1. Introduction

1.1. The Privacy Policy of Flavia.lt, operated by MB Flara, applies when an individual provides their personal data through the www.flavia.lt website. This Privacy Policy sets out the main principles and procedures for collecting, processing and storing personal data by the Flavia.lt online store and its customer. By providing your personal data in the online store, you agree that www.flavia.lt will control and process it for the purposes, by the means and according to the procedures specified in this Privacy Policy and applicable legislation.

1.2. The Seller ensures the security and confidentiality of Visitors’ and Customers’ Personal Information submitted through the Website in accordance with this Privacy Policy. The Privacy Policy forms an integral and inseparable part of the Terms and aims to protect the Personal Information of Website Customers and Visitors against unlawful use.

1.3. The Seller is a personal data controller registered in the State Register of Personal Data Controllers. As a data controller, the Seller may process Visitors’ and Customers’ Personal Data, including, without limitation, for e-commerce, direct marketing and other purposes, in accordance with this Privacy Policy and/or any other document forming part of the Terms.

1.4. By submitting Personal Information through the Website, you confirm your acceptance of the Privacy Policy and the Terms and agree to the processing of your Personal Information as described in this Privacy Policy. This Privacy Policy is binding on anyone who visits the Website and/or purchases Goods using its tools, otherwise uses the Website or any part of it, or uses any services, tools or other Website content. If you do not agree with this Privacy Policy, you may not use the Website or any services, tools or other content available on it.

1.5. Your Personal Information may be processed by the Seller both in the country where it was collected and in other countries with less stringent personal information processing laws. The Customer also understands and agrees that Personal Information and any other Customer-related information collected by the Seller may be stored in the Republic of Lithuania or in any other country. By using the Website, the Customer consents to the transfer of this information outside the Customer’s country.

1.6. To notify us of a breach of the Privacy Policy, submit questions or complaints, or request help interpreting or applying this Privacy Policy, please email info@flavia.lt. We will respond to written enquiries within 14 (fourteen) calendar days of receipt.

  1. Definitions

2.1. Capitalised terms and expressions in this Privacy Policy are defined in the Website’s terms of use, other documents forming part of the Terms and/or other requirements and instructions available on the Website, except where this document, including its preamble, assigns them the following meanings:

2.1.1. Personal Data means Personal Information about a Visitor and/or Customer who is a natural person. Personal Data means any information relating to a natural person, the data subject, whose identity is known or can be established directly or indirectly using data such as a personal identification number or one or more factors specific to that person’s physical, physiological, psychological, economic, cultural or social identity.

2.1.2. Cookies are small files sent to your browser and stored on your computer, phone or other device. Their purpose is to help websites remember your previous actions.

  1. Anonymity and automatic processing of anonymous information

3.1. The Website’s tools allow you to use it anonymously, meaning that only Anonymous Information about you is collected through the Website. Visitors and Customers who are not signed in to their Account may use the Website anonymously. You may continue to do so until you decide otherwise or perform actions requiring disclosure of Personal Information, such as creating or signing in to an Account or placing an order for Goods, including as a guest.

3.2. The Website does not automatically collect any of your Personal Information. Please note that it automatically collects the following Anonymous Data about you:

3.2.1. data contained in Cookie files. More information on the use of Cookies is provided in the Cookie Policy section of this Privacy Policy;
3.2.2. the Website may also collect information normally collected by system administrators, known as logs. Log information may include, among other things, an IP address, the access platform and web browser, the internet service provider and the address of the page from which a Visitor and/or Customer who is not signed in to their Account reached the Website.
3.2.3. Some Website subsections and other means of communication with the Customer may include Web Beacons. Web Beacons are used to assess the effectiveness of the Seller’s advertising. These data will not be linked to the Personal Information you provide. They will be archived and used for statistical analysis and an overall assessment of Website Visitors’ and/or Customers’ movements. Web Beacons can collect information such as IP addresses, page URLs, Website loading times, browser types and information stored in cookies.

  1. Collection and use

4.1. Whenever a Visitor and/or Customer who is not signed in to their Account visits the Website, the Seller’s servers temporarily store information about the connecting device, namely the Anonymous Information listed in section 3.2 of this Privacy Policy. Regardless of that person’s actions, this Anonymous Information is collected automatically and retained until deleted automatically and/or manually. It is collected and processed to allow the Visitor and/or Customer who is not signed in to their Account to use and access the Website, to ensure ongoing system security and stability, to enable technical administration of the network infrastructure, to optimise the Website and the Seller’s operations, and for internal statistical purposes. IP addresses may also be examined and used in cases involving breaches of the Terms or attacks on the Website’s infrastructure, for statistical purposes and in other cases specified in this Privacy Policy or applicable legislation.

4.2. When a Customer signs in to their Account, the Seller collects and stores Personal Information identifying that Customer. The following Personal Information about you may be collected and stored:

4.2.1. your first and last name, email address, postal address, phone number, other contact details and any other information provided in your Account;

4.2.2. where a Customer requests an invoice for Goods being purchased or already purchased, financial information provided when purchasing the Goods, for the purposes of issuing and receiving invoices;

4.2.3. information about your actions as a Customer on the Website, including your Goods purchase history;

4.2.4. for Website administration purposes, the Seller may also collect information about the device you use to access the Website, such as a desktop computer, laptop or mobile phone;

4.2.5. other information relating to your actions when purchasing Goods and using the Website, including a device identification number, access information, page-view statistics and standard access information;

4.2.6. additional information from or about you that is not separately described in this document, such as information relating to your enquiries to the Seller;

4.2.7. other information you provide on the Website, including your choice of whether to receive the Seller’s promotional offers, as described in the Advertising and online surveys section of this Privacy Policy.

4.3. The main purpose of collecting your Personal Information is to ensure that Website activities and Goods purchases proceed smoothly, and that all transactions are secure, effective and personalised. You agree and confirm that the Seller may use your Personal Information, including the information listed in section 4.2, for the following purposes:

4.3.1. identifying Customers on the Website and administering their Accounts;

4.3.2. fulfilling orders, selling and delivering Goods to Customers and providing access to the services and information offered on the Website;

4.3.3. improving the Website to meet your needs by adapting, evaluating and improving i) purchase and sale transactions carried out using the Website’s tools; ii) Website services; iii) Website content; and/or iv) advertising;

4.3.4. examining complaints, if any;

4.3.5. checking data sent from the Website;

4.3.6. carrying out demographic research on Customers;

4.3.7. preventing, detecting and investigating potentially prohibited or unlawful activities on the Website;

4.3.8. informing you about the Seller’s Goods;

4.3.9. carrying out direct marketing with your separate consent;

4.3.10. providing other Website services and assistance, for other purposes stated in this Privacy Policy and for purposes specified when the information is collected.

4.4. Providing the Personal Information listed in section 4.2 and consenting to its processing is voluntary, but necessary for you to use the Website properly and fully, including enabling the Seller to fulfil your orders correctly.

4.5. The Seller stores factual data about your orders for Goods but, to ensure the security of your data, has no direct access to those data. As a Customer, you can obtain all information about orders submitted to the Seller by signing in to your Account. Account tools allow you to view your orders and change your contact details. You must safeguard your Account access details and not disclose them to third parties, in accordance with the requirements and procedures in the Terms.

4.6. Information collected when you register and/or participate in surveys is also used to improve Website services and meet Customers’ needs and preferences, including for direct marketing relating to the Website services provided to you.

4.7. In accordance with this Privacy Policy, the Seller may also use your Personal Information for internal purposes, including contacting you by email about Goods and Website updates and providing information relating to e-commerce transactions you conclude on the Website.

  1. Advertising and online surveys

5.1. The Seller does not give third parties access to your Personal Information or sell any information about you to third parties without your separate consent.

5.2. Only with your separate consent, given in registration forms or otherwise, for example by selecting a checkbox, will we send the Seller’s commercial or promotional information, including newsletters, to your contact email address and/or phone number. With your consent, we may send this information by SMS and/or email. Your consent is voluntary, is not required to fulfil orders and may be withdrawn at any time. If you do not initially consent but later wish to receive such commercial or promotional information, or if you decide to stop receiving it, you may contact us at info@flavia.lt at any time or use other Website settings where available.

5.3. You cannot opt out of administrative information from the Seller relating to purchases of Goods, the Seller’s services or the Website, including the Terms, unless your Account is deleted. You also cannot opt out of messages containing legal information relating to purchases of Goods and/or use of the Website.

5.4. To learn about Visitors’ and/or Customers’ preferences when using the Website and Customers’ preferences when purchasing Goods, the Seller may conduct surveys. Participation is optional. If you participate, your answers will remain anonymous unless the specific survey states otherwise. We may also organise surveys subject to specific requirements that ask Customers for contact or demographic information, such as first and last name, email address and postal address. The Seller will not provide this information to third parties unless otherwise specified in the particular case.

  1. Disclosure of information

6.1. The Seller may disclose your Personal Information where required by applicable legislation and when implementing lawful and reasonable Seller policies and rules that comply with legal requirements, for example when responding to complaints involving infringements of third parties’ rights or legitimate interests, or to protect other persons, their legitimate interests or property.

6.2. With your separate consent as set out in section 4.3.9 of this Privacy Policy, the Seller may disclose your Personal Information for direct marketing purposes.

6.3. You agree and confirm that the Seller may provide your Personal Information to:

6.3.1. the Seller’s partners: third-party service providers engaged to fulfil orders or provide other services to you, including partners providing delivery, payment collection and other services ordered by the Customer, as well as Website support and/or maintenance providers and other partners helping the Seller develop its business or perform other Website operations;

6.3.2. other third parties when you request that your Personal Information be provided, or third parties of whom you are expressly informed by other means and whose receipt of information is agreed when using a particular service;

6.3.3. law enforcement authorities in accordance with the legislation of the Republic of Lithuania and where necessary to prevent or investigate criminal offences;

6.3.4. the Seller’s organisational units or affiliated companies;

6.3.5. other business entities if the Seller merges with, acquires or is acquired by another legal entity, or if the Website or assets relating to it are transferred.

6.4. In the cases listed in section 6.3, the Seller will transfer the minimum amount of your Personal Information. Without your express prior or separate consent, the Seller will not sell, rent or further distribute your Personal Information to third parties, except where necessary to implement this Privacy Policy or where legally required.

6.5. The data and information provided by the Customer are known only to the Customer, the Seller and the Seller’s partners, who must keep them confidential and for whose actions the Seller is responsible. Unless the Customer publishes comments or other content on the Website that is visible to other users, together with the data provided in that context, the Seller guarantees that it will not disclose the Customer’s data or information to anyone, except at the request or demand of entities entitled to receive that information under applicable legislation.

6.6. Payments in the online store are processed through makecommerce.lt, operated by Maksekeskus AS (Niine 11, Tallinn 10414, Estonia, registration number 12268475). Your personal information required to execute and confirm a payment will therefore be transferred to Maksekeskus AS.

  1. Customers’ rights and obligations regarding the processing of their Personal Information on the Website

7.1. When registering as a Customer, meaning opening or creating an Account on the Website, you will be asked to provide Personal Information.

7.2. As a Customer, you may sign in to your Account and independently manage, amend, update or remove the Personal Information submitted in your registration form. If you consider this insufficient, you may contact the Seller under this Privacy Policy. You may request all information about your data processed by the Seller and request that those data be amended, supplemented, updated or deleted and errors corrected. Customers may also object to the processing of Personal Information for direct marketing. To exercise these rights, please contact info@flavia.lt or use the method specified in section 1.6. The Seller will not manually change your Personal Information. You therefore understand and undertake to update it immediately if it changes or is inaccurate.

7.3. Your password is the key to your Account. Use a unique combination of numbers, letters and special characters and do not disclose your password to anyone. After signing in, you may change and update your details at any time. If you forget your password or experience other sign-in difficulties, contact info@flavia.lt or use the other contact details in the Terms.

7.4. If you disclose your password or other Account information to others, you will be responsible for all actions performed through your Account unless proven otherwise. Losing your password may prevent you from controlling the use of your Personal Information, and commitments for which you are responsible may be made in your name. If you suspect someone else may use your password, notify the Seller immediately using the contact details in this Privacy Policy. Your password is the key to your Account. Use a unique combination of numbers, letters and special characters and do not disclose it to anyone. Once signed in, you can change and update your details at any time. If you forget your password or have other sign-in problems, contact info@flavia.lt or the other contacts in the Terms and change the password used to access your Account.

7.5. If you access the Website from a shared computer or an internet café, some information about you may remain visible to subsequent users. Always sign out of your Account after use on a shared computer, even if you leave it only briefly. This helps prevent unauthorised persons from viewing, using or changing Customer information or data.

7.6. If you do not wish the Seller to process your Personal Information, you may notify the Seller at any time by submitting a request using the method specified in section 7.4. Following such a refusal, you will lose Customer status and may no longer use the Website as a Customer.

7.7. The Seller may retain your Personal Information until your Account is deleted, in accordance with this Privacy Policy and/or the Terms. Your Account and Personal Information are deleted in accordance with those provisions. Once your Account is deleted, you will lose access to your data on the Website unless otherwise provided in this Privacy Policy or the Terms.

7.8. To fulfil the purposes of collecting Personal Information set out in this Privacy Policy, it may be retained for no longer than 2 (two) years after your last Account sign-in. Nevertheless, where there are justified reasons, the Seller reserves the right to set a shorter or longer retention period.

7.9. Without limiting the above provisions, the Seller will in all cases retain Personal Information about Customers removed for breaches of applicable legislation or the Terms.

  1. Data protection

8.1. The Seller seeks above all to ensure the security of Visitors’ and/or Customers’ data. To safeguard transmitted information and data, the Seller implements security and organisational measures appropriate to the risks involved in providing services. Reasonable physical, electronic and procedural measures and methods are used to protect information, including Anonymous Information, against loss, theft, unlawful use, disclosure or alteration.

8.2. All connections relating to a Customer’s payment will, at the Customer’s choice, use a secure connection to the relevant website.

8.3. Although the Seller uses the reasonable measures described above, it cannot and does not guarantee the security of Personal Information submitted or collected over the internet. These measures may also be insufficient if you do not follow security rules. In particular, Customers must not disclose their sign-in details to third parties. The Website will request your email address and password only when you sign in to your Account. To prevent unauthorised use, please sign out after using your Account and/or the Website.

8.4. You can also reduce the risk of unauthorised use of Personal Information by acting carefully and choosing reasonable safeguards, such as a strong password and up-to-date antivirus software.

8.5. You may request all information about your data processed by the Seller. Customers may also request that data be amended, supplemented, updated or deleted and errors corrected, and may object to processing of Personal Information for direct marketing. To exercise these rights, please contact info@flavia.lt.

  1. Cookie policy

9.1. The Website uses Cookies. The Seller uses them for the following purposes:

9.1.1. ensuring the Website functions correctly and improving browsing, for example maintaining your session after sign-in and remembering your settings;

9.1.2. advertising and direct marketing;

9.1.3. collecting Website statistics and improving the Website;

9.1.4. The Website uses Google Analytics, developed and provided by Google Inc. (Google), for website analysis services. Google Analytics uses Cookies to analyse how you use the Website. Information generated by Cookies about your use, including your IP address, is transferred to and stored on Google’s servers in the USA. Google uses it to analyse your use of the Website, prepare reports on its popularity for the operator and provide other services relating to the Website and its use. Google may transfer this information to third parties where required by applicable legislation or where those parties process it on Google’s behalf. Google will not associate your IP address with other data it holds. You can prevent Google from installing Cookies through your browser settings, but this may prevent you from using all Website functions fully. By using the Website, you agree and confirm that Google may use all data relating to your Website activity for the purposes and in the ways described above.

9.2. All Cookies used on the Website may be temporary or persistent:

9.2.1. temporary Cookies remain valid and are not deleted while you browse;

9.2.2. persistent Cookies are not deleted when you close your browser, and the information stored in them facilitates subsequent access to your Account, including your password and email address. These Cookies make the Website faster and easier to use.

9.3. By using the Website, you confirm your agreement and permission for the Seller to store Cookies on your device, such as a computer or phone.

9.4. You can block Cookies and delete persistent Cookies at any time through your browser. For more information on managing Cookies, consult your browser’s Help menu.

9.5. Blocking or restricting Cookies may affect some Website functions.

9.6. The Website uses the following Cookies:

9.6.1. Essential cookies are technically necessary for the basic functionality of the website. Without them, you would not be able to add goods to your basket, place an order or sign in to your account.

9.6.2. Analytics cookies help make the website more user-friendly by analysing how visitors use it. They also enable us to monitor the performance of different sales channels.

9.6.3. Remarketing cookies are used to deliver personalised advertising to relevant audiences.

9.7. Cookies may also be used by the Seller’s partners or other third parties outside the Seller’s control. The Seller cannot be and is not responsible for their actions. If you suspect that such partners or third parties are using Cookies without your consent, contact the relevant partner or third party.

  1. Third parties

10.1. Unless expressly stated otherwise, this Privacy Policy applies only to the use and disclosure of information we collect from you through the Website. If you disclose Personal Information to others through this Website or other websites, whether to Customers or third parties, different rules may apply to its use and disclosure.

10.2. The Website may contain links to other websites. The Seller does not control or accept responsibility for their content. They may have their own privacy policies, which we recommend reading. The Seller does not control third-party privacy policies or other rules applicable to you; you are responsible for complying with them where applicable, at your own discretion and risk. The Seller is not responsible for other websites’ privacy policies or content, whether this Website links to them or they link to this Website. Clicking a link, logo or other element, or using services available on the Website, including online communication, may take you outside the Website.

10.3. The Seller does not collect information about Customers from third parties except as provided in this Privacy Policy or the Terms, or in cases involving breaches of legal requirements, the Terms or third parties’ rights.

10.4. We also use the services of Facebook, Google and other online advertising providers. Information about their privacy policies, collected data and personal data safeguards is available in their respective privacy policies. For further information on how these services work and how to object to such advertising or data use, consult the information provided by those service providers – https://lt-lt.facebook.com/policies/ads; https://policies.google.com/technologies/ads.

10.5. Analytics and remarketing cookies are anonymised before being transferred to third parties and cannot be used to identify you.

  1. Final provisions and dispute resolution

11.1. Rules on applicable law and dispute resolution are set out in the Website’s terms of use.

11.2. The Seller reserves the right to amend this Privacy Policy, any part of it and related information from time to time at its discretion in accordance with the Terms.

  1. Effective date and amendments to this notice

12.1. This Notice is effective from 1 January 2022. If its content changes, we will publish the updated, current version on flavia.lt or, where necessary, notify you by other means.