1.1.     This privacy policy (hereinafter – the Policy) regulates the main principles and rules regarding the collection, processing and storage of personal data carried out by UAB "DPD Lietuva", company code 111639299, address of registration: Terminalo g. 7, Biruliškių km., Kauno raj., address for correspondence: Liepkalnio g. 180, Vilnius (hereinafter - we), and terms of operation of the websites https://esiunta.dpd.lt/ (hereinafter – Esiunta Website) https://www.dpd.com/lt (hereinafter - DPD Website), hereinafter jointly referred to as the Websites, managed by us.

1.2.     We aim to ensure that the users of our services, visitors of the Websites, users of services provided on the Websites and other persons whose personal data we process, would entirely trust our services and would be informed in a transparent manner of how we process their data. In this Policy You shall find information on how we collect and use (or would like to collect and use) Your personal data.

1.3.     In our operations, we are guided by the following data processing principles:

1.3.1. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject (principle of lawfulness, fairness and transparency);

1.3.2. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (principle of purpose limitation);

1.3.3. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (principle of data minimisation);

1.3.4. Personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (principle of accuracy);

1.3.5. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required to safeguard the rights and freedoms of the data subject (principle of storage limitation);

1.3.6. Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (principle of integrity and confidentiality);

1.3.7. We are responsible for following, and be able to demonstrate compliance with, the abovementioned principles (principle of accountability).

1.4.     This Policy has been prepared in accordance to the Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (General Data Protection Regulation, hereinafter – the GDPR), the Act on Legal Protection of Personal Data of the Republic of Lithuania, other laws of the European Union and the Republic of Lithuania.

2.1.     By providing Your personal data, You agree to us processing it for purposes and by means and order laid out in the Policy and laws.

2.2.     It is very important that You read the Policy carefully, because when You visit the Websites and use our services, this Policy will be directly applicable to the collection, processing, and, in the cases provided for in the Policy, Your personal data to recipients.

2.3.     If You do not agree with this Policy and the processing of personal data described therein, please do not visit the Websites and / or use our services

2.4.     You are responsible for ensuring that the data You provide is precise, correct and detailed. Input of incorrect data is considered to be a violation of the Policy. If the data provided changes, You must immediately inform us about it. We shall under no circumstances be responsible for damages that may arise for You and (or) third parties if You provide incorrect and (or) undetailed personal data or did not request supplementation and (or) correction of data when it changes.

2.5.     The entities to which we may disclose Your personal data are described in each of the data processing activities laid down below.

2.6.     In certain cases, we may disclose Your information to entities other than the specified entities:

2.6.1. In order not to violate the law or to respond to a mandatory request in court proceedings (eg, upon receipt of a court order to provide data);

2.6.2. To confirm the legitimacy of our actions;

2.6.3. To protect our rights and property or to ensure its safety;

2.6.4. In other cases, with Your consent or at Your legitimate request.

3.1.     If You decide to contact us for recruitment, we will process the following personal data submitted by You as candidate for recruitment purposes:

3.1.1. First name, last name;

3.1.2. Date of birth;

3.1.3. Telephone number;

3.1.4. E-mail address;

3.1.5. Residence address;

3.1.6. Education;

3.1.7. Previous and current workplaces;

3.1.8. In the case of courier selection, data on the subcontractor with whom the courier has concluded the contract and the size of the clothing worn by the candidate, driver category and the driver's experience are also processed;

3.1.9. Other data voluntarily provided in Your curriculum vitae and / or other submitted documents.

3.2.     Legal basis for processing personal data is Article 6 (1) (b) (processing in order to take steps prior to entering into a contract) of the GDPR.

3.3.     We normally do not directly employ couriers, so if You provide data for the purpose of getting employed as a courier, Your personal data may be transferred to subcontractors for employment purposes. In that case, once we transfer the data, they are further processed by the subcontractor who received them.

3.4.     Whereas the laws of the Republic of Lithuania impose additional restrictions on the information of candidates that can be processed, we shall ensure that only the allowed personal data of You as the candidate is processed.

4.1.     In order to provide shipment collection and delivery services, we process personal data, the scope of which depends on the role of the individual in the process of providing said services.

4.2.     If You are a sender, we process the following personal data that You have provided Yourself:

4.2.1. First name;

4.2.2. Last name;

4.2.3. Address;

4.2.4. Telephone number;

4.2.5. E-mail address.

4.3.     If You are the consignee, we process the following personal data provided by the sender:

4.3.1. First name;

4.3.2. Last name;

4.3.3. Address;

4.3.4. Telephone number;

4.3.5. E-mail address;

4.4.     If You accept the shipment, we receive from You and process the following personal data:

4.4.1. First name;

4.4.2. Last name;

4.4.3. Address;

4.4.4. Last 5 digits of the identity document’s number.

4.5.     Legal basis for processing personal data for the provision of parcel collection and delivery services are Article 6 (1) (b) (processing for the performance of a contract), (c) (processing necessary to fulfill the legal obligations applicable to the controller) and, in case of the processing of data of consignees and persons accepting the shipment, (f) (the legitimate interest of us and the sender in delivering the parcel and identifying the receiving person) of the GDPR.

4.6.     Personal data collected for the abovementioned purpose shall not be shared with third parties, but we use the companies that provide IT services to us as data processors and subcontractors to provide You with the services.

4.7.     We transfer the data we process for this purpose to other DPD group companies if this is necessary to achieve said purpose. For data processing, we use companies that provide IT services to us as processors, and subcontractors to help us deliver shipments.

5.1.     In the event that You receive a shipment whose condition of delivery is a confirmation of Your identity, we shall process the following data we receive from You and / or the sender for authentication purposes:

5.1.1. First name;

5.1.2. Last name;

5.1.3. Identity document number;

5.1.4. Photocopy of an identity document.

5.2.     Legal basis for the processing of personal data is Article 6 (1) (f) of the GDPR – the legitimate interest of us and the sender in delivering a shipment to a properly identified recipient.

5.3.     Due to the specificity of this service, we provide Your personal data to senders. We also transfer Your data that we process for this purpose to DPD group companies if this is necessary to achieve said purpose. For data processing, we use companies that provide IT services to us as processors and subcontractors to help us deliver shipments.

6.1.     If You receive a shipment for which cash is collected, we handle the following personal data that we receive from You and / or the sender:

6.1.1. First name;

6.1.2. Last name;

6.1.3. Address;

6.1.4. Telephone number.

6.2.     Legal basis for the processing of personal data are GDPR Article 6 (1) (b) - conclusion and execution of the contract, (c) - execution of legal accounting obligations applicable to us, and (f) - the legitimate interest of us and the sender in receiving payment for the transferred shipment.

6.3.     Due to the specificity of this service, we provide Your personal data to senders. We also transfer Your data that we process for this purpose to DPD group companies if this is necessary to achieve said purpose. For data processing, we use companies that provide IT services to us as processors and subcontractors to help us deliver shipments.

7.1.     If You receive a contract for signing that is sent via our courier, we handle the following personal data that we receive from You and / or the sender

7.1.1. First name;

7.1.2. Last name;

7.1.3. Address;

7.1.4. Telephone number;

7.1.5. E-mail address;

7.1.6. Date of birth;

7.1.7. Identity document number.

7.2.     Legal basis for the processing of personal data is Article 6 (1) (f) of the GDPR – the legitimate interest of us and the sender in delivering a shipment to a properly identified recipient.

7.3.     Due to the specificity of this service, we provide Your personal data to senders. We also transfer Your data that we process for this purpose to DPD group companies if this is necessary to achieve said purpose. For data processing, we use companies that provide IT services to us as processors and subcontractors to help us deliver shipments.

8.1.     If You are a self-employed person, we process the following personal data received from You for the purpose of concluding and executing a contract with You:

8.1.1. First name;

8.1.2. Last name;

8.1.3. Personal identification number;

8.1.4. Address;

8.1.5. Telephone number;

8.1.6. E-mail address;

8.1.7. Identity document number and date of issue;

8.1.8. Billing account details.

8.2.     We transfer Your data that we process for this purpose to DPD group companies if this is necessary to achieve said purpose. For data processing, we use companies that provide IT services to us as processors and subcontractors to help us deliver shipments.

8.3.     Legal basis for the processing of personal data are GDPR Article 6 (1) (b) - conclusion and execution of the contract, (c) - execution of legal accounting obligations applicable to us.

9.1.     If You, as our contractual client, delay paying for our services, we may be forced to process the following personal data received from You and UAB "Creditinfo Lietuva" database for debt management purposes:

9.1.1. First name;

9.1.2. Last name;

9.1.3. Telephone number;

9.1.4. E-mail address;

9.1.5. Other data provided by UAB “Creditinfo Lietuva”.

9.2.     The legal basis for the processing of personal data is GDPR Article 6 (1) (b) - our legitimate interest in receiving payment for the services provided.

9.3.     We may transfer Your data we process for this purpose to third parties - courts, bailiffs, and we use companies that provide IT to services to us, acting as data processors, and lawyers.

9.4.     If You are our contractual client and You are delayed in fulfilling Your obligations for more than 30 days, we will provide information about Your identity, that is Your contact details and credit history, financial and property obligations and their execution, debts and their payment, to the credit bureau "Creditinfo Lietuva" (company code: 111689163, address: A. Goštauto g. 40A, LT 01112 Vilnius, Lithuania, www.manocreditinfo.lt, tel.: (8 5) 2394131). Credit bureau manages and provides Your information to third parties (financial institutions, telecom companies, insurance, electricity and utilities, trading companies, etc.) for legitimate interests and purposes - to assess creditworthiness and manage debt. Credit history data is processed 10 years after the fulfilment of obligations.

9.5.      You can access Your credit history by contacting the credit bureau directly or using the Finpass mobile app. You also have the right to request rectification or erasure or to limit the processing of data and the right to object to the processing of the data, as well as the right to data portability. You can learn more about the implementation and limitations of these rights at www.manocreditinfo.lt. If Your rights are violated, You can contact the data protection officer of UAB “Creditinfo Lietuva” by e-mail. by e-mail: [email protected] or by the above mentioned UAB “Creditinfo Lietuva” phone number or to file a complaint with the State Data Protection Inspectorate.

10.1.  In the event that the senders or recipients of the shipments have claims or complaints about the services provided, we process the following personal data of You as a sender or recipient:

10.1.1. First name;

10.1.2. Last name;

10.1.3. Address.

10.2.  In the event that You are the applicant, we process the following personal data:

10.2.1. First name;

10.2.2. Last name;

10.2.3. Address;

10.2.4. Bank details;

10.2.5. Details of the contents of the shipment;

10.2.6. Data contained in sent item purchase and shipment consignment documents.

10.3.  Legal basis for the processing of personal data is Article 6 (1) (f) of the GDPR – our legitimate interest in clarifying the circumstances and properly examining the claims and complaints received.

10.4.  We do not transfer Your data we process for this purpose to third parties, but for their processing we use companies that provide IT services to us as data processors.