Privacy Policy
APPROVED
by Order No.V-20- as of June…, 2020
of the Director General
of Lithuanian National Drama Theatre
LITHUANIAN NATIONAL DRAMA THEATRE
PRIVACY POLICY
I. GENERAL PROVISIONS
This Policy shall contain information about your personal data processed by the Lithuanian National Drama Theatre operating under entity code 190753924 at the address Gedimino Avenue 4, Vilnius, Lithuania. In this Privacy Policy, we explain what personal data the Theatre shall collect your personal data, and how it processes and protects it when providing its services. This shall include information that is collected online and received when providing services to clients by email, telephone, and when physically visiting the Theatre.
Contact details of the Personal Data Officer: email: dap@teatras.lt, telephone number +370 664 27277.
Terms used in the Policy:
2.1. The Data Subject shall be a natural person whose personal data is processed by the Theatre.
2.2. Personal data shall be any information relating to a natural person/data subject whose identity is known or can be established, directly or indirectly, by reference to certain data (for example, name, surname, personal identification number, address, telephone number, or other). For the Theatre to provide its services, i.e., to make ticket reservations, to ensure the safety of the Theatre's audience and property, to deal with complaints and requests from the audience, etc., the Theatre shall need certain personal data. The Theatre shall undertake to collect and process personal data only if and to the extent necessary for the fulfillment of a specific, defined, and legitimate purpose.
2.3. Processing of personal data shall mean any operation or sequence of operations that are performed upon personal data, such as collection, recording, sorting, organization, storage, adaptation or alteration, retrieval, access, use, disclosure by transmission, dissemination, distribution or otherwise making available, alignment with, or combination of, other data, restriction, erasure or destruction.
2.4. Data recipients shall be public bodies and state institutions exercising the functions entrusted to them by law, banks, debt collection companies and bailiffs, health care institutions, and other recipients of data who have a reason to receive personal data from the Theatre following the procedure established by law.
2.5. Provision of data shall mean the disclosure of personal data by transmitting or otherwise making them available (other than publication in the media).
3. All your personal data shall be processed following the requirements of Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation) (hereinafter referred to as the "GDPR"), the Law on Legal Protection of Personal Data of the Republic of Lithuania, and the requirements of other legal acts of the European Union and the Republic of Lithuania. The Theatre shall protect your personal data against loss, misuse, unauthorized access, disclosure, or alteration by implementing appropriate technical and organizational measures.
II. CATEGORIES OF PERSONAL DATA PROCESSED AND PURPOSES AND GROUNDS FOR PROCESSING
4. The Theatre shall collect and process the following personal data from you:
4.1. Your name, e-mail address, telephone number, and/or other Personal Contact Data that you provide to the Theatre when you write requests, applications, messages, and complaints electronically or call by telephone. The Theatre may also collect Personal Data provided by you through various questionnaires, registration forms, and video/audio data recorded during readings, video conferences, etc. This personal data shall be used to enable the Theatre to answer your questions, provide you with the information that you have requested, make a reservation, investigate and respond to your request or complaint, and, with the consent of the personal data subject, for artistic expression. The Theatre shall process these data based on your consent, as well as based on a contract with the data subject (including pre-contractual relationships).
4.2. The e-mail address that you provide on the Theatre's website when you fill in the newsletter subscription form. This data shall be used by the Theatre to provide you with information about the Theatre's activities that may be of interest to you, i.e., for direct marketing purposes. The Theatre shall process this data based on consent. You shall have the right to opt out of receiving direct marketing communications at any time by contacting the Theatre by e-mail at dap@teatras.lt or by clicking on the active "unsubscribe" link in the newsletter.
4.3. The information that is collected on the Theatre's website by cookies shall be data used to determine whether persons from your device have already visited the Theatre's website, to remember the actions performed (for example, the choice of the website's language), to provide you with the most relevant information, and to collect aggregate statistics on website traffic. Some of the cookies that we use are necessary for the basic functions of the Theatre's website, but cookies may also be used to analyze the use of the Website (so that we can evaluate and improve its performance), and, if you agree, the Theatre shall also use cookies for marketing based on legitimate interest. For more information about cookies, please see the section on Use of cookies.
4.4. Personal image and your actions within the coverage area of the Theatre's CCTV cameras. Specific signs shall be used to inform you about the video surveillance in progress. The Theatre shall process this data on the grounds of legitimate interest and the protection of essential public and personal interests, including health and life. Currently, no video surveillance is carried out during the reconstruction of the Lithuanian National Drama Theatre.
4.5. When registering for our events, you shall provide us with the following contact information: name, surname, email address, age, workplace, and telephone number.
Personal data shall be processed for the following purposes:
Event organization;
Managing the registration of participants for the event;
Necessary communication before, during, and after the event;
Event evaluation;
For artistic expression;
Defending the theatre's legal interests in the case of a complaint or lawsuit.
When selecting participants for a public workshop, we shall ask you to provide evidence of your eligibility for the event-specific selection criteria, including creative and professional experience.
The processing of the personal data that is referred to in this point above shall be based on the legitimate interest to organize and run the event properly, to communicate with the participants of the event, and on the consent of the participant.
4.6. Staff selection:
When selecting for a job position, the Theatre shall collect only the personal data of candidates that are relevant to their qualifications, professional skills, and business qualities. The Theatre shall not collect or process candidates' specific personal data for this purpose, except where the Theatre as an employer is required to do so by law.
The personal data of candidates who have sent their CVs directly to the Theatre by e-mail (name, telephone number, e-mail address, CV and cover letter, and position) shall be processed by the Theatre to select candidates for the position.
The Theatre shall process this personal data of candidates based on consent and the basis of a contract with the data subject (including pre-contractual relationships).
III. RECIPIENTS OF PERSONAL DATA
5. The Theatre shall be committed to confidentiality and will not disclose any information relating to your personal data to third parties. This obligation arises from the Civil Code of the Republic of Lithuania, the provisions of the GDPR, and the Law on Legal Protection of Personal Data. Information may only be disclosed to other persons in the cases that are provided for by law or with your consent.
6. The Theatre may provide certain of your personal data to the data processors who provide services to the Theatre (e.g., website maintenance services, ticket distribution services) and who process your personal data on behalf of and on the instructions of the Theatre as the data controller. The data controllers shall have the right to process personal data only on the instructions of the Theatre and only to the extent necessary for the proper performance of their contractual obligations. When using processors, the Theatre shall take all necessary measures to ensure that the processors have also implemented and applied appropriate organizational and technical security measures and respect the principle of confidentiality.
7. The Theatre shall not sell, trade, or otherwise transfer your personal data to third parties for remuneration or other benefits.
8. The following is a non-exhaustive list of third-party entities to which personal data may be provided:
8.1. companies providing information technology services, persons providing individual activity shall process data to ensure the development, improvement, and maintenance of information systems;
8.2. companies providing newsletter services – they shall process the data so that you receive the Theatre's news;
8.3. ticketing companies – they shall process your personal data so that you can get tickets for the Theatre's performances;
8.4. companies providing property security and video surveillance services – they shall process your personal data to ensure the security of the Theatre's premises and visitors;
8.5. attorneys and law firms, experts, etc. – the data shall be processed by the Theatre in cases where the Theatre seeks to assert a legal claim or to defend itself against such claim;
8.6. state institutions – the data are processed by the Theatre when the Theatre provides them in compliance with court or public authority orders (requests).
IV. DATA STORAGE LOCATION
9. Your personal data shall be stored in the Theatre or on servers (service stations) located in countries of the European Union (EU) or the European Economic Area (EEA), but may also be transferred to and processed in a country outside the EU/EEA (i.e., in third countries). The Theatre shall use e-mail, cloud, anti-malware, firewall, etc. services, which may transfer and process data outside the EU/EEA country. Any such transfer of your personal data shall be carried out following applicable law. Before transferring personal data outside the EU/EEA, the Theatre shall sign a data processing agreement with the service provider that complies with the GDPR.
V. USE OF COOKIES
10. When you visit a website, it saves or retrieves information in the browser that you are using in the form of cookies. This information may be about you, your browser settings, or the device that you are using, and is used to make the website that you are visiting work properly. This information does not identify you as a specific person, but it can make your browsing experience on the website more personalized and tailored to you.
11. Cookies shall be widely used by particular websites to "remember" you and your settings, either for a single browsing session (session cookies) or for several sessions (persistent cookies). They shall ensure a consistent and efficient experience as a visitor and perform basic functions, such as allowing you to register and stay logged in on a particular website.
12. The Theatre uses cookies to personalize the content and information provided on the website, to make offers, to enable social networking features, and to analyze visitor traffic. The Theatre also shares information about your use of the Theatre's website with social networking, advertising, and analytics partners.
13. Below is a detailed list of cookies that are used on the Theatre's website: popup_banner_hide_en, popup_banner_hide_en – valid until you close your browser; full – valid for 6 months; PHPSESSID – valid until you close your browser.
14. The Theatre's website shall be periodically scanned with specific tools and the cookie list shall be updated depending on the results.
15. The following categories of cookies shall be used on the Theatre's website:
Mandatory cookies;
Analytics cookies;
Marketing cookies.
16. You can opt out of each category of cookies (except essential cookies) by clicking "Cookie Settings" on the website.
17. Mandatory cookies. These cookies are essential for the functioning of the website and cannot be disabled. These cookies enable the functionality and personalization of the website. They may be set by the Theatre or by a third party whose services the Theatre uses on its website. They shall be usually only set in response to your actions to access certain services, such as setting your privacy preferences, logging in, or filling in data entry forms. Blocking these cookies may affect the functioning of the website. These cookies do not directly collect personal data, but they do identify your web browser and the device on which you are browsing the website.
18. Analytics cookies. These cookies allow the Theatre to monitor traffic and sources to measure and improve the performance of the website. They help us to know which pages are the least and most popular, and to monitor how visitors navigate the site. All information collected by these cookies is aggregated and therefore anonymous. If you block these cookies, the Theatre will have less information to analyze to optimize the performance of the website. The information contained in these cookies is collected by third parties that provide analytical services (Google Analytics, HotJar, CookieBot).
19. Marketing cookies. These cookies may be set on the Theatre's website by the Theatre's advertising and social media partners. By sharing anonymous data with third parties, it shall be possible to build a profile of your preferences and to show you information that may be of interest to you on other websites. These cookies do not directly store personal data, but they do identify your web browser and the device that you are browsing on, which can be used to create a profile of your preferences. If you block these cookies, you will receive less targeted advertising and may not be able to see or use ad-sharing tools.
VI. SOCIAL NETWORKS
20. All information that the Theatre receives when you use social networks (including notifications, use of the "Like" and "Follow" fields, etc.) shall be controlled by the operator of the relevant social network. Please note that social networks and the services that are available through them have their own separate privacy policies for which the social networks are responsible. Please review these privacy policies before submitting personal data to social networks.
21. Currently, the Theatre has the following accounts:
21.1. on Facebook, whose privacy policy is available at https://www.facebook.com/privacy/explanation;
21.2. on Instagram, whose privacy policy is available at https://help.instagram.com/155833707900388;
21.3. on YouTube, whose privacy policy is available at https://www.google.co.uk/intl/en-GB/policies/privacy/;
21.4. on Vimeo, whose privacy policy is available at https://vimeo.com/cookie_policy?vcid=32179.
VII. RIGHTS OF THE DATA SUBJECT
22. The Theatre shall ensure the exercise of the rights of the data subject under the GDPR, namely the following rights:
22.1. to receive information about your personal data that is processed by the Theatre: where and how the personal data are collected and on what basis the Theatre processes them;
22.2. to familiarize yourself with your personal data that is processed by the Theatre;
22.3. to request the Theatre to rectify your personal data if the data is incorrect, incomplete, or inaccurate;
22.4. to request the erasure of your personal data that is processed by the Theatre (right to be forgotten);
22.5. to request that the processing of your personal data be restricted;
22.6. to object to the processing of your personal data;
22.7. to request that your personal data be transferred to another data controller (right to data portability).
23. For the rules on the implementation of data subjects’ rights in the Lithuanian National Drama Theatre, please contact dap@teatras.lt. The Theatre shall deal with requests that are submitted in the official Lithuanian language.
VIII. PRINCIPLES GOVERNING THE PROCESSING OF PERSONAL DATA IN THE THEATRE
24. In collecting and using personal data entrusted to it by you, as well as personal data that has been obtained from other sources, the Theatre shall undertake the following:
24.1. to process your personal data that is referred to in this Policy only for the expressly defined and legitimate purposes of the Theatre;
24.2. not to process your personal data for purposes other than those set out in this Policy, except the cases as provided by law;
24.3. to process your personal data lawfully, accurately, transparently, fairly, and in such a way as to ensure the accuracy, identity, and security of the personal data processed;
24.4. to ensure that redundant personal data are not processed;
24.5. to process your personal data for no longer than is necessary for the purposes for which the personal data are processed;
24.6. to be responsible for compliance with the principles that are set out in this Policy and be able to demonstrate compliance with them;
24.7. comply with any other obligations under the legislature.
IX. TIME LIMITS FOR PROCESSING AND STORAGE OF PERSONAL DATA
25. Personal data that is collected by the Theatre shall be stored in the information systems of the Theatre. The Theatre shall store your personal data for no longer than the purposes of processing such data required or the legislation provides for if it stipulates a longer period of data storage:
25.1. personal data that you provide in requests, notifications, and complaints (contact information: name, surname, e-mail address, telephone number; other information that you provide) shall be processed until the information about the change of data is received or the relevant documents containing personal data are transferred to the archive and stored following the terms that are specified in the Index of General Document Retention Periods approved by the Order of the Chief Archivist of Lithuania.
25.2 The e-mail address that you provide when filling in the newsletter order form on the website shall be stored until you unsubscribe from the newsletter, but no longer than 2 years after you have consented to receive the newsletter.
25.3 The information that is collected by cookies shall be stored at the following: essential cookies shall be stored on the www.teatras.lt website and third-party plug-in cookies (targeting and analytical) shall be stored on third-party platforms.
25.4 Your personal image and your actions within the coverage area of the Theatre's CCTV cameras shall be stored in the CCTV recording system for 30 days from the moment of recording.
25.5 The data that you provide when registering for an event shall be stored for 3 months after the end of the relevant event.
25.6 Candidates’ personal data shall be deleted/destroyed immediately after selection. In cases where the data is processed based on the data subject’s consent, 1 or 3 years after the end of the selection procedure (according to the candidate's expressed will in the consent).
26. Unnecessary personal data shall be destroyed or depersonalized in such a way that the person cannot be identified.
27. The theatre shall not retain outdated or irrelevant information and shall ensure that information about data subjects is kept up to date and correct.
X. LINKS TO THIRD PARTY WEBSITES
28. The Theatre may, at its discretion, announce or offer third-party services on its website by providing links to the websites of the relevant third parties. These third-party websites have their own privacy policies. Therefore, the Theatre shall accept no responsibility for the content and performance of the websites to which you link from the Theatre's website. Nevertheless, the Theatre shall strive to ensure data security on its website and shall welcome your feedback on these third-party websites.
XI. FINAL PROVISIONS
29. If you have any questions about this Policy, the processing of your personal data, or if you would like to contact us regarding your personal data, please contact us by email at dap@teatras.lt
30. Complaints regarding the processing of personal data shall be dealt with by the Theatre's Personal Data Protection Officer, e-mail: dap@teatras.lt, telephone number 8 664 27277; the State Data Protection Inspectorate, office address L. Sapiegos g. 17, Vilnius, https://vdai.lrv.lt/; courts following the procedure set out in the Law on Administrative Proceedings of the Republic of Lithuania.
31. If necessary, the Theatre may amend this Privacy Policy by posting an updated version of the Privacy Policy here. We kindly ask you to visit this section more often and familiarize yourself with the current version of the Privacy Policy.
32. The Policy was last updated on June….,2020.