GENERAL PROVISIONS
Data Controller Frontu, UAB, legal entity registration number 304891896, registered office address: Aronijų g. 20-2, Kaunas region municipality, Užliedžiai subdistrict, Giraitė village, Republic of Lithuania, respects the privacy of visitors of the Website, the Company’s customers, partners/suppliers and/or their representatives and other persons who either provide Personal Data to the Company or the Company receives Personal Data having a legitimate basis for receiving and process such data, including also from the third parties (hereinafter referred to as “you” or “your“).
The present Privacy Policy describes the principles of information collection, use or other processing applied on the Website managed by us, as well as other information about the Personal Data processed by the Company in its activities, policies and principles applied to ensure the protection of Personal Data. Please note that additional and/or more detailed information about how we process your Personal Data may be included in contracts and other information and documents provided by the Company (for example, consent forms).
By using the Website and/or providing us with Personal Data (except where we are required to obtain your express consent under applicable legislation), you agree that the Personal Data you provide to the Company will be processed in accordance with the present Privacy Policy.
The provision of your Personal Data in the cases indicated on the Website or in other cases requested by the Company is usually voluntary, but is necessary in order for us to be able, for example, to respond to your inquiries, to provide conditions for trying our services, to carry out transactions concluded with you or the person you represent, etc.
The Data Controller has the right to process Personal Data in other cases and for other purposes not discussed in the present Privacy Policy, but in any case, you will be informed about the processing of your Personal Data in accordance with the procedure established by law.
You are requested to inform your current or future representatives (persons who represent you in relations with us, if you are, for example, our customer or supplier), as well as any other persons to whom this information may be relevant because you provide their Personal Data to us.
CONCEPTS
Capitalized terms and expressions used in the Privacy Policy have the following meanings:
- Personal Data means any information about you as an identified or identifiable natural person (Data Subject); an identifiable natural person is a person whose identity can be determined directly (by an identifier such as a name and surname, an Internet identifier) or indirectly (by one or more features of that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity);
- GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
- Data Controller or the Company or we, or us, or our means Frontu, UAB, legal entity registration number 304891896, registered office address: Aronijų g. 20-2, Kaunas region municipality, Užliedžiai subdistrict, Giraitė village, Republic of Lithuania;
- You or Your means any person, including the one who visits the Website and uses its functionalities (for example, submits an inquiry) or is a customer, partner/supplier of the Company and/or their representative, and either provides Personal data to the Company or the Company receives Personal Data having a legitimate basis for receiving and process such data, including also from the third parties;
- Privacy Policy means the principles, rules and requirements presented by the Company, which determine the procedure for the collection, storage, use and other processing of information related to the use of the Website and its functionalities, as well as processed in other activities of the Company, including the Personal Data, and other relevant provisions;
- Cookies means small files sent to your browser and stored on your computer, phone or other device that you use to connect to the Website, as well as other technologies, including pixels;
- Direct marketing means activities aimed at offering goods or services to individuals by mail, telephone or other direct means and/or asking for their opinion on the offered goods or services;
- Website means a web page accessible from the web address at https://frontu.com/, which is managed by the Company.
ACCESS TO THE WEBSITE
Every time you visit the Website, the Website servers temporarily save information about the connecting device in the login file. During this procedure, regardless of your actions, the following data is automatically collected and stored until it is automatically and/or manually deleted, i.e. date and time of login, information about the browser you use and its version, device type, as well as others technical data. This information is collected and processed so that you can use our Website, to guarantee the ongoing security and stability of the system, to enable the technical administration of the network infrastructure and for internal statistical purposes.
PURPOSES OF PROCESSING OF PERSONAL DATA, SOURCE OF DATA, CATEGORIES OF ENTITIES, OTHER INFORMATION RELATED TO THE PROCESSING OF YOUR PERSONAL DATA
In order to ensure transparency and responsible processing of Personal Data, we inform you that the Company processes your Personal Data for the following purposes and under the following conditions:
Management of Available Material and Financial Resources
In order to ensure our independent functioning and manage the available financial and material resources, including the management of the Company’s accounts, issuing invoices to customers, accounting for incoming invoices, we process Personal Data of the customers or partners/suppliers and their representatives/employees.
| Personal Data processed | The customer’s or supplier’s/partner’s name, surname, address, details about the individual activity, VAT registration number (if applicable), information about the amounts receivable/payable, and where the customer/supplier/partner (a natural person or a legal entity) is represented by a representative/employee – the representative’s/employee’s name, surname, e-mail address and/or telephone number, position. |
| Legal basis for the processing of Personal Data | The customer’s or supplier’s/partner’s Personal Data are processed in order to perform the contract to which the customer or the supplier/partner is a party, as well as to comply with the legal obligation to ensure the proper management of accounts, which is applicable to the Company, and in the event of the processing of Personal Data of the representative/employee of the Company’s customer or supplier/partner, the legitimate interest of the Company is to perform the contractual obligations with the customer or supplier/partner and to contact with the representative/employee for accounting purposes. |
| Period of retention of Personal Data | 10 (ten) years from the relevant accounting transaction, and in the event of the processing of Personal Data of the representative/employee of the Company’s customer or supplier/partner – 10 (ten) years from the proper execution of the contract. |
| Source of Personal Data | Personal Data of the customer or supplier/partner is received from the Data Subject and in the event of the processing of Personal Data of the representative/employee of the Company’s customer or supplier/partner, they may be received from the employer of the representative or any other person being represented (the Company’s customer, partner/supplier). |
Conclusion and Performance of Contracts
In order to conclude and properly execute the contracts we have concluded with our clients, partners/suppliers, including to keep record of the transactions entered into, to control their performance and payments, to collect debts, we may process the Personal Data of customers or partners/suppliers and their representatives/employees.
| Personal Data processed | The customer’s or supplier’s/partner’s name, surname, address, telephone number, e-mail address, amounts, date and basis of emergence of the debt/partial payments, date of birth or personal identification number, other information related to the performance of contractual obligations, and in the event the customer/supplier/partner (a natural person or a legal entity) is represented by a representative/employee, the representative’s/employee’s name, surname, telephone number, e-mail address, position. |
| Legal basis for the processing of Personal Data | The customer’s or supplier’s/partner’s Personal Data are processed in order to perform the contract to which the customer or the supplier/partner is a party, and in the event of the processing of Personal Data of the representative/employee of the Company’s customer or supplier/partner, the legitimate interest of the Company is to identify the representative and to perform the contractual obligations with the customer or supplier/partner. |
| Period of retention of Personal Data | 10 (ten) years from the end of the use of the service (deletion of the account and/or expiry of the validity term of the contract). |
| Source of Personal Data | Personal Data of the customer or supplier/partner is received from the Data Subject and in the event of the processing of Personal Data of the representative/employee of the Company’s customer or supplier/partner, they may be received from the employer of the representative or any other person being represented (the Company’s customer, partner/supplier). |
Administration of, including provision of answers to, inquiries (including the inquiries to become our partner), requests (including the requests to test our services (Demo)) or complaints made using the Company’s contact details (including the e-mail) or the functionalities available on the Website
In order to enable you to enter into contracts with the Company and in order to enable you to submit your inquiries, requests or complaints using the means available on the Website (for example, inquiry/contact details/becoming a partner forms), and the contact details of the Company (for example, the e-mail address specified in the Website or in the present Privacy Policy), as well as for us to be able to provide answers to your inquiries, requests or complaints, we may process your Personal Data as the person who has submitrted an inquiry/request/complaint.
Direct Marketing and Promotion of the Company’s Products, Solutions, etc.
In cases where we receive your separate consent for Direct Marketing or have another legal basis, we may process your Personal Data in order to offer you the Company’s goods or services (products, tools) and/or ask for your opinion on the offered goods or services.
Your consent to the processing of Personal Data for Direct Marketing purposes is obtained in advance, i.e. before the start of the processing of Personal Data for Direct Marketing purposes.
You are given the possibility to object to the processing of Personal Data for the purposes of Direct Marketing and/or to withdraw your consent to the processing of Personal Data for this purpose at any time.
| Personal Data processed | Name, surname, telephone number and/or e-mail address, data about the company being represented, other Personal Data provided by you in the course of communication. |
| Legal basis for the processing of Personal Data | Personal Data are processed on the basis of the consent given by the Data Subject. |
| Period of retention of Personal Data | 3 (three) years from the date of receipt of the consent or any other term specified in the consent given by the Data Subject. |
| Source of Personal Data | Personal Data is received from the Data Subject. |
Right to Object
You are given the possibility to object to the processing of Personal Data for Direct Marketing purposes and/or to withdraw your consent regarding the processing of Personal Data for this purpose (withdrawal of the consent will not affect the legality of the consent-based processing of Personal Data carried out by us prior to the withdrawal of the consent). Your waiver or objection will not prevent you from using the services provided by the Company, but the Company will no longer be able to provide you with useful offers, information, etc.
You can withdraw your consent or exercise your right of objections by informing the specific representative of the Company with whom you communicate by telephone, by using the functionalities provided in the e-mail messages, which allow you to waive notifications, as well as by contacting the Company at the e-mail address specified below in the present Privacy Policy.
COOKIES
General Provisions on Cookies and Their Use on the Website
We use cookies on the Website to ensure the proper functioning of the Website, smooth use of the Website, as well as for statistics on Website traffic, improvement of the user experience and for other purposes listed below.
Cookies can be session cookies, which are used only while you browse the Internet and are automatically deleted when you close the browser, persistent cookies, i.e. those that are stored on your terminal device (computer, tablet, smartphone, etc.) until the expiry of the cookie usage time or you opt out of the cookie using one of the methods described in the present Privacy Policy, or third-party cookies, i.e. those that are used by a person who is not the manager of the Website.
When you visit the Website, a pop-up message is displayed with a link to the present Privacy Policy, which informs you about the use of Cookies on the Website. By making the appropriate selections in the pop-up message, you express your consent for the Company to store the relevant selected Cookies (according to their type), which are described in more detail below in the present Privacy Policy, on your terminal device (computer, tablet, smartphone, etc.). You have the right to choose and consent for the use of all or certain types of Cookies.
Regardless of your choice, i.e. if you continue browsing the Website, strictly necessary (essential) Cookies will be recorded in any case.
Please note that Cookies can also be used by the Company’s partners or other third parties, which are not under the control of the Website Manager. The Company cannot and is not responsible for the actions of such persons. If you suspect that the Company’s partners or other third parties who are not under the control of the Website Manager are using Cookies without your consent, you should contact that partner or other third party.
Refusal of Cookies
If you do not want or do not consent to the storage of Cookies on your computer or other terminal device, you may refuse to take the appropriate steps to express your consent, and you can always opt out of the relevant or all Cookies using the instructions below.
You can uninstall Cookies in the following ways:
- you can waive or withdraw your express consent for the use of the relevant or all Cookies at any time [here].
- − in your browser, you can view the Cookies already installed on your computer and delete them one by one or all at once. The steps to follow vary (you can find instructions on Cookies for the most popular browsers by clicking on the browser name Opera, Firefox, Chrome, Safari, Internet Explorer), therefore, the specific actions that need to be performed should be determined taking into account the browser you use;
- in addition, you can set your internet browser to block Cookies or to receive a warning about the installation of any Cookie. The steps to be taken are different for each browser, therefore the specific actions that need to be taken should be determined taking into account the browser you use.
Types and List of Cookies Used on the Website[3] [4]
The types of Cookies, which are used by us on the Website, are listed in the table below. We will use all Cookies, except the strictly necessary Cookies, only after obtaining your separate consent.
Strictly necessary cookies (they are necessary for the Website visitor to be able to use the possibilities offered by the Website and to be identified, and they are necessary to ensure the functioning of the Website and electronic services. These Cookies are always active and do not require consent).
| Name | Purpose and data used | Duration | User |
| _hjIncludedInPageviewSample | This cookie is used to let Hotjar know if this visitor is included in the data sample defined by the page view limit of the website. | 2 minutes | frontu.com |
| _cf_bm | This cookie is used to distinguish between humans and robots. This is useful for the website to provide correct reports on its usage. | 30 minutes | pipedrive.com |
| _hjFirstSeen | The cookie is set so that Hotjar can determine the start of the user’s visit to the website and count the total session time. It does not contain any identifying information. | 30 minutes | frontu.com |
| _hjAbsoluteSessionInProgress | The cookie is set so that Hotjar can determine the start of the user’s visit to the website and count the total session time. It does not contain any identifying information. | 30 minutes | frontu.com |
| _hjIncludedInSessionSample | This cookie is set to let Hotjar know if the visitor is included in the data sample defined by the daily session limit of the website. | 2 minutes | frontu.com |
Analytical (they are used for the monitoring, accumulation and analysis of statistical (anonymous) data about the number of users who visited the Website, their origin, and the use of electronic services, and help improve the Website’s performance)
| Name | Purpose and data used | Duration | User |
| _ga | This cookie is used to distinguish unique users by assigning a randomly generated number as a customer identifier. It is included in each website page request and is used to calculate visitor, session and campaign data in website analytics reports. | 2 years | frontu.com |
| _gid | This cookie is set by Google Analytics. It stores and updates the unique value of each page visited and is used to count and track page views. | 1 day | frontu.com |
| _gat_UA-2873316-12 | This is a pattern-type cookie set by Google Analytics that contains a unique identification number of the account or website to which it is associated in the name pattern element. This is a variant of the _gat cookie, which is used to limit the amount of data Google records on high-traffic sites. | 1 minute | frontu.com |
| _ga_35WLHLEDWS | This cookie is used by Google Analytics to save the session state. | 2 years | frontu.com |
Advertising (they are used to collect information about how users who visit the Website use the website, to present offers (advertisements) that best meet the needs of users)
| Name | Purpose and data used | Duration User | User |
| IDE | This cookie is set by Doubleclick and provides information about how the end user uses the website and any advertising that the end user may have seen before visiting said website. | 1 year | .doubleclick.net |
| test_cookie | This cookie is set by DoubleClick (owned by Google) to determine whether the website visitor’s browser supports cookies. | 15 minutes | .doubleclick.net |
| _lfa | The Leadfeeder cookie collects behavioral data of all website visitors. This includes the pages viewed, the source of the visitor and the time spent on the website. | 2 years | frontu.com |
An alternative way to disable Google Analytics is to install a small plugin offered by Google, which you can find here. For more information about Google Analytics, click here.
STORAGE OF PERSONAL DATA
The Company will process your Personal Data to the extent specified in the present Privacy Policy above.
Please note that in certain cases, a longer period of storage of Personal Data or the right for us to store Personal Data for a longer period may be determined by legal acts, for example, in cases where it is necessary to process Personal Data in order to comply with the requirements of legal acts applicable to the Company, which require the processing of Personal Data, or when the processing of Personal Data is necessary in order to assert, execute or defend legal claims.
In such a case, we can process your Personal Data for a longer period of time, but only for as long as is necessary for the purposes for which we are processing Personal Data. Such Personal Data will be destroyed immediately when no longer needed.
DISCLOSURE OF PERSONAL DATA
We can disclose your Personal Data only if there is a legal basis (for example, when it is required by legal acts or a contract concluded with you, or when we have your separate consent) and in compliance with the requirements of applicable legal acts.
In addition to the cases already mentioned in the present Privacy Policy, you are informed that we may provide your Personal Data:
- to service providers acting as the Company’s Personal Data Processors and providing the Company with services related to IT, Website support and maintenance, maintenance of applications used by the Company, provision and maintenance of servers, etc.;
- to a company providing accounting services;
- in the cases provided for in legal acts, to law enforcement and supervision authorities, as well as to other state and municipal institutions in compliance with the requirements of legal acts, including the State Tax Inspectorate;
- to bailiffs, courts, other authorities engaged in the handling of disputes;
- to other third parties when you submit a corresponding request to provide your Personal Data, or to third parties about whom you are clearly notified in any other way and/or your consent is obtained and the provision of information is agreed upon when using a specific service;
- to the companies providing audit and related services to the Company, to legal and financial consulting service providers;
- to other business entities, in the event of a merger of the Company with or acquisition of the Company by another legal entity, including to the persons performing legal checks.
TRANSFER OF PERSONAL DATA OUTSIDE THE EEA
In cases where the Company transfers Personal Data outside the European Economic Area (for example, by using a relevant data processor), the Company ensures the adequate protection of Personal Data and compliance of such transfer with the GDPR requirements. In this case, the Company transfers Personal Data to countries in respect of which the European Commission has adopted a decision on suitability, or ensures and implements an adequate level of protection of Personal Data through standard contractual terms and conditions, other documents or measures in accordance with the GDPR.
RIGHTS YOU HAVE AS PERSONAL DATA SUBJECTS AND IMPLEMENTATION OF SUCH RIGHTS
As a Personal Data Subject, you have all the rights provided for in the applicable legal acts, including the the following rights:
Right to withdraw consent
If you have given us your consent for the processing of your Personal Data, you can withdraw it at any time (withdrawal of consent will not affect the legality of consent-based processing of Personal Data carried out before the withdrawal of consent) by contacting us by the contact details indicated in the present Privacy Policy or by using other functionalities provided by the Company (for example, by informing of your objection the representative of the Company with whom you are speaking on telephone, or by informing by the e-mail from which the offer was sent).
The right to request access to your Personal Data
You can familiarize yourself with your Personal Data, which are processed by the Company. You can receive information about how such data are collected, how long your data are stored and who and to what extent receives data about you. However, your right to access may be limited by legal acts.
The right to demand rectification of personal data
You may request that the Company correct the Personal Data processed in relation to you if it is incorrect, inaccurate or incomplete.
Right to object
In certain circumstances, you have the right to object to the processing of your Personal Data, including when your Personal Data are processed based on a legitimate interest. You also have the right to object to us using your Personal Data for Direct Marketing purposes (only when and if we process the data for these purposes).
The right to request restriction of the processing of Personal Data
If you believe that your Personal Data processed by the Company are incorrect or you have not consented to the use of the data, you may request that the Company limit the use of your data to storage only. Use will be limited to storage only until the data are correct or the legitimate interests of the Company outweigh your interests.
The right to request erasure of Personal Data.
If your Personal Data are processed illegally, you do not agree to such processing of your Personal Data or there are other legal grounds, you have the right to request that the data be erased in compliance with the restrictions provided for in the legislation.
Right to data portability
You have the right to receive the Personal Data relating to you, which you have provided to the Company, in a structured, commonly used and computer-readable format, and the right to request the transfer of such data to another data controller in accordance with the procedure laid down in legal acts.
Right to lodge a complaint
You also have the right to lodge a complaint with the State Data Protection Authority if you believe that the processing of Personal Data relating to you is carried out in violation of the requirements of legal acts. However, we always ask you to contact us first using the contact details listed in the present Privacy Policy.
Procedure of Exercising the Data Subject’s Rights
If you have any additional questions or wish to exercise your rights related to the processing of Personal Data and specified in the Privacy Policy, you should contact us by the contact details specified in the present Privacy Policy (by e-mail, by post (using the specified address), or by physically coming to the Company’s actual office the address whereof is indicated at the bottom of the Privacy Policy).
When submitting requests for the exercise of the rights related to the processing of Personal Data, you will need to confirm your identity (for example, when submitting a request through the electronic means, you must sign it with an electronic signature, and when contacting the Company by physically coming/sending a request by mail, you will need to provide a document confirming your personal identity or a copy of such document certified in accordance with the procedure laid down in legal acts).
We will only accept those requests for the exercise of the Data Subject’s rights, which will be completed/submitted in the state language (Lithuanian) that is coherent and comprehensible, in legible characters, the request will not contain any offensive or disrespectful wordings, it will clearly and specifically indicate which right(s) is/are intended to be exercised and presents the circumstances related to the exercise of the right.
We will consider the request to exercise the right(s) of the data subject as unfounded and we may refuse to implement it in cases where it does not specify which right(s) is/are intended to be exercised, as well as where it does not contain other necessary information required by the Privacy Policy or the GDPR. We may also refuse to implement your request if we do not process your Personal Data, if the appropriate documents for identifying you (or your representative) are not submitted together with the request, if the person who submitted the request is not properly authorized or does not have the right to submit the request (the power of attorney or any other document giving the right to represent you has not been submitted) or if legal acts do not provide for the possibility of satisfying your request.
Please note that in cases where you abuse the right on the basis of the request submitted by, we have the right to demand compensation for the implementation of the request.
We will respond to all your requests related to the exercise of the rights held by you as a Personal Data Subject without undue delay, but no later than within 1 (one) month from the date of receipt of the request. This term can be extended by additional 2 (two) months by notifying you in advance.
PROTECTION OF INFORMATION
We use reasonable technical and organizational measures to protect the information in our possession (including Personal Data) against accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access.
THIRD PARTIES
The Company does not control the privacy policies and/or any other rules applied to you by third parties. You are solely responsible, at your own discretion and risk, for and undertake to comply with them in cases where they apply to you (for example, when the Website contains links to websites not controlled by the Company). The Company is not responsible for the privacy policies or any other contents of other websites when the Website or other functionalities contain links to other websites or when they contain links to the Website. Please note that clicking on a link, logo or any other element of the Website or any other functionality, or using the services available on the Website or any other functionality, may take you outside the Website or other functionalities.
AMENDMENTS OF THE PRIVACY POLICY
The Company reserves the right to amend (including change, edit, supplement, revoke, cancel) the present Privacy Policy or any part thereof and any information relating thereot at its sole discretion.
The updated Privacy Policy will be published on the Website and will take effect from the date of its publication (reference “Effective from” at the bottom of the Privacy Policy indicates when the Privacy Policy was last updated).
We recommend that you check the Privacy Policy and its updates when visiting the Website or other functionality and make sure that you are satisfied with the current version of the Privacy Policy. If you use the Website or other functionality after the publication of the updated Privacy Policy, you agree to the currently applicable Privacy Policy.
FINAL PROVISIONS AND CONTACT DETAILS
The present Privacy Policy is governed by the law of the Republic of Lithuania.
Any disagreements regarding the implementation of the present Privacy Policy shall be resolved through negotiations. In the avent of failure to reach any agreement, disagreements shall be resolved in accordance with the procedure laid down by the laws of the Republic of Lithuania.
If you have any questions, claims or you need our assistance regarding the interpretation or application of the Privacy Policy, as well as if you wish to exercise the rights held by you as a Personal Data Subject, please contact the Company at the following contact details:
E-mai address: info@frontu.com
Tel. No.: +370 676 10015
Address: Aronijų g. 20-2, Kauno r. sav., Užliedžių sen., Giraitės k, Republic of Lithuania.
We will make every effort to respond to all your inquiries related to the present Privacy Policy and submitted in writing immediately (we will respond to any requests you may have in relation to the exercise of the rights held by you as a Personal Data Subject no later than within 1 (one) month from the date of receipt of the request, except for the cases specified in the legal acts or the present Policy).
Effective from 24/05/2023.