Privacy policy

1. GENERAL PROVISIONS

1.1. UAB “Lavireda” (hereinafter referred to as the “Company”) respects the right to privacy of all its service purchasers, potential clients (who have tried the services but did not become clients), and all visitors of the website TOPLED.LT (hereinafter referred to as the “Website”), (collectively referred to as the “Clients”), and undertakes to ensure the protection of the personal data provided and received. The Company also takes care to ensure the rights of clients as data subjects.

1.2. This Privacy Policy regulates the main principles and procedures of the collection, processing, and storage of personal data of the Company’s clients.

1.3. By using the Website, ordering goods, and providing your personal data to the Company, you agree to the provisions of this Privacy Policy. Clients are considered to have read the Privacy Policy when, during registration on the Website, they check the box indicating agreement with the Company’s Privacy Policy. The Privacy Policy is always available for review on the Website via the relevant link.

1.4. In processing client personal data, we comply with all relevant laws, including those of the EU, ADTAĮ, the Republic of Lithuania (LR), and other applicable legal acts governing the protection of personal data.

2. WHAT TERMS ARE USED?

2.1. Personal Data – any information about a natural person whose identity is identified or can be identified (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, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

2.2. Data Subject – a natural person, a client of the Company (including Website visitors), whose personal data are collected by the Company.

2.3. Consent of the Data Subject – 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.

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

2.5. Data Processor – a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Data Controller.

2.6. Data Controller – UAB “Lavireda”, a company established and operating under the laws of the Republic of Lithuania, code 302752652, registered at Gamyklos g. 31i, LT-89103 Mažeikiai, Republic of Lithuania, with data collected and stored in the Register of Legal Entities.

2.7. Direct Marketing – activities intended to contact the Client by mail, phone, or other direct means to offer goods or services and/or to ask for opinions regarding the offered goods or services, including by automated means.

3. WHAT COOKIES DO WE USE AND HOW?

3.1. What is a cookie – small files sent to a user’s browser and placed on their computer or other device upon first visiting the Website. Later, cookies are used to ensure the best possible user experience by identifying the user’s device and simplifying access to the Website or its information, thereby customizing content for convenience.

3.2. These cookies are used on the Website and related Company systems to properly and efficiently serve the Client.

3.3. To ensure a more convenient and efficient browsing experience and to provide useful offers, the Website uses the following cookies:
PHPSESSID (session information), “CookieInfoScript” (cookie consent), _gat, _ga, _git, __utma, __utmb, __utmc, __utmt, __utmz (Google Analytics cookies), datr, Fr, sb, locale, reg_ext_ref, reg_fb_gate, reg_fb_ref (Facebook Pixel cookies), and “GPS”, “PREF”, “VISITOR_INFO1_LIVE”, “YSC” (YouTube video content cookies).

3.4. Client’s right to refuse cookies – The Client may delete or block some or all cookies at any time by changing browser settings. More information about deleting or blocking cookies can be found on the browser manufacturer’s website. Please note that doing so may result in some website features partially or completely ceasing to function.
The Client understands that third-party plugins (such as partners, analytics systems, communication tools, etc.) used on the Website may also use cookies for proper functionality. The Website operator does not control and is not responsible for third-party cookies, content, or privacy practices. Clients are encouraged to review those individually.

4. WHAT PERSONAL DATA DO WE COLLECT?

4.1. The Company collects and processes the Client’s personal data that you provide when using or purchasing goods on the Website: name, surname, personal ID number (optional), address, email address, phone number, IP address, and other data related to the nature of the order (e.g., online store name, settings, etc.). You provide this data voluntarily when registering, ordering, or managing the Company’s services.

4.2. The personal data provided by the Client are stored by the Company for the duration of cooperation (service period) and for 10 (ten) years after its end. Data may be stored for a shorter period if no legal basis for retention exists. 

5. FOR WHAT PURPOSES AND HOW DO WE PROCESS PERSONAL DATA?

5.1. The Company processes Client data lawfully, fairly, and transparently (principles of legality, fairness, and transparency).

5.2. The Company processes the Client’s personal data for order processing and administration, client identification in information systems, server access, accounting related to service orders, communication regarding contractual obligations, and direct marketing (with prior consent).

5.3. We ensure that Client personal data are processed lawfully, fairly, transparently, collected for legitimate and clearly defined purposes, not further processed in a manner incompatible with those purposes, adequate, relevant, and limited to what is necessary, accurate and updated when needed, and processed securely using appropriate technical and organizational measures to protect against unauthorized or unlawful processing, accidental loss, destruction, or damage (principle of integrity and confidentiality).

6. WHAT RIGHTS DO DATA SUBJECTS HAVE?

6.1. The Client has the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal. The data subject is informed of this before giving consent. Withdrawal is as easy as giving consent.

6.2. You have data subject rights, which we will fulfill upon receiving a written request by registered mail (address: Gamyklos g. 31i, LT-89103 Mažeikiai) and upon proper identity verification. The Client has the right to access their personal data and how they are processed, to request correction of inaccurate data, and to request completion of incomplete data.

6.3. The Client has the right to request deletion of personal data if they are no longer necessary for the purposes for which they were collected or otherwise processed; to withdraw consent where no other legal basis exists; if data were processed unlawfully; or on other grounds established by law. The Client also has the right to request restriction of processing, to receive personal data provided to the Company in a structured, commonly used, and machine-readable format, to request data portability to another controller, or to object to processing (e.g., for direct marketing).

7. HOW DO WE PROCESS PERSONAL DATA FOR DIRECT MARKETING PURPOSES?

7.1. The Company will contact the Client only with prior consent and in accordance with ERĮ, ADTAĮ, and the Regulation. We will send newsletters and/or request feedback regarding service quality and other related matters.

7.2. We process the following personal data for direct marketing: name, email address, phone number, and the address of the installed e-store.

7.3. Personal data for direct marketing are stored until the Client opts out of receiving marketing messages (an unsubscribe link is provided at the bottom of every email).

8. TO WHOM DO WE PROVIDE PERSONAL DATA?

8.1. Company employees are granted access to Client personal data only when necessary for their duties and only after committing to confidentiality.

8.2. The Company may provide Client personal data to processors who provide services and process data on behalf of the Company or the Client, to law enforcement authorities when there is a legal basis, or to other third parties with the Client’s consent. Such processors may process data only according to the Company’s instructions.

8.3. For certain services (e.g., domain or certificate registration in other countries), Client data may be transferred to other countries (including third countries).

8.4. Client personal data may also be disclosed in response to official requests from state institutions or courts, but only after verifying the legality of such requests.