1. GENERAL PROVISIONS

1.1 We care about privacy and safety of personal data on our customers, website visitors and other persons with whom We maintain a relationship (hereinafter referred to as ‘You’), therefore, We have formulated this Privacy and Cookie Policy (the ‘Privacy Policy’) in which We explain how We process and store Your personal data and what are your rights, and provide other information on the processing of Your personal data.

1.2 The term personal data as used in this Privacy Policy (the ‘personal data’) means any information or set of data that allows us to identify You, e. g. based on your first name, surname, email address, telephone number etc., either directly or indirectly.

1.3 In the processing of the personal data, We comply with the General Data Protection Regulation No 2016/679 (EU) (GDPR) and legal acts of the Republic of Lithuania as well as with instructions of supervisory authorities.

1.4 This Privacy Policy applies when You visit our website www.rmtools.eu or shop in our online store RM TOOLS at www.rmtools.eu/lt/shop (hereinafter the website and the online store referred to as the ‘Online Store‘), visit our accounts on social networks such as Facebook, Instagram, LinkedIn, and YouTube (the ‘Social Networks‘), visit and shop in physical RM TOOLS stores, review information provided by us, contact us by phone or other communication channels, show interest in our offers or contact us on other matters. The Privacy Policy also contains information on the personal data processing conducted by us in the process of concluding and performing contracts with service providers and suppliers.

1.5 The Online Store and the Social Accounts may contain links to external websites. This Privacy Policy does not apply to any websites accessed via such links. We recommend that You should review privacy policies of such websites before browsing them or providing Your personal data on accounts created thereon.

1.6 Please read this Privacy Policy carefully. If You order our goods or use the Online Store otherwise, contact us, subscribe to our newsletters, collaborate with us, or visit our physical stores, We deem that You have read and familiarised yourself with the Privacy Policy and the specified purposes, methods and procedures for using the personal data.

1.7 This Privacy Policy is subject to change, therefore, please visit the Online Store from time to time and read the latest version of the Privacy Policy.

2. ABOUT US

2.1 We are RM tools, UAB, registered company No 300531445, address Kalvarijų g. 143-16, LT-08352 Vilnius, Lithuania (the ‘Company’ or ‘We’). Data on the Company are collected and stored in the Register of Legal Entities managed by State Enterprise Centre of Registers.

 2.2 We manage the Online Store and the Social Accounts and, in offering goods, engaging in usual business activities and complying with the law, We act in the capacity of a personal data controller.

3. YOUR PERSONAL DATA WE PROCESS

3.1 We process Your personal data obtained in the following ways:

3.1.1 You provide Your personal data to us, e. g. by registering on the Online Store, ordering goods, or contact us by email or by telephone;

3.1.2 Your personal data are collected by us during Your use of the Online Store and the Social Accounts, e. g. Your IP address, history of visiting the Online Store, Your choices, URL links opened etc.;

3.1.3 Your personal data are collected while You visit and shop in our physical stores, e. g. by means of video cameras;

3.1.4 Your personal data are received from your employers (our service providers/suppliers) in the contracting process, when they specify You as their representative and/or person responsible for the performance of the contract;

3.1.5 Your personal data are received from other persons, e. g. public registers, state or local authorities or other organisations, our partners that deliver goods to You, or other third parties such as payment institutions that provide information on payments made etc.

3.2 By providing Your personal data You assume responsibility for their truthfulness, completeness and relevance, also, if You provide personal data on another person – for obtaining their consent to such provision. We may ask You to prove that You have the right to provide or receive data on another person. If necessary (e. g. when a person has enquired about receipt of their personal data), We will specify You as the personal data provider.

3.3 We process Your personal data for the following purposes and on the following grounds:

Purpose of personal data processing	Personal data processed	Term of personal data processing	Legal ground for personal data processing
Registration on the Online Store, creating a registered user account, and user identification	First name, surname, password, email, telephone No, address; business licence No/No of certificate of individual business activities; type of activities; in the case of a representative – name of entity being represented, relationship with the entity, VAT ID No; details of using the account.	During the term of the account use plus 2 years after last log-in to the account.	Performance of a contract with You or an intention to take steps at Your request prior to entering into a contract (Article 6(1)(b) of GDPR). Your consent to the personal data processing given to us (Article 6(1)(a) of GDPR).
Sale of goods and provision of services including goods delivery	First name, surname,  email, telephone No, address; in the case of a representative – name of entity being represented, relationship with the entity, VAT ID No; order (purchase) details, order history, delivery details, payment details, other related information.	During the term of order fulfilment (performance of contract) plus 10 years after the end of the term of the contract; Accounting and tax documentation is stored on the ground of compliance with legal acts within time limits specified therein.	Performance of a contract with You or an intention to take steps at Your request prior to entering into a contract (Article 6(1)(b) of GDPR); Compliance with a legal obligation (Article 6(1)(c) of GDPR).
Performance of warranty obligations, management of issues related to goods quality	First name, surname,  email, telephone No, address / delivery address; in the case of a representative – name of entity being represented, relationship with the entity, basis of representation; content of communication, data related to warranty service.	During the term of warranty service and management of a quality-related issue (2 years from the purchase date) plus for 5 years after the end of this term (the last contact).	Performance of a contract with You (Article 6(1)(b) of GDPR); Compliance with a legal obligation (Article 6(1)(c) of GDPR) in accordance with the Civil Code of the Republic of Lithuania (Official Gazette, 2000, No 74-2262).
Management of queries about the Company’s activities and goods	First name, surname,  email, telephone No, address / delivery address (if necessary for the query management), content of the query and the reply; business licence No/No of certificate of individual business activities, type of activities; in the case of a representative – name of entity being represented, relationship with the entity, basis of representation; other information related to the query and efficient management.	During the query management period and for no longer than 1 year after expiry thereof.	Your consent to the personal data processing given to us (Article 6(1)(a) of GDPR); If We have entered into a contract and Your query is related to such contract, then performance of the contract is the legal ground for the personal data processing (Article 6(1)(b) of GDPR)
Finance management, financial accounting, fulfilment of tax liabilities, debt management	First name, surname,  email, telephone No, job title, address; in the case of a representative – name of entity being represented, relationship with the entity, current account No, credit institution, information on payments, information on debts, information on tax documents, details of communication on taxes, other relevant information.	Accounting and tax documentation is stored on the ground of compliance with legal acts within time limits specified therein; Where data do not fall within the area of storage according to the law – during the term of the contract plus for 10 years after expiry thereof.	Performance of a contract with You  (Article 6(1)(b) of GDPR); Compliance with a legal obligation (Article 6(1)(c) of GDPR); Our legitimate interest in performing our obligations properly and efficiently (Article 6(1)(f) of GDPR).
Administration of e-information channels (Online Store, Social Accounts) and quality management	IP address, data collected by means of the Online Store‘s cookies and settings, browser used, log-in date and time; model, manufacturer and operating system of mobile device; data collected by way of integration of the Social Accounts etc.	As stated in Section 9 of the Privacy Policy. Information is stored in the Social Accounts on the terms and conditions set by the owner of the relevant social network.	Your consent to the personal data processing given to us (Article 6(1)(a) of GDPR); Our legitimate interest in managing the Social Accounts and other e-information channels properly and efficiently (Article 6(1)(f) of GDPR).
Sending of newsletters, arranging surveys about the Company‘s activities and quality of goods and services	First name, surname,  email, telephone No, details requested for the survey; in case of communication via social networks – public information in the survey, reactions (Likes) and comments; expression of consent to receiving newsletters, list of newsletter recipients and amendments thereto; other relevant information.	For no longer than 2 years after receipt of consent or until its withdrawal. The consent/the evidence of its receipt is stored for 2 years after the receipt/withdrawal. For no longer than 2 years after collection of the data if the data are processed on a ground other than consent. Data from the Social Accounts; according to the platform or user settings.	Your consent to the personal data processing given to us (Article 6(1)(a) of GDPR); Our legitimate interest in managing the list of newsletter recipient addresses, analysing summary marketing results and resolving issues related to the sending of newsletters (Article 6(1)(f) of GDPR).
Organising promotional competitions, campaigns and games	First name, surname,  email, telephone No; in the case of a representative – name of entity being represented; details specified in announcement of the competition, campaign or game and/or data requested in the questionnaire; information on the Social Account and messages shared to us by the account holder.	Throughout the period of the competition / campaign / game  plus for 1 year after the end thereof (unless the consent is withdrawn earlier).	Your consent to the personal data processing given to us (Article 6(1)(a) of GDPR); Our legitimate interest in promoting sales and increasing customer satisfaction  and visibility of our brand (Article 6(1)(f) of GDPR).
Conclusion and administration of contracts/agreements with service providers, suppliers and partners	First name, surname,  email, telephone No, address, job title, business licence No/No of certificate of individual business activities; in the case of a representative – name of entity being represented and basis of representation; content of communication, data related to performance of contracts etc.	Personal data are be processed during the term of the contract plus for 10 years after expiry/termination thereof.	Performance of a contract with You or an intention to take steps at Your request prior to entering into a contract (Article 6(1)(b) of GDPR). Our legitimate interest in performing our contractual obligations properly and efficiently (Article 6(1)(f) of GDPR).
Ensuring security of persons, assets and information, investigating and managing situations of unlawful conduct or conflicts by means of video surveillance	Video recordings and related data (date and time, location etc.), personal image; Our video surveillance systems do not involve facial recognition and/or analysis technologies; video data recorded by them are not grouped or profiled by individual persons.	Personal data are stored for up to __ days from the moment of recording. On expiry of the storage term, video data are deleted automatically except in cases where it is necessary to store them for a longer time. If storage for a longer time is necessary (for example, video data are used as evidence in investigations or disputes, a substantiated request of a data subject has been received etc.), the data will be stored as long as necessary for the specific data processing purposes, and will be destroyed as soon as they become unnecessary.	Our legitimate interest in protecting persons and assets as well as in ensuring safe working conditions for the Company‘s employees (Article 6(1)(f) of GDPR).
Assessment and selection of candidates for a job vacancy as well as processing of data on them in order to offer a job in the future	First name, surname,  email, telephone No, address, education, information on the candidate‘s career, information in the CV, information in the motivational letter, information provided during the job interview, results of tests and/or practical tasks; links to the Social Accounts (if provided), photograph (if provided), other information provided by the candidate; first name, surname, job title and contact details of a person submitting a letter of reference for the candidate.	Personal data are stored during the selection period plus for 1 month after the end thereof, unless the person has given a consent to further storage of their data, or for 3 months after the end of the selection if the person has given their consent to store the data also after the end of the selection. Where the data are not intended for a specific selection procedure, they are stored for 1 year after receipt thereof.	Your consent to the personal data processing given to us (Article 6(1)(a) of GDPR); Our legitimate interest in assessing Your skills, qualifications, experience, suitability for a specific job, and in selecting the best candidate for the job vacancy (Article 6(1)(f) of GDPR).
Resolution of disputes and claims	First name, surname,  email, telephone No, address / delivery address, in the case of a representative – name of entity being represented, relationship with the entity; content of claim or another document; details of and documents on the dispute/claim (date, method of receipt etc.).	Throughout the dispute/claim resolution process plus for 5 years after a non-judicial dispute/claim has been resolved or for 10 years after the end of the trial in the event of a judicial dispute.	Compliance with a legal obligation (Article 6(1)(c) of GDPR); Our legitimate interest in exercising and defending our rights and in making and defending our legal claims (Article 6(1)(f) of GDPR).

3.4 The personal data may be stored for longer than stated above solely in cases where:

3.4.1 this is necessary for our defence against claims or lawsuits and for the exercise of our rights;

3.4.2 there are reasonable suspicions over an unlawful activity and such activity is under investigation;

3.4.3 the personal data are required for a proper resolution of a dispute or claim;

3.4.4 such storage is provided for by the law.

3.5 You have the right to object to or withdraw, at any time, Your consent to the processing of Your data if the data are processed on the basis of consent.

3.6 We post information about our Company and its activities in the Social Accounts. Apart from this Privacy Policy, users of the Social Accounts are also subject to the privacy policies of the relevant social networks‘ owners. When You contact us through the Social Accounts, We can see certain information in Your account depending on privacy settings of the relevant social network. If You publish any information during our communication through the Social Accounts, such information can be public depending on Your privacy settings (e. g., shown in our Social Account).

3.7 In some cases We may send You messages or call You regarding Your goods‘ orders or sales, for example, We can inform You about a confirmation of Your order, goods delivery, changes in the delivery, or if the delivery place has to be ascertained. Such messages are necessary for the proper performance of Your order and are not considered as marketing messages.

3.8 You have the right to change and update the information provided to us. In some cases (for example, for the purposes of fulfilment of Your orders) We need the latest accurate data on You, therefore, We may ask You to confirm, on a periodic basis, the correctness of the data available to us.

4. HOW DO WE USE YOUR PERSONAL DATA AND THE PRINCIPLES WE ADHERE TO

4.1 We collect and process only the personal data that are required for the processing purposes as specified above.

4.2 In the processing of Your personal data, we:

4.2.1 comply with current applicable legal acts including the GDPR;

4.2.2 process Your personal data in good faith, lawfully and transparently;

4.2.3 collect your personal data for stated, clearly defined and lawful purposes and do not process them by any method that is incompatible with such purposes, except to the extent permitted by the law;

4.2.4 take all reasonable measures to ensure that any personal data that are not accurate or complete having regard to the purposes of processing are rectified or supplemented, their processing is suspended, or are destroyed without delay;

4.2.5 store them in a form that allows Your identification for no longer than it is required for the purpose for which the personal data are processed;

4.2.6 We do not transfer the personal data to third parties and will not publicise them in a way other than stated in the Privacy Policy or applicable laws;

4.2.7 We guarantee secure processing of Your personal data.

5. RECIPIENTS OF YOUR PERSONAL DATA AND CASES OF PERSONAL DATA TRANSFER

5.1 We will transfer Your personal data solely as stated in this Privacy Policy.

5.2 We may transfer Your personal data to:

5.2.1 our partners, consultants (e. g. auditors), lawyers and other persons with whom we cooperate in the performance of our activities;

5.2.2 to the personal data processors hired by us, such as:
`

5.2.2.1 administrator of the shipments’ return and collection site;

5.2.2.2 marketing and advertising partners, survey organisers;

5.2.2.3 payment administration service providers;

5.2.2.4 personnel recruitment service provider;

5.2.2.5 customer management, document management, human resources management service providers;

5.2.2.6 security and video surveillance equipment maintenance services’ providers;

5.2.2.7 courier and postal services;

5.2.2.8 data management software vendors;

5.2.2.9 IT solutions, cloud and hosting service providers.

5.2.3 state or local authorities and institutions, law enforcement and pretrial investigation bodies, courts and other dispute resolution institutions, and other persons performing statutory functions according to a procedure prescribed by the Lithuanian law;

5.2.4 other third parties, e. g. financial, credit, payment institutions etc.;

5.2.5 if necessary – to companies intending to buy or would buy our business or conducting joint activities with us, or cooperating with us otherwise, as well as companies founded by us.

5.3 Usually We process the personal data within the EU / EEA, however, in some cases Your personal data may be transferred outside them. We may transfer Your personal data outside the EU / EEA provided that the following conditions have been fulfilled:

5.3.1 the personal data are transferred solely to reliable partners and service providers that facilitate the supply of goods and services to you; and

5.3.2 data processing or data provision agreements have been concluded with such partners and service providers under which they have undertaken to ensure protection of Your personal data; and

5.3.3 the European Commission has adopted a decision on the suitability of the state in which the relevant partner/service provider has been established, i. e. appropriate level of security is ensured; or

5.3.4 we and the partner/service provider have signed the Standard Contractual Clauses for the Transfer of Personal Data to Third Countries approved by the European Commission,

5.3.5 You have given Your consent to the transfer of the personal data outside the EU / EEA; or

5.3.6 other grounds for the lawful data transfer under the GDPR exist.

6. YOUR RIGHTS AS A DATA SUBJECT

6.1 You have the following rights in relation to Your personal data as a data subject:

6.1.1 to know (be informed) about the processing of Your personal data (the tight to know);

6.1.2 to have access to Your personal data and know how they are processed (the right of access);

6.1.3 to request rectification, or having regard to the purposes of processing of the personal data, supplementing any incomplete personal data on You (the right of rectification);

6.1.4 to request to erase Your personal data or suspend the personal data processing actions (except storage) (the right to erase and the right ‚to be forgotten‘);

6.1.5 to request restriction of processing of Your personal data for a valid reason (the right to restrict processing);

6.1.6 to transfer the personal data (the right to portability). The data subject may exercise this right provided there exists a ground therefor and it is technically feasible, so that the personal data transfer will not give rise to any risk of a data breach for other persons‘ data;

6.1.7 to object to the processing of the personal data (the right to object). In such a case we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims;

6.1.8 to withdraw Your consent to the processing of Your personal data at any time (the right to withdraw consent);

6.1.9 to file a complaint to a supervisory body – the State Data Protection Inspectorate (the right to file a complaint).

6.2 You can submit Your request or instruction related to the processing of the personal data to  info@rmtools.lt. In order to better understand the content of Your request, we may ask You to fill relevant forms and to present a personal identification document or other information so that we can identify You. The request can also be sent by post to the address of our registered office or delivered to the registered office directly.

6.3 On receipt of Your request or instruction for the personal data processing, We will reply no later than within 1 month and either perform the actions requested or inform You about the reasons for refusal to perform them. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In such a case We will inform You of any such extension within one month of receipt of the request.

7. WILL WE SEND OUR NEWSLETTER TO YOU?

7.1 You can give Your consent if You wish to receive our offers and information about our goods, services, activities and offers, and to take part in our research and surveys.

7.2 Subject to Your consent, the email address or the telephone number provided by You will be used (i) to send a newsletter to you; (ii) to enquire about the quality of our services and servicing and to invite You to take part in our research and surveys; we may also send messages to Your account on the Online Store for these purposes.

7.3 By sending newsletters We can collect information on their recipients, e. g. which notice was opened, which links were clicked on etc. Such information is collected in order to offer newsletters that are relevant and tailored to the recipients.

7.4 Your contact details can be transferred to our partners /processors that provide the newsletter sending or quality assessment services to us.

7.5 Even if You have given Your consent to process Your personal data for marketing purposes, You can easily withdraw this consent at any time, in respect of all the personal data processing activity or a part thereof. In order to do this, You can

7.5.1 notify Your refusal in a way specified in e-newsletters and/or offers (e. g. by clicking on a link ‘Unsubscribe’ in the newsletter); or

7.5.2 through Your account settings on the Online Store; or

7.5.3 send us a message to the email address provided in this Privacy Policy.

7.6 After You withdraw Your consent We will make every effort to terminate the sending of the newsletter to You without delay.

8. HOW DO WE STORE YOUR PERSONAL DATA

8.1 We process Your personal data responsibly and securely, protecting them from loss, unauthorised use and modifications. We have physical and technical measures in place (such as controlled access, restrictions on data sharing, use of passwords, verification of identity, protection against viruses and malware, data protection documentation etc.) to protect the information We collect from accidental or unlawful destruction, damage, modification, loss, disclosure and any other unlawful processing. Personal data security measures are selected having regard to risks arising from the personal data processing.

8.2 Our employees have signed written undertakings not to disclose and disseminate Your personal data to unauthorised third parties.

9. COOKIES AND OTHER TRACKING TECHNOLOGIES

9.1 Cookies are small pieces of data that the Online Store stores on Your computer or mobile device when You visit the Online Store. Cookies enable the Online Store to remember Your actions and options (e. g. registered name, font size and other display options) and You do not need to enter them anew when visiting the Online Store or browsing its pages. Other technologies including data that We store in Your browser or device, device-specific identifiers, and other technologies can be used for similar purposes. Cookies are widely used in order to ensure the functioning of the Online Store, or to improve its functioning and make it more efficient. All such technologies are referred to as ‘cookies‘ in this Policy.

9.2 We may use cookies for the traffic and use behaviour analysis, to promote trust and for security purposes, to ensure that the Online Store is able to function properly and to improve it, to remember Your settings, and to personalise the content shown to You.

9.3 You can choose whether to accept cookies or not. If You do not agree to the storing of cookies in the browser on Your computer or another device, You can block the cookies through the initial cookie options screen or change browser settings and disable cookies (all at once, one by one, or in groups). If You wish to disable cookies on Your mobile device, You have to follow official instructions for the device.  Please note that in some cases disabling of cookies can slow down Your browsing speed, restrict the functioning of certain website functions, or block access to the Online Store. More detailed information is provided on http://www.AllAboutCookies.org or https://www.google.com/privacy_ads.html. You can disable third party cookies for marketing purposes by visiting Digital Advertising Alliance‘s website https://optout.aboutads.info/?c=2&lang=EN.

9.4 We can use strictly necessary cookies that ensure that the Online Store is able to function properly, analytics cookies, persistent cookies intended for analysing visits to the Online Store, remember user options and adapt them to the Online Store so that We can improve its functions, third party cookies, and marketing cookies that are used so that We can tailor the advertisements that You receive.

9.5 Cookies used on the Online Store:

Cookie	Cookie type	Cookie purpose	Duration
_ga	Persistent	Google Analytics uses it to store a unique user ID in order to track users and generate statistical data on the use of the Online Store.	2 years
_gat	Persistent	Google Analytics uses it to reduce the request rate.	1 day
_gid	Persistent	Google Analytics uses it to store a unique user ID in order to track users and generate statistical data on the use of the Online Store.	1 day

9.6 We also use the following tools and solutions for the storing of cookies and collection of data:

Tool	Purpose of the tool
Google Analytics	Generating statistics on the use of the Online Store and reducing the request rate. The data collected are transmitted to the USA for saving. You can block Google Analytics by changing Your browser settings or installing an opt-out browser add-on from https://tools.google.com/dlpage/gaoptout?hl=en.
Google Tag Manager	Analysing the popularity of the Online Store. The data collected are transmitted to the USA for saving. For more information, visit: https://support.google.com/tagmanager/answer/9323295?hl=en.
Google Ads	Creating and managing advertising campaigns, selecting ad formats, setting offers for clicks or views, and focussing on specific localities, languages and devices. For more information, visit: https://ads.google.com/intl/lt_lt/home/faq/, https://policies.google.com/technologies/ads.
Meta Pixel	Showing interest-based advertising on Facebook or other websites where this tool is used. The data collected are transmitted to the USA for saving. For more information, visit https://www.facebook.com/business/tools/meta-pixel.

10. CONTACT US

10.1 If You have any questions concerning this Privacy Policy, please contact us by email info@rmtools.lt or by phone +370 521 65 246.

10.2 If You believe that Your rights under the GDPR have been violated, You can file a complaint to the supervisory body – the State Data Protection Inspectorate. For more information and contact details, please visit the Inspectorate‘s website  (https://vdai.lrv.lt/). We seek to resolve all disputes amicably and effectively, therefore, We invite You to contact us before filing a complaint.

11. FINAL PROVISIONS

11.1 We can amend this Privacy Policy from time to time. Such amendments will be notified on the Online Store by uploading the updated Privacy Policy; also, You will be informed by email or by other usual methods of communication if possible. Any amendments to the Privacy Policy enter into effect upon its publication on the Online Store.