Newsletter Data Protection Information Notice
The subscriber (hereinafter referred to as the “Subscriber”) to digital newsletters (hereinafter referred to as “Newsletter”) distributed by UAB “Biomapas” (registered office at Savanoriu Ave. 109, Kaunas, Lithuania, legal entity code 135750888 (hereinafter referred to as “Biomapas”)), and/or Biomapas group affiliate company (all together referred to as the “Biomapas Group”) may provide to Biomapas Group his/her personal data. The Biomapas (upon request by Biomapas – Biomapas Group and/or Biomapas Group service provider) will collect, process, and use personal data relating to the Subscriber as defined below.
The purpose of this Newsletter Data Protection Information Notice (hereinafter – the “Notice”) is to inform the Subscriber about data processing purposes, data processing and transfer procedures within and outside the Biomapas Group and is without prejudice to applicable local data protection/privacy laws which prevail over this Notice. It supplements – but does not replace and is without prejudice to – any specific local notices, policies or procedures that may have been distributed to or agreed on by the Subscriber, if any, or that may be implemented in the future.
This Notice supplements global and local data protection policies, notices, or guidance (hereinafter – “Additional Policies“) of Biomapas and/or Biomapas Group, which set out the principles that apply to the use of personal data throughout Biomapas. Wherever such Additional Policies are in any respect inconsistent with this Notice, this Notice shall only apply to the extent that it is consistent, or may be made consistent, with that Additional Policy.
The Data Protection Officer. The Data Protection Officer contacts: email: firstname.lastname@example.org; address: Savanoriu ave. 109, Kaunas, Lithuania. Any queries in relation to Subscriber’s personal data or enforcement of any of the below-mentioned Subscriber’s rights shall be addressed to the Data Protection Officer via email as described in Section 4 of this Notice.
2. COLLECTION, PROCESSING AND USE OF SUBSCRIBER’S DATA
Biomapas Group is committed to protecting Subscriber’s personal data and to being transparent about the information Biomapas Group companies, including Biomapas, are collecting about the Subscriber and what they do with it.
Biomapas uses Subscriber’s personal data so that the Subscriber could receive the Newsletter. Biomapas will process following personal data collected directly from the Subscriber:
name and last name;
contact details (e-mail address);
names of the employers;
occupation (job title);
interests in the services provided by Biomapas;
device information (information about the device and applications used to subscribe to and access the Newsletter, such as IP address, operating system, browser ID, and other information about system and connection);
usage data (usage data about interactions with the Newsletter, which may include dates and times the Newsletter is accessed and browsing activities (such as what pages are viewed and which emails are opened);
information regarding the performance of the Newsletter (metrics related to the deliverability of Newsletters).
Terms and conditions for data processing. Subscriber’s personal data may be collected, stored, maintained, including transferred, both digitally and in a material medium, by any means such as email and internet connection which are selected considering the nature of the data processed, to ensure safe handling, and prevent unauthorised access to personal data. Personal data might be stored in Biomapas’ IT or it’s contractors’ systems under secure conditions and with limited access. Subscriber’s personal data will not be used for an automated decision-making including profiling.
Purposes of collection, processing and use of Subscriber’s personal data. Biomapas uses the email address of the Subscriber to send the newsletter to the Subscriber. The additional personal data (name and last name, names of the employers, occupation (job title), interests in the services provided by Biomapas) the Subscriber has indicated may be used to provide the Subscriber with a more personalised experience (i.e. better targeting the content of the information). The usage data allows Biomapas to monitor and prevent abuse, and to ensure Biomapas attains certain usage standards and metrics in relation to the Newsletter. The information regarding the performance of the Newsletter allows Biomapas to improve the content and distribution of the Newsletter and facilitate research and perform analysis into the use and performance of the Newsletter.
Legal basis for Subscriber’s personal data processing. Biomapas will process the Subscriber’s personal data as he has expressed a wish to receive the Newsletter and has given consent to the processing of personal data for the purpose of receiving the Newsletter.
Personal data retention period. Biomapas only keeps the Subscriber’s personal data for the time necessary to fulfil the purpose of collection, namely until the Subscriber communicates his/her decision to unsubscribe from the Newsletter. The Subscriber can withdraw his/her consent to receive the Newsletter at any point by using the link included in the footer, at the bottom of each Newsletter sent to the Subscriber, or by contacting Biomapas directly.
3. TRANSFER OF PERSONAL DATA
Biomapas may transfer all or part of Subscriber’s personal data to Biomapas Group companies, any Biomapas contractor engaged in Newsletter preparation and distribution, and Biomapas vendor residing in the European Economic Area (“EEA”) and outside EEA. Only a limited number of individuals within Biomapas Group companies’ marketing, information technology or other departments as well as certain managers will receive access to the Subscriber’s personal data.
Biomapas Group may contract with third party service providers to facilitate the preparation and distribution of the Newsletter. Biomapas and any company of Biomapas Group will (i) diligently choose such third-party service providers, and (ii) ensure that such third-party service providers adopt adequate technical and organizational security measures to safeguard the Subscriber’s personal data, and use such personal data only as instructed by Biomapas and appropriate company of Biomapas Group, and for no other purposes.
In limited occasions, Biomapas and the Biomapas Group company may also need to make the personal data available to Biomapas Group professional advisors; potential or existing investors and acquirers; third parties and/or their advisors located inside or outside the EEA, including in countries which do not adduce the same level of protection of personal data as in the EEA.
Biomapas Group company will only carry out personal data transfers outside the EEA where it is confident that the level of protection applied to personal data will be similar as if it had remained within the EEA. In such case where personal data is transferred outside the EEA, we will apply proper protection measures (e.g., appropriate internal rules or Standard Contractual Clauses will apply) to ensure that personal data is adequately protected against unauthorized processing in such countries.
4. RIGHTS OF THE SUBSCRIBER
The Subscriber has a right to withdraw any of his/her consents for personal data processing (at any time, without affecting the lawfulness of processing before the consent given for data processing was withdrawn), to know (to be informed) about the processing of his/her personal data, to access personal data held about him/her and obtain a copy of personal data, to have inaccurate personal data corrected or to have personal data erased and to restrict or object to processing of personal data for legitimate reasons. The Subscriber has the right to data portability and to lodge a complaint with the State Data Protection Inspectorate as well as other competent authority in the country of Subscriber’s residence.
5. ACKNOWLEDGMENT OF NOTICE RECEIPT
BY SUBSCRIBING FOR THE NEWSLETTER DISTRIBUTED BY BIOMAPAS, YOU CONFIRM THAT YOU HAVE MADE YOURSELF ACQUAINTED WITH THIS NEWSLETTER DATA PROTECTION NOTICE, AND HAVE UNDERSTOOD IT, AND THAT YOU HAD THE OPPORTUNITY TO ASK BIOMAPAS ANY QUESTIONS ABOUT YOUR PERSONAL DATA AND THAT YOU HAVE RECEIVED ALL THE NEEDED ANSWERS IN DETAIL.