Privacy Policy

UAB “Europos tabakas”, address Medziotoju Str.9, LT-37176 Panevezys, Lithuania (»Europos tabakas«, »we«) is processing Personal Data, as a Controller, of website visitors and other individuals who might have entrusted Europos tabakas their Personal Data.

The purpose of this Privacy Policy is to inform you how we process your personal data, what are your rights and how you can exercise them and provide you all necessary information.

We are committed to respect the trust you have shown us by providing your Personal Data and we are implementing measures for keeping your Personal Data confidential and processing them in accordance with your wishes and applicable legislation related to Personal Data.

‍

‍

‍

‍

Description of Processing of Personal Data

‍

This section will provide you with explanation about:‍

• ‍PERSONAL DATA which we process about you;‍
• PURPOSES for which Personal Data is processed;‍
• LEGAL GROUNDS on which we process Personal Data;‍
• HOW LONG we process Personal Data for a specific purpose.

‍

‍

‍

‍

Personalized Marketing Communication

‍

Personal Data

• Name
• Surname
• Address
• Phone number
• E-mail address
• Gender
• Birth Date
• Consent information

‍

‍

Purpose of processing

‍

We  process the above defined Personal Data for the purpose of personalized  marketing communication in order to inform you about any new products, offers  and deals, promotions or any other information about our products or Europos  tabakas. Processing of Personal Data for this purpose includes:

• Preparation  of database, using the above defined information;
• Personalized  marketing communication via phone (telemarketing, robocalls), e-mail, SMS  (including Viber, Whatsapp and similar messages) or post (sending catalogue  to your address);
• Management  of returned catalogues (e.g. wrong address) or bounce e-mails/SMS (cannot be  delivered due to incorrect number).

‍

‍

Legal Ground

‍

Personal Data is performed for this purpose on the basis of the consent (positive subject consent), we have documented in the relevant system and which you have provided to us via various means (on our website, or other ways).

‍

‍

Period of processing

‍

Until  your consent is withdrawn. You can withdraw your consent in various ways,  including:

• By sending e-mail request to withdraw the consent to EMAIL, or
• By calling to NUMBER
• By sending request via post, or
• By following unsubscribe link included in all e-mails (such withdrawal of  consent can be applied only for unsubscribing from the e-mails)
• By unsubscribing following the instructions in SMS (such withdrawal of consent  can be applied only for unsubscribing from SMS communication).

We will withdraw  your consent as soon as possible after receiving the request, but not later  than in 30 days after receipt of the request and we will inform you about it.

Any processing of Personal Data for this purpose processed before the withdrawal of the consent  is considered as a lawful processing. We apologize if you will for example  receive marketing communication after the withdrawal of consent, but we might  have already sent the marketing communication prior to the withdrawal of the consent.

‍

‍

‍

‍

‍

Defense or Establishment of Litigation, Administrative or Other Legal Proceedings‍

‍

‍

Personal Data

• Name
• Surname
• Address (Street name and number, ZIP Code, City, Country)
• Phone number
• Email address
• Gender
• Birth date
• IP address
• Any other information Europos tabakas may process about you based on this Privacy Policy.

‍

‍

Purpose of Processing

‍

In the event of initiation of litigation, administrative or other legal proceedings, by third party (which might also be you), we will process relevant Personal Data for the defense of legal claims aimed toward Europos tabakas (or in other role as applicable in relevant case). We might also process Personal Data in the event Europos tabakas wishes to initiate litigation, administration and other legal proceedings toward third party.  

‍

‍

Legal Ground

‍

Europos tabakas will process your Personal Data based on legitimate interest in order to either establish the claims toward third party or defend the claims aimed to Europos tabakas, taking into account the circumstances of the relevant case.

‍

‍

Period of Processing

‍

Personal Data used for this purpose will be processed at least until the final judgement/proceeding and for 1 year after the expiry of the finalization of the relevant judgement/proceeding.

‍

‍

‍

‍

‍

Online Registration Management

‍

‍

Personal Data

• Name
• Surname
• Address
• Phone number
• E-mail address
• Gender
• Birth date
• Consent information
• Password

‍

‍

Purpose of processing

‍

Personal Data processed for this purpose is used for enabling access to registered uses, which enables Personal Data and consent. In addition, Personal Data is used for resetting the password.

‍

‍

Legal Ground

‍

Consent

‍

‍

Period of processing

‍

Personal Data processed for this purpose until the individual does not request the  deletion of his/her account or Personal Data.

‍

‍

‍

‍

‍

Online Advertising (Google)

‍

‍

Personal Data

• Personal Data

‍

‍

Purpose of processing

‍

We display our advertisements with Google, in the following ways:

• By  selecting demographic characteristics of individuals (e.g. detailed  demographics, affinity segments, life events, in- market segments, custom  segments), or
• By  targeting those, who have interacted with Europos tabakas:
  
  • Website Visitors: the data is collected via  Cookie and transferred to Google
    
  • Customers & Contacts: the data (e-mail)  is submitted to Google. When (if) you are signed into Google, the ads across  different Google products may be shown to you.
• By  deciding that we wish to target individuals who are similar than our data  segments. Those individuals are selected by Google, and we do not directly receive any Personal Data about the targeted individuals.

Personal Data shared with Google for this  purpose is used for advertising also based on their Privacy Notice, which you  can find Privacy Policy – Privacy  & Terms – Google.

‍

‍

Legal Ground

‍

Personal Data is processed based on Legitimate Interest of promoting our products, offers, brands and other  advertising communication with you.

You can object to such processing at any time by sending us an e-mail to EMAIL  or by adjusting the settings on Google related to Ad Personalization on the following link: Ad Settings (google.com)

‍

‍

Period of processing

‍

Personal Data for this purpose is processed  for each advertising campaign individually.

‍

‍

‍

‍

‍

Online Advertising (Facebook)

‍

‍

Personal Data

• Email address

‍

‍

Purpose of processing

‍

For  the purposes of advertising, we are using Facebook Advertising  functionalities, namely:

• Core  audience: we do not process any Personal Data, however we define the criteria  (such as age, interest, geography and others) to instruct Facebook that  individuals which fall under this criteria should be targeted with  advertising we prepare. Europos tabakas does not receive any information from  you, except if you provide it to us related to other purpose (e.g. purchase a  product from our website or otherwise)
• Custom  audiences: we submit to Facebook an e-mail address of our Customers or  Contacts and Facebook checks whether they have a user with this e-mail  address who has a Facebook account and if they have a legal ground to target  such individual. If you there is no Facebook account, nothing happens with  your e-mail, otherwise you are being targeted with the advertising, we have  prepared for that specific campaign.
• Lookalike audiences: We order Facebook to target Facebook users which are similar/have similar interest than the users included in one of our previous campaigns.

Facebook Advertising is also done based on the Privacy Policy of Facebook, which you can find on: Facebook

‍

‍

Legal Ground

‍

Personal  Data is processed based on Legitimate Interest of promoting our products,  offers, brands and other advertising communication with you.

You  can object to such processing at any time by sending us an e-mail to EMAIL or by adjusting  the settings in Facebook about which ads you see: About the Ads You See From  Facebook.

‍

‍

Period of processing

‍

Personal Data for this purpose is processed for each advertising campaign individually.

‍

‍

‍

‍

‍

Website Chat Communication

‍

‍

Personal Data

• Data you  might disclose

‍

‍

Purpose of processing

‍

On  our websites we have possibilities to chat (communicate) with you. During the  conversation you might disclose certain information that is considered as  Personal Data. We will process this information in order to interact with you  and (if needed) to proceed with further steps related to the communication  (e.g. Return Management).

‍

‍

Legal Ground

‍

Personal Data is processed based on your voluntary will to provide information.

‍

‍

Period of processing

‍

Personal Data is processed during the period of your conversation, but might be stored  for longer periods.

‍

‍

‍

‍

‍

Management of Social Media Sites (Facebook, Instagram)

‍

‍

Personal Data

• Publicly  available information your share with the social media providers

‍

‍

Purpose of processing

‍

Europos tabakas has pages on Facebook and Instagram. By liking/following the page or  interacting with the posts, we process certain Personal Data you publicly  share on Facebook or Instagram and we process this Personal Data for the  purpose of interaction on the social media and analytics related to the usage  of the social media sites.

Facebook  and Instagram are processing Personal Data based on their Privacy policies.

‍

‍

Legal Ground

‍

Consent, which you give by liking/following the page and which you can at any time  “unlike” or “unfollow”

‍

‍

Period of processing

‍

Until  we have your consent for processing of the data.

‍

‍

‍

‍

‍

‍

Log Records for Security Purpose

‍

‍

Personal Data

• IP address
• Information about browser version

‍

‍

Purpose of processing

‍

The  purpose of log records is to ensure the security of network and information  (to enable detection and prevention of unauthorized accesses which may  compromise the accessibility, integrity and confidentiality of Personal Data  stored or transferred and the security of related services accessible through  those networks and systems.

‍

‍

Legal Ground

‍

This  purpose is stored in order to protect the interest of individuals/visitors of  the websites.

‍

‍

Period of processing

‍

Until  the purpose of processing is achieved, but not longer than one year.

‍

‍

‍

‍

‍

Analytics

‍

‍

Personal Data

• Data we have collected  from you

‍

‍

Purpose of processing

‍

Europos  tabakas is processing Personal Data obtained from you when visiting the  website or otherwise communicating with us for analytic purposes for various  types of analysis intended to improve our strategy and business operations,  and which may include (but are not limited to):

• Verification of  accuracy of data in the systems of Europos tabakas
• Monitoring responses  of outgoing communications to adjust investments and advertising
• Other analytics  purposes.

 The Personal  Data used for this purpose is  in majority cases pseudomized or anonymized.

‍

‍

Legal Ground

‍

Legitimate interest of the Controller in order to improve the strategy and optimize  business operations.

‍

‍

Period of processing

‍

Until the Personal Data is processed by Europos tabakas.

‍

‍

‍

‍

‍

Exercise of Your Personal Data Rights

‍

‍

Personal Data

• All  Personal Data we process about you

‍

‍

Purpose of processing

‍

If  you wish to exercise your Personal Data Rights (see relevant section) we  process this Personal Data in order to enable you the exercise of this  Personal Data rights and to keep the documentation about the processing of  Personal Data for this Purpose.

‍

‍

Legal Ground

‍

Based on legal obligation.

‍

‍

Period of processing

‍

Until  the purpose of processing is achieved, but not longer than one year.

‍

‍

‍

‍

‍

Cookies & tracking technologies

‍

Europos tabakas may collect certain data via cookies. You can read what are the cookies, which type of cookies Europos tabakas uses and their description and for what purposes in our Cookie Policy link.

‍

‍

‍

‍

‍

Recipients of Personal Data and transfer to third countries

‍

Europos tabakas will not share or sell your Personal Data. However in certain cases, Europos tabakas will disclose your Personal Data to the:

• ‍Processors: Companies which are providing certain services for Europos tabakas, as a processors of Personal Data (acting on behalf and subject to documented instructions of Europos tabakas), which may include:
  
  • IT service& maintenance providers
  • Providers of cloud services, online platforms and other IT Systems (e.g. for sending e-mails, SMS etc.)
  • Accounting,legal, tax or other advising
  • Logistic service providers
  • Companies providing online advertising (e.g. Google, Facebook)‍
• Auditors and Shareholders: In the event of commercial, compliance, official or other Due Diligence of the Share holders of Europos tabakas, your Personal Data might be available to the Shareholders.‍
• Applicable Authorities: in the event of any legal, administrative or other proceedings, Europos tabakas will submit your Personal Data to the applicable authority (if requested or required by applicable legislation).

In the event any of the processing of your Personal Data will be processed outside of European Union or your Personal Data will be transferred out of the European Union or to international organization, Europos tabakas will adopt appropriate safeguards required to protect your Personal Data, namely:

• Transfer or processing of your Personal Data only in countries which offer adequate protection of Personal Data
• Conclusion of Standard Contractual Clauses (SCC), as adopted by European Commission.

‍

‍

‍

‍

‍

Security of your Personal Data

‍

Europos tabakas is implementing appropriate technical and organizational measures with the intention to protect your Personal Data in accordance with internal policiesand best practices to avoid loss, destruction, unauthorized access or use of your Personal Data.

‍

‍

‍

‍

‍

Processing Personal Data of Minors

‍

Europos tabakas does not process or collect Personal Data of minors for the purpose of providing information society services.

‍

‍

‍

‍

‍

Your rights

‍

Applicable legislation provides you certain rights in relation to your Personal Data. You can exercise all of your rights by contacting us via e-mail on E-MAIL or by calling to NUMBER.

We will reply to you as soon as possible, but not later than within 30 days after the receipt of the request. In the event the request cannot be processed within this period, we will inform you about this and provide you additional information.

‍

‍

Right to withdraw consent

‍

If we process Personal Data based on your consent, you have the right to, at anytime, withdraw your consent. This will not affect the lawful processing of your Personal Data for relevant purpose processed prior your consent has been withdrawn.

‍

‍

Right of access

‍

You have the right to obtain from us the confirmation as to whether or not your Personal Data is being processed, and where this is the case, to obtain access to your Personal Data and the following information:

• Purposes of processing
• Categories of Personal Data concerned
• Recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations and information about adopted safeguards related to such transfer
• Where possible, the envisaged period for which the Personal Data will be stored, or where this is not possible, the criteria used to determine that period
• Existence of the right to request rectification or erasure, restriction of processing or to object to the processing of your Personal Data
• Right to lodge complaint with a supervisory authority
• If the information is not collected from you, the information about the source
• Existence of automated decision making, including profiling, which have legal or similar consequences on you.

‍

‍

Right to rectification

‍

You have the right to request rectification of inaccurate Personal Data or to request the completion of incomplete Personal Data.

‍

‍

Right of erasure / Right to be forgotten

‍

You have the right to request from Europos tabakas to delete your Personal Data if the following applies:

• Personal Data is no longer necessary in relation to the purposes for which it was collected or processed,
• You withdraw consent on which processing is based and there is no other legal ground for processing
• You object to the processing and there are no overriding legitimate grounds for the processing,
• Personal Data have been unlawfully processed,
• Personal Data needs to be erased for compliance with legal obligation of European Union or applicable national law,
• The personal data have been collected in relation to the offer of information society services of minors.

Europos tabankas will not erase your Personal Data, in the event:

• It is required by legal obligation based on European Union law or applicable national legislation
• It is necessary for establishment, exercise or defense of legal claims.

‍

‍

Right to restriction of processing

‍

You can restrict the processing of your Personal Data in the event:

• You contest the accuracy of processing. Restriction of processing applies during the period until we verify the accuracy of your Personal Data,
• If we determine the processing is unlawful and you object erasure of the Personal Data and request the restriction of their use,
• We do not need your Personal Data for the purposes of processing, but you require them for establishment, exercise or defense of legal claims,
• You object to the processing pending verification whether the legitimate grounds override yours.

Where the processing has been restricted, we will, with the exception of storage, process your Personal Data only based on your consent or for the establishment, exercise or defense of legal claims.

In the event the restriction of processing is lifted, we will inform you about this beforehand.

‍

‍

Right to data portability

‍

You have the right to receive Personal Data concerning you, in a structured, commonly used and machine readable format and have the right to transmit this Personal Data to another controller, if:

• The processing is based on consent or on contract, or
• The processing is carried out by automated means.

‍

‍

Right to object

‍

You have the right to object to the processing of your Personal Data, if your Personal Data is processed based on legitimate interest. We will not process your Personal Data further for this purpose unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of you or if needed for establishment, exercise or defense of legal claims.

You have the right to,at any time, object to the use of your Personal Data for direct marketing purposes, which includes profiling and your Personal Data will no longer be processed for this purpose.

‍

‍

Right to lodge complaint to supervisory authority

‍

You have the right to lodge complaint with a Supervisory Authority- State Data Protection Inspectorate (more information - https://vdai.lrv.lt/), if you think your Personal Data is not processed in accordance with applicable legislation.

Validity of Privacy Policy

This Privacy Policy is valid from the date on which it is published. Any changes of Privacy Policy will be published on this website.

Panevėžys, Lithuania

DATE: August 22, 2025

UAB “Europos tabakas”

‍

‍

‍

‍

‍