Privacy Policy


By Order of the Director

No. 18-100 of 25 July 2018

‘On the Approval of the Privacy Policy’




adopted in accordance with 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


  1. PASPARA, UAB, registered company number 220052540, registered office address and address for correspondence: T. Ševčenkos g. 16F, LT-03111 Vilnius, contact details: email, telephone: +370 (5) 2660760, hereinafter referred to as the “Company”.
  2. Website – the website at
  3. Browser – a program designed for displaying web pages (websites) on the Internet or a personal computer.
  4. Personal data – any information related to a natural person, a data subject, whose identity is either known or can be established directly or indirectly using data such as a personal ID number or one or more factors specific to the physical, physiological, mental, economic, cultural, or social identity of that natural person.
  5. Privacy Policy – this document setting out the main rules for the collection, accumulation, processing, and storage of personal data using the Website.
  6. Cookie – a file sent to and stored on the user‘s computer upon accessing the Website;
  7. IP address – a unique number assigned to each computer connected to the Internet that is known as the Internet Protocol (IP) address and which is used for the identification of a person.


  1. The Website Privacy Policy sets out the main rules for the collection, accumulation, processing, and storage of personal data while using the Website. The Privacy Policy has been formulated having regard to the fact that the Website is not an online store and creating a user account is not possible thereon. The user may, upon accessing the Website, send an enquiry and provide personal data by email.
  2. The Privacy Policy is intended to protect and defend the personal data of the Website users against any unauthorised use.
  3. The purpose of the Privacy Policy is to regulate the personal data processing on the Company Website, in accordance with the provisions of 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, the Republic of Lithuania Law on the Legal Protection of Personal Data and related legal acts.
  4. The Website may contain links to websites of the Company‘s partners. Please note that other websites to which users are directed by clicking on the links contained on the Website have privacy policies of their own and the Company assumes no liability for these privacy policies. It is recommended that users familiarise themselves with such privacy policies prior to providing any personal data to such websites.


  1. The Company shall enable Website users to send an email to the Company‘s email address provided on the Website.
  2. The Company shall store the data received by email for 6 (six) months after the date of receipt thereof.
  3. The Company shall not disclose the personal data of the user to third parties except in the following cases:
    • The user has given the Company consent to the disclosure of their personal data;
    • The Company‘s partners that render services related to the due provision of the Company‘s services ordered by the user;
    • Provision of the user‘s personal data to third parties that act as data processors on behalf of the Company. The personal data shall only be provided to those data processors with whom the Company has concluded relevant agreements or in cases where cooperation agreements contain provisions on personal data transfer/provision and the data processor ensures appropriate protection of the personal data being transferred;
    • In all other cases, the user‘s personal data may only be disclosed according to the procedure prescribed by the law of the Republic of Lithuania. The Company may transfer the personal data of a data subject to governmental or law enforcement institutions at the latter‘s request.
  4. Notwithstanding the Company‘s best efforts to protect personal data, the Company cannot guarantee that the transmission of data to the website is secure. Any data transmission is performed solely at the user‘s risk. From the moment of receipt of the data, the Company applies stringent personal data protection procedures as well as technical and organisational measures to secure protection against any unauthorised access to personal data.
  5. The Company uses the user‘s personal data to:
    • Ensure that the content of the Website is provided to users in the most efficient and appropriate way;
    • Furnish users with information and services that are requested by the users or which may be of interest for the users if the latter have given their consent to being informed for this purpose.
  6. The Company‘s website may gather certain information about the user‘s visit, for example: (i) the IP address of the user; (ii) the date and time of the user‘s visit to the Company‘s website; (iii) other websites that the user visits from the Company website; (iv) the browser used by the user; (v) information about the operating system of the user‘s computer; (vi) mobile application versions; (vii) language settings. If the user accesses the website from a mobile device, the website may also gather data enabling the identification of the type of mobile device, device settings, and geographic coordinates (longitude and latitude). Such information shall be used to improve the Company website as well as its products and services, to analyse trends, and to administer the website. The user shall provide such data voluntarily by visiting the website.


  1. The Website uses performance cookies and functional cookies.
  2. Performance cookies. These cookies enable the counting of website users and the viewing of the origin of users. Based on such information, the Company may determine which pages of the website are visited most/least frequently and view the website browsing of users. Any information gathered by means of cookies is aggregated and anonymous. However, it enables the Company to ensure the smooth and efficient use of the website. These performance cookies are accumulated:
Name Provider Type Description Validity duration
_ga HTTP Registers a unique ID that is used to generate statistical data on how the visitor uses the Website. 2 years
_gat HTTP Used by Google Analytics to throttle request rate Google Analytics Session
_gid HTTP Registers a unique ID that is used to generate statistical data on how the visitor uses the website. Session
  1. Functional cookies – the cookie is stored on the user‘s computer upon accessing the website:
Name Provider Type Description Validity duration
pll_language HTTP Stores information which language is used in the website. 1 year
  1. The user is informed about cookies and browsing the website means the user’s consent to accumulate relevant information. The consent is unlimited in time or is valid until the user changes their consent by changing the browser cookie settings and deleting the stored cookies.
  2. By changing the browser settings, the user may delete or block the cookies, but part of the website may consequently not function properly.


  1. Users of the Website have the following main rights:
    • To know about the processing of their personal data;
    • To gain access to their personal data and to know how they are processed;
    • To order the rectification or erasure of the user’s personal data at the Company‘s disposal;
    • To object to the processing of the user’s personal data.
  2. The user, having submitted a written application to the Company (accompanied by a personal identification document), shall have the right to receive information about the personal data processed on the Website and about the sources from which their personal data were collected and what personal data were collected, about the purpose of the personal data processing, and the data recipients to which the personal data are provided. On receipt of the user‘s application, the Company shall, no later than within 30 calendar days from the date of receipt thereof, provide the data requested or specify the reason for the refusal to grant the application in the same form in which the user applied to the Company, unless the user has agreed to receive information about the data by any other method offered by the Company.
  3. Users may submit applications for access to, or the rectification or destruction of the personal data collected by the Company by email at, or by registered letter to the Company’s place of business at T. Ševčenkos g. 16F, LT-03111 Vilnius.
  4. Any application or instruction related to personal data processing shall be submitted by the user to the Company in writing by one of the following methods: (i) by registered letter to the Company‘s place of business at T. Ševčenkos g. 16F, LT-03111 Vilnius; or (ii) by email at
  5. Complaints filed by persons concerning the improper or unlawful processing of personal data shall be considered by the State Data Protection Inspectorate, registered office address at A. Juozapavičiaus g. 6, LT-09310 Vilnius,


  1. This Privacy Policy is available and can be printed out from the Website at any time. Users shall be notified of any amendments and/or additions to the Privacy Policy by the publication of the new version of the Privacy Policy on the Website.
  2. The Company is not responsible for any disruptions in communications due to which users and other persons cannot access or use the Company Website.
  3. The Company is not in a position to fully guarantee that the function of its website will be continuous and without disruptions or errors, or that the website will be fully protected against viruses or malware. The user must be aware that any materials that the user reads, downloads, or receives otherwise using the Company website are received solely at the user’s risk and discretion, and the user is fully liable for any damage caused to the user and the user‘s computer system.
  4. Users may send any questions, comments, and preferences regarding this Privacy Policy to

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