Privacy Policy

Last updated on 02/01/2021

This Privacy Policy (the "Privacy Policy" or "Policy") explains how MB Octovenio (the "Company", "we" or "us") collects and uses information for you using our Afterway mobile app or any other services we provide (the “Services”).

MB Octovenio is committed to handling your personal data responsibly and securely in its activities. In accordance with this fundamental principle, we will always strive to ensure an adequate level of protection of your data and the protection of your rights. We process Personal Data in accordance with this Privacy Policy in accordance with applicable law, including the General Data Protection Regulation (2016/679) (the “GDPR”) and applicable Lithuanian national data protection law.

Any reference in this Policy to "Your Personal Data" means any personally identifiable information ("Personal Data").

We are the controllers of the Personal Data falling within the scope of this Policy.

We use your personal data in carrying out our activities and providing services to you. Our purpose is to process only the personal data that you have voluntarily provided to us after receiving detailed information about the purposes of data processing and the data that is necessary for the performance of contracts with you, the implementation of legal requirements and our activities.

We kindly ask you to read this privacy policy to find out how we collect, use, transmit and store your personal data.

1. Collection and use of personal data

1.1. What information we collect

In order to provide quality Services, we process the following personal data of yours:

  • Contact information (name, surname, telephone number, e-mail)

  • User name

  • Photos, comments, reviews you share

  • Geolocation information

1.2. Legal basis for the processing of your personal data

We generally collect your personal data only to the extent necessary to provide the service to you. EU law obliges us to inform the individuals whose data we process about the legal basis for the processing. We rely on one of the following legal bases for processing your personal data:

  • Basis for performance of the contract. Applicable when the processing of your data is necessary to fulfill our obligations to you under the contract.

  • Basis for the legal requirement. Applicable when we are required by law or regulation to process your personal data, e.g. for tax accounting purposes, the provision of data to public authorities or the police.

  • Legal basis for consent. In certain cases, we will only process your personal data if we have obtained your prior consent. You can withdraw your consent to the processing at any time by contacting us at hello@afterway.com

  • Legal basis for legitimate interests. We will process your personal data in cases where we have a legitimate interest and such processing does not infringe the protection of your interests and rights.

For the above legitimate interest we have, for example:

  • We provide information about the Company's services to the visitors of our website and app;

  • We strive to prevent fraud and crime, protect our assets and the IT systems we use;

  • We organize and monitor the advertising solutions we use;

  • We seek to ensure the fulfillment of the Company's corporate and public obligations;

  • We ensure the implementation of the rights enshrined in Articles 16 and 17 of the Charter of Fundamental Rights of the European Union, including the freedom to conduct a business and the right to property.

1.3. Automatic collection of personal data

In some cases, we or our service providers use cookies, web beacons and other intelligent technologies to automatically collect certain information about you when you visit our website and email us. by mail. The collection of this information helps to tailor our website to your needs, increase the awareness, efficiency and usefulness of our information dissemination, and organize and track the effectiveness of the advertising solutions we use.

1.3.1. IP addresses

An IP address is a number assigned to your computer when you connect to the Internet. It allows computers and servers to recognize each other and share data. When you visit our website, your IP address is recorded and used for system diagnostic and security purposes. An IP address is also used to compile indicators that measure website traffic and usefulness.

1.3.2. Cookies

Cookies will normally be stored on your computer or other device to which you connect to the Internet each time you connect to our website. This allows us to differentiate your device from others.

In certain cases, when you visit the website, you will be given an information message asking you to consent to the use of cookies. If you do not give your consent, your computer and other device will not be targeted for direct marketing purposes. Cookies necessary for the functioning of the website (user-imput) will still be used to ensure the proper functioning of our website. Your choice regarding the use of cookies is stored in a separate cookie, which is valid for 90 days. If you wish to withdraw consent, you can do so by clearing your internet browser's cookies.

Most web browsers automatically accept and accept cookies, but you can usually modify your browser setting to block cookies. These settings are usually stored in your browser's Tools or Preferences menu items. You can also delete all cookies or certain cookies at any time. If you choose not to accept cookies at all, you may not have access to all the functionality of our website.

We sometimes use third-party tools and widgets to extend the functionality of our website. Typically, these tools and controls will store a cookie on your computer or device to ensure that additional functionality works.

Cookies do not automatically tell us your e-mail address or otherwise allow us to identify you. We use different identifiers, including IP addresses, to evaluate website performance, but only to determine the number of unique website visitors and the geographical distribution of users, and not to single out specific users.

BY BROWSING ON OUR WEBSITE AND APP, YOU AGREE THAT YOUR COMPUTER OR OTHER DEVICE WILL KEEP THE COOKIES NECESSARY TO OPERATE THE PAGE.

1.3.3. Web beacons

A network data logger is a small video file on a web page that can be used to gather information about a visitor's computer, including the IP address, time of visit, type of browser, and cookies already stored on the same server. When using Network Data Collectors, we strictly follow the legal requirements.

You may restrict the functionality of Network Data Collectors by prohibiting the storage of cookies necessary for their operation. In this case, the Network Data Collector can still record an anonymous visit from a specific IP address, but the cookie information will not be stored.

1.3.4. Means of locating

When you use our services, we may collect information about where you use your computer or other device. We use this information to better tailor our services to you.

1.4. Social Media Tools and Applications

Our websites may have functionality that allows you to share information using social platforms operated by third parties, e.g. Facebook like and share features. These social platforms may store data about your use of our website. Your personal data that you provide through such social platforms may often be transferred to other members of the social platform. Such data transfer is regulated in the privacy policy of the social platform manager. We do not control how your personal data is processed and we cannot take any responsibility for this.

2. Transfer of personal data to third parties

We do not transfer your personal data to any third parties who may use this data for direct marketing purposes.

We do not share your personal data with third parties unless it is necessary to provide services to you, fulfill your requests, our reasonable business needs and / or if required by law. That includes:

  • Our service providers: We share your personal data with third parties who provide services to us, e.g. our IT maintenance providers, our website hosting providers, our accounting providers, consultants, lawyers and other providers of goods and services. We work with these third parties and transfer the processing of your personal data to them. We only transfer your personal data to these third parties if they comply with our strict personal data processing and security requirements. We share your personal data only to the extent necessary to provide the services of these third parties.

  • If we or part of our business were sold, reorganized or transferred to another company: we would transfer personal data related to the sale or reorganization insofar as it is directly related to the performance of the business being sold or transferred.

  • Pre-trial Investigation Authorities, Courts or Other Authorities Authorized by the State: We will transfer personal data requested by courts, pre-trial investigation authorities or other authorized authorities when necessary for the performance of our legal duties or when there is another legal basis for the transfer of data.

  • Audit: We will transfer personal data if it is necessary to conduct a financial, data privacy and security audit or to investigate and respond appropriately to a complaint or security threat.

3. Your choices

As a general rule, when you use our services, we will not require you to provide personal information unless it is necessary to provide the services. Upon receipt of your request for information about our services to you, we may ask you to provide additional personal data. In certain cases, we may ask for your additional consent to the processing of personal data and you have the right to refuse to give consent to the processing of data for these purposes. If you consent to the receipt of certain services or information notices, we will give you the opportunity to withdraw this consent at any time. In the event of withdrawal of consent, we will endeavor to stop the use of your personal data for the purposes specified in the consent as soon as possible.

As stated in the "Cookies" section above, if you wish to disable your tracking using cookies on our website, you may remove cookies from your web browser and prohibit further storage of such cookies. In this case, some features of our website may not work properly.

4. Your rights

If we process your personal data, you can exercise the following rights:

  • Familiarization and correction. You have the right to access your personal data processed by us. In order to get acquainted with your personal data processed by us, you can submit a request to us. If, after evaluating your request, we decide that we must grant you such a right, we will provide the information free of charge. In order to ensure the protection of the rights of others and to respond appropriately to your request, we may ask you to provide personally identifiable information and other information about your relationship with us before providing a response. If your data processed by us is inaccurate, you have the right to request correction of this data.

  • Right to object to data processing. You have the right to object to us processing your personal data if we are no longer able to use it.

  • Other rights. If you feel that we should not process or store your personal data for too long, you have the right to request that your personal data be deleted or that its use be restricted. In certain cases, you also have the right to request a copy of the electronically stored information.

To exercise your rights you can contact us by e-mail. hello@afterway.com Upon receipt of your request, we will make every effort to assist you in exercising your rights, in accordance with applicable law and professional practice.

5. Data security and integrity

When storing your personal data, we use organizational and technical data protection measures and procedures to protect your personal data from unauthorized loss, misuse, alteration or destruction. Despite all our efforts, it is not possible to take into account all possible threats and guarantee the absolute security of personal data. In order to ensure maximum protection of personal data when processing your personal data, access to the data is restricted to our employees in accordance with the "need to know" principle. Data controllers are obliged to comply with strict requirements for the processing of personal data.

We make every effort to ensure that your personal data is processed only:

  • as long as this information is necessary for the provision of services to you or the provision of information to you;

  • until we are required to retain this information in accordance with law or business necessity, or until you request the destruction of your personal data. The specific period of data retention depends on the circumstances in which the information was collected and the purposes for which the information was used, but subject to the requirements set out in I) -III) above, personal data will not be stored for more than 2 years.

6. Links to other websites

Please note that our website contains links to other websites, including those operated by third parties, which are not covered by this Privacy Policy and the privacy provisions applicable to them may differ substantially. We encourage you to review the privacy policies of each such website before providing any information that identifies you.

7. Changes to this policy

We may review and update this Privacy Policy in accordance with our privacy policies. Each time we update the Privacy Policy, we will update the "Last Updated" field at the top of the Policy. You will be notified of any changes to your Privacy Policy between you and us by normal means of communication.

8. Ensuring a Privacy Policy

We are committed to protecting your personal data. If you have any questions or comments regarding the processing of your personal data, please contact us by e-mail at hello@afterway.com You may also submit any comments on this Privacy Policy to this address.

We will acknowledge receipt of your request within 14 days of receiving your request and will endeavor to provide a response within one month of receiving your request. If your request is complex or we have received a very large number of requests at that time, we may extend the deadline for responding to the request to three months from the date of receipt of the request.

Finally, you always have the right to lodge a complaint about the improper processing of your data with the State Data Protection Inspectorate.

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