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ReACTION

Privacy Policy

MB „REACTION LT“ (hereinafter – ReACTION) respects your privacy and processes personal data only for specifically defined purposes and to the extent required. This privacy policy explains how REACTION processes personal data. It applies to REACTION and to people who use, have used, have expressed an intention to use, or are otherwise connected with the services REACTION provides and the events it organises.

Data controller

The controller of client data is MB „REACTION LT“, legal entity code 305599140, registered address Perkūnkiemio g. 19, Vilnius. Company records are held at the Vilnius branch of the Register of Legal Entities of the Republic of Lithuania. Contact for personal data matters: email info@reaction.lt; tel. +37066344120.

Data processors

REACTION may disclose information about the Client to its employees, to entities carrying out marketing activities, to information technology service providers, to brokers and to other authorised parties.

In addition, REACTION may disclose information about the Client:

  • in order to defend its rights or interests (including providing the Client's personal data to third parties in order to recover the Client's debts owed to us);
  • when intending to sell REACTION's business or part of its assets, by disclosing the Client's personal data to a potential buyer of the business or part of it;
  • after selling REACTION's business or a substantial part of its assets to third parties.

Personal data, its categories and processing purposes

Personal data is any information collected by REACTION about the Client that can be used to establish the Client's identity and that is stored electronically or by other means.

Personal data includes information such as the Client's name, surname, address, email address and telephone number. It also includes publicly available personal information about the Client that REACTION learns when the Client contacts REACTION through social media or takes active steps on REACTION's social media accounts.

REACTION processes data about:

  • people who agree to receive REACTION marketing material;
  • people who have contacted REACTION or its authorised representatives (for example, brokers);
  • visitors to the reaction.lt website;
  • social media users who contact REACTION through its social media accounts in any way or take active part in them;
  • people who attend REACTION events.

Processing purposes

REACTION processes personal data only for the purposes set out in this Privacy Policy or in a separate consent or agreement between the Client and REACTION (for example, for direct marketing purposes).

Direct marketing

REACTION carries out direct marketing only in respect of people who are at least 16 years of age, and only to people who have provided their contact details and expressed a wish to receive information about the property and/or services REACTION offers. ReACTION uses electronic communication means (email or other) to send offers, newsletters and other promotional material about REACTION's services or property acquisition, to ask for opinions about its service and about acquired property, and to announce REACTION news. For direct marketing purposes REACTION will process the following personal data of the Client: name, surname, telephone number, email address. The Client's data will be used for direct marketing purposes for 2 (two) years after consent is obtained, after which it is deleted. The Client has the right to opt out of direct marketing messages at any time by writing to info@reaction.lt.

Collection and use of data

REACTION processes personal data in order to prepare for the performance of a contract or to answer questions the Client may have. If the Client does not provide contact details, it will not be possible to contact the Client. Correspondence is kept for 5 (five) years from receipt of the message, or 10 (ten) years if the Client acquires real estate brokered by REACTION, except for information for which the Privacy Policy or legislation lays down other retention periods.

Cookie policy

Cookies

A cookie is a small file of letters and numbers that, with the Client's consent, we place in the Client's browser or on the hard drive of the Client's computer. We use different cookies for different purposes. Cookies also help us to distinguish the Client from other users of the website, which makes the reaction.lt website more pleasant to use and allows us to improve it. Most browsers allow all cookies to be rejected, and some browsers allow only third-party cookies to be rejected. The Client is free to use these options. Please note, however, that blocking all cookies will have a negative effect on the use of the reaction.lt website, and without cookies the Client will not be able to use all the services offered on reaction.lt. We use the cookies described below:

Strictly necessary cookies

These cookies are necessary for the reaction.lt website to function. The basis for processing data through such cookies is the proper performance of a contract while the Client visits the reaction.lt website, with MB „REACTION LT“ ensuring the quality and security of the visit.

Analytical and/or performance cookies

These cookies allow MB „REACTION LT“ to recognise and count visitors to the reaction.lt website and to see how visitors move around it while using it. This helps MB „REACTION LT“ to improve how reaction.lt works — for example, by making sure that users can easily find what they are looking for. The basis for processing the data collected by these cookies is the Client's consent.

Functional cookies

These cookies are used to recognise the Client when they return to the reaction.lt website. This allows MB „REACTION LT“ to present content tailored to the Client's needs and to remember information relevant to the Client. The basis for processing the data collected by these cookies is the Client's consent.

If the Client wishes, they can control and/or delete cookies. The Client can delete all cookies already stored on their computer and set most browsers so that cookies are not stored on their device. In that case, however, the Client may need to change some options manually each time they visit the reaction.lt website, and some services and features may not work.

Third-party services

In order to improve the reaction.lt website, we need to know which information is of most interest to our visitors, which cities the site is visited from, how often visitors return, which browser they use, on which devices the site is read, and so on. We collect this information using Google Analytics tools, which allow statistical website usage data to be recorded and analysed.

Social media

All information you provide through social media (including messages, use of the „Like“ and „Follow“ buttons, and other communication) is controlled by the operator of the social network. The reaction.lt website contains links to our social media accounts. We recommend reading the privacy notices of these third parties and contacting the service providers directly if the Client has any questions about how they use the Client's personal data.

Participation in events organised by ReACTION or its partners

With the Client's consent, the fact of the Client's attendance, their name, surname and photograph will be used when informing the public about ReACTION events. Photographs of the Client taken during ReACTION events may, with the Client's consent, be published on ReACTION's social media accounts and on the reaction.lt website. Media representatives may publish photographs of the Client only in accordance with the laws applicable to them, and ReACTION is not responsible for the actions of media representatives. Photographs will be published and retained for 2 (two) years after the event, except where the law provides otherwise.

Geographical processing territory

The Client's personal data will not be transferred to a third country and/or an international organisation. We do not provide the Client's personal data to any third parties except in the cases set out in this Privacy Policy.

Data security

The Client's personal data will be processed in accordance with the requirements of the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legislation. When processing the Client's personal data we implement organisational and technical measures that protect personal data against accidental or unlawful destruction, alteration and disclosure, and against any other unlawful processing.

Client rights

The Client has the right:

  • to obtain information about whether ReACTION processes their personal data and, if so, to access it;
  • to request rectification of personal data if it is incorrect, incomplete or inaccurate;
  • to object to the processing of personal data. This right does not apply where personal data is processed for legitimate reasons that override the interests of the data subject;
  • to withdraw consent (for example, to processing for direct marketing purposes). Withdrawal of consent has no retroactive effect and does not affect the lawfulness of consent-based processing carried out before the withdrawal;
  • to request erasure, portability or restriction of the processing of personal data, other than storage, where personal data is processed in breach of legislation or of the Privacy Policy.

How to exercise your rights

If the Client wishes to obtain more information about their rights or to exercise them, they should get in touch by email at info@reaction.lt. Without undue delay, and no later than 1 (one) month from receipt of the request, ReACTION will provide the Client with information about the action taken in response to the Client's request regarding the exercise of their rights. Taking into account the complexity of the request and the number of requests received, that period may be extended by a further 2 (two) months, in which case we will inform the Client of the extension and the reasons for it within 1 (one) month of receiving the request.

If the Client believes that their rights as a data subject are and/or may be infringed, the Client may immediately submit a complaint to ReACTION by email at info@reaction.lt. Once it has received the Client's complaint, ReACTION undertakes to contact the Client within a reasonable period and to inform them about the progress of the investigation and subsequently about its outcome. If the Client is not satisfied with the results of the investigation, the Client may lodge a complaint with the supervisory authority — the State Data Protection Inspectorate.

Responsibility

The Client is responsible for ensuring that the data provided to us is accurate, correct and complete. If the data provided by the Client changes, the Client must inform us without delay by amending the relevant data in the registration form or, if the data is not stated in the registration form, by informing us by email at info@reaction.lt. Under no circumstances will we be liable for damage caused to the Client as a result of the Client providing incorrect or incomplete personal data or failing to inform us of changes to it. A Client who does not agree with any provision of the Privacy Policy loses the right to visit the reaction.lt website and to take active steps on ReACTION's social network accounts.

Changes to the privacy policy

ReACTION may update or amend this Privacy Policy at any time. Such an updated or amended Privacy Policy will take effect from the moment it is published on the reaction.lt website. The Client should check it from time to time and make sure that they are satisfied with the current version of the Privacy Policy. When ReACTION updates the Privacy Policy, it informs the Client about material changes by publishing them on the website. If the Client accesses the reaction.lt website after such a notice has been published, the Client is deemed to agree with the new requirements set out in the update.

This is a translation provided for convenience. The Lithuanian version of this policy is the binding one.