PRIVACY POLICY OF THE WEBSITE PERKS.LT AND THE PLATFORM APP.PERKS.LT
This Privacy Policy establishes the terms, conditions, and procedures for processing personal data when visiting the website perks.lt and using the service and discount platform app.perks.lt.
1. DATA CONTROLLER AND DATA PROCESSOR
1.1. Data Controller
When personal data is processed for direct marketing, inquiry management, general account management, and platform operation purposes, the Data Controller is:
- Legal Entity: UAB „Ryte ir vakare”
- Company Code: 304409524
- Registered Address: A. Vivulskio g. 7, LT-03221 Vilnius, Republic of Lithuania
- Email: [email protected]
1.2. Data Processor (B2B Relationships and DPA)
When user accounts on the app.perks.lt platform are initiated, created, or employee lists are uploaded by a business client (employer), such business client is considered the Data Controller, while UAB „Ryte ir vakare” acts as a Data Processor. In such cases, the specific terms, scope, and obligations regarding personal data processing are governed separately under a Data Processing Agreement (DPA) signed between UAB „Ryte ir vakare” and the business client.
2. PERSONAL DATA PROCESSED, PURPOSES, AND LEGAL BASES
The Data Controller processes personal data in strict compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the legal acts of the Republic of Lithuania.
Purpose of Processing | Personal Data Processed | Legal Basis (GDPR) |
|---|---|---|
Account creation and authorization (app.perks.lt) | Work email address, authorization code, secondary email address, phone number, SSO data (Microsoft Azure SSO, JumpCloud). | Performance of a contract or pre-contractual steps (Article 6(1)(b) GDPR). |
Provision of the service platform | Account settings, selected discounts, platform usage history. | Performance of a contract (Article 6(1)(b) GDPR). |
Inquiry management (perks.lt) | Name, email address, content of the inquiry. | Legitimate interest to respond to inquiries (Article 6(1)(f) GDPR). |
Merchandise/Attributes ordering | Name, surname, delivery address, phone number, payment information. | Performance of a contract (Article 6(1)(b) GDPR) and legal obligation to retain accounting records (Article 6(1)(c) GDPR). |
Direct marketing and newsletters | Email address, marketing preference settings. | Separate consent of the User (Article 6(1)(a) GDPR). |
Website analytics and marketing (perks.lt) | IP address, browser type, device data, browsing behavior (Google Analytics, Meta Pixel). | Separate consent for cookies (Article 6(1)(a) GDPR). |
Note regarding statistics: Reports provided to business clients (employers) contain only anonymized and aggregated data regarding employee platform usage. Individual employee actions or specific selected offers are not disclosed to the employer.
3. DATA TRANSFERS AND SUB-PROCESSORS
Depending on which part of the service you use, your personal data is processed with the assistance of the following service providers:
3.1. Platform app.perks.lt Service Providers (Sub-processors)
For platform functionality, account management, and sending system notifications, the following sub-processors storing data within the EU/EEA are used:
- Infrastructure and Hosting: „DigitalOcean” (Frankfurt data center, Germany).
- Communication and Authorization: „Twilio” (for transactional emails and SMS messages), „Google Workspace” (for email infrastructure).
- Authentication Integrations (SSO): „Microsoft Azure”, „JumpCloud” (applicable only to organizations that enable this login method).
3.2. E-commerce and Delivery Partners (Only during purchase)
If a User purchases merchandise on the platform, data required for payment and fulfillment is transferred to:
- Payment and Sales Platforms: „Ecwid”, „Paysera”, „Stripe”.
- Delivery Services: AB Lietuvos paštas („LP Express”).
3.3. Website perks.lt Analytics and Marketing Partners
On the informational website perks.lt, the following tools are used for visitor behavior analysis and marketing, activated only upon the visitor’s consent via the cookie banner:
- Analytics: „Google LLC” („Google Analytics”).
- Marketing: „Meta Platforms Ireland Ltd.” („Meta Pixel”).
3.4. International Data Transfers
Some service providers listed in sections 3.1–3.3 (e.g., „Twilio Inc.”, „Google LLC”, „Stripe Inc.”) are registered in the USA. Data transfers to these providers are conducted based on the European Commission’s adequacy decision under the EU-US Data Privacy Framework or using Standard Contractual Clauses (SCCs) approved by the European Commission.
4. COOKIES AND TRACKING TECHNOLOGIES
- 4.1. On the perks.lt website: Essential (technical) cookies ensuring website functionality, as well as analytics and marketing cookies (Google Analytics, Meta Pixel), are used. Analytics and marketing cookies are activated only upon the visitor’s consent via the cookie management banner.
- 4.2. On the app.perks.lt platform: Essential session and authorization cookies / access tokens required for secure User login and platform functionality are used.
- 4.3. Management: Users can change or withdraw their cookie choices at any time through the website’s cookie settings or by modifying their web browser settings.
5. DATA RETENTION PERIODS, DELETION, AND AGE RESTRICTIONS
- 5.1. Account Data (app.perks.lt): Upon termination of the contract or account deletion by the User, personal data is permanently deleted or anonymized (rendered anonymous so that the User’s identity can no longer be determined) within no more than 30 (thirty) calendar days. Anonymized data may continue to be used solely for aggregated statistics and analytics.
- 5.2. Inquiry Data (perks.lt): Retained for 3 (three) years from the date of the last contact, after which it is deleted.
- 5.3. Accounting and Purchase Documents: Merchandise order and payment data are retained for 10 (ten) years from the execution of the transaction in accordance with the requirements of the legal acts of the Republic of Lithuania.
- 5.4. Direct Marketing Data: Retained until consent is withdrawn, but no longer than the validity of the User’s platform account.
- 5.5. Age Restriction: The platform app.perks.lt is intended for individuals aged 16 and older. By registering on the platform, the User confirms that they have reached the specified age.
6. RIGHTS OF USERS (DATA SUBJECTS)
Users, as data subjects, have the following rights:
- Right to be informed about the processing of their personal data.
- Right of access to their processed personal data.
- Right to rectification of inaccurate or incomplete data.
- Right to erasure („right to be forgotten”).
- Right to restriction of processing.
- Right to data portability.
- Right to object to processing or to withdraw consent at any time (e.g., for direct marketing).
Account and Data Deletion
A User can initiate the deletion or anonymization of their account at any time:
- Directly on the settings page of the app.perks.lt platform; or
- By submitting a request at: https://perks.lt/delete.
Requests regarding the exercise of rights can also be submitted by email: [email protected]. A response will be provided no later than within 30 days from the request.
If a User believes their rights have been violated, they have the right to lodge a complaint with the supervisory authority – State Data Protection Inspectorate (L. Sapiegos g. 17, Vilnius, www.vdai.lrv.lt).
7. SECURITY ASSURANCE AND FINAL PROVISIONS
- 7.1. The Data Controller implements strict technical and organizational data protection measures (including SSL/TLS data encryption, authorization controls, and strict access restrictions). Security processes are organized following international information security standards and best practices (ISO/IEC 27001 principles).
- 7.2. This Privacy Policy is periodically reviewed and may be updated. The updated version takes effect from the date of its publication on the perks.lt and app.perks.lt websites.
- 7.3. For any questions, please contact us by email: [email protected].