PRIVACY POLICY – SLC PANORAMA

This Privacy Policy (hereinafter – the “Policy”) provides basic information about the processing of personal data of the website visitors, newsletter subscribers and customers of the shopping and leisure centre Panorama (hereinafter – “SLC Panorama”).

The personal data controller is Panorama LT, UAB, company registration number: 125765062, registered address: Saltoniškių g. 9, Vilnius, tel.: (8 5) 275 81 57, email: panorama@panorama.lt (hereinafter referred to as the “Data Controller”).

Contact details of the Data Protection Officer: Donatas Jakštas, tel.: +370 616 04552, email: donatas.jakstas@panorama.lt.

If you have any inquiries about this Policy or about the protection of your data, feel free to contact the Data Controller using the contact details above.

1. PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES

1.1 The Data Controller processes your personal data for direct marketing purposes whenever you subscribe to the Data Controller’s newsletters which contain information about the latest special offers, promotional campaigns, events as well as other information relevant to the visitors of SLC Panorama.

1.2. When sending these newsletters, the Data Controller processes your personal data only on the basis of your consent, i. e. after you have subscribed to these newsletters on the Data Controller’s website or social media accounts. The Data Controller processes the following personal data for direct marketing purposes: your name, email address and sex.

1.3. The Data Controller can transfer your personal data to the data processor that the Data Controller might use.

The data processor assists the Data Controller in administering the website of SLC Panorama and in the distribution of newsletters. The data processor may only process your personal data subject to the Data Controller’s instructions.

1.4. Your personal data processed for direct marketing purposes are stored for as long as you remain subscribed to our newsletters. Once you withdraw your consent for the processing of your personal data for direct marketing purposes, the Data Controller will process such data for the period specified in section 5.2 of this Policy.(e. g. via email) by informing the Data Controller using the contact details above.

2. PROCESSING OF PERSONAL DATA AFTER SUBMITTING AN ENQUIRY

2.1. The Data Controller processes your personal data whenever you contact the Data Controller by email, submit an enquiry on the website or social media pages of SLC Panorama or using other means.

2.2. In such case, your personal data are processed for the following purposes: for ensuring the quality of the services provided to you (managing enquiries), for complying with legal requirements and for protecting the Data Controller’s interests.

2.3. The Data Controller processes your personal data for the purposes specified in section 2.2 of this Policy on the basis of your consent which is implied through you contacting the Data Controller.

2.4. The retention period of your personal data processed by the Data Controller after you submit an enquiry is up to three (3) years depending on the type of data provided to the Data Controller and other factors. However, such data may be stored for a longer period if it is necessary for the protection of the rights and lawful interests of the Data Controller, for replying to your enquiry, for resolving a dispute or in other cases stipulated by law.

3. PROCESSING OF PERSONAL DATA OF THE VISITORS OF SLC PANORAMA

3.1. After you visit SLC Panorama, the Data Controller may process your personal data in the following cases:

3.1.1. Where general video surveillance of the premises of SLC Panorama is performed.

3.1.2. Where SLC Panorama hosts various events during which visitors may be photographed and/or filmed (the processing of the visual data of such visitors is performed);

3.1.3. Where SLC Panorama provides Wi-Fi that visitors can use on their devices (the processing of the technical data of the devices of such visitors is performed).

General video surveillance performed by SLC Panorama

3.2. The Data Controller processes the visual data of the visitors of SLC Panorama and their vehicles on the basis of the Data Controller’s legitimate interests to ensure the protection of individuals and their property and to manage the car park effectively.

3.3. The recipients of such visual data are the data processors that the Data Controller might use, i. e. security companies, companies engaged in the maintenance of video surveillance equipment or companies managing the car park of SLC Panorama. The Data Controller may only share the visual data of the visitors of SLC Panorama with other data recipients on the legal basis stipulated by law.

3.4. Visual data are recorded and are usually stored for a period of up to thirty (30) days. Such visual data may be stored for a longer period (especially in cases when the visual data obtained from the tenants/visitors of SLC Panorama involves offences committed at SLC Panorama) where such data are required for the protection of the rights of the Data Controller or other persons as well as in other cases stipulated by law.

Processing of visual data of the visitors of events organised by SLC Panorama

3.5. SLC Panorama hosts various events during which visitors may be photographed and/or filmed. The Data Controller processes such visual data for the purpose of publicising such events and on the basis of the visitors’ consent (which is implicitly given when you attend such events).

3.6. We would like to inform you that such visual data of the visitors (e. g. photographs) of the events held at SLC Panorama may be made public (e. g. by posting them on the social media account or website of SLC Panorama, newsrooms or other media outlets). The publication of the visual data of the visitors of the events is related to the public awareness-raising of such events.

3.7. The visitor of the event organised by SLC Panorama has the right to withdraw his/her consent for the processing of his/her visual data for the purpose of publicising such event. This can be done by notifying the Data Controller in writing (e. g. via email) using the contact details above.

3.8. The visual data of the visitors of the events hosted by SLC Panorama are stored for up to five (5) years. However, such personal data may be stored for a longer period in certain cases if it is necessary for the protection of the rights and lawful interests of the Data Controller or in other cases stipulated by law.

Processing of personal data of the Wi-Fi users of SLC Panorama

3.9. Whenever the visitors of SLC Panorama access Wi-Fi available at SLC Panorama on their devices, the Data Controller processes certain types of technical information (e. g. access time, etc.) from the devices of such visitors. The processing of such personal data is required for the provision of Wi-Fi service at SLC Panorama and such data are processed on the basis of the Data Controller’s legitimate interest.

3.10. Such personal data of the visitors of SLC Panorama are usually processed for a period of up to two (2) years. However, such personal data may be stored for a longer period in some cases if it is necessary for the protection of the rights and lawful interests of the Data Controller or in other cases stipulated by law.

4. WEBSITE USE

4.1. Whenever the user visits the website of SLC Panorama, the Data Controller may process the IP address and network data of such user where he/she provides such data. Such data are collected through the use of cookies and/or similar technologies on the basis of the user’s consent.

4.2. The website of SLC Panorama uses the following types of cookies:

4.3. Cookies are small text files that are sent to your internet browser and placed on your computer or other device. Cookies are placed on your computer when you visit the website of SLC Panorama for the first time. Cookies are used to make the website safe, secure and user-friendly and to analyse the browsing habits of the website visitors in order to ensure continuous improvement of the functioning of our website. Certain types of cookies (essential and analytical cookies) are necessary to make the website of SLC Panorama operational. Turning these cookies off may result in a loss of functionality when using the website.

4.4. You can manage your preferences concerning cookies by changing your browser settings. To learn more about how to delete cookies as well as other useful information relating to the use of cookies, visit here or here.

4.5. To opt out from Google Analytics cookies, download and install Google Analytics Opt-out Browser Add-on. You can find Google Analytics Opt-out Browser Add-on : here.

5. PERSONAL DATA RECIPIENTS AND OTHER INFORMATION

5.1. Along with the data processors and recipients listed in this Policy, the Data Controller may use other data processors (e. g. specific service providers) to process your personal data. Such data processors may include companies specialising in the provision of data storage services, software development and support companies, network operators, web analytics providers, marketing service providers or other providers of services. Your personal data may be disclosed to such data processors used by the Data Controller as much as is necessary for the provision of their services.

5.2. We further inform you that the consent given by you for the processing of your personal data will be stored by the Data Controller for a minimum retention period (one (1) year following the expiry of the storage period of personal data for which the consent has been given) established by the Office of the Chief Archivist of Lithuania.

6. YOUR RIGHTS AS A DATA SUBJECT

6.1. You may exercise the following rights:

6.1.1. To request to access your personal data and the way they are being processed. You have the right to receive the confirmation by the Data Controller as to whether the Data Controller processes your personal data and to access your personal data being processed by the Data Controller as well as to access information about the purposes of processing your data, categories of data being processed, categories of data recipients, data processing periods and sources of obtaining your personal data.

6.1.2. To request rectification of incorrect, incomplete or inaccurate personal data. If you think that the information that the Data Controller processes about you is inaccurate or incorrect, you have the right to request to change, update or rectify such data.

6.1.3. To have your personal data erased. In certain situations stipulated by law (where the processing of personal data is unlawful or where the basis for the processing of personal data is no longer valid), you have the right to have such data erased by the Data Controller.

6.1.4. To request to restrict the processing of your personal data. In certain situations as prescribed by law (where the processing of personal data is unlawful, you have disputed the accuracy of data, you have objected to the processing of your personal data on the basis of the legitimate interest of the Data Controller, etc.), you have the right to request the restriction of processing of your personal data.

6.1.5. To request that the Data Controller transmits your personal data to another data controller or to provide such data directly to you in a form convenient to you. You have the right to transmit the data to another data controller where such data are being processed by the Data Controller on the basis of your consent and where the processing of such data is carried out by automated means.

6.1.6. The right to object to the processing of your personal data where such data are being processed on the basis of legitimate interests except for cases where there are legitimate grounds for the processing of such data or in order to submit, perform or defend lawful claims.

6.1.7. In cases where your personal data are processed on the basis of a separate consent, you have the right to withdraw your consent for the processing of your personal data at any time. In this case, the processing of your data carried out on the basis of your consent will be terminated.

6.2. If you want to exercise your rights as a data subject or if you have other enquiries concerning the protection of your personal data, you can contact the Data Controller in written form (e. g. via email) using the contact details provided above. If you think that your personal data are being processed unlawfully or your rights pertaining to the processing of personal data are being violated, you have the right to bring the matter to the attention of the State Data Protection Inspectorate and to file a complaint with this institution regarding this issue. However, in any case, we recommend that you contact the Data Controller first before you file an official complaint with the supervision body.

7. FINAL PROVISIONS

7.1. This Policy may be updated from time to time. In all cases, the Data Controller will make available the latest version of this Policy on the website of SLC Panorama.