privacy policy

How do we process Your data?

Latest update 2023-11-28

This privacy policy provides information about the processing of personal data of website http://compleg.lt/ (Website) visitors, Dovilė Boguševičienė law firm (Law firm) clients, service providers and candidates to employees.

Personal data – any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

By using any of the services specified in this privacy policy or by submitting any information about Yourself to the Law firm (for example, by filling out a request form on the website), You understand that Your personal data will be processed for the purposes and scope specified in this privacy policy. You may not use the
website and services if You do not agree to this privacy policy.

Personal data controller – Attorney at law Dovilė Boguševičienė, registered address Mindaugo g. 30-1, Vilnius, phone +370 686 40388, e-mail info@compleg.lt. If You have any questions regarding this privacy policy, You can contact us using the contact details provided.

When processing personal data, the Law firm is governed by this privacy policy, complies with applicable legal acts regulating the protection of personal data, including General Data Protection Regulation (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, hereinafter – GDPR), follows instructions of the competent authorities, as well as established standards and procedures to ensure that personal data is processed accurately, fairly, lawfully, transparently and securely.

The Law firm implements appropriate technical and organizational measures to protect Your personal data from accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access and from all other unlawful processing methods. However, You should understand that the Law firm cannot guarantee the security of any information You transmit, as currently none of the methods of data transmission or storage are 100 percent secure.

Collected personal data, legal bases and objectives of personal data processing

The Law firm is entitled to process Your personal data on at least one of the following legal bases:

1) in order to conclude and perform a contract for legal services, also to take steps at Your request prior to entering into such contract (GDPR Article 6, Paragraph 1, Clause b);

2) upon receiving Your consent to the processing personal data for one or more specific purposes (GDPR Article 6, Paragraph 1, Clause a);

3) for the performance of legal obligations applicable to the Law firm (GDPR Article 6, Paragraph 1, Clause c);

4) Law firm having
a legitimate interest in processing Your personal data in a specific way (GDPR Article 6, Paragraph 1, Clause f), except where Your legitimate interests or fundamental rights and freedoms, requiring protection of personal data, do not prevail over this Law firm‘s interest;

5) In exceptional cases – to protect vital interests of You or other persons.

Law firm usually receives personal data from You, but for the below stated purposes, personal data may also be received from third parties. The Website uses cookies to collect personal data. Strictly necessary cookies allows the Law firm to implement or change the Website’s content in real-time. To remember the language the user selects when returning to the Website and get the language information when unavailable in another way, the Law firm uses functional cookies. 

Processing of personal data for the purpose of providing legal services:

For the purpose of identifying a person, verifying the absence of a conflict of interest, restrictive measures, anti-money laundering and terrorist financing prevention, concluding and performing a legal services contract, including defending legal claims under a legal services contract, the Law firm processes the following personal data: name, surname of the client/potential client, client‘s representative, organization, job title or position, office address, personal or legal identification number, date of birth, identity document number and issuance information, nationality and country of residence, countries where the potential client or represented company maintains or intends to maintain business relationships, business activities’ links to special areas, status of politically exposed person (if exists), political affiliation, payment arrangements and source of funds / income, directorships, shareholdings, information about beneficial owners of the represented company, photo, address, e-mail, phone number, signature, bank account and payment details, involvement in other Law firm’s cases and assignments, other data related to the specific legal services requested by the client.

When processing is necessary for the establishment, exercise or defense of legal claims of the client, special categories of personal data may also be processed, such as health data (GDPR Article 9, Paragraph 2, Clause f) and other sensitive personal data, such as personal data relating to criminal convictions and offences or related security measures (GDPR Article 10).

To the extent necessary according to the procedure established by legal acts, personal data collected for this purpose are also processed for the purpose of fulfilling the legal obligations of the Law firm (meeting requirements of invoicing, tax payment, accounting, Lithuanian Bar Association, anti-money laundering, archiving, etc.) and are stored in compliance with the obligations, provided for in the relevant legal acts.

Processing of personal data for the purpose of direct marketing:

For direct marketing purposes (for example, sending newsletters), the Law firm may process the following personal data upon Your consent: first and last name, e-mail, organization, position.

You have the right to object to the processing of personal data for marketing purposes at any time, free of charge, by submitting an objection to the Law firm by e-mail. In this case, marketing messages will no longer be sent to You.

Processing of personal data for communication purposes:

In order to respond to Your inquiries, sent to the Law firm by mail, via contact form of the Website or social networks, the following personal data may be processed: name, surname, name of legal entity or profile name used in the social network, e-mail, other contact data that You provide (for example, phone number, social profile picture), content of the request. This personal data will be processed on the basis of Your consent (request to contact, provide information), legitimate interest in examining and responding to the request, also in the performance of the legal services contract. When contacting through the contact form, the person’s name of legal entity name may not be indicated, but the e-mail address is necessary in order to respond to the request. If You do not provide any contact details or the specified contact details are not relevant, we will not be able to respond. When contacting Law firm, You must ensure that the correspondence You send do not contain illegal content. 

Processing of personal data for recruiting purposes:

For the purpose of employee selection, the Law firm collects the following personal data: name, surname, e-mail address, telephone number, CV and other information provided to the Law firm when applying for an offered position. Candidate’s personal data is processed on the basis of a legitimate interest in assessing his suitability for the position and candidate‘s consent expressed by sending the documents specified in the Law firm‘s position offering. If the candidate does not provide the personal data specified in the Law firm‘s position offering, Law firm will not be able to assess candidate‘s suitability for the position.

Personal data, related to the candidate’s assessment, is most often provided by candidates themselves, but may be also received from third parties or created by the Law firm (interviews, evaluations, etc.).

The Law firm may collect personal data, related to the candidate‘s qualifications, professional abilities and subject characteristics from candidates‘ former employers. The Law firm may also request such information from the current employer, but only with the separate Consent of the candidate.

Personal data related to candidate‘s health shall be collected only in accordance with regulations for jobs and activities in which employees are permitted to work only if they have been pre-screened and subsequently periodically checked for contagious diseases.

Data on convictions shall be processed only when such personal data is necessary to verify whether the candidate complies with the requirements established by legal acts for the performance of duties. 

Personal data of the candidate, obtained during the selection process shall be kept for as long as the Law firm carries out the selection for a specific vacancy. Once an employee has been selected, the documents he/she submitted to the Law firm are attached to the personal file and kept for as long as the employee works in the Law firm or longer for archiving purposes, as set by applicable laws. If the candidate is not employed at the end of the selection, the personal data,
collected for this purpose, shall be destroyed. Prolonged retention of a candidate’s personal data (up to 6 months) by the Law firm is possible upon candidate‘s consent.

For any of the above-mentioned purposes, Your personal data is processed only to the extent necessary to fulfill the purposes for which it was collected and processed. Your personal data will be deleted after the expiration of the above-mentioned terms. In some cases, if required or permitted by relevant legal acts, Your personal data may be stored for a longer period of time.

Data transfers

The Law firm does not normally disclose Your personal data, but it may be available to employees of the Law firm if they are assigned to perform certain functions specified in the privacy policy (providing legal services, sending marketing messages, etc.), as well as to external data processors, providing accounting, information, document management system administration, marketing and other services to the Law firm in accordance with instructions of the later.

In certain circumstances, we may be required to transfer personal data to law enforcement authorities, to the extent that such an obligation is provided by legislation and proportionately to specific legitimate purposes.

Disclosure of personal data may be reasonably necessary to assert or defend Law firm‘s claims (for example, at court) or to protect Your vital interests (for example, if You feel unwell in our premises and we have to contact doctor).

In the performance of the legal services contract and to the extent reasonably necessary for the provision of specific services, it may be necessary to transfer Your personal data to public registries, courts, arbitrators, mediators, other parties to the process, police, tax and other law enforcement authorities, other lawyers, legal assistants, experts and other advisers, translators, notaries, persons providing postal or courier services, other natural or legal persons, if this is necessary to provide You with legal services as efficiently as possible.

The Law firm does not transfer Your personal data to third countries (not belonging to the EU/EEA), unless it is reasonably necessary in order to provide You with legal advice (for example, to use experts in third countries). In this case such transfer of personal data is carried out in accordance Chapter V of the GDPR, informing You about appropriate security measures related to data transfer.

Your rights as a data subject:

i) right of access (to obtain from the Law firm confirmation as to whether or not personal data concerning You are being processed, and, where that is the case, access to the personal data);

ii) right to obtain from the Law firm without undue delay the rectification of inaccurate personal data concerning You. Taking into account the purposes of the processing, You also have the right to have incomplete personal data completed;

iii) right to obtain from the Law firm the erasure of personal data concerning You without undue delay where at least oneof the grounds set in GDPR applies;

iv) right to restriction of processing where at least one of the grounds set in GDPR applies;

v) right to receive the personal data concerning You, which You have provided to the Law firm, in a structured, commonly used and machine-readable format and right to transmit those data to another controller.

In case the processing of Your personal data is based on Your consent, You have the right to withdraw this consent at any time. The withdrawal will not affect the legality of the data processing that was carried out before the withdrawal of consent.

In case the processing of Your personal data is based on the legitimate interest of the Law firm, You have the right to object to the processing of Your personal data at any time for reasons related to the specific case.

To exercise these rights, You should submit a request to the Law firm by e-mail or by post. The Law firm will exercise Your rights within 30 days, unless there are legitimate reasons to extend this period. In order to ensure data protection and properly implement Your rights, the Law firm has the right to ask You to confirm Your personal identity.

You also have the right to file a complaint with a data protection authority, i.e. Lithuanian State Data Protection Inspectorate (address L. Sapiegos str. 17, 10312 Vilnius, Lithuania, e-mail ada@ada.lt, website https://vdai.lrv.lt/). We recommend that You always contact the Law firm and inform about any concerns or questions before submitting a complaint.

Other important information:

The Law firm has the right, at its sole discretion, at any time, based on new features or legislation, in whole or in part, to change, modify, supplement or remove the Website, its content including this privacy policy. Changes to the privacy policy take effect from the date of their publication. We recommend that You review this privacy policy regularly to be aware of any changes.

The Website may contain links to websites owned, published and maintained by third parties. The Law firm does not assume any responsibility for the accuracy or reliability of such third party websites.

The Website contents are provided as general guidance only and should not be relied upon as a substitute for specific legal advice.

The Website is intended for persons over 18 years of age. The data of persons under the age of 18 may be processed for the purpose of providing legal services, the personal data of legal representatives (parents, guardians) of such persons are processed for the purpose of communication, the legal representatives also
decide on giving consent to process the data of persons under the age of 18, when the data is processed with consent basis.