Privacy Policy
We respect your privacy, and the security of your Personal Data is our priority. We take appropriate organizational and technical security measures to ensure that your Personal Data is always safe and that its processing complies with applicable legal requirements and our internal policies.
By visiting the Website, you entrust us with your data, including Personal Data, and grant us the right to process it in accordance with this Policy.
Providing your Personal Data on the Website is voluntary. Additionally, in specific cases, you will be asked to express your consent separately for the processing of Personal Data for a specific purpose (e.g., for direct marketing purposes) – in such cases, you are free to choose whether to consent or not, and your choice will not result in any negative consequences.
In this Policy, you will find all the necessary information about the data we collect and process about you, including Personal Data, how we use it, how long we retain it, and other related information. This information is important, so we recommend you review it carefully.
Definitions Used in the Policy
Personal Data
– any information about you as an individual whose identity is identified or can be identified; an identifiable individual is a person whose identity can be identified directly (by an identifier, such as name and surname, internet identifier) or indirectly (by one or more factors of the individual's physical, physiological, genetic, mental, economic, cultural, or social identity).
Data Controller or we, or us, or our
– small partnership "KARJEROS KELIAS", legal entity code 304686375, registered office address Liepų g. 83, Klaipėda, which determines the purposes and means of processing your Personal Data collected as set out in this Policy and is considered your Data Controller.
You or Your
– the person visiting the Website without participating in a Scientific Study and without creating an Account, as well as the person who provides the required Personal Data through the Website and on whose behalf the Account is created.
Scientific Study
– a study of personality traits, cognitive processes, and career inclinations, which will ensure the validity and reliability of tests and tasks.
Account
– the result of your registration on the Website, which creates an account that stores your Personal Data, information about the tests taken in the Account, and other information.
Policy
– this privacy policy presented on the Website, which sets out the rules for collecting, storing, and using information related to the use of the Website, including Personal Data, as well as other relevant provisions.
System
– the innovative career modeling information system Spotiself, aimed at strengthening psychological well-being and modeling career choices, fostering human values and personal strengths.
Cookies
– small files sent to your browser and stored on your computer, phone, or other devices used to access the Website.
Website
– this online site accessible at www.spotiself.lt.
Creating an Account
To use Spotiself tools, you will be asked to register and create an Account according to the instructions provided on the Website. The Account creation process consists of the following four steps:
-
Step 1 – "Registration".
In this step, you will be asked to provide your Personal Data necessary for creating and managing the Account. To complete the registration, you will be asked to confirm your email address via a confirmation email sent by the System. By registering, you agree that your Personal Data will be processed for the purposes of creating and managing your Account as described below in this Policy.
-
Step 2 – "Collection of Basic Data Relevant to the Scientific Study".
In this step, you will be asked to provide answers to various survey questions, presented in test form (multiple choice). The answers provided in this survey will be used for forming test conclusions.
After completing all the steps above, your Account will be automatically created, and you can proceed to the gamified tests. The test questions and answers are only accessible to those who have created an Account.
The specific Personal Data we process and for what purposes are detailed in the tables below:
|
Purpose – Creating and Managing the Account
|
|
Processed Personal Data
|
For this purpose, we process part of the data provided in the "Login Data" step – email address, password, date of birth, gender.
|
|
Legal Basis for Processing
|
Your consent for participation in the Scientific Study and the related processing of Personal Data is expressed in the "Registration" step.
|
|
Data Processing Duration
|
2 (two) years from the moment of consent.
|
Please note that individuals under 16 years old must obtain parental consent to create an account and use Spotiself tools. For those under 14 years old, the tools are not suitable for use, although technically available with parental consent.
|
Purpose – Direct marketing, offering you to join the created System
|
|
Processed Personal Data
|
For this purpose, only your email address is processed.
|
|
Legal Basis for Processing
|
Your consent for processing Personal Data for direct marketing purposes is expressed in the "Registration" step.
|
|
Data Processing Duration
|
2 (two) years from the moment of consent.
|
For this purpose, we will only process your email address to offer you to join the completed System and try it out. Joining the created System is completely voluntary, and in doing so, you may be asked to provide Personal Data, which will then be processed in accordance with the System's privacy policy. No Personal Data processed under this Policy will be automatically transferred to the new System.
We only process Personal Data that we receive directly from you, e.g., data you provide during the Account creation process or when answering test questions available in the Account.
Personal Data Processing Period
We process your Personal Data for no longer than required to fulfill the specific purposes for processing the Personal Data.
Your Personal Data will be processed for the purposes mentioned in this Policy for the specified duration of each purpose.
Once the duration has passed or if you withdraw your consent for processing your Personal Data for a specific purpose, the Personal Data will no longer be processed for that purpose and will be deleted.
Sharing Your Personal Data
We may disclose your Personal Data only if there is a legitimate basis (e.g., if required by law, for our legitimate interests, or if we have your separate consent). In such cases, Personal Data is disclosed in accordance with applicable legal requirements.
We inform you that we may disclose your Personal Data to the following entities:
-
Our carefully selected service providers, acting as Personal Data processors, providing services related to the maintenance and support of the Website and servers, as well as providing other services necessary for achieving the purposes set out in this Policy. These processors process Personal Data only according to our instructions and cannot process the Personal Data for their own purposes or transfer it without our consent;
-
Authorities, in cases provided by law;
-
Your academic institution if the institution has decided to purchase a Spotiself license and thereby grant you access to Spotiself tools.
-
Other third parties, when you make a request for your Personal Data to be provided.
In addition to the entities mentioned above, anonymized data processed for the purpose of conducting a Scientific Study (as stated above) is shared with our partner – Vilnius University's Faculty of Philosophy, Applied Psychology Laboratory, Universiteto g. 9, Vilnius, which improves the personality/career test based on the mentioned non-identifying data.
Place of Personal Data Processing
Your Personal Data is processed only within the territory of the European Union and/or the European Economic Area. We do not intend to transfer and do not transfer your Personal Data to third countries.
Your Rights and Their Exercise
As a subject of Personal Data, you have all the rights provided by applicable laws, including those listed below, and you can exercise them by contacting us at the contacts provided in this Policy or by following other instructions provided below:
-
Right to withdraw consent.
When we process Personal Data based on your consent, you have the right to withdraw your consent at any time for one or more specific purposes. In such a case, processing of Personal Data based on consent will cease, but the withdrawal of consent will not affect the legality of the processing performed before the consent was withdrawn.
Some of your consents (e.g., consent to receive our marketing information) can be adjusted (withdrawn or re-granted) by updating your Account information.
You also have the right to delete your Account by following the instructions provided within it. In such a case, it will be considered that you have withdrawn your consent for Personal Data processing.
-
Right to access your Personal Data.
You have the right to receive our confirmation on whether we are processing your Personal Data, as well as to access the Personal Data we are processing about you and related information (information about what Personal Data we process, for what purposes, to whom we disclose it, how long we retain your Personal Data, and information about your rights).
All the above information is provided in this Policy, and we believe it is useful to you. In cases where you have an Account on the Website, you can access part of your Personal Data that we process at any time in your Account.
-
Right to request the correction of Personal Data.
You have the right to request that we correct Personal Data processed about you if it is incorrect, inaccurate, or incomplete.
You can also review and correct the Personal Data you have provided to us at any time in your Account.
-
Right to object.
In certain circumstances, you have the right to object to the processing of your Personal Data, including when your Personal Data is processed based on legitimate interests. You also have the right to object to the use of your Personal Data for direct marketing purposes.
-
Right to request restriction of Personal Data processing.
If you believe that the Personal Data we process is inaccurate, we are processing it unlawfully, or there are other grounds provided by law, you may request that the processing of this data be restricted to storage only. The processing will be limited to storage until the accuracy of the Personal Data is established, unless otherwise provided by law.
-
Right to request the deletion of Personal Data.
If your Personal Data is processed unlawfully, you object to such processing (including if you withdraw your consent) or other grounds provided by law exist, you have the right to request that the Personal Data be deleted.
-
Right to data portability.
You have the right to receive your Personal Data that you have provided to us and that we process by automated means on the basis of your consent, in a structured, commonly used, and machine-readable format, and, if technically possible, you have the right to request the transfer of this data to another data controller.
You also have the right to lodge a complaint with the State Data Protection Authority if you believe that the processing of Personal Data related to you is being carried out in violation of legal requirements. However, we will always try to resolve all issues related to your Personal Data processing amicably and directly with you. Therefore, before filing an official complaint, we suggest contacting us to resolve any disputes or complaints peacefully.
When submitting requests related to your rights concerning Personal Data processing, you will be asked to confirm your identity, for example, by providing part of the Personal Data (name, date of birth, etc.) you provided in the "Login Data" step or by performing other actions to help us identify you as the data subject. If you do not confirm your identity, we will not be able to satisfy your request to exercise the rights of the data subject.
Please note that laws may provide certain limitations on the exercise of your rights, which may apply to you when seeking to exercise your rights as a data subject.
Purchase Conditions
The "Spotiself" online store's (hereinafter – Store) electronic trading rules (hereinafter – Rules) apply to the Customer when placing an order in the "Spotiself" Store.
The Customer, in order to order goods from the "Spotiself" online store, must provide accurate personal data to successfully complete the order. In all cases, it is considered that the Customer, by placing an order, has read and unconditionally agrees with all the Store's Rules, as well as all other conditions indicated with the order. The Customer confirms their agreement to the Rules by ticking the box next to the Rules information line in the shopping cart.
The contract is concluded and executed in Lithuanian.
"Spotiself" reserves the right to adjust the Store's Rules. When the Customer shops at the Store, the Rules applicable at the time of the order (indicated with the order) apply.
"Spotiself" is exempt from any liability when losses arise due to the Customer's failure to comply with the Store's Rules, despite being provided with the opportunity to do so.
The Customer, in order to order goods from the "Spotiself" Store, must register on the "Spotiself" website by entering their name, surname, email, gender, and date of birth. "Spotiself" confirms that the fact of registration does not imply that the Customer will receive informational messages from "Spotiself" partners, except those necessary for ordering goods or informing about "Spotiself" Store news. If the Customer wishes to receive informational messages from "Spotiself" partners, they are provided with the option to choose to receive such messages.
It should be noted that if the buyer purchases a product for another person, then the person for whom the product is purchased must register with the online store.
"Spotiself" undertakes not to disclose such information to third parties, except for "Spotiself" partners providing delivery or other services related to the Customer's order. Any other disclosure of the Customer's personal information to third parties will always be agreed upon with the Customer. In all other cases, any personal data of the Customer may be disclosed to third parties only in cases provided for by the laws of the Republic of Lithuania.
By acknowledging the Rules, the Customer confirms that they are informed that cookies will be placed on their computer while browsing the "Spotiself" Store. More information about cookies can be found in the described Cookie Policy.
"Spotiself" confirms that it strives to use the latest technologies to protect Customers' personal data.
Order Submission Procedure and Conditions
The Customer visits the Store's website and selects the desired goods. A shopping cart is formed based on their selection.
After selecting the desired product, the Customer enters the payment window, where they must enter their name, surname, email, and phone number. "Spotiself" confirms that the Customer's provided data will be used exclusively for the purposes of selling and delivering goods, in compliance with the personal data protection requirements provided for by the laws of the Republic of Lithuania.
Additionally, the Customer has the opportunity to enter a discount code if received during certain promotions or from a represented organization or educational institution. After entering the discount code, the corresponding discount is applied, and the final payment amount is adjusted.
The Customer cannot confirm the order until they acknowledge and agree to the "Spotiself" Store Rules. The Customer must also ensure that the provided data is correct, i.e., the correct name, surname, email address, and phone number are entered. The Customer has the opportunity to correct incorrect data before sending the order to "Spotiself".
Next, the Customer is directed to the payment module of UAB "Paysera", where the final order amount is presented. In this window, the Customer's email address entered in the "Spotiself" payment window is automatically entered.
The Customer pays for their ordered goods by bank transfer using UAB "Paysera" (an electronic money institution operating under license No. 2 issued by the Bank of Lithuania) money collection module. By participating in the purchasing procedure, the Customer must read and agree to the terms of services provided by UAB "Paysera".
The Customer agrees that by submitting an order electronically at the Store, they are obligated to pay the price indicated in the order for the goods.
Prices in the Store and the order are indicated in EUR with VAT.
Final Provisions
These Rules, as well as the purchase and sale contract concluded between the Buyer and the Seller, are drawn up, interpreted, and applied based on the laws of the Republic of Lithuania, excluding international private law rules and the Vienna Convention on the International Sale of Goods.
The Buyer has the right to withdraw from the services purchased without stating any reason and without incurring any costs within 14 (fourteen) calendar days from the date of conclusion of the contract, by submitting a request in writing to the Seller. It should be noted that this provision applies only in cases and to the extent that the Buyer has not used the Spotiself services. If the services have not been provided under the Contract, the Seller must refund the amount paid by the Buyer for the services within 14 (fourteen) calendar days from the day they received the Buyer's request to withdraw from the Contract.
Once the "Spotiself" services are used, the Seller does not refund the amount paid for the services. The return and exchange of goods are carried out in accordance with the procedure established by the Resolution of the Government of the Republic of Lithuania No. 738 of July 22, 2014 "On the Amendment of the Government of the Republic of Lithuania Resolution No. 697 of June 11, 2001" "On the Approval of Retail Trade Rules" and the procedures set forth in Articles 6.22810 and 6.22811 of the Civil Code.
All notifications to "Spotiself" must be submitted via email to info@spotiself.lt
The contract is concluded, executed, and all communication between the Customer and "Spotiself" takes place in the official state language.
All disputes between the Buyer and the Seller are resolved amicably. If no agreement is reached, disputes are resolved in accordance with the laws of the Republic of Lithuania at the Seller's registered office.
Please send any comments, feedback, or suggestions regarding these terms to the Seller via email at info@spotiself.lt
Validity and Changes of the Privacy Policy
This Privacy Policy is effective from February 22, 2021. We reserve the right to change the Privacy Policy by notifying you on the Website. Such amended Privacy Policy will be published on the Website and will take effect on the date of publication (the "effective from" reference in this section of the Privacy Policy indicates when the Privacy Policy was last updated). We recommend checking the Privacy Policy and its updates when visiting the Website to ensure that the current version of the Privacy Policy meets your expectations.
If you have any questions, complaints, or need our assistance regarding the interpretation or application of the Privacy Policy, or if you wish to exercise your rights as a data subject, please contact us using the following details:
-
By email at info@spotiself.lt; or
-
By mail to Liepų g. 83, LT-92195 Klaipėda, Republic of Lithuania.
We will respond to your requests related to exercising your data subject rights without undue delay, but in any case, no later than 1 (one) month from the date of receipt of the request, except for exceptions provided by law. We will respond to other inquiries or requests related to this Privacy Policy no later than within 30 (thirty) days. We will provide the response in the form in which we received your request.