Privacy Policy

AB KAVINUKO PREKYBA (hereinafter – the “Company”) values and protects your privacy. Therefore, in this Privacy Policy (hereinafter – the “Policy”), we clearly and unambiguously set out the principles for the collection and use of information applied in the Company’s activities and on the website http://www.gurmans.eu (hereinafter – the “Website”), as well as other information regarding the Company’s provisions and principles for ensuring the protection of personal data. 

The terms “You”, “Your” and “visitor” refer to any subject, individual, company or organization using our Website or otherwise providing personal data to us. The terms “we” and “our” refer to UAB KAVINUKO PREKYBA, a company established in accordance with the laws of the Republic of Lithuania, as well as its subsidiaries, branches and representative offices. 
This Policy applies when you visit the Company’s Website, when you directly provide your data to the Company, when we receive data relating to you from state authorities or other sources, and when properly fulfilling contractual obligations to which you are a party. This Policy also aims to inform you about other personal data processing activities carried out by the Company and the key principles intended to ensure your privacy. 
Personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation), the Law on Legal Protection of Personal Data of the Republic of Lithuania, other applicable legal acts, and instructions of supervisory authorities. 

This Policy is an integral part of the Company’s Terms of Service. However, it does not apply to any third-party websites or applications that you may access via our Website, including those related to our services. Before clicking on any links, you should review the terms and privacy policies of such third-party websites or applications. 

Please read this Policy carefully. If you have any questions, contact us by email at info@gurmans.eu. By using the Website, we assume that all visitors have read and agreed to this Policy. If you do not agree with this Policy or any part of it, please do not use our Website. 

1. PERSONAL DATA WE COLLECT AND PROCESS 
The Company collects and processes the following categories of personal data: 
 - Login data provided when creating an account on the Website: first name, last name, email address, phone number, password, username. 
 - Basic data, such as address, first name, last name, date of birth, documents. 
 - Contact details: address, email address, phone number. 
 - Payment information provided when ordering services and/or products on the Website and necessary to process payments. The Company uses third-party payment service providers and does not collect or store bank card data. Payment information is provided directly to payment service providers. All payment data is stored by Paysera. Their privacy policy is available at: www.paysera.lt/v2/en-LT/legal/privacy-policy.
 - Service-related data, including order data, account and invoice data, data related to completed payments, information about purchased products or services, and similar information. 
 - Other information, such as survey responses or other data provided by visitors. 

2. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA 
The Company processes personal data only on lawful grounds established by applicable laws. These include the conclusion and performance of contracts, inquiries submitted by you, and visits to the Website. The Company may also process personal data based on its legitimate interests, for example, when assessing creditworthiness or managing and recovering debts. Your consent constitutes another legal basis for processing personal data. The Company may also process personal data to comply with legal obligations, respond to lawful requests from public authorities, or on other lawful grounds provided for by law. 

3. DATA COLLECTED ON THE WEBSITE 
When you visit the Website or contact us via electronic communication channels, the Company may automatically collect certain personal data: 
 - Geolocation data, indicating the geographical location from which you access the Website. 
 - Data collected from third parties, for example through the use of Google Analytics provided by Google LLC. Google Analytics uses cookies and other tracking technologies to analyze website traffic and user behavior, generate reports, and share data with other Google services. Google may use collected data to personalize advertising. Data collected by Google includes cookies and website usage data. More information is available at: policies.google.com/privacy.
 - Publicly available personal data, collected where necessary for proper service provision or maintenance of Website functionality. 

Collected data is protected against loss, unauthorized use, and alteration. Physical and technical security measures are applied to prevent unauthorized access. 

4. PURPOSES OF PERSONAL DATA PROCESSING 
The Company processes personal data for the following purposes: 
 - fulfilling orders; 
 - identifying visitors; 
 - creating accounts; 
 - ensuring Website security; 
 - providing services and performing contracts; 
 - responding to inquiries, comments, or requests; 
 - issuing invoices and providing service-related information; 
 - improving service quality; 
 - internal administration purposes; 
 - providing customer support; 
 - collecting feedback; 
 - ensuring data security and preventing fraud; 
 - publishing reviews and recommendations; 
 - fulfilling legal obligations; 
 - preventing misuse of products or services; 
 - sending marketing communications; 
 - notifying customers of changes to service conditions; 
 - resolving issues related to service provision. 

By providing personal data, you confirm your voluntary consent to its processing in accordance with this Policy and applicable laws. 

5. DIRECT MARKETING 
The Company may use personal data to send general direct marketing offers, which may be personalized based on data provided by you or collected automatically (e.g. location data). 
You may opt out of direct marketing at any time by changing your account settings, clicking the unsubscribe link in emails, or contacting us at info@gurmans.eu.

6. DATA DISCLOSURE AND COOPERATION WITH THIRD PARTIES 
The Company may transfer personal data to data processors providing services on behalf of the Company. Such parties are not permitted to use personal data for other purposes and must ensure appropriate data protection measures. Personal data may be disclosed to: 
 - third parties with your consent; 
 - hosting providers; 
 - companies providing communication, security, or related services; 
 - data processors acting on behalf of the Company; 
 - courts or public authorities where required by law; 
 - other parties with explicit consent. 

The Company may also disclose your personal data to third parties in the following cases: 
 - where required by applicable laws, court judgments, rulings, decisions, or other lawful requirements of law enforcement authorities; 
 - in response to lawful requests from state or municipal authorities, including for the purposes of ensuring national security or enforcing legal obligations; 
 - in connection with the sale, transfer, merger, bankruptcy, restructuring, or other reorganization of the business; 
 - for the purpose of protecting the rights, legitimate interests, or property of the Company or third parties; 
 - for the purpose of protecting the right to privacy of other individuals. 

7. COOKIES 
A cookie is a small text file that a website stores on your computer or mobile device when you visit it. A cookie stored on your device ensures the functionality of our Website and helps us recognize you when you revisit our Website. 
Most web browsers automatically store cookies unless you refuse them or change your browser settings. 
The following cookies may be used on our Website: 
 - Necessary cookies – these cookies are required for the proper functioning of our Website. They include, for example, cookies that allow us to store information you have entered during a browsing session and enable you to access secure areas of our Website. Without these cookies, the operation of the Website would be impossible or certain functions would not work properly. 

More information about how to delete cookies and other useful information related to the use of cookies can be found at www.allaboutcookies.org/.

8. SPECIAL CATEGORIES OF DATA 
The Company does not collect special categories of personal data such as political opinions, religious beliefs, health data, biometric or genetic data, or data related to sexual orientation. Please do not provide such data. If such data is identified, it may be deleted immediately. 

9. THIRD-PARTY LINKS 
The Website may contain links to third-party websites or applications. The Company is not responsible for their data processing practices. Please review their privacy policies separately. 

10. DATA RETENTION PERIODS 
Personal data collected by the Company is stored in paper documents and in the Company’s information systems. The Company retains your personal data no longer than required for the purposes of data processing or for a longer period where such retention is required by applicable laws. 
Personal data is generally retained for as long as justified claims may arise from contractual relationships or for as long as necessary to pursue and protect the Company’s legitimate interests. Personal data that is no longer necessary is destroyed. 
If you wish to delete your account and terminate the storage of your personal data, you may do so by submitting a request to the Company using the contact details provided below. Please note that in such cases the provision of services to you may be terminated. Please be aware that even after receiving a request to delete your personal data, the Company may retain certain data where this is necessary for tax, legal compliance, and audit purposes. 
The Company takes all reasonable measures to ensure that personal data is processed accurately, fairly, and lawfully, and that it is processed only for specified purposes, in strict compliance with the clear and transparent personal data processing requirements set out in applicable laws. 

11. YOUR RIGHTS 
As a visitor to our Website, you have the right to: 
 - contact the Company with a request to receive information about the personal data processed by the Company, including the source and method of collection and how such personal data is processed. Requests may be submitted in person, by post, or by electronic means; 
 - request the correction of your personal data and/or suspension of data processing activities (except storage), where, after reviewing your personal data, you determine that such data is incorrect, incomplete, or inaccurate; 
 - request the deletion of your personal data where, after reviewing your personal data, you determine that the data is processed unlawfully or unfairly, or where other legal grounds for deletion exist; 
 - object to the processing of your personal data where such data is processed or intended to be processed on the basis of the legitimate interests pursued by the Company or a third party to whom the data is disclosed; 
 - request that you not be subject to decisions based solely on automated data processing, including profiling; 
 - receive personal data relating to you that you have provided to the Company in a structured, commonly used, and machine-readable format and to transmit such data to another data controller, or request that the Company directly transmit such data to another data controller where technically feasible (right to data portability); 
 - refuse to provide personal data. In such cases, you automatically waive any claims regarding the quality of services provided by the Company, as the requested data may be necessary to properly provide the services or products requested by the data subject. In such cases, the Company has the right to refuse to provide services where service provision is related to the collection of your personal data. 

For the exercise of your rights or to submit complaints, you may contact the person responsible for personal data protection at the Company by email at info@gurmans.eu. You also have the right to contact the State Data Protection Inspectorate; however, we encourage you to contact the Company first, as we always aim to resolve issues directly with visitors. 
PWhen submitting a request, you must verify your identity as follows: 1) if the request is submitted in person at the Company – by presenting an identity document or a copy certified in accordance with the laws of the Republic of Lithuania; 2) if the request is submitted by post or email – by providing identifying information held by the Company; 3) if the request is submitted through a representative – by providing a copy of the identity document certified in accordance with Lithuanian law, together with a document confirming representation (or a duly certified copy of a power of attorney). 
Upon receipt of your written request, the Company shall provide the requested information in writing (including by electronic means) or indicate the reasons for refusal no later than within 30 calendar days from the date of receipt of the request. Where necessary, the 30-day period may be extended by an additional two months, taking into account the complexity and number of requests. The Company shall inform the requesting person of such an extension within one month of receipt of the request, together with the reasons for the delay. 

12. UPDATES TO THE PRIVACY POLICY 
This Policy may be amended in response to changes in circumstances or legal requirements. Upon updating the Policy, the new version shall be published on the Website www.gurmans.eu. In the event of material changes to the Policy, we may contact you by email or inform you by other means. 

13. CONTACT INFORMATION 
If you have any questions regarding the information provided in this Privacy Policy, please contact the Company using any of the following methods: 
info@kavinukoprekyba.lt
Rodūnios kelias 9, Vilnius
+370 616 70 964