Privacy policy

Updated version. Valid from 5th of April 2019


PRIVACY POLICY


UAB „Newsec advisers LT“ (hereinafter in this document – the Auctioneer or NEWSEC) especially respects yours (hereinafter in this document – Visitors, Registered users, Participants or Buyers) privacy, therefore, collects, stores, uses and discloses your personal data, including Personal Data, which you submit when using an electronic auction platform managed by NEWSEC and available at www.newsecaukcionai.lt (hereinafter in this document – the Website), only as described in this privacy policy (hereinafter – the Privacy Policy) and in accordance with the applicable legal acts.


DEFINITIONS

In the Privacy Policy definitions and expressions, which are written in the capital letter, shall have the same meaning as defined in the Terms of Use of Website, other documents of the Rules and (or) other requirements and instructions available on the Website, except the cases where for definitions in this document and written in the capital letter down below the specified meaning are given:

Anonymous Information – information, which is not related to your Personal Data; anonymous information does not allow to identify specific persons and is collected automatically or created using the Personal Data but excluding data (including such as your name or surname), which would allow to identify your identity;

Personal Data – any information about you, as a natural person, whose identity has been identified or can be identified; 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).

Cookies – small file, which is sent into your browser and stored in your computer, mobile phone or other device, which you are using to connect to the Website.


GENERAL PROVISIONS

NEWSEC ensures your Personal Data, which is submitted while using the Website tools, security and confidentiality under the terms and conditions that are set in the Privacy Policy.

By transmitting Personal Data through the Website, you confirm that you agree to the Privacy Policy and the Rules and also confirm that your Personal Data would be processed in accordance with the Privacy Policy.

The Privacy Policy is mandatory to any person, who visits the Website and (or) by using its tools is interested in, makes inquiries about the contacts indicated on the Website, participates in real estate auctions, and in the other way uses the Website, any services, tools available on the Website, or any content of the Website ie a person is a NEWSEC client. If you disagree with this Privacy Policy or any of its provision, you cannot use the Website and any services, tools available on the Website, or any other content of the Website. 

NEWSEC reserves a right to revise (including to modify, amend, supplement, annul) this Privacy Policy or any part thereof and any linked information in accordance with the rules established in the Terms of Use of Website.

NEWSEC reserves the right, at its sole discretion, to change, modify, add, remove, discontinue, annul or terminate any portion of the Website and (or) the Website services without prior notice.


ANONIMITY AND AUTOMATIC PROCESSING OF ANONYMOUS INFORMATION

The Website creates an opportunity to use it anonymously, i. e. to use it in the way that only Anonymous Information would be collected about you through the Website’s tools. You can use the Website anonymously until you decide otherwise or until you decide to perform the actions, which requires to disclosure your Personal Data (for example, to create an Account or to connect to your Account, to register in the Auctions and etc.).

We note that the Website automatically collects that Anonymous Data about you, which is in the Cookies’ files. More information about the use of the Cookies is given in the Section 9 of the Privacy Policy.


DATA COLLECTION AND USE

Each time the Visitor, Registered user and (or) Participant visits the Website, the Website’s servers temporarily save the information about the device, which is connecting, i. e. the Anonymous Information listed in Clause 3.2 of the Privacy Policy. In this procedure, regardless actions of the Visitor's, Registered user’s and (or) Participant’s, the specified Anonymous Information is automatically collected and stored as long as it is deleted automatically and (or) manually. This Anonymous Information is collected and processed in order to allow the Visitor, Registered users and (or) Participants use the Website (to login) and in order to guarantee the constant security and stability of the system, technical administration of the network infrastructure, as well as to optimize the Website and, simultaneously, NEWSEC activities and for internal statistical purposes. In addition, the IP address may be investigated and used in the cases of the violation of the Rules, attacks on the Website’s infrastructure and in other cases where this is provided by the Privacy Policy or applicable legal acts.

While creating the Account or participating in the Auctions, NEWSEC collects and stores Personal Data that identifies the Registered user and (or) Participant. In such case, depending on the information actually provided, the following data, including Personal Data, may be collected and stored:

  • name and surname, address, telephone number, e-mail address, information about a legal entity, when and if you are representing it, and any other information provided in your Account;
  • for the purpose of the return of the Initial participant fee, bank account numbers can be collected;
  • IP address and Registered user’s identifier (which is assigned by the system);
  • for the purposes of invoicing – financial information, which you provide, when you are buying Auction objects, also VAT payer’s code, if applicable;
  • information about your actions that you perform on the Website as a Registered user and (or) Participant (including history of participation in the Auctions);
  • other information related to your actions performed while participating in the Auctions on the Website, using the Website, including data about standard login information;
  • additional information from you or about you, which is not separately described in this document (for example, information, which is related to your applications to NEWSEC);
  • NEWSEC may collect information about your device that you use to connect to the Website for example, personal computer, notebook, mobile phone etc.) for purposes of the Website administration;
  • other information related to the actions of the Visitor, Registered User and (or) Participant from interaction with the Website, the Website services, content and advertising, including discussions, chats, correspondence through the Website, correspondence sent to us, device ID, connection information, statistics on page views, traffic to and from the Website, advertising data and standard web log information;
  • other information that you provided on the Website, including the choice of getting NEWSEC newsletters or not, as is described in Section 0 of the Privacy Policy.

The main purpose of the collection of your Personal Data is to ensure that operations while performing actions on the Website and participating in the Auctions and purchasing the Auction objects, would be executed smoothly and without interruptions, all operations would be safe, efficient and individually tailored. You agree and approve that the NEWSEC has a right to use your Personal Data, including the data specified in Clause 0 of the Privacy Policy, for the following purposes:

  • provide NEWSEC services, Website services and Visitor, Registered user and/or Participant support, if requested;
  • collect Initial participants fees and resolve troubleshoot problems;
  • prevent, detect, and investigate potentially prohibited or illegal activities on the Website;
  • customize, measure and improve NEWSEC services, Website service, content and advertising;
  • to perform the real estate e. Auctions, i. e. to organize Auctions, to conclude and perform sale-purchase contracts of the Auction objects with the Auction’s winners and (or) Buyers (Participants’, Auction’s winners and (or) Buyers identification, sale of the Auction object, organization of the settlements and fulfillment of the other obligations arising from the relations of the sale-purchase of the real estate in the Auctions);
  • to perform the directly marketing in order to send you the newsletters (only with your separate consent);
  • to ensure an access to the services and information on the Website, also for the other purposes, which are indicated in the specific case, when the information is collected.

Submission of Personal Data specified in Clause 0 of the Privacy Policy and confirmation on its processing, are voluntary, but mandatory in order to ensure your appropriate and comprehensive use of the Website.

NEWSEC stores the actual data about your participation in the Auctions and purchases of the Auction objects. By using the tools installed in your Account, you can view your participation in the Auctions and the proposed price history, acquisitions of Auction objects, and change your Personal Data. You must keep safe your Account’s access data and not disclose it to the third parties.


NEWSLETTERS AND USE OF E-MAIL

By pursuing a legitimate interest as a real estate consulting company to provide services to our clients, we send you newsletters about ongoing auctions, auction objects, events, and similar NEWSEC services, if you have not previously objected to such notifications. For other purposes, we will process your data only with your separate consent. When your data is processed with your consent, your consent is voluntary and is not required to use the Site or to participate in the Auction. You can opt-out of newsletters at any time by using the Website functionality sent by email. or by contacting the NEWSEC Privacy Policy at 11.2.

In any case, you cannot refuse to receive administrative information, which is related to the participation in the Auctions, services provided by NEWSEC or the Website (including the Rules) from NEWSEC. Also, you may not refuse to receive messages from NEWSEC, which provide the legal information related to Auctions and (or) use of the Website.


DISCLOSURE OF INFORMATION

We may disclose your Personal Information to respond to legal requirements, enforce our policies, reply to provided claims or other content, that violates the rights of other third parties, or protect anyone's rights, property or safety. Such information will be disclosed in accordance with applicable laws and regulations of the Republic of Lithuania and European Union.

You agree and confirm that NEWSEC could provide your Personal Data:

  • to NEWSEC partners – third parties, who are used by NEWSEC while executing Auctions or providing other services as providers of third parties services. For example, to NEWSEC partners, who provide services of collection of the payments, other services that were ordered by the Registered user and (or) Participant, also to the NEWSEC partners, who provide the Website’s assistance and (or) maintenance, other services that help NEWSEC to develop activities or perform other operations on the Website;
  • to the other third parties, when you submit appropriate request to submit your Personal Data (or to the third parties, about who you are clearly informed in the other way and providing of the information is agreed while using the specific service);
  • to the other business subjects, in case NEWSEC merges with the other legal entity, NEWSEC acquires the other legal entity or the other legal entity acquires NEWSEC, also in cases where the Website or assets related to the Website would be transferred.

In the cases specified in Clause 6.2 of the Privacy Policy, NEWSEC will transfer a minimum amount of your Personal Data. In the other cases, without your clearly expressed consent (prior or separate), NEWSEC will not transfer your Personal Data to the third parties, except the cases where it is necessary to be done in order to implement provisions of the Privacy Policy or if NEWSEC would be legally bound to do so.  


YOUR RIGHTS AND OBLIGATIONS RELATED TO PROCESSING OF YOUR PERSONAL DATA ON THE WEBSITE

While registering (the Visitor), i. e. opening (creating) the Account on the Website, or registering in the Auction (the Participant), you will be asked to submit your Personal Data.

When you become the Registered user and create the Account, you can log in to your Account and independently manage your Personal Data, which is submitted in the registration form (to change or update).

Your password is your key to your Account. While creating your password, please use unique numbers, letters and special signs and do not disclosure your password to anyone. You can change your password at any time by logging in to your Account. If you forget your password or have any other problems while logging in, we kindly ask you to click on the "Forgot your password?" link in the Website or contact NEWSEC by the contacts specified in Clause 11.2 of the Privacy Policy.

If you disclosure your password or any other information about your Account to the other persons, you will be liable for all and any actions performed while using your Account. We note that in case you are connecting to the Website while using the shared or public computer, some information about you may be visible for other persons, who will use the computer after you. If you use the computer jointly with other persons, you have to log out, when you finish using your Account. It is necessary even then, when you leave the computer just for a moment. In such a way you will be ensured that the other persons would not see, use or change your information or data.

If you lose your password, you may not control actions made with your Personal Data and may, in your name, be bound by the obligations for which you will be liable. Therefore, if you suspect that anyone else could use your password, you have to inform NEWSEC as soon as possible by the contacts indicated in Clause 11.2 of the Privacy Policy and change your password.

If your Personal Data is changed or it is inaccurate, you understand and undertake to update your Personal Data while using the Website‘s functionalities or contacting NEWSEC as soon as possible by the contacts indicated in Clause 11.2 of the Privacy Policy.

If you do not want to use the Account anymore and wish to delete it, you can delete it with the tools in the Website or submit the request to NEWSEC by the contacts indicated in Clause 11.2 of the Privacy Policy. NEWSEC has a right to process your Personal Data till deletion of your Account under provisions of the Privacy Policy and (or) Rules. Your Account and your Personal Data are deleted under the provisions of the Privacy Policy and Rules. You may lose the access to your data, which is in the Account, after the deletion of your Account, unless the Privacy Policy or Rules provide otherwise.

In order to ensure the implementation of the Personal Data collection purposes provided in the Privacy Policy, your Personal Data may be stored for a period not exceeding 2 (two) years, calculated it from the last your access to your Account, the last your participation in the Auction or purchase of the Auction object while using the Website or when Personal Data is processed for the purpose provided in Clause 4.3.6 of the Privacy Policy, from the moment you give the consent, except exceptions provided in the applicable legal acts.


DATA PROTECTION

NEWSEC, first of all, seeks to ensure his Visitor‘s, Registered user‘s, Participants and (or) Buyer‘s data security. To ensure the security of transferred information and data, NEWSEC implements technical and organizational measures, corresponding the threats of security of services’ provision. NEWSEC uses reasonable physical, electronic and procedural measures and methods in order to protect the information from loss, theft or any unauthorized use, disclosure or alteration.

We want to draw your attention that despite the fact that NEWSEC uses appropriate above indicated measures, NEWSEC may not guarantee and not guarantee security of your Personal Data, because it is submitted and collected via internet. Also, the measures implemented by NEWSEC may be insufficient, if you do not comply with the security rules. First of all, the Registered users and (or) Participants must do not disclosure their Account access data to the third parties. Please note that the Website will ask you to submit your e-mail and password just when you try to log in to your Account. In order to prevent unauthorized persons from access to your Account, please disconnect from your Account and (or) Website after using it.

By your actions you can also reduce the risk of unauthorized access to Personal Data, if you act with caution and choose smart security measures, such as choosing a complex password, using the latest anti-virus software, etc.

You have a right to ask NEWSEC to provide you with all information about your Personal Data that is processed by NEWSEC, you also have a right to ask NEWSEC to correct (change, supplement, and update) or delete such data, or to restrict processing of such data under the applicable legal acts. You also have a right to object to processing of Personal Data and withdraw the given consent for the processing of Personal Data for direct marketing purposes under the procedures provided in this Privacy Policy, without prejudice to legitimacy of processing of data based on such consent till the withdrawal of the consent, also you have the right to the transferability of the Personal Data. If you want to use these rights, we kindly ask you to contact NEWSEC by the contacts indicated in Clause 11.2 of the Privacy Policy. We also inform that you have a right to lodge a complaint with a supervisory authority in case you think that your rights related to processing of Personal Data, are infringed.


COOKIES POLICY

The Cookies are used in the Website for the following purposes:

for proper functioning of the Website and improvement of your browsing experience;

for collection of statistical Website data (including Website’s traffic calculation) and development of the Website.

The first time you access the Website, there is an information line, which contains a link directing to this Privacy Policy with all the information about Cookies, which are installed and used on this Website. By continuing to browse the Website or clicking the button "x", you confirm, that you agree and allow the Website’s to install Cookies to your terminal device (computer, tablet, smartphone, etc.).

Annex No. 1 of this Privacy Policy provides detailed information regarding Cookies that are used on the Website.

You can block the use of the Cookies and remove Cookies at any time by using your browser software. For more information on how to manage the Cookies in your browser, see the "Help" tab on the internet browser's menu. However, we want draw your attention to the fact, that in this case you may not be able to fully use all the features of the Website, because blocking or deleting the Cookies may affect some of the features of the Website.



This Privacy Policy covers use and disclosure of that information, which we are collecting from you through the Website, unless otherwise is clearly stated in the Privacy Policy. If you through the Website or other internet websites disclose your Personal Data for other persons, no matter they are Visitors, Registered users or other third parties, other rules may be applied to use and disclosure of appropriate information.

NEWSEC does not control privacy policies and (or) other rules that are applied to you by the third parties. Therefore, you, at your own discretion and risk, are liable and obligated to comply with them in those cases, when it is applied to you. NEWSEC is not liable for other Websites’ privacy policies or any other content, when reference to the other Websites are given on the Website, or the reference to the Website is given on other websites. Those websites may have their own privacy policies, with which you are recommended to get acquainted. When you are pressing the reference, logo or any other element of the Website, or when using the services available in the Website, we notice that at the time, when you press any mentioned element, you may leave the Website.

NEWSEC does not collect any information about you from third parties, except the cases specified in the Privacy Policy or in the Rules, also when the legal acts’ requirements or the Rules are infringed, or third parties rights’ are infringed.


FINAL PROVISIONS

The Privacy Policy is integral and inseparable part of the Rules. Matters, which are not regulated by this Privacy Policy, are regulated by the Terms of Use of Website and other documents of the Rules.

If you need help or have any questions and (or) claims related to the Privacy Policy and (or) its application, we kindly ask you to contact NEWSEC by using the following contacts and we will answer into all your requests under the procedure established in the Terms of Use of Website.

Annex No. 1

Nr.

Cookie

Name

Purpose of data processing

Moment of creation

Date of expiry

Used data
1.
Cookie, necessary for the Website’s functionality
october_session
Cookie, necessary for the Website’s functionality
When entering the Website
2 hours
from the last user’s action in the website
Encoded settings of the user’s website visit: search filter values and so on
2.
user_auth
user_auth
A cookie, necessary for the logged in user's functionality
Successfully logged in with your username and password
5 years
from the last user’s action in the website or till closing of the website, i. e. annul his session on the Website
Encoded settings of the technical data (unique ID and role), necessary for the logged in user's functionality
3.
__cfduid
__cfduid
Maintain Cloudflare functionality
When entering the Website
1 year

4.
_ga
_gid
_gat
_ga
_gid
_gat
part of the Google Analytics statistics system, it preserves information about the user's website visits, the number of visits, the visit time, browser data, etc.
When entering the Website



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