Primus

GENERAL PROVISIONS

DEFINITIONS

In the Privacy Policy definitions and expressions, which are written in the capital letter, shall have the same meaning as defined down below:
– Personal data – any information about you, as a natural person, whose identity has been identified or can be identified (the Data subject); the natural person, whose identity can be identified, is the person, whose identity can be identified directly (using an identifier such as name and surname, internet identifier) or indirectly (according to one or more physical, physiological, genetic, psychological, economic, cultural or social identity features);
– GDPR – 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;
– Controller or Primus, or we, or us, or our – Law firm Juodka and partners – Primus, address Konstitucijos av. 7, Business centre “Europa”, 22nd floor, Vilnius, Lithuania;
– You or your or yours – any person, including who visits the Website and uses its functionalities (e. g., submits the inquiry) or provide the Personal data to Primus or Primus, having legitimate ground for receive and processing of the Personal data, receives such data, including from third parties;
– Privacy Policy – the principles, rules and requirements provided by Primus that establishes the procedure of collection, storage, use and any other processing of information, including the Personal data, related to the use of the Website and its functionalities, also processed in Primus’ activity, as well as other relevant provisions;
– Cookies – small files, which are sent into your browser and stored in your computer, mobile phone or other devise, which you are using to connect to the Website, also other technologies, such as pixels;
– Website– a website accessible via the Internet at https://primuslegal.eu/, and the administrator of which is Primus.

CONNECTION TO THE WEBSITE

PURPOSES OF THE PROCESSING OF PERSONAL DATA, SOURCES OF DATA, CATEGORIES OF THE DATA SUBJECTS, OTHER INFORMATION RELATED WITH THE PROCESSING OF YOUR PERSONAL DATA

To ensure transparency and responsible processing of Personal data, we inform that we process your Personal data for the following purposes and under the following conditions:
Administration of inquires or requests received by Primus‘ contacts (including e-mail) or other functionalities available on the Website, including submission of responses

In order to ensure opportunity for you by using the means available on the Website (for example, form of inquiries/contacts) or by using contacts of Primus (for example, e-mail specified in the Website or this Privacy Policy) to submit for us the inquiries, requests, as well as to submit you the answers to your inquiries, requests, we can process your Personal data (as person, who submitted inquiry/request/complaint).

Processed Personal data	E-mail address, your name, surname (when submitted), topic (related practise area) / the content of the message, as well as any other Personal data provided in the inquiry, request or further communication
Legal basis for processing of Personal data	Personal data are processed on the basis of the Data subject‘s consent (Article 6(1)(a) of GDPR), which is expressed by submitting an appropriate inquiry, request to Primus.
Period of storage of Personal data	1 (one) year from the date of submission of the relevant inquiry, request.
Source of Personal data	Personal data are obtained from the Data subject.

Recruitment – processing of data submitted by potential candidates for vacancies or traineeships via the email address indicated by Primus or via the functionalities available on the Website

To ensure our independent functioning and to select the most suitable candidates for the vacancies announced by Primus, we process the Personal data of persons applying and submitting (including by email, other channels) to Primus Personal data required for this purpose.

When applying for a vacancy at Primus, you are informed that we have the right to contact the former employer you have indicated in order to obtain information from him/her/they regarding your qualifications, professional skills and business qualities. By providing your former employer’s contact details, you should inform him/her/they that you are providing such details to Primus and that he/she/they may be contacted by Primus for the purposes of your selection.

Processed Personal data	Name, surname, email address, information on education, professional skills and professional attributes, information on work experience, other information provided voluntarily by the candidate (including during the interview), including references, curriculum vitae (CV), and information relating to qualifications, professional skills and professional attributes from the candidate’s former employer.
Legal basis for processing of Personal data	The processing of Personal data is based on the Data subject’s consent (Article 6(1)(a) of GDPR), which is expressed by providing us with information about oneself or otherwise applying for a job vacancy. Data from a former employer is obtained based on a legitimate interest of Primus to obtain information about the candidate from his/her former employer (Article 6(1)(f) of GDPR).
Period of storage of Personal data	6 (six) months from the date of submission of the application.
Source of the Personal data	The Personal data is obtained from the Data subject himself/herself, as well as from third parties, such as a representative of the candidate’s former employer.

Registration to events organised by Primus or co-organised by Primus with partners

To enable you to participate in events organised by Primus or co-organised by Primus with partners (workshops, conferences, etc.), we process Personal data about you as a person who wishes to register or who has registered to the event.

Please note that in case where we organise certain events together with partners, the Personal data you provide for registration purposes may also be transferred to these partners, which perform certain functions in relation to the event. Such partners will only process Personal data to the extent necessary for the purposes of ensuring your registration/participation in the event, unless otherwise stated.

Processed Personal data	Email address, name, surname (when provided), the content of the message (when provided), the company represented, as well as any other Personal data provided at the time of registration or during further communication.
Legal basis for processing of Personal data	The processing of Personal data is based on the Data subject’s consent (Article 6(1)(a) of GDPR), which is expressed by providing us with the relevant data for registration.
Period of storage of Personal data	3 (three) months after the end of the relevant event.
Source of the Personal data	Personal data are obtained from the Data subject.

Right to object

You are given the opportunity at any time to withdraw your consent to the processing of Personal data (withdrawal of consent will not affect the lawfulness of consent-based processing of Personal data carried out by us prior to the withdrawal of your consent).

You may withdraw your consent by contacting Primus at the email address set out below in this Privacy Policy.

COOKIES

General provisions related to the Cookies and its usage on the Website

On the Website we use Cookies to ensure the proper functioning of the Website, smooth use of the Website, also for the Website’s traffic statistic, user’s experience improving and other below mentioned purposes.

Cookies may be “session cookies” that are used only while you are browsing the internet and are automatically deleted after closing the browser, “persistence cookies”, i.e. that are stored on you back device (computer, tablet, smartphone, etc.) until Cookie’s validity term ends or you refuse use of Cookie using one of the methods, described in this Privacy Policy, or “Third Party Cookies”, i.e. those that are used by the person, which is not the Website’s controller.

When you visit the Website, it displays a pop-up notification informing about the use of Cookies on the Website with link to this Privacy Policy. By making relevant choices in the pop-up notification, you consent that Primus will save relevant chosen Cookies on your back device (computer, tablet, smartphone, etc.) that are described in more detail below. You have a right to choose and accept or withdraw your consent on all or particular type of Cookies.

Despite your choice i. e. if you continue using the Website, the strictly necessary Cookies will be installed in all cases.

Please note that Cookies may also be used by Primus’ partners or other third parties that are not controlled by the Website’s controller. Primus may not be and is not responsible for the actions of such persons. By suspecting that, without your consent, Primus’ partners or other third parties, who are not controlled by the Website’s controller, use Cookies, you should contact the specific partner or other third party.

Refusal of Cookies

If you disagree on instalment of Cookies on your back device, you can refrain from any actions expressing consent, also, you can always refuse all or specific Cookies by following the instructions bellow.

You can uninstall Cookies in the following ways:

– you can waive or withdraw your consent at any time regarding specific or all Cookies [here];
– on your browser you can preview the Cookies installed on your computer or other device and delete them one by one or all at once. The steps you need to make are different (see the instructions of Cookies of the most popular browsers by clicking on the following browser name Opera, Firefox, Chrome, Safari, Internet Explorer) thus the specific actions that shall be made should be set according to the browser you are using;
– you can also set your internets browser to block Cookies or receive a warning about installing of any Cookies. The steps you need to make are different in each browser, therefore the specific action you want to perform should be set according to the browser you are using.

List and types of Cookies used on the Website

Website uses Cookies specified below in the table, which are classified into four types. All the following Cookies, except the strictly necessary Cookies, will be installed only upon your consent.

STORAGE OF THE PERSONAL DATA

DISCLOSURE OF THE PERSONAL DATA

TRANSFER OF PERSONAL DATA OUTSIDE THE EEA

YOUR (AS THE DATA SUBJECT) RIGHTS AND THEIR IMPLEMENTATION

You, as the Data subject, have all rights specified in the applicable legal acts, including indicated down below:

Right to revoke the given consent

If you have given us your consent to process your Personal data, you may revoke it at any time (withdrawal of the consent shall not affect the lawfulness of the processing of Personal data based on the consent before its withdrawal) by contacting us using the contact details specified in this Privacy Policy or by using other functionalities provided by Primus.

Right to request the access to your Personal data.

You can access your Personal data, which are processed by us. You can get information on how it is collected, period for which your data are stored and who and to what extent receive your data. However, your right of access may be limited by legal acts.

Right to request rectification of Personal data

You may require us to rectify processed Personal data that is related to you, if it is incorrect, inaccurate or incomplete.

Right to object

Under the certain circumstances, you have the right to object the processing of your Personal data, including when your Personal data are processed on the basis of the legitimate interest.

Right to restriction of the processing

If you think that your Personal data processed by Primus is incorrect or you disagree with the use of the data, you may require Primus that the use of this data would be limited solely to storage. The use will be limited to the storage until the verification of the accuracy of the data or until the verification whether the legitimate grounds of Primus override those of the Data subject.

Right to erasure

If your Personal Data are processed illegally, you disagree to such processing of your Personal Data or there are other legal grounds, you shall have the right to obtain from Primus the erasure of the Personal data in accordance with the restrictions specified in legal acts.

Right to data portability

You have the right to get the Personal data related to you, which you submitted to Primus, in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller in accordance with the procedure established by legal acts.

The right to lodge a complaint

You also have the right to lodge a complaint to the State Data Protection Inspectorate, if you consider that the processing of Personal data relating to you infringes requirements of legal acts. However, we kindly as you to firstly contact us using the contacts indicated in this Privacy Policy.

Procedure of implementation of the Data subject’s rights

If you have additional questions or you want to implement your rights indicated in this Privacy Policy and related to the processing of the Personal data, you should contact us by using the contacts indicated in this Privacy Policy (by email, by post (by sending to the indicated address) or physically upon arrival at Primus’ actual registered office, the address of which is set out at the bottom of the Privacy Policy).

When submitting requests on rights related to the processing of Personal data, you will be asked to confirm your identity (e. g. in case you apply by electronic means, you must sign it by electronic signature).

We will consider the request on the right(s) of the Data subject as unjustified and may not execute it in cases where it does not specify the right(s) to be implemented, as well as any other information required by the Privacy Policy or the GDPR. We may also not execute your request if we do not process your Personal data, the appropriate documentation to identify your (or your representative) identity are not provided together with the request, the person submitting the request is not duly authorized or has no right to make the request (no Power of Attorney or other document granting the right to represent you is submitted) or legal acts do not provide possibility of satisfying your request.

Please note that in cases where you abuse your right to submit the request, we have the right to charge a fee for execution of the request.

We will respond to all your requests related to the implementation of your, as the Data subject, rights without undue delay and no later than within 1 (one) month after receiving the request. That period may be extended by 2 (two) further months by informing you in advance.

THIRD PERSONS

FINAL PROVISIONS AND THE CONTACT DETAILS