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General provisions 

SE Lietuvos Airports, legal entity code 120864074, registered office address: Rodūnios kelias 10A, Vilnius, Lithuania, tel. No.: +37061244442, e-mail: (hereinafter - Lithuanian Airports) understands that the protection of personal data is important for our customers, suppliers, partners and other persons (hereinafter - data subjects) who cooperate or use the services of Vilnius, Kaunas or Palanga branches of Lithuanian Airports. For this reason, we take all necessary measures to ensure the privacy of each data subject and the exercise of personal data protection rights. 

You can contact our appointed Personal Data Protection Officer on all data protection issues by e-mail.

This Privacy Notice provides all information about how we, as Data Controllers, process personal data, including information about the purposes of the processing of personal data and the legal basis, what data is collected and further processed, how long it is stored, to whom it is provided, what rights you have and where you can ask about their implementation or any other issues related to the processing of personal data. 

The Privacy Notice applies to natural persons who cooperate with or use the services of any of all three branches of Lithuanian Airports (Vilnius, Kaunas and Palanga), visit our websites, social network accounts, or provide data to us for other purposes.

Our employees and members of the management body are informed about the processing of their personal data in accordance with the procedure established in the internal legal acts of Lithuanian Airports.

The Privacy Notice is prepared in accordance with the following legislation:  

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as GDPR or Regulation)
  • Law of the Republic of Lithuania on the Legal Protection of Personal Data of 30 June 2018 no. XIII-1426 (hereinafter - ADTAĮ); 
  • Law of the Republic of Lithuania on Electronic Communications of 15 April 2004 No. IX-2135; 
  • Guidelines of the State Data Protection Inspectorate.  

This Privacy Notice is an integral part of the data protection policy approved by Lithuanian Airports. 

How do we collect your data? 

Depending on the nature of our cooperation, we process personal data as follows: 

  • Received directly from the data subject (you), for example when you send us inquiries, share your experience with the specified contacts, use our parking services, participate in our privilege programs or send us your CV in order to apply for vacancies;
  • which are generated when you use our services or enter our territory, for example when you visit our website or enter our video surveillance field;
  • obtained from other sources, such as insurance companies, airlines, other third parties.

For what purposes and what personal data do we process?  

Purpose of data processing

Legal basis for data processing

Data categories

Data retention period

Execution of contracts with suppliers, subcontractors

GDPR Article 6 (1) (b) - performance of the contract

Name, surname, personal identification code, date of birth, contact telephone number, postal address, e-mail of representatives of suppliers and subcontractors. Name, surname, position, contact details of the person signing the contract

10 years after the end of the specific contract

Administration of invoices provided by suppliers and subcontractors

GDPR Article 6 (1) (c) - legal obligation 

Name, surname, position, address, e-mail, telephone number

10 years 

Training and information of natural persons working outside the airport

GDPR Article 6 (1) (c) - legal obligation 

Company, name, surname, e-mail, telephone number

3 years

Issuance of permanent permits to enter the airport area for natural persons

GDPR Article 6 (1) (c) - legal obligation 

Registered place of residence, place of work, reasons for unemployment, extracts, confirmations, personal identification code, name, surname, list of functions requiring a permit. Confirmation of the accuracy of personal data, conviction record, dates. Certificates from third parties for impeccable reputation

5 years

Issuance of permits for driving a motor vehicle

GDPR Article 6 (1) (c) - legal obligation, 

Driving license number, data, personal data, etc., health data, name, contact information

5 years

Issuance of permits for flights with drones

GDPR Article 6 (1) (c) - legal obligation, 

Pilot's license number, number, name, surname, customer's name, surname

5 years

Registration of media representatives for access to the airport area

GDPR Article 6 (1) (c) - legal obligation, 

Company, name, surname, e-mail

5 years

Administration of applications for the reception of excursion groups

GDPR Article 6 (1) (a) - Consent 

Name, surname, personal identification code, date of birth of the excursion participants

1 year

Video surveillance, implementation of aviation security measures, for the protection of Lithuanian Airports property, and for crime prevention purposes

GDPR Article 6 (1) (f) - legitimate interest, GDPR Article 6 (1) (c) - legal obligation, 

Image, other data visible in the video

30 days 

Screening of passengers for aviation security purposes

GDPR Article 6 (1) (c) - legal obligation, 

Name, surname, flight number, flight time

24 hours

Recording of conversations for quality assurance purposes

GDPR Article 6 (1) (f) - legitimate interest 

Call metadata: time, duration, phone number. Call content

6 months

Claims administration, insured events

GDPR Article 6 (1) (c) - legal obligation, GDPR Article 6 (1) (f) - legitimate interest 

Name, surname, personal identification code, information about damaged property, information provided by the insurance company, airline

10 years

Execution of direct marketing

GDPR Article 6 (1) (a) - Consent 

Name, surname, e-mail, telephone number, age, purpose of travel

Until withdrawal of consent

Sending newsletters.

GDPR Article 6 (1) (a) - Consent 

E-mail

Until withdrawal of consent

Organization of lotteries

GDPR Article 6 (1) (f) - legitimate interest, GDPR Article 6 (1) (a) - Consent  

Participants' social account details, winner's contact information required to deliver the prize

Until the end of the lottery

Administration of Lithuanian Airports websites and social media

GDPR Article 6 (1) (f) - legitimate interest 

Opinions, comments, and other information provided on social media

Opinions and comments on social media are not deleted. 

Information collected by cookies

GDPR Article 6 (1) (a) - Consent 

The specific information collected by cookies is presented in the cookie control window

The duration of the activity of specific cookies is displayed in the cookie control window

Examination of passenger inquiries, complaints, sharing of their experience

GDPR Article 6 (1) (b) - performance of the contract GDPR Article 6 (1) (a) - Consent 

Name, surname, e-mail, telephone number, flight information, damage suffered, bank account number and other information provided by the passenger

6 months

Provision of services to very important persons, as provided for in the internal legal acts of Lithuanian Airports

GDPR Article 6 (1) (b) - performance of the contract

Name, surname, date of arrival / departure, time, flight number, airport of arrival / departure, name, surname of persons meeting / disembarking, information about vehicles arriving / meeting passengers, their model, state registration numbers

6 months

Participation in the Lithuanian Airport Privilege Program - Privilege Card

GDPR Article 6 (1) (a) - Consent 

Name, surname, date of birth, e-mail, telephone number, address, visit history

1 year from the expiration of the privilege card

Business Lounge administration

GDPR Article 6 (1) (b) - performance of the contract

Name, surname, flight number, class, loyalty card number, flight time

3 months

Fast Track service

GDPR Article 6 (1) (b) - performance of the contract

Action records - date, time, airlines, name, surname of the passenger

3 months

Administration of e-shop VNO.lt/e-shop.lt user accounts and orders

GDPR Article 6 (1) (b) - performance of the contract

Name, surname, company information, telephone number, e-mail, postal address

5 years from last activity of the account

Provision of parking

GDPR Article 6 (1) (b) - performance of the contract

Name, surname, e-mail, vehicle registration numbers, photo, accident information, parking time, date

10 years

Conducting public property auctions

GDPR Article 6 (1) (b) - performance of the contract

Name, surname, personal identification number, address, telephone number, e-mail address; name, surname, contact details of the authorized person, payment order information

10 years

Accounting for provided services

GDPR Article 6 (1) (c) - legal obligation 

Name, surname, position, address, e-mail, telephone number

10 years 

Debt administration

GDPR Article 6 (1) (f) - legitimate interest

Name, surname, personal identification number, amount of debt

5 years, from the date of debt settlement

Selection of candidates for vacant positions

GDPR Article 6 (1) (a) - Consent, BDAR Article 6 (1) (f) - legitimate interest

Name, surname, contact details, CV details, cover letter

Until the end of selection

Organizing events GDPR Article 6 (1) (a) - Consent Name of the company, person's job title, name, surname, e-mail, phone number. 6 months

How do we protect your data? 

Lithuanian Airports have implemented proper technical and organizational measures to ensure an appropriate level of security in data processing. We guide the selection and implementation of the technical and organizational measures to ensure the security of data processing: 

To whom do we provide your data? 

Lithuanian Airports uses only those data processors that ensure compliance with the GDPR and the same level of personal data security as set out in our personal data protection policy. 

Here is a list of categories of data recipients at Lithuanian Airports

  • state institutions in accordance with the procedure provided by law;
  • Data Centre, Hosting, Cloud, Website Administration and Related Services, Software Development, Provisioning, Supporting and Development Companies, IT Infrastructure Services Companies, Communication Services Companies; 
  • subcontractors; 
  • law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offense has been committed, as well as courts and other dispute resolution bodies.

Do we provide your data outside the European Union and the European Economic Area?

We ensure that your data is processed in accordance with the requirements and standards established by the legal acts of the European Union and we inform you that your data is processed only within the European Union and the European Economic Area.

Consequences of non-submission 

You have the right to refuse to provide your personal data, but the provision of your personal data is necessary and mandatory for the purposes set out in this Privacy Notice, so if you do not provide your personal data, we will not be able to achieve the purposes listed. 

What rights do you have and how can you exercise them?  

In accordance with the provisions of the GDPR, you, as a data subject, can exercise these rights:  

1The right of access to personal data. I.e. to submit a request for information on whether your personal data is processed, and if personal data is processed, you have the right to access your processed personal data. 

2. The right to correct personal data. I.e. to submit a request to correct your personal data if you find that the personal data we process is incorrect, incomplete or inaccurate. 

3The right to delete data (a right “to be forgotten”). I.e. to request the deletion of your personal data if you believe that your data has been processed illegally or fraudulently. 

4. The right to restrict data processing. I.e. to make a request to restrict (suspend) the processing of your personal data, except for storage - in case, for example, you request the rectification of your personal data (while the accuracy of personal data is checked and / or corrected), if it is established that personal data is processed unlawfully and you do not consent to the deletion of the data and you have expressed your consent to the processing of your personal data, etc. 

5. The right to data transfer. I.e. to submit a request to transfer your personal data, which is processed by automated means, to you and / or another data controller in a systematic, commonly used and computer-readable format. 

6. The right to object to data processing. I.e. to object to the processing of personal data where the processing is carried out on a legal basis or on a legal basis in the public interest.  

7The right to request that you are not subject only to a decision based on automated data processing, including profiling, which has legal consequences for you or which has a significant effect on you in a similar way;  

8. The right to withdraw a consent given to us at any time, with regard to the processing of personal data, for example for direct marketing.  

 

You can exercise your rights: 

  1. By sending us a free-form request by e-mail: The application must be electronically signed or accompanied by a notarized copy of an identity document in order for us to verify your identity. 
  1. By sending the application by registered mail to the address Rodūnios kelias 10A, Vilnius, Lithuania. The application must be signed and accompanied by a notarized copy of your identity document. 
  2. You can also exercise your rights through a representative. In this case, your representative must provide your name, contact details, a copy of an identity document certified by a notary, information about you, namely: name, surname, other data on the basis of which we could identify you as a data subject, as well as a notarized copy of the document supporting your representation.

 

The request must be legible, signed, state the name, address and other details of the data subject in the desired form of communication, information on which of the data subject's rights and to what extent the data subject wishes to exercise.  

We will provide a response to your request no later than within 30 (thirty) calendar days from the date of receipt of the request. In exceptional cases requiring additional time, we will, after notifying you, have the right to extend the deadline for submission of the requested data or examination of other requirements specified in your request to 60 (sixty) calendar days from the date of your request.  

Where can you submit questions regarding personal data? 

If you have any questions regarding the information provided in this Privacy Notice or the protection of your personal data and the exercise of your rights at Lithuanian Airports, please contact our data protection representative in any way convenient for you: 

  • by e-mail: 
  • in writing to the address: Rodūnios kelias 10A, Vilnius, Lietuva.

If a solution that is suitable for both parties cannot be found, you have the right to contact the State Data Protection Inspectorate at the address: L. Sapiegos str. 17, Vilnius.

 

Cookies 

A cookie is a small text file that a website saves in the browser of your computer or mobile device when you visit the website. It allows your website to "remember" your actions and options (such as registration name, language, font size, and other display options) for a period of time so that you don't have to re-enter them each time you visit the site or browse its various pages. 

The information collected by cookies allows us to ensure that you can browse more conveniently, as well as learn more about the behavior of website users, analyze trends and improve the website. 

You can find out what cookies are used on this page and how to manage them in the cookie control panel of each page. 

 

Final provisions of the Privacy Notice

The Privacy Notice is adjusted at the discretion of the Data Controller or in the event of a change in the requirements of applicable legislation.

The current version of the Privacy Notice is published on the website, so it is recommended that you read the latest version.

Last updated: 2021 03 12 14:23
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