Privacy Policy

GENERAL INFORMATION

Privacy Policy) sets out the conditions for the processing of Personal Data  by using the website maintained by the Data Controller  https://digitorum.eu (hereinafter referred to as the Website). The Privacy Policy applies to each time you visit the website, regardless of which device (computer, mobile phone, tablet, TV, etc.) you use.

You can contact with Digitorum data protection officer by e-mail: edu@digitorum.eu.

It is very important that you carefully read the Privacy Policy because, each time you visit the website owned by the Data Controller, you agree to the terms and conditions described in this Privacy Policy. If you do not agree to these terms, please do not visit our site, do not use our content and / or services.

The Data Subject agrees and does not oppose the Data Controller to provide and process Personal Data  (including data provided directly or indirectly by the Website and using its services) in order to manage and maintain it in this Privacy Policy, in accordance with the Data Subject’s consent and purposes and in accordance with the law.

Participant – is a person participating or intending to participate in games, campaigns and / or contests organized by the Data Controller.

The Data Subject in this Privacy Policy shall be the Applicant, the Patient, the Candidate, the Participants in the Training, Callers by phone or any other natural person whose Personal Data is managed by the Data Controller.

Applicant – means a natural person interested in the provision of healthcare provided by the Data Controller or who wishes to register for the provision of a healthcare service.

Candidate – is a person participating or intending to participate in the selection of personnel by the Data Controller.

Participant – is a person participating or intending to participate in the training organized by the Data Controller.

Patient – a person who has entered into a contract with the Data Controller for the provision of health care (dentistry) services.

Caller – is a person calling by the contact telephone number that is shown via the Internet, for registration with doctors and / or other issues.

The Data Controller will collect Personal Data in accordance with the requirements of the valid legal acts of the European Union and the Republic of Lithuania and the instructions of the controlling institutions. All reasonable technical and administrative measures shall be taken to prevent data subjects being protected against loss, unauthorized use and alteration.

Persons under the age of 16 years cannot provide any Personal Data through the Data Controller’s web site. If you are a person below the age of 16, you must obtain the consent of your parent or other legal guardians before submitting personal information.

This Privacy Policy is based on Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter – the General Data Protection Regulation), Law on the Legal Protection of Personal Data of the Republic of Lithuania, other legal acts of the European Union and the Republic of Lithuania. The concepts used in the Privacy Policy are understood as defined in the General Data Protection Regulation and the Law on the Legal Protection of Personal Data of the Republic of Lithuania.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

Information provided directly by you.

Information on how do you use our website.
If you visit our website, we also collect information that reveals the peculiarities of using our services or automatically generated visitor statistics. Read more about Cookies.

Information from third-party sources
We may receive information about you from public and commercial sources (as far as that is permitted by applicable law) and associate it with other information we receive from you or about you. We can also receive information about you from third-party social networking services when you sign in, for example, through your Facebook network account.

Another information we collect
We may also collect other information about you, your device or your use of the content of our site with your consent.
You may choose not to provide us with certain information, but in such a case you may not be allowed to use our service.

PERSONAL DATA PROCESSING FOR THE REGISTRATION PURPOSES

The processing of Personal Data for Applicants, including Phone Callers, to the Data Controller for the purpose of registering for a doctor and / or other matters. The Data Controller processes the following Personal Data of Applicants, including Callers by phone:

Name;
Surname;
Date of birth;
Phone number;
E-mail address;
Health data (as much as the Data Subject submits voluntarily).

In case if the registration is carried out by the representative of the Applicant, the Data Controller shall manage the following data of that representative of the Applicant:

Name;
Surname;
Relation to the Data subject;
Phone number;
E-mail address.

The data of the Applicants are not forwarded to third parties.

PERSONAL DATA PROCESSING FOR JOB OPENINGS PERSONNEL SELECTION PURPOSES

The Data Controller processes the Personal Data submitted by the Candidate voluntarily for the purpose of personnel selection, to the extent that Personal Data have been provided.

The data are obtained directly from the Candidates submitting applications and / or third parties websites of job advertisers. These data are not forwarded to third parties.

Candidates’ data are processed by agreeing on the submission of their data and evaluating the submission of these data as an active consent to process his/her Personal Data for a specific staff selection (announced or otherwise known to the Candidate) and / or a pre-contractual request (Article 6 part 1, clauses a) and b) of the General Data Protection Regulation).

PERSONAL DATA PROCESSING FOR TEACHING REGISTRATION PURPOSES

Processing of Personal Data of those who are interested in the Data Controller organized teaching trainings or who intend to participate in the training. The Data Controller collects the following Data Subject data:

Name;
Surname;
Phone number;
E-mail address.

Data are obtained directly from the training Participants. The Personal Data of the learners are not transferred to the third parties.

PERSONAL DATA PROCESSING FOR PARTICIPATION IN TEACHING PURPOSES

Managing trainees involved in training. The Data Controller collects the following Data Subject data:

Name;
Surname;
Phone number;
E-mail address;
Specialty;
License details;
Checking account data.

Data are obtained directly from the training Participants. The Personal Data of the trainees can be transferred to the following third parties:

Lithuanian Dental Chamber;

An accounting services company (in relation to the internal accounting of the Data Controller).

The Personal Data of the Participants in the training shall be processed on the basis of the consent expressed in the submission of their data (Article 6 part 1, c. a) of the General Data Protection Regulation).

PERSONAL DATA PROCESSING FOR GAMES, PROMOTIONS, COMPETITIONS ORGANIZING PURPOSES

The Data Controller may process Personal Data for the purpose of playing games, promotions or competitions only with the consent of the Data Subject. The Data Controller may collect the following Personal Data of the Participants:

Name;
Surname;
Photo pictures;
Telephone;
E-mail.

Data is obtained directly from the Data Subjects participating in games, campaigns and / or contests. These data are not transferred to third parties, but can be made public through the Data Controller web site and / or the social network Facebook accounts that belong to the Data Controller. The Data Controller can post: name (or social networks registered Data Subject pseudonym), a picture.

Personal data are processed on the basis of the consent expressed in the submission of Personal Data (Article 6 part 1, c. a) of the General Data Protection Regulation).

PERSONAL DATA PROCESSING FOR DIRECT MARKETING PURPOSE

The Data Controller seeks with newsletter recipients to share only relevant news and other useful information. That is implemented in accordance with this Privacy Policy.

The Data Controller processes Personal Data for direct marketing purposes only with clearly expressed consent of the Data Subject. For the purpose of direct marketing, the following Personal Data of the clients and other Data Subjects are processed:

Name;
Surname;
Phone number;
E-mail address.

By sending a newsletter, the Data Controller can collect statistics on the behaviour of the Data Subject related to the use and content of the newsletter (for example, if the newsletter has been read, what links have been opened by the Data Subject).

Data Subject e-mail address can be used to serve ads on Facebook, Google, and other advertising platforms by tailoring the advertisement to the target audience.

According to Personal Data you submit for direct marketing purposes, your Personal Data may be profiled in order to offer tailor made individual solutions and suggestions. You can at any time cancel your consent to process Personal Data in an automated manner, including profiling, processing or contradiction (if applicable).

Personal data are received directly from Data Subjects. Personal Data may only be transferred by the Data Controller to third parties providing specialized services in order to send an e-mail, to tailor e-mails for the nature of advertising ordered through advertising platforms.

The Personal Data of customers and other Data Subjects are processed on the basis of the consent expressed in the submission of their data and consent to the processing of Personal Data for the purpose of direct marketing (Article 6 part 1, c. a) of the General Data Protection Regulation).

We inform you that the Data Subject has the right to decline or at any time cancel his/her consent to process his/her Personal Data for direct marketing purposes without specifying reasons for disapproval:
– By clicking on the “unsubscribe” link at the end of the newsletter or on the website; or
– By sending e-mail to edu@digitorum.eu.

Cancellation of consent does not affect the legality of consent-based data processing prior to the withdrawal of consent.

PERSONAL DATA PROCESSING FOR PERSONNEL, PATIENT SECURITY AND PROPERTY PROTECTION ASSURANCE (VIDEO MONITORING) PURPOSES

The Data Controller processes the image data of his staff and the Patients and other persons who have entered the video surveillance field in order to ensure their and property security (video surveillance).

Please be advised that your video data is captured by the Data Controller video surveillance system when you visit the Data Controller’s clinic in the reception and outdoors area around the clinic. Image data may only be transmitted to law enforcement agencies in accordance with the procedure provided for in the legal acts of the Republic of Lithuania.

Personal Data for the purpose of video surveillance are maintained on the basis of the Data Controller’s legitimate interest protection (Article 6 part 1, c. f) of the General Data Protection Regulation).

WHAT DO WE DO TO PROTECT YOUR INFORMATION?

Personal Data is protected against loss, unauthorized use and alteration. We have implemented organizational and technical measures to protect all information we collect for our service provision. We remind you that while we are taking appropriate action to protect your information, no website, online transaction, computer system or wireless connection is completely safe.

The Data Controller applies different terms for the storage of Personal Data, in accordance with the requirements of the law and taking into account the purposes for the processing of Personal Data.

Terms of Personal Data storage:

Purpose of Personal Data processing Storage term
Processing of Personal Data of Data Subjects for registration purposes By the date of the registered visit. If the Data Subject does not arrive on a designated visit, Personal Data submitted by him will be destroyed
Processing of Callers’ Personal Data 6 months from the date of recording of the call
Processing of Patient data for the provision of health services 15 years after the last visit to the clinic
Patient Personal Data processing for visit reminder purposes 2 years after the date of the last visit to the Data Controller clinic
Processing of Personal Data of Candidates for the purpose of staff selection 4 months after the Candidate is recruited. The Candidate’s consent is required for a longer storage period for the curriculum vitae of Candidate and other data
Processing of Personal Data of Data Subjects for registration for training and participation in training purposes 2 years from the date of registration
Processing of Personal Data of Data Subjects for the purpose of organizing games, promotions, competitions 1 year from the date of the event taking place
Processing of Personal Data of Data Subjects for video surveillance purposes 1 month
Processing of Personal Data of Data Subjects for direct marketing purpose 5 years from the date of consent, unless the Data Subject wishes to extend this term.

Exceptions to the terms of retention may be determined to the extent that they do not violate the rights of the Data Subjects, comply with legal requirements and are properly documented.

After expiration of the deadlines, if they were not extended, the data will be destroyed in such a way that they cannot be reproduced.

YOUR RIGHTS

The Data Subject, whose data is processed by the Data Controller, shall have the following:

  • To know (to be informed) about the processing of his/her data (right to know);
  • To access his/her data and to find how they are processed (right to access);
  • Require correction or, in the context of the purposes for processing Personal Data, supplement the incomplete Personal Data of a person (right to rectify);
  • To destroy his/her data or suspend their processing (except storage) (right to destroy and right “to be forgotten”);
  • The right to require the Data Controller to restrict the processing of Personal Data for one of the legitimate reasons (right to limit);
  • The right to transfer data (right to transfer);
  • Disagree on the processing of Personal Data when processed or intended to be processed for direct marketing purposes, including profiling, to the extent that it relates to such direct marketing;
  • Submit a complaint to the State Data Protection Inspectorate of the Republic of Lithuania.

If you do not want your Personal Data to be processed for direct marketing purposes, you can e-mail us at edu@digitorum.eu and disagree that your Personal Data will be processed for direct marketing purposes without giving reasons for disapproval.

Any request or instruction related to the processing of Personal Data, the Data Subject has the right to submit to the Data Controller in writing in one of the following ways: by direct delivery at the address (Kalvarijų g. 128A-2, Vilnius); by post: Kalvarijų g. 128A-2, LT-08210 Vilnius; by e-mail: edu@digitorum.eu.

Upon receipt of such a request or instruction, the Data Controller shall, within one month from the date of the request, provide an answer and perform or refuse the actions specified in the request. If necessary, the specified period may be extended by another two months depending on the complexity and number of requests. In this case, the Data Controller shall inform the Data Subject about such extension within one month from the receipt of the request, together with the reasons for the delay.

The Data Controller may not create the conditions for Data Subjects to exercise the above rights, except to refuse to process Personal Data for direct marketing, in cases provided for by law, when it is necessary to ensure the prevention, investigation and detection of violations of criminal, official or professional ethics offenses, as well as the protection of the rights and liberties of the Data Subject or other persons.

THIRD PARTY WEBSITES, SERVICES AND PRODUCTS ON OUR WEBSITET

The Data Controller’s website may contain third-party billboards, links to their websites and services that are not controlled by the Data Controller, such as, e. g., a link to the Data Controller’s Facebook profile. The Data Controller is not responsible for the safety and privacy of information collected by third parties. You must read the privacy practices applicable to third-party websites and services that you use.

If you submit your personal information with the help of Facebook, we understand that you agree that we can contact you by phone and e- mail and submit service offers.

COOKIES

When you visit the Data Controller website, we want to provide content and features that are tailored to your needs. This requires using of cookies. These are small elements of information that are automatically generated when you browse the site and are stored on your computer or other terminal device. They help the Data Controller recognize you as the previous visitor to a certain website, save the history of your visit to the site and adapt the content accordingly. Cookies also help ensure the smooth running of websites, allow you to monitor the duration, frequency of visits to websites, and collect statistical information about the number of site visitors.

Descriptions of our site cookies

Cookie name Description /
Purpose of use		 Creation time Expiry date Data used
wpcw_timezone Set the local users timezone When visiting the website By closing the website window Local users timezone
analytics (ga,gid,gat) Google analytics – to track user behaviour on the site When visiting the website By closing the website window Uses information about how the visitors behave on the website
pll_language Records what language the user used during browsing When visiting the website By closing the website window Language selection.
woocommerce_cart_hash, wp_woocommerce_session, woocommerce_items_in_cart Records what products the user added to the shopping cart When visiting the website By closing the website window Products in cart
wp-settings Used for Content Management System Settings When visiting the website By closing the website window Saves website data in the user browser

How to manage and delete cookies

When you use the browser to access the content we provide, you can configure your browser to accept all cookies, reject all cookies or notify when the cookie is downloaded. Each browser is different, so if you do not know how to change cookie preferences, look in its help menu. Your device’s operating system may have additional cookie controls. If you do not want the information to be collected using cookies, use the current easy-to-use procedure in most browsers that allows you to stop using cookies. To learn more about managing cookies, visit: http://www.allaboutcookies.org/manage-cookies/.

However, please note that in some cases, deleting cookies may slow down the speed of browsing the web, restrict the functionality of certain website features, or block access to the website.

Our website may contain links to other people’s, company’s or organization’s websites. We note that the Data Controller is not responsible for the content of such web pages or the privacy principles they use. So if you click on a link from the Data Controller website to access other websites, you should take a look at their Privacy Policy separately.

FINAL PROVISIONS

The additions or changes to the Privacy Policy come into force on the day they are published on the website.
When the Data Subject uses the website and / or the services provided by the Data Controller after the supplementing or changing of the Privacy Policy, the Data Subject shall not be deemed to have objected to such additions and / or modifications.

CONTACT US

If you have any questions about this Privacy Policy, please feel free to contact us by e-mail: edu@digitorum.eu.