This is the privacy statement of UAB Alumingo (hereinafter referred to as “Alumingo”), applicable to the processing of personal data of individuals not associated with our organization (external/third parties). Alumingo respects your privacy and processes all personal data in accordance with the EU General Data Protection Regulation (GDPR). This privacy statement aims to help you understand what data we collect, why we collect it, and what we do with it, as well as to inform you about your choices regarding the use, access, and correction of your personal information.
Alumingo is the data controller responsible for processing the relevant personal data. The general data processing activities are described in this privacy statement.
1. Alumingo Personal Data Processing Rules
Alumingo is committed to adhering to general personal data protection principles according to the code of conduct. To implement such protection, Alumingo has established personal data processing rules (hereinafter referred to as PDPR). The PDPR ensures consistent and uniform data protection principles followed by Alumingo.
2. How and Why We Collect and Use Personal Data
2.1. Our Website
We collect and use personal data on our websites. This includes data collected through cookies and instances when you contact us by filling out contact forms or applying for jobs via our careers page, where you voluntarily provide us with your personal data. This activity and data processing are further detailed in the privacy notice provided in the footer of each relevant website.
2.2. Marketing
You will receive marketing communications (including newsletters) if you have requested such information from us or purchased our goods or services, or if you have provided us with your data by filling out a contact form and consented to receive our marketing communications. If you subscribe to newsletters or other marketing communications, we will collect and store information such as your name and email address to send the requested material. You can also follow us on social media sites, in which case each individual social media channel provider will hold your personal data as specified in their respective privacy policy statements.
2.3. Recruitment
We process personal data related to you when you apply for a job in our company. We collect and use the personal data you provide us, which typically includes your name, surname, email address, and phone number, information from your CV, and other information included in your application. The purpose of this processing is to handle your application, and the legal basis for processing is your consent. You can withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of data processing conducted based on consent before its withdrawal. More information about data processing related to our careers page can be found when filling out the application form.
When selecting candidates for certain positions, we also conduct thorough candidate checks. The purpose of this check is to verify the candidate’s identity, education, employment history, certificates, and other relevant aspects for the position. Such processing may include personal data such as name and surname, age, references, and information that is publicly available. Where appropriate or required by applicable laws, the legal basis for personal data processing related to thorough checks is your consent. You can withdraw your consent at any time. Please note that the withdrawal of consent will not affect the lawfulness of data processing based on consent before its withdrawal. If thorough checks are mandatory under applicable laws, the legal basis for data processing is the respective law. In other cases, the legal basis for data processing is our legitimate interest to protect our business.
2.4. Security
Alumingo has implemented various security measures that involve processing personal data. This is to protect against illegal or unauthorized access to certain zones, buildings, premises, as well as unauthorized or unlawful access to systems, processes, or equipment. For example, Alumingo premises may have activity logs, surveillance cameras, control of supply vehicles, and access control for drivers and employees. The personal data we collect and use depends on the relevant security measures. They may include your images and video recordings, your name and surname, phone number and workplace, date and time of entry into the premises, and information about the vehicle you drive. The legal basis for such personal data processing is our legitimate interests related to protecting our business and any applicable legal requirements.
2.5. Business Relationship Purposes
We process personal data to maintain and manage relationships with customers, suppliers, and partners, primarily for contract conclusion and execution. We process personal data for these business relationship purposes based on your consent and our legitimate interests in maintaining and well-organized relationships with customers, suppliers, and partners. If the data is processed based on your consent, you can withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of data processing conducted based on consent before its withdrawal.
2.6. Social Events
Alumingo may process registration for social events organized or sponsored by Alumingo. In such cases, Alumingo processes personal data about people invited to and registered for the event. This processing is limited to the information necessary to organize the social event and includes personal data such as name, surname, email address, phone number, workplace, and position (if necessary), as well as any special requirements. We process personal data for these purposes based on your registration and given consent. Once the purposes are fulfilled, personal data will be deleted. You can withdraw your consent at any time by canceling the event registration. Withdrawal of consent will not affect the lawfulness of data processing conducted based on consent before its withdrawal.
2.7. Integrity Check
Following our integrity check procedures, we collect information about our suppliers and business partners to ensure compliance with anti-corruption laws and export controls, among other things. This process may involve collecting personal data of individuals associated with such suppliers and business partners. The legal basis for the integrity check is legal obligations and our legitimate interests to protect our business.
2.8. Legal Obligations and Legal Proceedings
Alumingo has various legal obligations that require the processing of personal data. These legal obligations differ across countries and companies and typically include obligations related to taxes and accounting. These legal obligations form the basis for such personal data processing. Alumingo also processes personal data related to legal proceedings. The purpose and legal basis for such processing are Alumingo’s legitimate interests in establishing, exercising, or defending legal claims.
3. With Whom We Share Personal Data
Alumingo shares personal data only in accordance with our PDPR and applicable data protection laws. We share personal data with:
Our third-party service providers,
Authorities and private entities (e.g., financial institutions), as required by law.
In cases where we sell or buy business or assets, we may disclose your personal data to potential buyers or sellers. If sharing personal data involves transferring personal data to a recipient outside the EU or EEA, the transfer will be carried out in accordance with our PDPR procedures.
4. Information Security
Alumingo protects your personal data by applying technical and organizational security measures
5. Your Rights
You have the right to request information about what personal data related to you (if any) Alumingo processes. You can also request that any excessive personal data we may process be deleted or blocked, and you can demand the correction of any incorrect personal data we may process. Additionally, you can contact the national data protection inspectorate and file a complaint (more information can be found below).
If you want more information than what is outlined in this policy, such as how we use your information, how we maintain the security of your information, and what rights you have to access the information we hold about you, please contact us via email at [email protected]
6. Complaints
6.1. Complaints to Alumingo
If you are dissatisfied with the processing of your personal data, you can file a complaint with Alumingo. To file a complaint, write to [email protected]. Generally, you will receive a written response from us within four (4) weeks after we receive your complaint. If we are unable to provide a response within four (4) weeks due to the complexity of the complaint, we will inform you and provide a reasonable estimate of when you can expect a response. The timeframe will not exceed three (3) months from the date we received the complaint.
6.2. Complaints to the Data Protection Authority
You can file a complaint with the national data protection inspectorate. We would ask you to first file a complaint directly with Alumingo before contacting the national data protection inspectorate.
7. Contact Information
If you have any questions or concerns regarding your privacy or wish to exercise your rights, you can contact us via email at [email protected]
8. Changes to This Privacy Statement
We continuously review our privacy statement. This privacy statement was last updated on July 1, 2024. New versions will be posted on the website and will be notified to you in atimely manner.
