Privacy policy

This Privacy Policy contains the mandatory information about the processing of personal data carried out by Kauno grūdai, AB and its subsidiaries pursuant to 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 (General Data Protection Regulation) (hereinafter referred to as the Regulation).

The information provided below covers the following purposes of data processing: (i) processing of data of job candidates participating in the recruitment procedure and administration of the database of candidates; (ii) loyalty programme and direct marketing; (iii) video surveillance; (iiv) implementation of legal acts regulating penalties; (v) administration of appeals, enquiries and responses; (vi) e-mail communication; (vii) use of cookies; (viii) use of social networks; (ix) conclusion of contracts with natural persons. This Privacy Policy also describes the rights you, as the data subject, may have, provision of data to the recipients and any other conditions of personal data processing applied to personal data processed by the company on the basis of the purposes listed above.

Data controllers determining the purposes and means of the personal data processing may include Kauno grūdai, AB (legal entity number 133818917, address H. ir O. Minkovskių g. 63, Kaunas, Lithuania), KG mažmena, UAB (legal entity number 302602745, address H. ir O. Minkovskių g. 63, Kaunas, Lithuania), “Šlaituva“, UAB (legal entity number 134019827, address Linksmakalnio k. Sodų g. 7, Kauno r. sav.), Baltic Fumigation Service, UAB (legal entity number 300094020, address H. ir O. Minkovskių g. 63, Kaunas, Lithuania), KB „Grybai LT“ (legal entity number 302765404, address Zibalų g. 37, LT – 19124, Širvintos, Lithuania) and related company UAB „Agro logistic service“ (legal entity number 303014392, address H. ir O. Minkovskių g. 120, Kaunas, Lithuania)  (hereinafter collectively referred to as the Companies, and individually as the Company). For some purposes of personal data processing these Companies may be joint data controllers, meanwhile for other purposes – individual data controllers. Information as to which purpose data processing purpose entitles the Company to be the data controller, is provided below or may be submitted in any other way convenient to you.

 

Processing of Personal Data of the Job Candidates Participating in the Recruitment Procedure and Administration of the Database of Candidates

If you sent us your CV (curriculum vitae), resume, references and/or other documents or data based on the job advertisement published on our website or a specialised website for employee recruitment and job search or uploaded elsewhere, any personal data submitted by you voluntarily as well as any other data provided below will be processed for the purposes of recruitment of employees.

Your personal data will be processed until the end of the recruitment procedure, i.e. a specific candidate will be employed, his/her trial period will expire or the selection will be completed without choosing a specific candidate. This period should not exceed 4 months. After the end of the recruitment procedure, your personal data will be stored for a period of 3 years in order to be able to offer you a job in case of a new vacancy unless you express your disagreement or objection to such further storage of data. If you disagree with the storage of your data after the end of the recruitment procedure, please inform us thereof by email, a form of information on the processing of personal data or in any other way convenient to you.

Your personal data will be processed on the basis of your consent to participate in the recruitment procedure, as well as on the basis of the legitimate interest and the rights and duties stipulated by the laws.

If you submit your personal data voluntarily allowing us to store them in the database of the candidates and to contact you when needed, the Companies, acting as joint data controllers, will store your personal data for a period of 3 years.

Please note that in exercising the right granted by the laws that regulate the protection of personal data, your former employers may be contacted and asked to give their opinion about your qualification, professional skills, and disciplinary characteristics. However, your current employer will not be contacted without your express consent that should be obtained in advance.

The Company having the status of data controller in respect of your personal data processed for this purpose will be indicated in the job advertisement or any other way. Data controller may also one particular Company and all Companies acting as joint data controllers.

 

Loyalty Programmes and Direct Marketing

If you are a client of the Company or Companies, if you participate in the loyalty programme or have expressed your will to receive direct marketing material, the personal data that you have voluntarily submitted, including e-mail and telephone number, will be used to send you information about the goods and services, news, promotional campaigns, events or any other information considered as direct marketing on the given contact details as well as through social networks, media channels and other similar electronic communication channels.

Without your consent, direct marketing will be conducted by your e-mail only if you are a client of the Company or Companies. Such marketing will be conducted pursuant to the right provided by legal acts.

For the purposes of direct marketing, your personal data will be processed for a period of 5 years as from the day of receipt of your consent or after the expiry of relations between you and the Company.

In each e-mail sent to you we will provide you with an option to unsubscribe to direct marketing communication. You may also reject or recall your consent by contacting the Company on the indicated contact details.

The data controller responsible for the personal data processing for the purposes of loyalty programme is KG mažmena, UAB. Data controller responsible for the personal data processing for the purposes of direct marketing is the Company that you are a client to and to which you have given your consent to conduct direct marketing.

 

Video-surveillance

The data controller Kauno grūdai, AB has video-surveillance for the purpose of ensuring the safety of property and persons (includes all surveillance cameras used) and for the purpose of control and quality assurance of the food production process (includes all the surveillance cameras used to monitor the food production process).

Footage is stored by the Company for 30 days, except in cases where there is reason to believe that a misdemeanor, misconduct or gross misconduct, a criminal act or other illegal actions have been captured and recorded. In such a case, the footage is stored until the end of the relevant investigation and/or trial. Footage of the food production process is stored for 3 months.

Video-surveillance is carried out to meet the purpose of a legitimate interest. Data subjects are informed about sites, where video-surveillance is carried out, using warning signs.

Footage data can be provided as evidence or in other cases established by law to a pretrial investigation institution, prosecutor, or court for administrative, civil, criminal cases before them. Companies providing security services may also have access to the said footage.

 

Implementation of legal acts regulating penalties

In compliance with the laws of the Republic of Lithuania, the European Union and international laws that provide for penalties, we check whether we can cooperate and have business relations with any natural and legal person. For this purpose, we process such personal data as the name, date of birth, nationality of contractors or their managers, shareholders, or beneficiaries, as well as information about any penalties imposed on them. We receive this data from potential contractors and also check it in national and international databases and other publicly accessible and available sources. We use the services of a data verification service provider. The data controller is the Company, with which a potential contractor may have business relations.

 

Administration of Appeals, Enquiries or Responses

If you have sent an appeal, enquiry or response on the Company’s e-mail or submitted it by any other means, your voluntarily submitted personal data will be processed for the purposes of administration of this appeal, enquiry, or response.

If your appeal is related to a potential dispute, presumed damage, etc., your personal data may be stored for a maximum period of 10 years. If personal data is not related to the potential dispute, they will be deleted within a shorter period of time.

Processing of your personal data will be based on your free-will notice, i.e. a consent. In certain cases, however, a legal act may become the basis of a further storage of the appeal.

Data controller responsible for the personal data that is processed for this purpose is the Company, which received your appeal, enquiry, or response.

 

Communication by E-mail

In any electronic communication, the basis for processing of your personal data provided is the expression of your free will for the communication by e-mail and provision certain data therein, i.e. consent. If you communicate with the Companies as employees of companies with which we have or may have contractual relations, the basis for the processing of your data provided during electronic communication may be a legitimate interest. Furthermore, the basis for processing of data may also be performance of the duties stipulated by the laws.

In addition to the use of your data for conclusion and performance of the contract, they are also processed for the purpose of internal administration.

Your e-mail address, content of correspondence and related data will be processed in accordance with the principle of proportionality. Such data will, first of all, be available to the person with whom you have a direct e-mail communication. In certain cases, however, your correspondence may be read and processed by other employees, for example, for the purposes of electronic monitoring of the workplace, investigation of possible breaches of laws or internal rules, implementation of internal rules, substitution of employees and related purposes, as well as similar situations.

The data controller responsible for the personal data processing for this purpose is the Company the employees or other representative of which you are communicating with.

 

Use of Cookies

Cookie is a small file of letters and digits recorded to your web browser or a hard-disk of your computer. Different cookies are used to seek different purposes. Cookies also help to distinguish you among other website users, thus ensuring a more convenient use of website and enabling us to improve the website.

The majority of browsers allow to reject all cookies, while some browsers provide an option to reject only the cookies of third parties. You may use these options. However, please note that not allowing to use all cookies will have a negative effect on the use of website; without cookies you will not be able to use all the services offered by the website.

The following cookies are used on Kauno grūdai, AB website:

• performance (session) cookies. They are used to improve the performance of website and collect general (anonymous) information on the use of website;
• analytical (monitoring cookies from “Google Analytics”). These cookies allow to recognise and calculate website visitors and monitor how the visitors move on the website. It helps to improve the performance of website, for example, to ensure that the users could easily find what they are looking for. The basis for the processing of data collected by these cookies is a consent;
• functional cookies. These cookies are used to recognise website users when they visit the website again. It allows to present the content of social networks adapted to the needs of website users, to memorise the information that is relevant to the clients. The basis for the processing of data collected by these cookies is a consent of the clients.

 

Below please find a list of cookies used on the website of Kauno grūdai, AB:

1P_JAR	This type of cookie is used to collect the statistics of website and follow the quantities of conversions.
4click	This cookie shows information related to your use of website.
AID	This cookie shows information related to your use of website.
APISID, HSID, NID	Google attributes cookies on any website that uses Google Maps. We do not have the opportunity to control Google cookies. These types of cookies collect information on the behaviour of users of Google Maps.
CONSENT	Google Analytics cookie used to enable the session.
JSESSIONID	Newrelic cookie aimed at monitoring the performance.
PHPSESSID	This cookie allows to present the text via website.
SAPISID	This cookie helps to show YouTube videos.
SID	This cookie supports the main functions of YouTube videos. They are used only on pages with YouTube videos.
SIDCC	Protection cookies used to protect the data of users from unauthorised access.
SSID	This cookie allows to save the choices of visitors by using Google maps
__utma	This permanent cookie shows how many times the website was visited by a particular visitor, what was the time of the first and last visit.
__utmz	This cookie shows which search engine is used by the visitor, which website he/she came from to visit this website, which search words were used by the user.
_hjIncludedInSample	This cookie shows the information about the use of website.

 

How to disable cookies? The majority of browsers are set to accept the cookies automatically. Having the information on how and why they are used, you may decide to accept or disable the cookies in the browser. The majority of browsers allow you to control cookies via their settings. If you do not want to accept the cookies, you may choose not to accept all cookies via the settings or to send a notice when a cookie is created. We would like to warn you that in case of rejection of cookies you may lose a possibility to use certain functions. In order to disable cookies, you can set your browser to reject all cookies or send a notification when a cookie is created.

Data controller responsible for the personal data processed for this purpose is Kauno grūdai, AB.

 

Use of social networks

Any information provided by you via social media (including the status messages, use of “Like” and “Follow” functions, as well as other information) is controlled by the controller of social network.

At the moment, Kauno grūdai, AB uses the following profiles:

• on Facebook, the privacy statement which is provided at https://www.facebook.com/privacy/explanation;
• on LinkedIn, the privacy statement which is provided at https://www.linkedin.com/legal/privacy-policy.

We recommend you reading the privacy statements of third parties and contact the service providers directly if you have any questions regarding the method of use of your personal data.

 

Conclusion of Contracts with Natural Persons

We will store the personal data processed for the purposes of conclusion and performance of contracts with natural persons for a period of 10 years from the expiry of the contractual relations. We will process your personal data on the basis of performance of contract which you are a party to as well as in order to take actions on your request before the conclusion of contract. For the performance of certain individual actions, we may request your consent and we may also have an obligation to carry out legal duties, for example, the duties stipulated in the legal acts regulating the payment of taxes.

For the aforementioned purposes, we will manage your personal data submitted directly before the conclusion of contract and during the performance thereof. In case you fail to provide the said data, we would not be able to conclude and perform the contract.

Furthermore, in order to verify the accuracy of personal data and information, provide a commercial credit, perform the assessment of solvency and financial risk as well as control your liabilities, to perform any other actions necessary for the performance of contract, we may collect the following personal data from third parties: immovable and movable property possessed, other data from the register of real property, data from the Register of Property Seizure Acts, data controlled by the Central Mortgage Office, data from the Register of Agriculture and Rural Business, Register of Tractors, Automotive and Agricultural Machines and their Trailers of the Republic of Lithuania, Register of Domestic Animals, data from the Register of Residents, any other data controlled by State Enterprise Centre of Registers, State Enterprise Regitra, State Enterprise Centre for Agricultural Information and Rural Business, data administered by Creditinfo Lietuva UAB, Loan Risk Databases of the Bank of Lithuania, any other data available from the registers and information systems of the state and municipalities and their institutions as well as data administered in the public files of private companies.

A data controller responsible for the personal data processed for the aforementioned purposes is a Company with which the contract is concluded.

 

Provision of personal data to the recipients of data

Your personal data may be provided to:

• the providers of IT, server, postal, archiving, marketing, accountancy and other services and their subcontractors;
• notaries, bailiffs, lawyers, consultants, auditors, debt recovery companies, as well as debt buyers and assignees;
• law-enforcement authorities, courts, other institutions involved in the examination of disputes and other authorities and persons performing the functions assigned to them by law;
• potential or current assignees of our business or part thereof or their authorised consultants or persons, other participants in the reorganisation.

The companies belong to AB “Linas Agro Group” of companies, therefore, we can transfer your data within AB “Linas Agro Group” of companies on the basis of legitimate interest for the purpose of internal administration thereof. The structure of the group of companies and any modifications thereof can be accessed at: https://www.linasagrogroup.lt/apie-mus/grupes-struktura/.

 

What are the principles of personal data protection that we follow?

The below principles are followed when collecting and using personal data submitted by you or received from other sources:

• your personal data are processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
• your personal data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’);
• your personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘the principle of data minimisation’);
• the processed personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are being processed (‘data minimisation’);
• your personal data is kept in a form which permits identification of data subjects for no longer than necessary for the purposes for which the personal data are being processed (‘storage limitation’);
• your personal data is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).

 

Realisation of the rights of data subjects

Please be informed that you as the data subject have the following rights:

• the right to familiarise with your data and the method of their processing;
• the right to request that any inaccurate or incomplete data we have be rectified;
• the right to request to delete your personal data. This right is exercised in the cases provided for in Article 17 of the Regulation;
• the right to request that the processing of personal data be restricted or that the data is not processed ;
• the right to the transmit the data that is processed by automated means and that we received from you after you gave your consent or for the purposes of concluding a contract;
• the right to object to the data being processed, as provided for in Article 21 of the Regulation, especially in the case where the data is processed on legitimate grounds;
• the right to withdraw your consent to process personal data, if you have given such consent;
• the right to submit a complaint to the State Data Protection Inspectorate (L. Sapiegos Str. 17, 10312 Vilnius).

In order to implement the rights of you as the data subject, it is necessary to establish your identity. In case of failure to establish your identity, we will not be able to make sure, whether a person who submits an application is the one whose personal data is processed, therefore we will not be able to ensure your personal rights.

We may refuse to examine your application for the implementation/exercise of your rights or we may ask for a respective, if the application is clearly unreasoned or excessive, as well as in other cases established by the laws.

If you wish to exercise your rights as the data subject or if you have any questions regarding the processing of personal data, please contact us by the following contacts: duomenu.apsauga@kggroup.eu, or submit/send your enquiry to the Company you want to apply to at the address provided at the beginning of this Policy.

You can find information about personal data processing by AB “Linas Agro Group” of companies at the following link: https://www.linasagrogroup.lt/wp-content/uploads/2013/03/1.-LAG-Privatumo-politika_2022-05-30.pdf. In the cases mentioned in this policy, Kauno grūdai, AB, along with other specified companies of the group, is a joint data controller.

Policy updated on: 14^th of November, 2023