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Privacy policy

This Privacy Policy was last updated on March 20, 2019

We are conscious of the great importance of your personal data protection. We collect and process only the data that is necessary for the performance of our activities. We process personal data in a legitimate, transparent and fair manner, for pre-defined purposes and only to the extent necessary for the achievement of the purposes of the processing. When processing personal data, we want them to be accurate, safe, confidential, duly stored and protected.

Your personal data is managed from our residence country, i.e. the Republic of Lithuania. Your personal data is managed in accordance with the General Data Protection Regulation (EU) 2016/679 adopted on 27 April 2016 (the ‘GDPR’), as well as the requirements for managing personal data as set in other applicable legal acts.

1. WHAT IS THIS DOCUMENT?

After reading this privacy policy (the Privacy Policy) you will know how and why we process your personal data, how we receive your personal data, to whom we provide, how we store your personal data and what are your rights as the data subject. Data subject refers to any natural person who can be identified, directly or indirectly, via identification information (i.e. personal data). However, the users of our services are business persons or students (please find more information in General Terms of Use). Accordingly, pay attention to the fact that just personal data processing (not of all scope of information processing) is regulated by GDPR and other applicable law.

The Privacy Policy sets privacy conditions regarding your personal data processing and our privacy rules applied in our activities with respect to use of our website, i.e. platform www.customsclearance.net (the ‘Platform’) and/or our accounts in social networks (Facebook, YouTube, Linkedin) as regards personal data processing and our privacy rules applied in our activities. Please read the Privacy Policy carefully, as each time you visit our Platform and/or our social network accounts, you accept the conditions of this Privacy Policy. If you do not accept these terms and conditions, please do not visit our Platform and/or our accounts.

The Privacy Policy is also applied to anyone visiting the Platform and/or our social network accounts as well as to actions that might have been performed on the Platform and/or our social network accounts, including the review of content, submission of inquiries, writing of comments, etc.

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children should not use our services. If we learn that we’ve collected personal data from a child, we will take reasonable steps to delete it. Parents and guardians who believe that we may have collected personal data from a child can submit a request that it be removed to us. 

The definition ‘personal data’ used in this Privacy Policy defines as any information that allows us to identify you – to establish your identity directly or indirectly. Personal data might be (for example) first name, last name, e-mail, telephone number, location data and online identifier, characteristics and any other personal data, as they are specified in the GDPR.

2. WHO ARE WE?

This Platform is managed and administered by us, i.e. CC Learning UAB, сontact e-mail: info@customsclearance.net (‘We’ or ‘we’).

When you provide us with (each time you use our Platform and/or our social network accounts) your personal data or we collect or get your personal data from other sources, we become controllers of your personal data and process them for the purposes indicated in this Privacy Policy. You have a right to exercise your rights (as set in the GDPR) in respect of us.

3. WHAT PRINCIPLES DO WE FOLLOW?

When processing your personal data we:

  1. will comply with the requirements of the effective and applicable laws, including the GDPR;
  2. will process your personal data in a legitimate, fair and transparent manner;
  3. will collect your personal data for the established, clearly defined and legitimate purposes and will no longer process them for any method that is not coordinated with such purposes, except to the extent permitted by the laws;
  4. will take any reasonable means to ensure that personal data which is not accurate or complete, in view of the purposes of processing, would be immediately corrected or supplemented, the processing of such would be terminated or it would be destroyed;
  5. will keep such data in a form which permits to identify you for no longer than it is necessary for the purposes for which personal data is processed;
  6. will not share personal data with any third parties and will not publish such data, except for the cases indicated in the Privacy Policy or the applicable laws;
  7. will ensure that your personal data is processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against the accidental loss, destruction or damage, using appropriate technical or organizational measures.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

We process your personal data received under the following methods:

  1. When you provide data to us. You provide us with your personal data and other information by using the Platform and/or our social network accounts through your active actions when using such network, i.e. by writing to us or communicating with our team, by submitting your complains and/or inquiries, assignments, comments, by creating own profile, etc. Please note that in case you contact us in writing or by e-mail, we may store the data of correspondence.
  2. When you use our Platform and/or our social network accounts. When you use our controlled Platform and/or our social network accounts certain information (e.g. address (IP), type of used browser, year, number of visits, reviewed Platforms, time spent on the Platform, internet source (that you were redirected from), information on the user's device information, language, country, internet provider, etc.) is collected automatically.
  3. When we receive your personal data from other persons in accordance with the procedure established by the laws and/or this Privacy Policy.

We can combine personal data received directly from you with data collected individually from public or available sources. For example, your presented personal data can be combined with data received by using cookies on Platforms and/or social networks, data collected when providing services to you or with data that was legally obtained from third parties. You will always be able to request the correction of erroneous personal data and exercise any other rights granted to you as the data subject.

5. WHY AND HOW DO WE PROCESS YOUR PERSONAL DATA?

We can process your personal data for the purposes indicated below in this Section of the Privacy Policy. Each purpose of the processing of personal data is individual and separate. In case of any questions which specific personal data we process about you, please feel free to contact us by exercising your rights indicated in Section 12 of the Privacy Policy.

1. For the purpose of direct marketing. We process your personal data upon the receipt of your consent and in order to provide you with newsletters. The content of the newsletters depends on your chosen preferences and may include the news about us, the news about course providers/publishers/other partners of us, our proposals and information on our goods and/or services or the goods and/or services of persons related to us and our partners/course providers/publishers, events or any other information and in order to improve our services).
For this purpose, we may process such personal data as login name, e-mail address, first name, and last name (if they actually constitute your e-mail address), a chosen frequency for the subscription (weekly, weekly, monthly, etc.), chosen type of the content (topics, geography, languages, etc.).
In this case, we receive this personal data directly from you.
For this purpose, your personal data may be supplied or transferred to legal persons providing Platform maintenance and other IT services, or marketing companies, etc.
For this purpose, your personal data is stored until we get your withdrawal of the consent regarding relevant data processing.
For more information on the processing of personal data for the purposes of direct marketing, please read Section 6 of this Privacy Policy.

2. For the purpose of quality control of our activities and ensuring functionalities of the use of Platform and/or our social network accounts (processing of your submitted inquiries and/or complaints, comments and communication (including the storage)). When you contact us (or we contact you in case of receipt of your inquiry), we process information received by phone, e-mail, via Platform and/or our social network accounts or any other form of communication. We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.
For this purpose, we may process such personal data as the first name, last name, e-mail address, internet address (IP), nickname, related company, telephone number, the content of the complaint and/or inquiry, date and time of your application, communication information. For this purpose, your personal data can be received directly from you, by performing the inquiry or analyzing the complaint, we can also create personal data by ourselves (e.g. having received your complaints, we contact third persons regarding the factual circumstances and record them, etc.), the controllers of social networks.
For this purpose, your personal data may be supplied or transferred to legal persons providing website maintenance and other IT services.
For this purpose, your personal data is stored for a period of 1 year from the day of recording, except for the cases, when there are grounds to believe that a crime or any other illegal actions have been committed or internal investigation is initiated until the end of the examination of the respective investigation and/or the case.

3. To improve the Platform, to offer better and customized services. Your personal data, including personal data received by using our Platform and/or visiting our social network accounts, will be used to improve and develop the Platforms and to offer better and more customized services.
Cookies enable us to collect personal data indicated in Section 7 of the Privacy Policy.
For this purpose, we use personal data received from you or created when using the Platform and/or received from other persons (including the controllers of social network). For more detailed information on how we use cookies and similar technologies, please read Section 7 of the Privacy Policy.

4. For the purpose of managing the Simple User Account and provision of our services to the simple user (i.e. solo user). You have to create/update the Simple User Account and your profile in order to use our services (to read articles, to watch a video, to do a quiz, to get the certificates, etc.).
When you create or update your Simple User Account, we collect and store the personal data and other information in part ‘Personal information’ of your profile: your full name (i.e. you first name, last name or other your submitted name information), your picture (optional), country (optional), industry information (optional), other your submitted information about you (optional); in part ‘Account/password’ of your profile: email address, university email address, corporate email address, password; in part ‘Payment Methods’ of your profile: name on credit card, credit card number, credit card date, country, billing information (i. e. country, first name and last name, address, phone number, related company/organization code (optional), related company (optional), related organization CAT code (optional)); in part ‘Preferences of your profile’: content preferences (languages you speak), markets of your interests; in part ‘My video courses’ of your profile: video in progress, completed video with issued certificates, saved for later video, assigned video; in part ‘My articles and journals’ of your profile: history of the usage, saved for later articles and journals, subscription plan information, purchased articles and journals, purchase history information (i.e. name of the product, purchase date, total price, payment method, other information of the invoices); also we are processing the date of your Simple User Account creation, updating, deactivation. 
Part of your profile data (such as your full name (i.e. you first name, last name or other your submitted name information), your picture (optional), country (optional), industry information (optional), other your submitted information about you (optional)) will be publicly viewable by others.
For this purpose, we use personal data received from you or created when using the Platform and/or received from other persons (including Course provider/Publisher, banks, payment institutions, employers, etc.).
For this purpose personal data may be supplied or transferred to legal persons providing Platform maintenance, other IT or legal services.
For this purpose personal data is stored not longer than 1 year after deactivation of your Simple User Account.

5. For the purpose of content publishing, i.e. the online video courses, tests, and/or written articles publishing on the Platform and/or via social network accounts.
For this purpose, we may process such a creator‘s personal data as first name, last name, the professional experience description. 
For this purpose personal data can be received directly from the data subject (i.e. creators) or by Course Provider/Publisher.
For this purpose personal data may be supplied or transferred to legal persons providing Platform maintenance and other IT services.
For this purpose personal data is stored for a period, which is defined in the agreement concluded between creators and Course Provider/Publisher.

6. For any other purposes stipulated in our internal documents when we are obliged to process your personal data by the laws or on the basis of any legal interest or on any other grounds for legitimate processing of personal data stipulated by the laws.

6. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING AND WHAT ARE THE RULES FOR SUBSCRIPTION TO OUR NEWSLETTERS?

Upon the receipt of your consent, we can use your personal data for the purpose of direct marketing in order to provide you with our offers, news, and information on our services, which we consider to be interesting for you.

For this purpose, we process such personal data as stipulated in Section 5.

You can choose whether to allow us to use your personal data for direct marketing. You can do so by Platform subscribing or unsubscribing from our newsletter.

If you give your consent to use your personal data for direct marketing, we can use your personal data for the analysis and improvement of the effectiveness of our Platforms, advertising, and market research and any other purposes of our marketing and sales. In such a case, we will use depersonalized data.

Even if you gave your consent to process your personal data for direct marketing, this consent can be withdrawn at any time for all or part of the actions of processing. In such a case, you can:

  1. notify us on the withdrawal by the method indicated in electronically received messages and/or proposals (e.g. by pressing the link regarding the refusal of subscription);
  2. by sending the application by e-mail (our contact e-mails are available in Section 2 of the Privacy Policy). Your first name and last name and other data (if any) shall be clearly indicated in the application. If you express your wish to withdraw your consent by this method, we can ask to submit the documents proving your identity.
  3. If you withdraw your consent, we will try to terminate the processing of your personal data for the purposes of direct marketing as soon as possible.
  4. The withdrawal of consent automatically obliges us to destroy your personal data or to provide you with information on our processed personal data, therefore, if you want us to perform these actions as well, you should inform us of such requests separately.

7. HOW DO WE USE COOKIES?

We collect information about you by using cookies and similar technologies. Cookies are small text files which are recorded temporarily to the hard disk of your device and allow us to recognize you during your next visits on the Platform, social network, save the person’s browsing history, options, to adapt the content, to accelerate the searches performed on the Platform, to create a comfortable and friendly environment on the Platform, to provide it in a more effective and reliable manner. Cookies are a usual practice of browsing on websites that facilitate the use of a website.

Cookies enable us to collect such information stipulated in Section 7 of the Privacy policy.

Information obtained by using cookies is used for the following purposes:

  1. to ensure the functionality of Platform (e.g. in order to use personalization of specific Platform);
  2. in order to improve Platform or to develop it to better reflect your needs;
  3. for the development of services and analysis of the use of Platform;
  4. for the targeted orientation of marketing solutions.

Without prejudice to the legal acts, we can combine information received by using cookies with information received about the person by other means (e.g. information on the use of Platform, your submitted personal data).

Please note that the following cookies may be used on the Platform, social network:

  1. technical cookies – cookies necessary for the functioning of Platforms;
  2. functional cookies – cookies which, while not necessary for the functioning of Platforms, considerably improve their functioning, quality, and user experience;
  3. analytical cookies – cookies used for the preparation of statistical analysis of navigation methods of Platform visitors; data collected by these cookies are used anonymously;
  4. targeted or advertising cookies – cookies used to show offers or other information which could be interesting to you;
  5. social network cookies – cookies that are necessary in order to use the information of Platforms on your social profile account.

All information on the cookies used on our Platform, their purpose of use, validity and used data is provided below:

You can give your consent to use cookies on our Platform in the following ways:

  1. without deleting them and/or without changing the settings of website browser to disable cookies;
  2. by choosing ‘Accept’ on a specific link (bar) used on the Platform.

You can withdraw your consent to use cookies at any time. You can do so by changing the settings of your browser to disable cookies. The way of doing so depends on the used operating system and browser. Complete information on cookies, their use, possibilities of withdrawal is available on http://AllAboutCookies.org or http://google.com/privacy_ads.html.

In certain cases, especially in cases of disabling technical and functional cookies, non-acceptance of cookies or deletion thereof can slow down the speed of browsing online, restrict the functioning of certain specific functions on the Platform or block the access to the Platform.

More information on external websites (such as social networks) is available in Section 11 of the Privacy Policy.

8. HOW DO WE SHARE YOUR PERSONAL DATA?

We guarantee that your personal data will not be sold, supplied or otherwise shared with third parties without any legitimate grounds, as well as used for any purposes other than they were collected for. We will not transfer your personal data in any way other than pursuant to this Privacy Policy and/or other internal documents and legal acts. However, we reserve a right to provide information about you, if we have to do so in accordance with the procedure established by the laws or if the legally operating institutions or institutions engaged in criminal prosecution request so.

We can transfer your personal data to companies that help us to perform our activities. We request such partners to process your data only according to our given instructions and according to the valid legal acts ensuring the protection of your personal data. We conclude contracts with these persons in order to oblige them to follow the requirements of the protection of personal data in a strict manner.

The possibility of the aforementioned service providers to use your data is restricted – they cannot use such data for any purposes other than the provision of services to us.

A non-exhaustive list of persons and categories of such person with whom we share your personal data is provided in Section 5 of the Privacy Policy for each purpose of use of personal data individually.

9. HOW LONG DO WE STORE YOUR PERSONAL DATA?

We store your personal data for no longer than it is necessary for the purposes of the processing of data or stipulated by the laws if they establish a longer period for the storage of data.

Our aim is not to store outdated, irrelevant personal data, therefore, in case of an update of data (e.g. specification, change of information, etc.), the only relevant information is stored. Historical information is stored only if it is necessary in accordance with the procedure established by the laws or for the performance of our activities.

The terms of storage of your personal data are indicated in Article 5.1 of this Privacy Policy for each purpose of use of personal data individually.

10. HOW DO WE STORE YOUR PERSONAL DATA?

Data collected from you will be stored in the territory of the EU, but can also be transferred or stored outside the EU. They may also be processed by our personnel or the personnel of our partners based outside the EU. When transferring your data outside the EU, we will perform all the necessary actions in order to ensure that your data is processed in a safe manner and pursuant to this Privacy Policy.

Unfortunately, the transfer of information online is not completely safe. Even if you put our every effort in protecting your personal data, we cannot ensure the security of data when you provide such data on the Platform – you shall accept the risk related to the transfer of data to the Platform. When we receive your data, we will apply strict procedures and security means for the protection of your data from any unauthorized access.

In case of unlikely circumstances of finding out about the security breach of your personal data, which may cause considerable risk to your rights and freedoms, we would immediately inform you as soon as we find out and establish what kind of information has been accessed.

11. EXTERNAL WEBSITES

The Platform may contain links to external websites – the websites where we have accounts and where our services are advertised or to customs-related content on other websites. By using such links to reach any of such websites, please note that these websites and services provided through such websites have their own privacy policies and we assume no responsibility or obligations for these policies or any personal data collected on these websites or by providing services, for example, contact or location data. We recommend reviewing such policies before submitting personal data on such websites or by using any other services. We also recommend reading the privacy statements of third parties having control of these websites and contact the service providers directly if you have any questions on how they use your personal data.

12. WHAT ARE YOUR RIGHTS?

By processing your personal data, we guarantee your rights according to the GDPR and the Law on the Legal Protection of Personal Data of the Republic of Lithuania. As the subject of personal data, you have the following rights:

  1. to know (be informed) about the processing of your personal data;
  2. to familiarise with your personal data that is processed by us;
  3. to request rectification or supplement, specification of your incorrect, imprecise, incomplete personal data;
  4. to request to destroy personal data when it is no longer necessary for the purposes for which they have been collected;
  5. to request to destroy personal data if they are processed illegally or when you withdraw your consent regarding the processing of personal data or do not give a consent, which is necessary;
  6. to object to the processing of personal data or to withdraw a previously given consent;
  7. to request to terminate the actions of processing of personal data (except for storage) in case of any disputes or it is necessary to inspect the legitimacy of the processing of data, the precision of data, as well as in certain cases when we no longer need personal data, but you do not want us to delete such data;
  8. to request to submit your personal data, where technically possible, collected according to your consent or for the purposes of performance of the contract in an easily readable format or request to send to another data controller.

 

We will seek to ensure the realization of your rights as a personal data subject and to form all the conditions for the effective realization of these rights, however, we reserve a right to refrain from fulfilling your claims when it is necessary to ensure the following:

  1. performance of legal obligations that have been set to us;
  2. national security or defense;
  3. public order, prevention of criminal activities, investigation, detection or criminal prosecution;
  4. important economic or financial interests of the state;
  5. prevention, investigation, and detection of breaches of official or professional ethics;
  6. protection of your rights and freedoms as well as those of other persons.

You can submit your claims related to the realization of your rights by mail or any means of electronic communication. After the receipt of your application, we may request to submit the documents proving your identity as well as any other additional information related to the application and necessary to us.

In case of receipt of your claim, we will reply to you no later than within 30 calendar days from the receipt of your claim and the day of submission of all the documents necessary to prepare the reply.

If we consider it necessary, we will terminate the processing of your data (except for storage) until the decision regarding your application is made. If you withdraw your consent in a legitimate manner, we will immediately but no later than within 30 calendar days terminate the actions of processing of your personal data, except for the cases stipulate in Article 12.2 of this Privacy Policy and the legal acts, i.e. when we are obliged to continue to process your data by the effective laws, our legal obligations, court decisions or mandatory instructions given by the institutions.

In case of refusal to perform your claim, we will clearly indicate the reasons of such refusal.

In case of disagreement with our actions or the answer to your application, you can appeal our actions and decisions by applying to competent state authority.

13. WHERE CAN YOU SUBMIT A COMPLAINT?

If you want to submit a complaint regarding the processing of your data, you shall submit it in writing, by indicating as much information as possible, to the contact details provided at the end of this Policy. We will cooperate with you and will seek to solve all the matters immediately.

If you think that your rights have been breached, you can submit an appeal to our supervisory institutions. You also have the right to lodge a complaint with our lead supervisory authority (please find more information and contact details: http://vdai.lrv.lt/), or your local supervisory authority in accordance with legal act requirements. However, our principal aim is the expedient and peaceful settlement of any disputes in cooperation with you.

14. HOW IS THIS PRIVACY POLICY UPDATED?

Any changes in our Privacy Policy will be published on the Platform. We will notify you of any changes, where necessary. New terms and conditions of the Privacy Policy may also be provided on the Platform and you may have to read them and to accept them in order to continue to use the Platform and/or our services.

15. HOW TO CONTACT US?

All documents related to this Privacy Policy shall be sent to us or you can contact us according to the contact details provided in Section 2 of this Privacy Policy. 

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