Privacy Policy
UAB „cargoGO Logistics“
PRIVACY POLICY
1. What does this Privacy Policy mean?
In this privacy policy (“Privacy Policy“) we provide you with information about how cargoGO Group processes your personal data for the purposes described below.
For the purposes of this Privacy Policy, the term “you” or “Data Subject” refers to representatives/employees of cargoGO Group’s customers, cargoGO Group’s partners, suppliers, or the representatives/employees of partners, suppliers, website visitors, or any other persons who contact cargoGO Group’s companies.
2. About cargoGO Group
cargoGO Group means a group consisting of the companies listed below:
- UAB “cargoGO Group”, legal entity code 304051372, registered office at Laisvės av. 10, Vilnius.
- UAB “cargoGO Logistics”, legal entity code 302337649, registered office at Laisvės av. 10, LT – 04215, Vilnius.
- UAB “Saturn transport”, legal entity code 306167621, registered office at Minsko pl. 26A, Vilnius.
- UAB “Sun transport”, legal entity code 306167678, registered office at Minsko pl. 26A, Vilnius.
- UAB “Jupiter transport”, legal entity code 306167660, registered office at Minsko pl. 26A, Vilnius.
- UAB “TL TRANSPORT”, legal entity code 302450216, registered office at Minsko pl. 26A, Vilnius.
- UAB “Transaibė”, legal entity code 135997714, registered office at Minsko pl. 26A, Vilnius.
- UAB “DD transportas”, legal entity code 302877307, registered office at Minsko pl. 26A, Vilnius.
Contact e-mail address for personal data protection questions is dataprivacy@cargogo.eu
3. What is personal data?
Personal data is any information collected by the cargoGO Group about a Data Subject that can be used to identify the Data Subject and is stored electronically or otherwise, for example, name, surname, contact data.
In any event, all personal data collected by us shall be processed in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR“), the Law on Legal Protection of Personal Data of the Republic of Lithuania and other applicable legislation.
4. What personal data we process and for what purposes?
The table below sets out the purposes, legal basis and categories of personal data processed about Data Subjects:
| Purpose of processing | Personal data | Legal basis |
| Concluding contracts with customers (partners, suppliers) or taking pre-contractual steps | Name, surname, title, position, basis of representation, contact details (telephone number, email address), content of correspondence (date, time, contents of emails, letters or other forms of communication) and any other personal data provided by the Data Subject, of the customer’s (partner’s, supplier’s) employees/representatives | Legitimate interest |
| Performance of contracts with customers (partners, suppliers) | Name, surname, position, basis of representation, contact details (telephone number, email address), content of correspondence (date, time, content of emails, letters or other forms of communication) and other personal data provided by the Data Subject, of employees/representatives of the customer (partner, supplier) | Legitimate interest |
| Concluding a contract with partners, suppliers (natural persons) or taking pre-contractual steps | Name, surname, individual activity certificate number, account details, contact details (telephone number, email address), content of correspondence (date, time, content of emails, letters or other forms of communication) and other personal data provided by the Data Subject, of the partner, supplier | Taking steps before the conclusion of a contract |
| Execution of contracts with partners, suppliers (natural persons) | Name, surname, individual activity certificate number, account details, contact details (telephone number, email address), content of correspondence (date, time, content of emails, letters or other forms of communication), nature of goods and services, financial details (payments) and other personal data provided by the Data Subject, of the partner, supplier | Performance of the contract |
| To improve the quality of goods/services, infrastructure | History of actions performed on the cargoGO Group’s website, technical information, including the Internet Protocol (IP) address used to connect the Data Subject’s computer to the Internet, browser type and version, time zone settings, operating system and platform, type of device used | Legitimate interest |
| For direct marketing purposes and/or to obtain feedback on the goods and services provided by cargoGO Group companies | Name, surname, contact details, content of correspondence (date, time, content of emails, letters or other forms of communication) of the Data Subject | Consent |
| To provide a response when you contact cargoGO Group companies via the cargoGO Group website or other means of communication | Name, surname, contact details, content of correspondence (date, time, content of emails, letters or other forms of communication) | Consent |
| Archiving | Name, surname, position, basis of representation, contact details (telephone number, email address), content of correspondence (date, time, content of emails, letters or other forms of communication) and other personal data provided by the Data Subject of the employees / representatives of the customer (partner, supplier) | Legal obligation or legitimate interest |
| To defend rights and legitimate interests | Name, surname, title, position, basis of representation, contact details (telephone number, email address), content of correspondence (date, time, content of emails, letters or other forms of communication) and other personal data provided by the Data Subject of the customer’s (partner’s, supplier’s) employees/representatives
Name, surname, individual activity certificate number, account details, contact details (telephone number, email address), content of correspondence (date, time, content of emails, letters or other forms of communication), nature of goods and services, financial details (payments, debts) and other personal data provided by the Data Subject, of the partner, supplier |
Legitimate interest |
5. Social media
The information you provide to us via social media (including messages, the use of the “Like” and “Follow” buttons, and other communications) is controlled by the operator of the social media platform.
Our website provides links to our social media accounts (“Social Media Accounts“). We currently administer the following Social Media Accounts:
We process the information contained in Social Media Accounts for the purpose of administering the accounts on the basis of our legitimate interest. We do not separately store the information contained in the Social Media Accounts (where the data is processed for the purpose of administering the Social Media Accounts, but the data may be stored if it is necessary to process the data for another purpose, such as for the purpose of defending rights).
When you visit the Social Media Accounts, the administrators of the Social Media Accounts place cookies on your device which collect personal data. Cookies are stored both if you are a registered user of a social media network and if you do not have an account with the relevant social media platform. We do not have access to the personal data collected about you and can only obtain statistical information from the administrators of the Social Media Accounts about the traffic of the Social Media Accounts.
We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions about how they use your personal data.
6. Direct marketing
In case you are existing cargoGO Group‘s customers or customers‘ employees/representatives, we may use your e-mail address for direct marketing purposes, but only with regard to goods and/or services that are similar or related to the services or goods we usually provide , and only if you do not object to such use of your e-mail address. You are also granted with a clear, free of charge and easily enforceable possibility to object or withdraw from such use of your contact details.
In other cases, we may use your personal data for the purpose of direct marketing, only if you give us your prior consent regarding such use of the data.
We are entitled to offer the services provided by our partners or other third parties to you or find out your opinion on different matters in relation to our partners or other third parties taking account of the legal basis for this, i.e., your prior consent.
In case you do not agree to receive these marketing messages offered by us, our partners or third parties, this will not have any impact on the provision of our goods or services to you as the customer.
We provide a clear, free-of-charge and easily enforceable possibility not to give your consent or, at any time, to withdraw your consent to receive our marketing messages. We shall state in each notification sent by e-mail that you are entitled to object to the processing of the personal data, and to refuse receiving messages from us. You shall be able to refuse to receiving our marketing messages by clicking on the respective link in each marketing e-mail received from us.
7. Transfer of data to third countries
If your personal data will be transferred outside the European Economic Area (EEA), cargoGO Group will take all necessary steps to process your personal data securely and in accordance with this Privacy Policy and will ensure that it is stored and transferred in accordance with the legal requirements applicable to personal data. This may be done in a number of ways, such as:
- the territory of the country to which we send the personal data or one or more of the specified sectors in that third country ensures an adequate level of protection;
- the recipient has signed or has in its service contract standard contractual clauses approved by the European Commission;
- a special authorisation from the supervisory authority has been obtained.
We may transfer personal data to a third country by other means, provided that they ensure appropriate safeguards as set out in the GDPR or on the basis of derogations.
The above measures do not apply if the transfer of personal data outside the EEA is necessary for the performance of a contract between you and a cargoGO Group company or for the implementation of pre-contractual steps taken at your request.
8. Receipt and disclosure of data
We receive your data from you, your devices, customers, partners, suppliers or other counterparts.
We disclose information about you to the parties listed below:
- shareholders of cargoGO Group companies;
- cargoGO Group companies;
- law enforcement agencies, attorneys or debt collectors (to protect our rights, including in the event of civil dispute);
- courts, out-of-court dispute resolution bodies;
- auditors, legal and financial advisors;
- successors to the rights and obligations of the cargoGO Group companies (in connection with the intended sale of the cargoGO Group’s business or part of its assets, the disclosure of your personal data to a potential buyer of the business or part of the business or the sale of the cargoGO Group’s business or a substantial part of its assets to a third party);
- other persons who provide services to cargoGO Group companies or are related to the services provided to cargoGO Group companies (for example, IT service providers, web hosting companies, archiving service providers);
- cargoGO Group companies’ partners with whom services are provided in cooperation;
- other persons where we are required to do so by law.
The list of recipients or categories of recipients referred to in the Privacy Policy may change, therefore, if you wish to be informed about changes in the recipients of your personal data, please notify us by sending an e-mail to the e-mail address specified in this Privacy Policy.
9. Data retention period
We will keep your personal data for as long as it is necessary for the purposes for which it was collected and processed, but no longer than required by applicable laws and regulations. After this period, the personal data will be erased/destroyed in a way that it cannot be retrieved.
If the legislation of the Republic of Lithuania does not provide for any retention period for personal data, this period will be determined by us, taking into account the purpose of the retention of the data, the legal basis for the retention and the principles of lawful processing of personal data.
Main periods for processing personal data:
- as long as your consent is valid;
- in the case of the conclusion and performance of a contract, for 10 years after the end of the contract.
Please also note that in certain cases your personal data may be stored for longer:
- if necessary to enable cargoGO Group companies to defend themselves against requests, claims or lawsuits and to exercise their rights;
- in the event of a reasonably suspected illegal activity that is the subject of an investigation;
- where the personal data are necessary for the proper settlement of a dispute or complaint;
- on other grounds provided for by law.
10. Security of your personal data
Your personal data will be processed in accordance with the GDPR, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legal requirements. When processing your personal data, we implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure, as well as against any other unlawful processing.
11. Your rights
In this Section, we provide information about your rights in relation to our processing of your personal data and when you can exercise these rights. If you would like more information about your rights or to exercise them, please contact us at the email address set out in this Privacy Policy.
cargoGO Group will provide you with information about the action taken following your request to exercise your rights without undue delay, but no later than 1 (one) month after receipt of your request. Depending on the complexity of the request and the number of requests received, the aforementioned time limit may be extended for a further 2 (two) months. In this case, we will inform you within 1 (one) month of receipt of the request of such extension and the reasons for it. cargoGO Group will only refuse to exercise your rights in cases provided for by law.
As a Data Subject, you have the following rights:
11.1. You have the right of access. If we store or use your personal data in any way, you have the right to access it. To do so, please submit a written request to us at the email address set out in this Privacy Policy, confirm your identity;
11.2. Right to withdraw consent. If you have given us your explicit consent to the processing of your data, you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal of consent;
11.3. You have the right to ask us to correct any inaccuracies in the data we hold. In this case, we may ask you to confirm the corrected information;
11.4. You have the right to ask us to delete your personal data. This right shall be exercised in the cases provided for in Article 17 of the GDPR;
11.5. You have the right to ask us to restrict or not to process your personal data:
– for the period necessary to ensure the accuracy of your personal data when you make a complaint regarding this;
– where our collection, storage or use of your personal data is unlawful but you choose not to request erasure;
– where we no longer need your personal data but you need it to establish, exercise or defend a legal claim;
– for the period necessary to determine whether we have an overriding legal interest in continuing to process your personal data if you have exercised your right to object to the processing of personal data.
11.6. You have the right to the portability of the data which is processed by automated means and which we have received from you in a structured, commonly used and computer-readable format with your consent or for the purposes of concluding a contract. If you exercise this right, we will, at your request, transfer a copy of the data provided by you to you or to a data controller of your choice;
11.7. You have the right to object to our use of your personal data in accordance with Article 21 GDPR. You have the right to object when your personal data is processed on the basis of legitimate interest (each of the above processing purposes is accompanied by a statement of the basis on which the data is processed) or for direct marketing purposes.
We hope that you will understand that it is very difficult to address all possible ways of collecting and using personal data. We strive to provide you with as clear and comprehensive information as possible and we undertake to update this Privacy Policy as and when our use of personal data changes. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or do not understand the information provided, please contact us.
12. Complaints
If you believe that your rights as a Data Subject have been and/or may be violated, please contact us immediately at the email address specified in this Privacy Policy. We ensure that upon receipt of your complaint, we will contact you within a reasonable period of time to inform you of the progress of the investigation and the outcome thereof.
If you are not satisfied with the outcome of the investigation, you may lodge a complaint with the supervisory authority, the State Data Protection Inspectorate: https://vdai.lrv.lt/.
13. Liability
You are responsible for maintaining the confidentiality of the data you provide to us and for ensuring that the data you provide to us is accurate, correct and complete. If there is any change in the data you have provided, you must inform us immediately by e-mail. In no event shall we be liable for any damage caused to you as a result of your providing incorrect or incomplete personal data or your failure to inform us of any change in the data.
14. Cookies Policy
If you visit our website, you should be aware that we use cookies.
For more information on how to manage your cookie settings and browser preferences, or how to delete cookies from your device, please see the Cookie Policy on our website.
15. Changes to the Privacy Policy
We may update or change this Privacy Policy at any time. If you wish to be notified of changes to this Privacy Policy, please notify us at the email address set out in Section 2.
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