Privacy Policy
1. What does this Privacy Policy mean?
In this privacy policy (hereinafter – Privacy Policy), we provide you with information on how UAB MOTOREMA (hereinafter – MEMELGO) processes your personal data obtained:
- when visiting the website www.memelgo.lt (hereinafter – Website);
- when Memelgo provides services to you;
- when you perform active actions on Memelgo’s social media accounts;
- when you register on our website and log in to your account;
- when Memelgo carries out direct marketing;
- when participating in Memelgo’s recruitment for job vacancies;
- when submitting inquiries to us.
Hereinafter, all specified persons whose data is processed by Memelgo are referred to as – Clients. The Privacy Policy also provides for certain obligations of Clients that must be followed when visiting the Website.
2. About UAB Memelgo
UAB Motorema, legal entity code 300887893, registered office at I. Simonaitytės g. 23-9, Klaipėda, data about the company is collected and stored in the Register of Legal Entities of the Republic of Lithuania. For data protection matters, you can contact us by email at info@memelgo.lt.
3. What is personal data?
Personal data is any information collected by Memelgo about a Client that can be used to identify the Client and is stored electronically or otherwise.
Personal data includes any information, including the Client’s first name, last name, address, and IP address, which Memelgo collects about Clients for the purposes specified in this Privacy Policy or in a separate Client consent or agreement with Memelgo.
This data also includes Clients’ personal information available in the public domain, which Memelgo becomes acquainted with when the Client contacts Memelgo via social media or performs active actions on Memelgo’s social media accounts.
4. How do we collect your data?
How we collect your data depends on the services we provide to you or the nature of our cooperation.
Memelgo processes data:
- obtained directly from the data subject (You), e.g., when you send us inquiries or messages via the specified contacts, sign cooperation agreements with us, send us your CV when applying for job vacancies, fill out questionnaires, register in our information systems, provide your email address to receive newsletters, etc.;
- which are generated when you use our services, e.g., when you use our network and services, i.e., make a phone call, send a text message, browse the internet, visit our websites, etc.;
- which we receive from other sources, e.g., where there is a basis, from other institutions or companies, i.e., publicly available registers, insurance companies, etc.
5. Personal data processed when providing services
| Purpose of data
processing |
Personal data processed | Data processing period | Basis for data processing |
| Conclusion of purchase and sale agreements with clients | First name, last name, identity document number, residential address, other data required for invoicing (for example, a copy of the identity document if paid in cash)
|
10 years after the end of the agreement | Agreement
GDPR Art. 6(1)(b)
|
| Conclusion of rental agreements with clients | First name, last name, address, date of birth, phone number, driver’s license number, driving experience
When concluding an agreement with a legal entity – details of the responsible person – first name, last name, phone number, position in the company, and a copy of the driver’s license.
|
10 years after the end of the agreement | Agreement
GDPR Art. 6(1)(b)
|
|
Provision of services using a company account (used only after concluding a rental agreement)
|
First name, last name, data, agreement details | Data is stored for 10 years from the client’s last login to the client account or the day of the client’s last purchase.
|
Agreement
GDPR Art. 6(1)(b)
Consent
GDPR Art. 6(1)(a)
|
| Debt administration
/recovery |
First name, last name, phone number, email address, address, amount of debt incurred, circumstances of debt occurrence, circumstances of debt coverage.
|
Until full coverage of the debt and 10 years after the end of this period. | Legitimate interest
GDPR Art. 6(1)(f) |
6. Direct marketing
| Purpose of data
processing |
Personal data processed | Data processing period | Basis for data processing |
| Sending offers, newsletters, and advertisements to clients
|
First name, last name, phone number, email address. | 2 years after the end of the agreement | Consent
GDPR Art. 6(1)(a)
Law on Electronic Communications Art. 81(1) |
You have the right to opt-out of receiving direct marketing communications at any time by contacting us by email at info@memelgo.lt.
If you are our active Client and have not expressed an objection to receiving Memelgo’s direct marketing communications, we will send you communications by email regarding goods or services that are similar to the services provided to you on the basis of our legitimate interest.
7. Personalized offers
| Purpose of data
processing |
Personal data processed | Data processing period | Basis for data processing |
| Provision of personalized offers based on data provided by the client | First name, last name, phone number, email address, address, frequency of service use, duration of the concluded agreement, etc. | 1 year after receiving consent | Consent
GDPR Art. 6(1)(a) |
You have the right to opt-out of receiving personalized offers at any time by contacting us by email at info@memelgo.lt.
8. Participation in recruitment for job vacancies
| Purpose of data
processing |
Personal data processed | Data processing period | Basis for data processing |
| Recruitment for job vacancies | Your CV and/or cover letter and other information provided by you. | Until the end of the recruitment process; cover letters are deleted after the interview with a potential candidate | Consent
GDPR Art. 6(1)(a)
|
9. Handling of inquiries, messages, and complaints
| Purpose of data
processing |
Personal data processed | Data processing period | Basis for data processing |
| Handling of inquiries by email | Your first name, last name, email address, and correspondence text. | 1 year from the resolution of the inquiry | Consent and agreement
GDPR Art. 6(1)(a) and (b)
|
| Receiving inquiries by phone | The phone number you are calling from, the recording of the phone conversation, call metadata – duration, time. | 30 days | Consent and agreement
GDPR Art. 6(1)(a) and (b)
|
All personal data you provide when communicating with us is used only for the purposes specified above and for reviewing messages and administering and managing communication flows.
We undertake not to use your personal data in any publications in a way that would allow your identity to be determined without your explicit consent.
10. Cookies
A cookie is a small file consisting of letters and numbers that we store in your browser or on your computer’s hard drive with your consent. We use different cookies for different purposes. Cookies also help us distinguish you from other website users, thus ensuring a more pleasant website experience and allowing us to improve the website.
Most browsers allow you to reject all cookies, and some browsers provide the option to reject only third-party cookies. You can take advantage of these options. However, please note that blocking all cookies will have a negative impact on the use of the Website, and without cookies, you will not be able to use all the services provided on the Website.
We use the cookies described below:
- Strictly necessary cookies. These cookies are essential for the Website to function. The basis for data processed by such cookies is the proper performance of the agreement when the Client visits the Website, and Memelgo ensuring the quality and security of the visit. These may be cookies that, for example, allow the Client to log in and access secure areas of the Website, use the shopping cart function, or other services.
- Analytical and/or performance cookies. These cookies allow Memelgo to recognize and count website visitors and monitor how visitors move around the Website while using it. This helps Memelgo improve the website’s performance, for example, by ensuring that users can easily find what they are looking for. The basis for processing data collected by these cookies is the Clients’ consent.
- Functional cookies. These cookies are used to recognize Clients when they return to the Website so that Memelgo can adapt the content provided to the Clients’ needs and remember information relevant to the Clients. The basis for processing data collected by these cookies is the Clients’ consent.
Detailed description of cookies:
| Cookie name | Purpose / function of data processing | Moment of creation | Validity period | Nature of the cookie (necessary, analytical, functional) |
| cclist | Records the client’s choice regarding cookies | After confirming the Cookie choice in the table | 1 year | Necessary |
| _ga [2x] | Registers a unique ID used to generate statistical data on how the visitor uses the website. | 2 years | Analytical | |
| _gat | Used by Google Analytics to regulate the request rate. | 1 day | Analytical | |
| _gid | Registers a unique ID used to generate statistical data on how the visitor uses the website. | 1 day | analytical | |
| _gcl_au | Used by Google AdSense to experiment with advertising efficiency across websites using their services. | 3 months | Analytical | |
| _fbp | Used for Facebook advertising. | 3 months | analytical |
11. Social media tools
The Website provides links to our accounts on social media tools. We currently have the following accounts:
- on the network “Facebook”, whose privacy notice is provided at https://www.facebook.com/privacy/explanation;
- on the network “Instagram”, whose privacy notice is provided at https://help.instagram.com/155833707900388;
- on the network “LinkedIn”, whose privacy notice is provided at https://www.linkedin.com/legal/privacy-policy;
- on the network “YouTube”, whose privacy notice is provided at https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/.
We recommend reading the privacy notices of third parties and contacting the service providers directly if you have any questions about how they use your personal data.
12. Disclosure of data
We may disclose information about you:
- to our professional advisors, auditors;
- to notaries, if the agreement concluded with you requires a notarial form;
- to bailiffs, entities providing legal and/or debt collection services,
- to entities taking over the right of claim to the debt;
- to processors of joint debtor data files;
- to companies providing data center, hosting, cloud, website administration and related services, companies developing, providing, supporting and evolving software, companies providing information technology infrastructure services, companies providing communication services;
- to companies providing advertising and marketing services;
- to companies providing archiving, physical and/or electronic security, asset management and/or other business services;
- to state institutions in the manner prescribed by law: State Tax Inspectorate, Register Center, Sodra, Labor Exchange, etc.;
- to law enforcement agencies upon their request or on our initiative if there are suspicions that a criminal offense has been committed, as well as to courts and other dispute resolution institutions;
- to tax administrators.
Your personal data will not be transferred to a third country and/or an international organization. Except as provided in this Privacy Policy, we do not provide your personal data to any third parties.
The list of recipients or categories of recipients specified in the Privacy Policy may change, so if you wish to be informed about changes in the recipients of your personal data, please inform us by email at info@memelgo.lt, stating “I wish to receive information about the change of recipients of my personal data, first name, last name”.
13. Security of your personal data
Your personal data will be processed in compliance with the requirements set by the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other legal acts. When processing your personal data, we implement organizational and technical measures that ensure the protection of personal data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing.
14. Your rights
In this section, we provide information about your rights related to our processing of your personal data and the cases when you can exercise these rights. If you want to receive more information about your rights or exercise them, please contact us at this email address: info@memelgo.lt.
Memelgo will provide you with information on the actions taken upon receipt of your request regarding the exercise of your rights without undue delay, but no later than within 1 (one) month from the receipt of the request. Depending on the complexity of the request and the number of requests received, the said period may be extended for another 2 (two) months. In such a case, we will inform you of such an extension and its reasons within 1 (one) month from the receipt of the request.
Memelgo will refuse to exercise your rights only in cases provided for by legal acts.
- Right to withdraw consent. If you have provided us with explicit consent for the processing of your data, you can withdraw it at any time at this email address info@memelgo.lt.
- Right to access your data. We aim for you to fully understand how we use your personal data and not experience any inconvenience because of it. You can contact us at any time and ask if we process any of your personal data. If we store or use your personal data in any way, you have the right to access it. To do this, submit a written request to us at this email address info@memelgo.lt, confirm your identity, and when submitting such a request, follow the principles of fairness and reasonableness.
- Right to request more information. If you have any questions about the use of your personal data, we will be happy to answer them or provide any additional information we can disclose. If you have any specific questions or did not understand the information provided, please contact us by email at info@memelgo.lt.
15. Additional rights
Below we provide information about additional rights you have, which you can exercise following the procedure described below.
- You have the right to request us to rectify any inaccuracies in the data held. In such a case, we may ask you to confirm the rectified information.
- You have the right to request us to erase your personal data. This right is exercised in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679.
- You have the right to request us to restrict the processing of your personal data or not to process them:
i. for the period necessary for us to verify the accuracy of your personal data when you submit claims regarding the accuracy of the data;
ii. when our collection, storage, or use of your personal data is unlawful, but you decide not to request the erasure of the data;
iii. when your personal data is no longer necessary for us, but you need it to establish, exercise, or defend a legal claim;
iv. for the period necessary to determine whether we have a more important legal basis to continue processing your personal data if you have exercised your right to object to the processing of personal data. - You have the right to the portability of data that we received from you with your consent or for the purposes of concluding an agreement. Upon your exercise of this right, we will transfer a copy of the data provided by you at your request.
- You have the right to object to our use of your personal data:
i. when we use such data to ensure our legitimate interests, but we do not have a more important legal basis to continue using your personal data; or
ii. at any time when we use your personal data to send newsletters or for direct marketing purposes. In such a case, the data will no longer be used for these purposes, but it may be used for other lawful purposes.
16. Complaints
If you believe that your rights as a data subject are and (or) may be violated, please contact us immediately with a complaint at the email address info@memelgo.lt. We assure you that upon receipt of your complaint, we will contact you within a reasonable period and inform you about the progress of the complaint investigation, and later about the result.
If the results of the investigation do not satisfy you, we inform you that you will be able to submit a complaint to the supervisory authority – the State Data Protection Inspectorate (contacts at www.ada.lt).
17. Liability
You are responsible for ensuring that the data you provide to us is accurate, correct, and complete. If the data you provided changes, you must inform us immediately by changing the relevant data in the registration form or, if the data is not specified in the registration form, by informing us by email. We will in no case be liable for damage caused to you because you provided incorrect or incomplete personal data or did not inform us of their change.
18. Changes to the Privacy Policy
We may update or change this Privacy Policy at any time. Such updated or changed Privacy Policy will take effect from its publication on our Website. You should check it occasionally to ensure that you are satisfied with the current version of the Privacy Policy.
After updating the Privacy Policy, we will inform you about what we consider to be significant changes by publishing them on the Website. If you log in to the Website after such a notice is published, you agree to the new requirements specified in the update. You can look at the “Update date” indicated at the bottom to find out when the Privacy Notice was last updated.
