider of security services) | Lithuania | Not applicable |
| 6.5. | Asistentai.lt (provider of visitor access administration services) | Lithuania | Not applicable |
| 6.6. | ChatMarketing UAB (provider of marketing services) | Lithuania | Not applicable |
| 6.7. | ManyChat UAB (provider of marketing services) | Lithuania | Not applicable |
| 6.8. | Euroleague Properties S.a. | Luxembourg | Not applicable |
| 6.9. | Koobin S.S.L. (provider of ticketing platform services) | Spain | Not applicable |
| 6.10. | Typeform SL (provider of survey and quiz services) | Spain | Not applicable |
| 6.11. | UAB „Synopticom“ (provider of marketing services) | Lithuania | Not applicable |
| 6.12. | Stripe Inc. (provider of payment processing services) | USA | Standard contractual clauses |
| 6.13. | ActiveCampaign, LLC. (provider of marketing services) | USA | Standard contractual clauses |
| 6.14. | Facebook, Inc., Facebook Ltd. (provider of social network services) | USA | Standard contractual clauses |
| 6.15. | Parties and representatives in legal proceedings, other participants of legal proceedings | EEA | Not applicable |
| 6.16. | Lawyers, notaries, bailiffs | EEA | Not applicable |
| 6.17. | Law enforcement institutions and courts of the Republic of Lithuania and the European Union | EEA | Not applicable |
| 6.18. | Service providers (e.g., providers of such services as event and activity planning, social networks, photography, mobile app administration tools, technological measures, accounting, insurance services) | Various countries | In cases of transferring personal data outside the EEA, we follow: ● European Commission decisions concerning adequacy (Article 45 of the GDPR) ● Standard contractual clauses (Clause (c) of Paragraph 2 of Article 46 of the GDPR) |
7. WHAT ARE MY RIGHTS?
In compliance with the conditions, limitations and exceptions set forth in data protection laws, you have the following rights:
| My right | When does this right apply to me? |
| The right of access | when you seek to obtain confirmation as to whether we are processing data relating to you and, if so, access to the data and information about the processing of the data. |
| Right to have personal data rectified | when you seek from us rectification of inaccurate data relating to you. |
| Right to erasure (“right to be forgotten”) | when the data is no longer necessary to achieve the purposes for which it was collected or otherwise processed, when you revoke your consent on the basis of which the data processing was carried out and there is no other legal basis for processing the data, when you object to data processing and there are no overriding legal grounds for the processing, or you object to data processing for direct marketing purposes, when the data was processed illegally, when the data must be erased in compliance with the legal obligation imposed on the Company, when the data was collected in the context of offering an information society service directly to a child and after receiving a consent from the child. |
| Right to restrict processing | when you dispute the accuracy of the data, when the processing is illegal and you object to the erasure of the data and request to limit its use instead, when we no longer need the data for processing purposes, but you require the data to assert, exercise or defend legal claims, when you object to data processing. |
| Right to data portability | when you seek to receive the data you have provided to us in a structured, commonly used and computer-readable format and to forward that data to another data controller where the data processing is based on consent or contract and is carried out automatically. |
| Right to disagree | when the data processing is based on a task carried out in the public interest or in the performance of public authority functions, or the legitimate interest of the data controller, including profiling, or if you object to the processing of your data for direct marketing purposes. |
| Right to withdraw consent | when processing is based on consent and you seek to withdraw your consent at any time. |
| Right to lodge a complaint | when you want to lodge a complaint with a supervisory authority, in particular in the Member State where you have your permanent residence, place of work or violation of the GDPR is suspected. |
8. DO YOU PROFILE ME AND MAKE AUTOMATED DECISIONS?
We do not make decisions that are based solely on automated data processing, that could have legal consequences for you or that could have any other significant impact on you.
9. DO USE COOKIES OR OTHER SIMILAR TECHNOLOGIES?
When you visit websites, we use cookies and other similar technologies to ensure high quality content and functionality of the website. Cookies are small text files containing information and stored in your browser or computer. Cookies allow us to recognize you as a website visitor, to save your browsing history and to adapt personal content for you to ensure a faster and more convenient use of our website, to analyze your behavior patterns and to improve the services rendered to you. The list of cookies used by us is available at https://zalgiris.lt/slapuku-politika/.
10. HOW CAN I MANAGE COOKIES?
When visiting our website, you can select the desired cookies in the agreement form that shows up at the bottom of the page once the website is opened (we only ask to fill it once). Žalgiris will apply the cookies in line with the filled agreement form.
You can edit the agreement form to change and/or to cancel your selections in relation to the cookies at any time. Please be aware that if you block certain cookies, the website may be modified, previously selected parameters may be deleted and some parts of the website might not be functional.
For more information about cookies and handling of cookies please visit www.allaboutcookies.org or www.google.com/privacy_ads.html and web browser help pages:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
11. HOW CAN I USE MY RIGHTS AND CONTACT YOUR DATA PROTECTION OFFICERS?
If you have any questions in relation to data protection, please contact our data protection officers by e-mail at [email protected].
