hold. earth Privacy Policy  


This privacy policy (hereinafter – the Privacy Policy) determines the basic information about the processing of your personal data by UAB “HOLD Earth”, legal entity code 305981204 (hereinafter – hold.earth or we), when visitors use and navigate the website of hold.earth hold.earth (hereinafter – the Website), as well as means and sources wherefrom such data is obtained, legal basis for processing of personal data and measures, which have been taken by hold.earth to protect the collected data.

The controller of the data provided on or through the Website is hold.earth. If any questions regarding this Privacy Policy or your data protection arise, you may contact us by e-mail: hello@hold.earth

Please note that hold.earth shall have the right to unilaterally amend the present Privacy Policy at any time. In such cases the amended Privacy Policy will be published on our Website.

The processing of personal data upon provision of services
hold.earth processes your data for the purposes of provision of its services when entering into and (or) performing the agreement entered into with you.
For this purpose, hold.earth may process your personal data such as:
personal identity data (such as name, surname, personal identity code, date of birth, nationality, personal identity document and other);
Contact details (such as e-mail, place of residence and other);
data which is used for signing into account on the Website (such as username, password and other);
other data provided and required for the provision of the respective services of hold.earth.
The data mentioned above is processed only to such extent which is necessary to ensure proper provision of hold.earth’s services to you, also to implement hold.earth’s legal obligations binding us.

hold.earth shall store the personal data for a term of 10 years from the date of the fulfilment of the respective agreement, except for the cases when the legal acts provide for a longer term or the longer storage of such data is necessary for the protection of our interests.
The processing of personal data for direct marketing purposes
hold.earth Processes your personal data for direct marketing purposes when you subscribe to our newsletter through the Website or other means like our Client using services of our Partners. Our newsletter may include information about hold.earth offers and other news.
The basis for the processing of your personal data for direct marketing purposes is your consent expressed by subscribing to our newsletter.
Personal data collected for direct marketing purposes will be stored for 3 years after the consent is obtained, unless you withdraw your consent or otherwise express your objection before the expiry of this term.After this term or after you withdraw your consent, your personal data processed by hold.earth will be immediately destroyed.
In any case you have the right to refuse our newsletters at any time. You can do this by clicking on a special link at the bottom of our newsletters or by informing us by e-mail at hello@hold.earth.
hold.earth may also process its clients’ personal data for direct marketing purposes in order to inform the clients about other services provided by hold.earth. Before becoming a client of hold.earth, also current clients of hold.earth may at any time disagree or revoke such processing of their personal data for the purpose of sending newsletters. The clients may express their objection by contacting us at hello@hold.earth or by clicking on a special link at the bottom of our newsletters.

The processing of personal data upon visitors requests
hold.earth processes your personal data when you contact us by email, mail, social networks or by any other means of communication.
The purposes of such data processing are:
to ensure timely and appropriate processing of your requests;
to contact you regarding any information you provide;
to protect our interest;
to comply with legal obligation.
The basis for the processing of your personal data upon your request is hold.earth’s legitimate interest or implementation of legal requirements.
Personal data collected for the above mentioned purposes will be stored for up to 3 years depending on the data and other circumstances. Longer periods of personal data retention may be applied where:
there is a reasonable suspicion of an unlawful act which is subject to investigation;
your data is necessary for the proper resolution of the dispute, complaint or claim or the defence of hold.earth’s rights and interests;
hold.earth has received complaints related to you or if the hold.earth has noticed any violations committed by you;
it is necessary for back-up copies or related purposes of functioning of information systems of the hold.earth;
it is mandatorily required by applicable laws.
The processing of personal data on the website
Each time you access or visit the Website, the following technical personal data may be automatically collected: IP address, access date and time, webpage name and URL, device operating system data, information about the internet provider, language settings and other relevant data. Such data is collected by cookies and / or similar technology solutions on the basis of users’ consent.
A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. We use cookies to ensure the efficient and safe operation of the Website and to analyse your habits so that the Website could be comfortable, efficient and tailored to meet your needs and expectations.

We use the following cookies:
Name Description Creation moment Validity Used data
PHPSESSID Standard cookie used to support the user’s session. Required cookie Moment of entering the page Until the closing of the website window Unique identifier
_gid Used to unbundle users. Analytical cookie Moment of entering the page 24 hours Unique identifier
Most browsers allow you to refuse cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. However, some cookies (such as “required cookies”) are necessary for the proper functioning of a website, therefore by not accepting such cookies you may face functionality issues on a website. You can obtain up-to-date information about blocking and deleting cookies via this link: http://www.allaboutcookies.org/.
Please note, that required cookies are the condition of the Website use. If you opt out of these cookies, we cannot be sure how the Website will work.
Data transmission to third parties
hold.earth may use the services provided by third parties, i. e. data processors (such as third-party data centres, servers, online traffic and website analysis, direct marketing services, etc.) that may receive access to your personal data. In any such case, we ensure that your personal data is transmitted only to the extent it is necessary to provide certain services of third party providers.
Moreover, in the light of investigations or other cases provided by law, your personal data may be submitted to the law enforcement, judicial or pre-trial institutions.You personal data may also be submitted to payment services providers, attorneys, auditors, other professional consultants, other third parties, related to the provision of hold.earth services and / or having legal basis to obtain such data.
Additionally, particular technical data pertaining to your visits on the Website (such as IP address, data collected or placed on the devices by the cookies, technical information of the browser, other information related to your browsing activities, etc.) may be transferred or made available to the entities in the EEA as well as outside the EEA for the purposes related to statistics, analysis and other related purposes. Please note that the personal data in non-EU countries may be subject to less protection than the EU. The Company will carefully assess the conditions under which such data will be processed and stored after transfer to the above entities
Your rights as the data subject
As the data subject, you have the following rights:
The right of access to personal data. You have the right to receive our confirmation that hold.earth is processing your personal data as well as the right to access your personal data processed and information about the purposes of processing, the categories of data being processed, the categories of data recipients, the period of data processing and the sources of data.
The right to rectification. If you think that data processed by hold.earth is inaccurate or incorrect, you have the right to request this data to be modified, clarified or corrected.
The right to erasure (right to be forgotten). When there are circumstances specified in certain legal acts (when the processing of personal data is illegal, the basis of processing of data has disappeared, etc.), you have the right to request hold.earth to erase your personal data.
The right to restriction of processing. When there are circumstances specified in certain legal acts (when the processing of personal data is illegal, you contest the accuracy of the data, etc.), you also have the right to request hold.earth to restrict the processing of your data.
The right to data portability. You have the right to transfer your data processed by hold.earth with your consent and by automated means to another controller.
The right to disagree with the processing of your personal data if it is processed on a legitimate interest basis, unless there are legitimate reasons for such processing or for the purpose of claiming, enforcing or defending legal requirements.
The right to revoke your consent to process your personal data. If we have no other legal basis for the processing of personal data, we will cease processing of personal data immediately after the cancellation / revocation of the consent provided by you.
If you wish to exercise any of the abovementioned rights, please contact us by email (hello@hold.earth).
The above mentioned request shall at least comply with the following requirements:
The request shall be in writing, readable and understandable;
The request shall include your full name and (or) other contact information which may help us to identify you properly;
The request shall include clear and precise information on which of the rights mentioned in clause 6.1 you would like to exercise;
If you are exercising your rights through a representative, your request shall include the representative’s first name, last name, contact information for the communication and include a document certifying the representation.
hold.earth will reply to your written request within a period of note more than 30 calendar days since the day of receipt of such request. In exceptional circumstances, which may require additional time, this deadline for our reply may be extended by a further two months depending on the complexity of the situation. We may refuse to satisfy your request by giving you a written substantiated notice in case any circumstances set out in the applicable legislation are determined.
In case you deem that your rights have been violated, you have the right to file a complaint to the State Data Protection Inspectorate(you can find more information on the website vdai.lrv.lt/en/) However, we strongly recommend you to contact us firstly in order to find the right solution to a problem.
Final provisions
By using our services and/or browsing the Website, you agree to the terms of this Privacy Policy.
This Privacy Policy may be updated from time to time updated by hold.earth. We will inform you about the updates by submitting a new version of the Privacy Policy.

Grounds for data collection 

hold.earth processes your data for the purposes of provision of its services when entering into and (or) performing the agreement entered into with you.
For this purpose, hold.earth may process your personal data such as:
personal identity data (such as name, surname, personal identity code, date of birth, nationality, personal identity document and other);
Contact details (such as e-mail, place of residence and other);
data which is used for signing into account on the Website (such as username, password and other);
other data provided and required for the provision of the respective services of hold.earth.
The data mentioned above is processed only to such extent which is necessary to ensure proper provision of hold.earth’s services to you, also to implement hold.earth’s legal obligations binding us.
hold.earth shall store the personal data for a term of 10 years from the date of the fulfilment of the respective agreement, except for the cases when the legal acts provide for a longer term or the longer storage of such data is necessary for the protection of our interests.

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 

A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at hello@hold.earth
Last Modified 2022 September 1.
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