This Privacy Policy is intended to inform you about how we,  TUTORY , collect, use and share your personal data that you provide or that we otherwise collect. We do this to ensure that we collect and use information about you fairly and transparently.

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We  aim to provide you with comprehensive information about the processing of your personal data and the rights of the data subject, regardless of whether you provide personal data when communicating with us by telephone, at events or by electronic means (for example, using the website) or in any other way you choose.

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Your personal data is processed in accordance with Regulation (EU) 2016/679, the Law of the Republic of Lithuania on the Legal Protection of Personal Data, as well as other legal acts.

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Key terms used in the privacy policy

Personal data – any information relating to a natural person whose identity is known or can be directly or indirectly determined using personal data, such as name, surname, personal identification number, address, email address, internet identifier, etc.

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Data subject – a recipient of training services, a person who submitted an inquiry, a natural person who has signed a contract with TUTORY and/or is performing these contracts, or a representative or employee of a legal entity, a person using the website, or another natural person whose identity is known or can be directly or indirectly determined using personal data.

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Data subject consent means any freely given, specific and unambiguous indication of the data subject's wishes, by a statement or by a clear statement, by which he or she signifies agreement to the processing of personal data relating to him or her.

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Processing is any operation or set of operations performed on personal data (collection, recording, use, consultation, storage, disclosure, etc.).

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Data controller – MB VN Solutions, a small partnership established and operating in accordance with the legal acts of the Republic of Lithuania. Company code – 305660554, address – Vokiečių g.18, Vilnius, LT-01130.

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For what purposes and legal grounds does TUTORY collect and process your personal data?

TUTORY collects and processes your personal data for the following purposes:

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In order to ensure communication with potential and existing service providers, to conclude and perform contracts, we process the personal data of potential and existing service providers (natural persons) (name, surname, individual activity certificate number, address, telephone number, e-mail address, contract terms, other necessary data). Personal data is processed in order to pursue our legitimate interests in conducting commercial activities and in order to conclude and perform a contract to which the data subject is a party.

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For the purpose of providing training services (organizing classes, registering for classes and confirming registration, establishing conditions for participating in classes, providing information about changes in the date or time of classes or their cancellation), we process the name, surname, information about classes (date, time, duration, location, tutor conducting classes), telephone number, email address, and other necessary data of potential and current service recipients. Personal data is processed in order to pursue our legitimate interests in conducting commercial activities and in order to conclude and perform a contract to which the data subject is a party.

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For the purpose of invoicing and accounting, we process name, surname, address, telephone number, e-mail address, contract terms, information about contract performance, account details, payment information, and other necessary data. This personal data is processed on the basis of concluding and performing the contract and in compliance with legal obligations.

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For the purpose of administering inquiries received via the website and/or by email, we process the contact person's data, email address, telephone number, IP address, message content, other data provided by individuals, the content of the response provided, and other information related to the response provided. Personal data is processed with the consent of the individual.

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For the purpose of direct marketing (so that we can inform you about the services provided, promotions and special offers, and ask for your opinion about the service provided both electronically and by phone), we process your name, surname, address, telephone number, and email address. By giving your consent to use your personal data for direct marketing purposes, you agree to receive TUTORY offers. You may withdraw your consent to the processing of your personal data for direct marketing purposes at any time by contacting us by e-mail info @tutory.lt . Withdrawal of consent does not affect data processing performed prior to withdrawal.

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We inform you that if you are our client (you have signed a service agreement), we will process your email and telephone contact data for direct marketing purposes without your separate consent. In pursuit of legitimate interest, we will process and analyze information about the services you have purchased, but this will not cause you any legal consequences or similar effects.

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If you do not agree to such processing of personal data, you may object at any time using any of the contacts specified in this Privacy Policy.

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For the purpose of presenting TUTORY and its activities to the public, we process the personal data of service providers (name, surname, education, other information related to the person's professional activity, photo) and information provided by service recipients (name, type of classes, feedback on the services provided). Personal data is processed with the consent of the person or in pursuit of the legitimate interest of TUTORY to present its activities to the public, considering that the processed personal data is necessary to achieve the specified interest, related only to the work (professional) activities of the data subjects or the services received. 

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We process personal data collected using cookies for the purpose of ensuring the functionality and efficiency of the website, ease of use, speed and security of the website, and other purposes. Personal data is processed based on consent and in accordance with the Law on Electronic Communications of the Republic of Lithuania.

TUTORY may process personal data for other purposes as well, to the extent necessary to lawfully carry out its activities, comply with legal requirements, defend itself against claims, lawsuits and protect our legitimate interests. Personal data is processed in accordance with the requirements of the Regulation and other legal acts.

When collecting personal data, we provide you with information about which data is mandatory, i.e. without which we will not be able to provide you with the services you have selected or achieve other established personal data processing purposes. 

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IMPORTANT: By providing us with the personal data of other persons, you undertake to ensure the legality of the provision of data (obtaining the consent of these persons, etc.) and to provide these persons with information about where and how they can access this Privacy Policy.

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To whom may your personal data be provided?

TUTORY is committed to maintaining confidentiality when processing personal data. Personal data is provided to third parties only if there is a legal basis for providing personal data and after assessing the purpose of providing personal data and the scope of personal data provided. We may disclose your personal data to the following recipients:

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• To the State Tax Inspectorate, other state institutions, when we are obliged to disclose data by law or at your request.

• TUTORY engages service providers (data processors) who provide training, accounting, hardware and software development, support and maintenance, sending direct marketing messages, website administration and other services to whom personal data is provided or who are given access to personal data. 

• Personal data may be provided to courts, law enforcement authorities, state institutions conducting inspections of the company's activities, and other third parties in order to protect the rights and legitimate interests of TUTORY.

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Personal data, in accordance with Regulation (EU) 2016/679 and other legal acts, may be provided to other third parties to whom we are obliged by law or other legal acts to provide personal data.

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We may transfer personal data to third countries on the basis of a decision of the European Commission on an adequate level of protection, standard data protection clauses approved by the European Commission or a data protection supervisory authority, or at least one of the conditions set out in Article 49(1) of the Regulation, if it is not possible to rely on the decisions of the European Commission or the data protection supervisory authority referred to above.

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How long and how will your personal data be stored?

The collected personal data is stored in our information systems. Personal data is stored for as long as it is necessary for the specified purposes or for the periods established in the legal acts of the Republic of Lithuania regulating the storage periods and procedure.

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We store your personal data:

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• for the purpose of concluding and executing contracts – during the validity period of the contract and for 1 year after the end of the contract;

• for the purpose of providing training services – during the contract period and for 1 year after the contract ends;

• for direct marketing purposes – 1 year from the date of submission of the data or during the validity period of the contract and 1 year after the end of the contract; until you withdraw your consent or object to the processing of your data;

• for the purpose of public information – while the person (tutor) has a valid contract with TUTORY, for service recipients – during the validity period of the contract and 1 year after the contract expires;

• for accounting purposes – 10 years after the end of the calendar year in which the economic transaction took place;

• For the purposes of ensuring the functionality and efficiency of the website, ease of use, speed of the website and security, personal data is processed during the validity period of the cookie.

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After the specified periods have expired, the data is deleted in a way that makes it impossible to restore it or transferred to the state archive, if such an obligation is imposed on us by legal acts.

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When processing personal data, we implement the necessary organizational and technical security measures for personal data in order to protect them from accidental or unlawful disclosure or other unlawful processing.

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What rights do you have?

In accordance with the procedure established by law, data subjects must:

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• the right to know about the processing of your personal data;

• the right to access your personal data and receive a copy of it;

• the right to request the correction of inaccurate personal data;

• the right to request restriction of the processing of personal data;

• the right to request the erasure of personal data (“right to be forgotten”);

• the right to withdraw consent to process personal data. Withdrawal of consent does not affect data processing carried out prior to withdrawal;

• the right to object to the processing of personal data when these data are processed or are intended to be processed for direct marketing purposes or for the legitimate interest pursued by TUTORY or a third party to whom the personal data are provided;

• the right to personal data portability.

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Data subjects can exercise their rights by contacting TUTORY by email at info@tutory.lt

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You can find out how to do this by reading the procedure for implementing data subjects' rights, which is presented below.

If the data subject believes that his or her rights have been violated, he or she has the right to file a complaint with the State Data Protection Inspectorate (L.Sapiegos g. 17, 10312 Vilnius,  www.ada.lt ). In all cases, before filing a complaint, please contact us so that we can find an appropriate solution together.

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If you have any questions related to the processing of personal data, please contact TUTORY using the contacts provided above.

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How can you apply for the exercise of your rights?

In order to exercise your rights as a data subject, you must submit a written request and confirm your identity (one of the following documents must be submitted to confirm your identity: passport of a citizen of the Republic of Lithuania, identity card, driver's license).

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The request must include information on which of the above rights and to what extent it is desired to exercise them.

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The data subject may also confirm the identity of the person by signing the application with a qualified electronic signature when the application is submitted electronically.

The requirement for the data subject to confirm their identity does not apply if the data subject requests information about the processing of personal data in accordance with Articles 13 and 14 of Regulation (EU) 2016/679.

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If we have doubts about the identity of the data subject or if we cannot determine the identity of the data subject based on the information provided in the request, TUTORY may request additional information necessary to unambiguously confirm the identity of the data subject.

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When applying for the exercise of rights, a free-form request can be submitted.

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No later than one month from the date of receipt of the request, TUTORY will provide you with information on the actions taken in response to the request. If the request is complex or there are several requests, this deadline may be extended by two more months, if necessary, taking into account the complexity and number of these requests. In any case, we will inform you of such an extension within one month from the date of receipt of the request and indicate the reasons for it.

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If TUTORY decides not to implement the request, you will be informed immediately, but no later than within one month from the date of receipt of the request. Such a decision can be appealed to the State Data Protection Inspectorate and other legal remedies can be used.

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You can withdraw your consent to the processing of your personal data for direct marketing purposes at any time by contacting TUTORY by email  at info@tutory.lt.