Galiojanti redakcija nuo 2025-09-12

INTRODUCTION

UAB Logigama, a company duly registered under the laws of the Republic of Lithuania, having its registered address at Kęstučio g. 34-203, LT-08112, Vilnius, Lithuania, respects and acknowledges the importance of the protection of privacy. The security of personal data is a top priority for UAB Logigama (hereinafter referred to as “Logigama”, “we”, “us”, “our” or the “Controller”).

Logigama duly owns and operates the website https://logigama.digitalkit.agency (the “Website”). The use of our Website is generally possible without the provision of personal data. However, if a data subject would like to use certain services provided on our Website, the processing of personal data may become necessary. In cases where such processing is required and no other statutory legal basis exists, we will obtain the explicit consent of the data subject prior to commencing the processing.

This Privacy Policy (hereinafter the “Policy”) is intended to provide you, as a data subject, with a clear and transparent explanation of how personal data is collected and processed through the use of our Website, including data that may be provided by you when submitting contact details for the purpose of obtaining further information regarding our services.

The processing of personal data (including but not limited to name, address, e-mail address, or telephone number) is carried out strictly in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament from 27 April 2016 (the “General Data Protection Regulation” or “GDPR”), as well as the applicable national data protection laws. Through this Policy, we inform data subjects of the nature, scope, and purposes of the personal data collected, used, and processed by us, and we also inform them of the rights to which they are entitled under applicable data protection legislation.

Logigama has implemented appropriate technical and organisational measures designed to ensure the protection of personal data processed through this Website. Nonetheless, it should be noted that Internet-based data transmissions may be subject to inherent security risks beyond our control, and therefore, absolute protection cannot be guaranteed.

In our capacity as the Controller, we are the legal entity responsible for determining the purposes and means of the processing of personal data and, consequently, for ensuring compliance with the data protection obligations described herein.

By using this Website, you acknowledge that you have read and understood this Privacy Policy. In circumstances where consent is required for specific processing activities (such as the use of non-essential cookies or the provision of electronic marketing communications), such consent shall be requested from you separately and explicitly.

This Policy also applies in other contexts where specific reference is made to it, including but not limited to:

• When we receive your personal data from third parties and are obliged to provide notice of such processing;
• When we first initiate communication with you by e-mail or other means;
• When we process your personal data in the context of events organised by us or by our business partners and explicitly refer to this Policy.

We may process personal data voluntarily provided by you, personal data received from third-parties with whom Logigama has or will establish business or commercial relations (such as our suppliers, partners, affiliates, or other third parties), personal data generated through your use of our Website, as well as personal data obtained from publicly available sources, for the purposes of marketing, contract performance, or other legitimate purposes as set out in this Policy.

This Policy may be amended or updated at any time at our sole discretion. Any changes will be published on our Website to ensure that you are informed of what personal data we collect, how we process such data, and under what circumstances disclosure may occur. The date of the most recent revision of this Policy is indicated at the beginning of this document.

Data subjects are encouraged to regularly review the latest version of this Policy. In the event of material changes, we will make reasonable efforts to notify you (for example, by e-mail where we have your contact details, or by posting a notice on our Website). Continued use of the Website after such updates shall be deemed to constitute acknowledgement and acceptance of the revised Policy.

DEFINITIONS

The Privacy Policy of Logigama is based on the terminology used in the GDPR. Our aim is to keep this Policy clear and understandable for the general public, our customers, and business partners. To that end, we explain below the key terms we use:

a) Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject is any identified or identifiable natural person whose personal data is processed by the Controller. In this Policy, references to “you” or “your” mean the data subject.

c) Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

e) Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

f) Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

g) Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

h) Third party means a natural or legal person, public authority, agency or body other than the Data subject, Controller, Processor and persons who, under the direct authority of the Controller or Processor, are authorised to process personal data.

i) Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

NAME AND ADDRESS OF THE CONTROLLER

For the purposes of the General Data Protection Regulation, other applicable data protection laws of the Member States of the European Union, and related provisions concerning the protection of personal data, the Controller is:

Name: UAB Logigama

Office address: Kirtimų g. 2, LT-02300, Vilnius, Lithuania

Registered address: Kęstučio g. 34-203, LT-08112, Vilnius, Lithuania

General e-mail contact: info@logigama.com

Website: https://logigama.digitalkit.agency

For all questions, requests, or concerns relating to data protection and privacy, you may contact us at: privacy@logigama.com.

COOKIES

Like most websites, the Logigama Website uses Cookies in order to provide you with the best possible browsing experience.

Cookies are small data files stored on your computer or mobile device, which enable us to recognise your device upon subsequent visits. By means of Cookies, we may automatically collect certain non-personal information (such as the type of Internet browser, operating system, domain name, number of website visits, average time spent on the website, and pages visited), without requiring prior registration.

There are generally two categories of cookies:

• Session cookies, which are automatically deleted once you close your browser; and
• Persistent cookies, which remain stored on your device until deleted manually or until they expire according to their defined lifetime.

For detailed information regarding the categories of cookies used, their purposes, storage duration, and management options, please refer to our dedicated Cookie Policy.

COLLECTION OF GENERAL DATA AND INFORMATION

When you access the Logigama Website, certain general data and technical information are automatically collected and stored in server log files. Such data may include the browser type and version, the operating system of the accessing device, the website from which the user arrived at our Website (referrer), the sub-pages visited, the date and time of access, the Internet Protocol (IP) address of the accessing system, the Internet service provider, and other similar technical information which may be relevant in the event of attacks on our information technology systems.

Logigama does not use this information to identify the data subject. Instead, the data is collected for the purposes of correctly delivering Website content, optimising the structure and presentation of the Website as well as associated advertising, ensuring the ongoing security and stability of our information technology systems and website infrastructure, and providing competent law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack.

The collected information is analysed on an anonymised and statistical basis in order to strengthen data protection and data security and to ensure the highest possible level of protection for the personal data that we process. The anonymised data contained in server log files is stored separately from any personal data provided by a data subject.

CONTACT POSSIBILITY VIA THE WEBSITE

The Website contains information that allows for the rapid electronic contact with us, including a general e-mail address, and provides means of direct communication with us.

If a data subject contacts us by e-mail or through a contact form available on the Website, then the personal data voluntarily transmitted by the data subject, is automatically stored. Such personal data is stored solely for the purpose of processing the inquiry or establishing contact with the data subject.

No transfer of this personal data to third parties shall take place, unless such transfer is required by law or is necessary in the context of fulfilling the purpose of the inquiry. Logigama ensures that all personal data received in this manner is processed securely and in accordance with applicable data protection legislation.

E-MAIL MARKETING

Where you have opted in to receive marketing communications from us, we may use your personal data to send you marketing e-mails or messages about our services, including but not necessarily exclusive offers, promotions or events. In such a case, the following categories of personal data may be processed: first name, last name, e-mail address, position/title, phone number, and non-precise location data (e.g. country/state/county).

In using your personal data for such marketing purposes, we rely on your consent. If a marketing e-mail is sent to you, it includes information on how to opt out of receiving such e-mail notifications in the future. You can opt out of processing for e-mail marketing purposes by clicking on the “Unsubscribe” link situated within any marketing e-mails sent to you. You also have the right to object to the processing at any time by contacting us via e-mail: privacy@logigama.com.

Keep in mind that where you withdraw your consent or unsubscribe (as applicable), the third-party’s product, which Logigama is utilising to conduct marketing campaigns, will retain specific personal data (only to the extent that it is absolutely required) on its “do not contact” list.

Logigama may share your personal data with companies that carry out services on our behalf, such as marketing solution providers, as mentioned above. Logigama will process your personal data unless you opt out of the processing for e-mail marketing purposes, and as long as it’s necessary for the specific reasons it was collected, but not longer than reasonably necessary or required by applicable statutory provisions.

PERSONAL DATA WE COLLECT

Clients and potential clients

If you are a contact person at a company that is an existing or potential client of Logigama, we may collect and process personal data obtained either directly from you or from publicly available sources such as LinkedIn, including your name, telephone number, e-mail address, location, LinkedIn profile information, professional role or position, and records of communications with you. This data is processed for the purposes of facilitating proactive client acquisition initiatives, maintaining and developing strong business relationships with clients, communicating in relation to projects and business opportunities, organising business trips, visits, and related logistics, and addressing matters necessary for the successful cooperation between Logigama and its clients. Such processing is necessary for the proper conduct, development, and growth of Logigama’s business operations and to ensure effective client engagement, and is based on our legitimate interests under Article 6(1)(f) GDPR when communicating with potential clients to engage them or to develop new projects with existing clients, as well as on the performance or conclusion of a contract under Article 6(1)(b) GDPR when personal data is processed in the course of contractual relations.

Vendors and suppliers

Similarly, if you are a contact person that is an existing or potential vendor or supplier of Logigama, we may collect and process personal data obtained either directly from you or from publicly available sources such as LinkedIn or your company’s website, including your name, telephone number, e-mail address, LinkedIn profile information, professional role or position, and records of communications with you. This data is processed for the primary purpose of procuring goods and services necessary for Logigama’s operations, and such processing is required for the performance of contracts and to ensure the smooth functioning of our business activities, while also being underpinned by our legitimate business interests under Article 6(1)(f) GDPR in efficient procurement and resource management.

Special categories of data

Logigama does not collect or process personal data that is by its nature particularly sensitive within the meaning of Article 9 GDPR. This includes genetic data, biometric data, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, sex life, or sexual orientation.

PURPOSE FOR COLLECTION AND STORAGE OF PERSONAL DATA

At Logigama, we may use personal data and information collected through our Website or in the course of our business activities for the following purposes:

• Website management: to administer and operate the Logigama Website, to ensure system security and stability, and to improve Website functionality and the overall user experience.
• Marketing and communications: to contact you in relation to the services we provide, to inform you of services offered by our partners, to request products or services provided by you or your company, and to communicate with you, including responding to enquiries or requests.
• Security and investigations: to prevent and investigate potential criminal offences, fraud, unauthorised access, breaches of our terms and policies, and other unlawful or harmful activities.
• Legitimate business purposes: to pursue other legitimate business interests, such as the development and improvement of customer service and client relationships.
• Legal obligations and other lawful purposes: to comply with our statutory obligations, to perform tasks carried out in the public interest, or to protect the vital interests of our clients or other individuals. Where required, we will also notify you of specific lawful purposes prior to or at the time of processing.

Personal data processed for the above purposes may be stored in our secure internal CRM system or other protected internal databases, with access restricted to authorised personnel only.

LEGAL BASIS FOR PROCESSING

We process your personal data under the following lawful basis and for the following reasons

Your consent

We rely on your consent when we use your personal data for optimising and enhancing the operation of our Website, developing new services, and providing you with relevant advertising materials as long as it is allowed by your device or browser’s personalisation and privacy settings. We also rely on this legal basis when we respond to you upon you have contacted us. You have a right to withdraw consent to processing of your personal data. You may enjoy this right at any time you wish. 

Please also take into account that if you have withdrawn your consent to processing of your personal data we may be limited in responding to you and/or providing you with our services.

For the performance of a contract with you or to take steps before entering a contract

We rely on this legal basis to provide certain services to you, to receive certain services from you, or to engage in employment or other contractual relations with you or the company that you represent. It also includes verifying the information provided by you via KYC form. 

Please note: providing inaccurate information in a KYC form, or refusing to provide required information or clarification/updated information, may result in Logigama declining to enter into or to continue any contractual relations.

For our vital interests 

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor was injured in our company premises and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party.

To perform a task carried out in the public interest

To perform a task carried out in the public interest we rely on this legal basis to report to the police or other competent law enforcement agencies in case we discover fraud or any other violations of the applicable law or suspicious behaviour or actions committed by you during your interaction with us, as well as in other cases when the disclosure of your personal data is required (e.g. our tax reporting obligations).

For our legitimate interests

We rely on this legal basis to contact you regarding potential cooperation between you and/or the company you represent with us, The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. To make non-marketing related communications to you about changes to our terms or policies or to provide other important notices (i.e. related to changes in legal details of Logigama or transfer of ownership); to enable or administer our business (quality control, consolidated reporting, customer service), transfer of ownership and so on, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Here are some short examples:

• Consent: “Get in Touch” form, “Contacts” webpage.
• Pre-contractual Measures: Communications preceding the provision of services.
• Legal Obligation: Tax reporting.
• Vital Interests: Health-related incidents of our employees.
• Legitimate Interests: maintaining ongoing client and vendor relations, business development, and internal administration.

ROUTINE ERASURE AND BLOCKING OF PERSONAL DATA

The Controller shall process and store the personal data of the Data subject only for the period necessary to achieve the purposes of processing, or for the duration prescribed by the European legislator, national legislators, or other applicable legal and regulatory provisions to which the Controller is subject.

Once the storage purpose no longer applies, or where a statutory retention period prescribed by the European legislator or other competent authority has expired, the personal data shall be routinely erased or blocked in accordance with the applicable legal requirements.

SAFETY OF YOUR PERSONAL DATA

Logigama implements appropriate technical, organisational, and security measures designed to protect personal data against unauthorised access, alteration, disclosure, or destruction. Such measures apply to the collection, storage, and processing of personal data, and extend to information such as transaction details and other data stored on our systems.

Personal data processed by Logigama will not be retained for longer than is reasonably necessary to achieve the purposes for which it was collected, including compliance with statutory obligations.

Where consent has been withdrawn, Logigama may nevertheless retain certain limited personal data for the duration required by applicable legislation, or where necessary to resolve disputes, enforce contractual and post-contractual relations, or comply with legal obligations.

INFORMATION TRACKING

This Website may automatically collect information about you in several ways, which includes tracking your activities through your IP address, computer settings, most-recently visited URL, operating system, date and time, your preferences and choices and saved options, subject to your browser settings. This Website uses your IP address to help diagnose problems with its server, and to administer the website.

LINKS TO THIRD PARTIES

The Logigama Website may contain links to third-party websites, including links to our official social media accounts on platforms such as LinkedIn. The privacy practices of such third parties may differ from those of Logigama.

These platforms may automatically collect certain information, such as your IP address and the webpage from which you accessed our social media account. They may also place cookies on your device to ensure the proper functioning of their features.

Any information, communications, or materials that you choose to submit to us via a social media platform are provided at your own risk. By clicking on third-party links, you may allow those parties to collect or share your personal data. Your use of such websites and platforms is governed by their respective privacy policies, which we do not control. Logigama is not responsible for the content, accuracy, security practices, or privacy standards of any third-party websites or platforms that may be linked from our website.

DATA TRANSFER

Logigama may sometimes be required to transfer your personal data to partners, clients, or service providers located in other countries, including those outside the European Economic Area (EEA). In such cases, we comply with applicable data protection laws designed to ensure the security and confidentiality of your personal data.

Under data protection laws, personal data may be transferred to third countries:

• on the basis of an adequacy decision issued by the European Commission, or
• in the absence of such a decision, under legally approved Standard Contractual Clauses (SCCs) or other recognised safeguards.

If we cannot, or choose not to, rely on either of these mechanisms, we will not transfer your personal data to third countries unless another lawful basis for transfer exists under applicable data protection law.

SHARING OF YOUR PERSONAL DATA

Logigama may share personal data with its professional advisers, employees, third-party service providers, partners, and contractors for the purposes described in this Privacy Policy or otherwise notified to you at the time of collection. Such service providers assist us in operating, supporting, and developing our business and Website. They may provide services including, but not limited to, cloud hosting, content delivery, customer and technical support, background checks, migration services, insurance services, marketing, analytics, and event hosting. Personal data will be shared only to the extent necessary to enable the provision of such services and subject to appropriate contractual safeguards. In addition, Logigama may disclose personal data to competent law enforcement bodies, regulatory authorities, government agencies, courts, or other third parties where such disclosure is required in order to comply with a legal obligation to which Logigama is subject, to protect the vital interests of the Data subject or another natural person, or where necessary for the establishment, exercise, or defence of legal claims.

CHILDREN’S PRIVACY

Logigama’s services and the Website are not directed to, and are not intended for use by, children. We do not knowingly collect or solicit personal data from children under the age of 14 in Lithuania, or under the age applicable in other EU Member States (which may range between 13 and 16 years). If Logigama becomes aware that personal data relating to a child below the applicable age threshold has been provided to us, such data will be promptly deleted from our systems. If you are a parent or legal guardian and believe that we may have collected personal data relating to your child, please contact us (see “Contact Information” section below or “Name and address of the Controller” above), and we will ensure that the data is erased without undue delay.

YOUR PRIVACY RIGHTS

As a Data subject, you are entitled to exercise the following rights under the GDPR and applicable data protection laws:

a) Right to be informed. You have the right to be informed about the collection and use of your personal data. It includes information about the purposes of processing, categories of data processed, recipients of the data, retention periods, and the rights available to you.

b) Right of access. You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, if so, access to such personal data together with the following information:

• the purposes of processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data has been or will be disclosed, including recipients in third countries or international organisations;
• the envisaged storage period or the criteria used to determine that period;
• the existence of your rights to rectification, erasure, restriction, or objection;
• the right to lodge a complaint with a supervisory authority; and
• where the personal data is not collected directly from you, any available information about its source.

c) Right to rectification. You have the right to obtain the rectification of inaccurate personal data concerning you without undue delay, and to have incomplete data completed, including by providing a supplementary statement.

If at any point you believe the information we process about you is incorrect or incomplete, you can submit a request to view this information and have it corrected, ported to you, or deleted by contacting us at privacy@logigama.com.

d) Right to erasure (“right to be forgotten”). You have the right to request the erasure of personal data concerning you without undue delay where one of the grounds set out in Article 17 GDPR applies, such as where the data is no longer necessary for the purposes for which it was collected, you withdraw consent and no other legal basis applies, you object to the processing and no overriding legitimate grounds exist, or the data has been unlawfully processed.

e) Right to restriction of processing. You have the right to obtain the restriction of processing where one of the conditions set out in Article 18 GDPR applies, for example, where the accuracy of the personal data is contested, the processing is unlawful but you oppose erasure, or the data is required for the establishment, exercise, or defence of legal claims.

f) Right to object. You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on legitimate interests or on the performance of a task carried out in the public interest (Articles 6(1)(e) and (f) GDPR). Logigama shall no longer process your data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or unless processing is required for the establishment, exercise, or defence of legal claims. Where personal data is processed for direct marketing purposes, you have an absolute right to object at any time to such processing.

g) Right to data portability. Where processing is based on consent or on a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller, where technically feasible.

h) Right to complain to a supervisory authority. You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement, if you believe that the processing of your personal data infringes applicable data protection laws.

In Lithuania, the competent supervisory authority is the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija). Contact details are available at: https://vdai.lrv.lt/.

i) Right to withdraw consent. Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

At any time, you may withdraw your consent or object to data processing by contacting us at privacy@logigama.com.

To exercise your rights, please contact us (see “Contact Information” section below or “Name and address of the Controller” above). When you send us a request to exercise a right, please specify as far as possible the scope of the request, the type of right exercised, the personal data processing concerned, and any other useful element, in order to facilitate the examination of your request. In addition, in case of reasonable doubt, you may be asked to prove your identity and provide additional clarifications as may be necessary.

We will do our best to answer your requests as soon as possible or within a reasonable period, taking into account the complexity of the request.

PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

Logigama retains personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a more extended retention period is required or permitted by applicable law, including for legal, tax, or regulatory reasons, or other lawful purposes.

In determining retention periods, we apply the following principles:

• Purpose-driven retention: personal data is retained only for the duration necessary to achieve the processing purpose described at the time of collection.
• Extension of retention: in certain cases, more extended retention periods may be required or permitted by applicable legislation, particularly in relation to statutory, tax, regulatory, or compliance obligations.
• Routine deletion and disposal: when there is no longer a legitimate business need to process personal data, and the applicable statutory retention period has expired, we will securely delete or anonymise the data.
• Criteria for retention: retention periods are defined in accordance with statutory obligations, recommendations of supervisory authorities, industry best practices, and operational needs of Logigama.

Different retention periods may apply depending on the type of personal data processed and the context of the processing. Following the end of the applicable retention period, personal data will be permanently erased or anonymised in a manner that prevents re-identification.

MISCELLANEOUS

Specific provisions relating to the processing of personal data are presented together in this section for clarity and ease of reference.

The provision of personal data may, in some circumstances, be required by law (for example, under financial or tax regulations) or may result from contractual provisions (such as information concerning a contractual partner). In particular, it may be necessary to provide personal data in order to conclude or perform a contract with Logigama. For example, when entering into a service agreement, completing a KYC form (where applicable), or otherwise engaging in a contractual relationship with us, the data subject may be required to provide specific personal data which Logigama must subsequently process.

Failure to provide such personal data in circumstances where it is required by law or contract would result in Logigama being unable to conclude or perform the relevant contract.

In all context-specific cases, Logigama will clearly inform the data subject whether the provision of personal data is legally or contractually required, whether there is an obligation to provide such data, and what the potential consequences of non-provision may be.

Finally, Logigama confirms that it does not use personal data for the purposes of profiling, automated decision-making within the meaning of Article 22 GDPR, or artificial intelligence (AI) systems that could evaluate or predict aspects relating to individuals.

CONTACT INFORMATION

Name: UAB Logigama

Office address: Kirtimų g. 2, LT-02300, Vilnius, Lithuania

Registered address: Kęstučio g. 34-203, LT-08112, Vilnius, Lithuania

General e-mail contact: info@logigama.com

Website: https://logigama.digitalkit.agency

For all questions, requests, or concerns relating to data protection and privacy, you may contact us at: privacy@logigama.com.