At Network Gate, accessible from https://www.networkgate.lt, one of our main priorities is the privacy of our visitors. This Privacy Policy document contains types of information that is collected and recorded by Network Gate and how we use it.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.
General Data Protection Regulation (GDPR)
We are a Data Controller of your information.
Network Gate, IKANDU VšĮ legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:
- Network Gate, IKANDU VšĮ needs to perform a contract with you
- You have given Network Gate, IKANDU VšĮ permission to do so
- Processing your personal information is in Network Gate, IKANDU VšĮ legitimate interests
- Network Gate, IKANDU VšĮ needs to comply with the law
Network Gate, IKANDU VšĮ will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification.
- The right to object.
- The right of restriction.
- The right to data portability
- The right to withdraw consent
Your personal data rights
IKANDU, VšĮ is responsible for using personal data has to follow strict rules called ‘data protection principles’. The information must be:
- used lawfully, fairly and transparently
- used for specified, explicit and legitimate purposes
- used in a way that is adequate, relevant and limited to only what is necessary
- accurate and, where necessary, kept up to date
- kept for no longer than is necessary
- handled in a way that ensures appropriate security, including protection against unlawful or unauthorised processing, access, loss, destruction or damage
There is stronger legal protection for sensitive information (known as ‘special category data’), such as:
- race
- ethnic background
- political opinions
- religious beliefs
- trade union membership
- genetics or biometrics (where used for identification)
- health
- sex life or orientation
- criminal record or alleged criminal activity.
Your rights under the Data Protection (EU) Law include the rights to:
- be informed about how your data is being used
- access personal data
- have incorrect data updated
- have data deleted (in certain circumstances)
- limit or restrict the processing of your data (in certain circumstances)
- data portability (allowing you to obtain and reuse your data for different services)
- object to how your data is processed (in certain circumstances)
Log Files
Network Gate follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
What we do with your data
Your data is primarily necessary to verify who you are when accessing your Account and to ensure you meet our eligibility requirements in order to submit an Application for an account. We or our Subcontractors also will use all or a part of your data for performance of our obligations under Rules and provision of other related services to you and/or for compliance with a legal obligations to which we or our Subcontractors are subject to and performance of internal administration activities.
Additionally, we will use all or a part of your data you provide us to notify you about:
- services of an interest for you; or
- changes to our Website or our services.
- We and our Subcontractors use any data we collect about you (as a result of your visit to our Website) to:
- personalize and improve our services (including the Website and its security);
- deal with your inquiries and requests;
- administer and monitor traffic and behaviors on our Website for analysis, testing, research, statistical and survey purposes;
- ensure that any part of our Website (including any Content) is presented in the most effective manner for you and your device, and to make improvements (where necessary); and
- keep our Website safe and payment devices secure.
Where we change our services, or any applicable terms and conditions, we will contact you. For more details please see Consent of the Policy.
Any data we obtain about you from third parties (Subcontractors or other data controllers) are used for the purposes of verifying your eligibility to submit an application for Account through our Website and/or to perform payment transactions and/or get any of the services accessible through the Website.
How and why we disclose your data
Subject to the rest of this Policy, we will only disclose your personal data to the third parties which shall be considered as data processors for the following purposes:
- credit-checking/reference agencies and fraud prevention agencies – in order to verify your identity, perform transactions you instruct on us or for the purposes of fraud detection or protection, or in other situations involving suspicious or illegal activities. We may as well perform a search of your credit file, if this is necessary and/or required to deliver our services to you;
- To process the transactions – in order to allow you to make the payment(s) and/or receive funds through your payment devices and by the Website;
- banking, including Electronic Money Institutions, crypto exchanges and financial service partners such as banking intermediaries, international payment services providers and regulated distribution agents – in order to perform our services and payments;
- our email provider – in order to be able to send emails to you (please note that only your email address is provided to approved email provider);
- other our services providers – in order to ensure the proper functioning and provision of the services (e.g. IT services provider, cloud storage providers, auditor, accounting services provider, etc.). In order to provide a proper service for all of our products, we may disclose data to any member of the IKANDU, VšĮ group, so that the data may be provided to any subsidiaries, affiliates or IKANDU, VšĮ related entities.
In addition to the transfers contemplated by part How and why we disclose your data, we or our Subcontractors may transfer or disclose your personal data to:
- comply with any legal obligation required under legal requirement (e. g. to state authorities);
- enforce any part of our Rules and/or any other agreements between you and us or to investigate potential breaches; or
- protect our rights or our property, or those of our other Account holders. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Any websites which are linked from the Website are not subject of this Policy and are not covered by this Policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.
Security
Each member of the staff can access the systems only by using his unique login credentials. Staff have access to personal data only for the purposes of performing their roles. You may have set a password in order to access certain parts of our Website. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We seek to put in place appropriate technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable Data Protection Laws. Nevertheless, you are responsible for using of the secure internet connection and the transmission of information via third party networks.
The deletion of your personal data (the right to erasure)
You can ask us to delete your information, this is also known as the right to be forgotten. This is underpinned by the principal of letting an individual to request the deletion or removal of your personal data where there are no strong grounds for its continued processing.
To respond to your request, your request and personal information will be shared with the relevant departments that may hold the information you have asked to be deleted.
That department(s) will then source the information, and erase only if:
- we no longer need your data in order to carry out our public functions
- you have initially consented to the use of your data, but have now withdrawn your consent
- you have objected to the use of your data, and your interests outweigh the States of Jersey in using it
- we have collected or used your data unlawfully
- we have a legal obligation to erase your data
- the data was collected from you as a child (aged under 13 years old) for an online service
We can refuse to delete data if at least one of the following exemptions applies:
- keeping your data is necessary for reasons of freedom of expression and information (eg journalism and academic, artistic and literary purposes)
- we are legally required to keep your data
- holding your data is necessary for reasons of public health
- keeping your data is necessary for legal claims
- erasing your data would prejudice scientific or historical research, or archiving that is in the public interest
We will contact you to confirm what information can be deleted or we will let you know if we can’t complete your request.
Information will not be passed to any other third party outside of the States of Jersey without your prior consent, or another condition of the law being met.
The correction of your personal data (the right to rectification)
The right to rectification lets you to request that inaccurate personal data is corrected or completed. This right is underpinned by the principle of accuracy of personal data.
To respond to your request, your request and personal information will be shared with the relevant departments that may hold the information you have asked to be amended or completed.
In the first instance, the department(s) may contact you to ask further information about your request. That department(s) will then take steps to check whether your data is correct or complete. Depending on the outcome of this review the department(s) will then take one of the follow steps:
- correct or complete the data if it was inaccurate or incomplete
- take no action if the data is already accurate and complete
- if it cannot be confirmed whether the data is accurate or complete, add a statement to the data to say that the individual disputes the accuracy or completeness, we may ask you to provide a written statement which includes the additional information in this regard
We will contact you to confirm what information can be corrected or we will let you know if we can’t complete your request.
Limit on the use of your personal data (the right to restrict processing)
You can ask us to limit how we use your personal data, this is known as ‘the right to restrict processing ’. The right gives individuals control over their personal data. This right only applies in certain circumstances.
To respond to your request, your request and personal information will be shared with the relevant departments that may hold the information you have asked to be restricted.
That department(s) will then source the information and restrict it depending on the basis.
On a temporary basis if you have either:
- challenged the accuracy of your information (through submitting a ‘Right to Rectification’ request)
- objected to our use of your information (through submitting a ‘Right to Object’ request).
On a permanent basis if we either:
- have processed your information unlawfully
- no longer need your information but you want us to keep it to create, exercise or defend legal claims.
If a restriction is placed on your information, we will continue to store it, however we may need to lift the restriction in certain circumstances including:
- with your consent
- to protect a person’s rights
- for the purposes of legal claims
- for reasons of important public interest
We will notify you in advance before lifting the restriction.
We will contact you to confirm what information can be restricted or we will let you know if we can’t complete your request.
Information will not be passed to any other third party outside of the States of Jersey without your prior consent, or another condition of the law being met.
The transfer of your personal data (the right to data portability)
The right data portability enables individuals to obtain their data from an organisation and provide it to another organisation for reuse or to have their data transferred to another organisation. This right gives individuals control over their personal data. This right only applies in certain circumstances.
The right to data portability applies only if you have provided us with your information, it is held electronically by the organisation and either one of the following applies:
- you have consented to us using your data; or
- you have entered into a contract with us.
In the majority of cases, we will be using your information to perform public functions and so the right to data portability is unlikely to apply. However, we may still be able to transfer data, for example school records under the general remit of data sharing.
Where applicable, we will provide you with your information in an electronic format that you can transfer to another organisation or we will transfer the data directly to the other organisation on your behalf.
To respond to your request, your request and personal information will be shared with the relevant departments that may hold the information you have asked to be transferred.
We will contact you to confirm what information can be transferred or we will let you know if we can’t complete your request.
Information will not be passed to any other third party outside of the States of Jersey without your prior consent, or another condition of the law being met.
Record of Processing Activities (ROPA)
A Record of Processing Activities (ROPA) is a record of an organization’s processing activities involving personal data. Some businesses may think of “processing” as being limited to active events, but a ROPA must also cover data that sits on a server or a shelf.
A ROPA includes the following information for each processing activity:
- • Names and contact details of the data controller, data processor, data controller’s representative, joint controller, and data protection officer (DPO), if applicable
- • Purpose (i.e., lawful basis) of processing personal data
- • Categories of data subjects and categories of personal data being processed
- • Categories of recipients to whom the personal data has been or will be disclosed
- • Third parties in other countries or international organizations who receive the personal data
- • Retention schedule for each category of personal data
- • General description of technical and organizational security measures related to each processing activity
A completed ROPA lists each processing activity involving personal data and provides detailed information about each of the items listed above.
Cookies and Web Beacons
Like any other website, Network Gate uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
Privacy Policies
You may consult this list to find the Privacy Policy for each of the advertising partners of Network Gate.
Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Network Gate, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
Note that Network Gate has no access to or control over these cookies that are used by third-party advertisers.
Third Party Privacy Policies
Network Gate’s Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
Children’s Information
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Network Gate does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Online Privacy Policy Only
Our Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in Network Gate. This policy is not applicable to any information collected offline or via channels other than this website.
Consent
By using our website, you hereby consent to our Privacy Policy and agree to its terms. If you have any queries relating to this Policy, please take a look at our data related FAQs or contact us at [email protected].
QUESTIONS OR CONCERNS
Questions regarding our Privacy Policy, or other policy related material can be directed to our support staff by clicking on the “Contact Us” link in the side menu. Or through the following ways:
- Tel: (+370) 68901259
- Email: [email protected] | https://crm.networkgate.info/
- Contact Address:
- Via Vittorio Emanuele, 196,
- 95131 Catania CT, Italy
Last update: 2022-08-19