1. General Provisions
2. 1. JSC "Invertus" (hereinafter referred to as the "Company"), while respecting the right to privacy of all individuals who interact with the Company - including but not limited to customers, website visitors, business partners, candidates, and event participants - ensures the protection of their personal data and upholds their rights as data subjects.
   2. This Privacy Policy sets out the fundamental principles and procedures for the collection, use, and storage of personal data provided to the Company through various channels, including but not limited to the Company’s website http://www.invertus.pro ("Website"), contact and inquiry forms, participation in events, commercial activities, and other interactions where personal data is voluntarily submitted to the Company.
   3. By using the Website, Company services, attending our events, submitting an inquiry, or otherwise voluntarily providing your personal data to the Company, you confirm that you have read and agree to this Privacy Policy (except in cases where your explicit separate consent is required). Consent is typically confirmed by checking a box or performing another affirmative action, depending on the context in which data is submitted. The Privacy Policy is publicly available on the Website at http://www.invertus.pro/privacy-policy.
   4. We handle your personal data by following (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 /EC (hereinafter referred to as the "Regulation") of 27 April 2016, as well as the Law on the Protection of Personal Data - "ADTAĮ") of the Republic of Lithuania, the provisions of the Law on Electronic Communications of the Republic of Lithuania (hereinafter referred to as the "ERRA") and other applicable legal acts regulating data protection.

2. Terms used in this Privacy Policy
3. 1. Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, personal identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
   2. Data subject - any identified or identifiable natural person who interacts with the Company and voluntarily provides personal data, including but not limited to customers, website visitors, individuals submitting inquiries, participants of events organized by the Company, business contacts, and job candidates.
   3. Data subject’s consent - any freely given, specific, informed, and unambiguous indication of the data subject’s will, by which he or she, through a statement or clear affirmative action (such as ticking a checkbox, submitting a form, or other active steps), agrees to the processing of personal data relating to him or her.
   4. Personal data processing - any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means. This includes collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing, or destroying personal data.
   5. "Data processor" means a natural or legal person, public authority, agency or other entity that processes personal data on behalf of the Data controller.
   6. Data controller - JSC "Invertus" is a company incorporated under the laws of the Republic of Lithuania. Code 300117946, address K. Donelaičio g. 62-522, LT-44248 Kaunas.
   7. A cookie is a small piece of text information that automatically creates when browsing the Website and is stored on your computer or other device.
   8. Direct marketing is an activity aimed at offering products or services by post, telephone or other direct means and/or inquiring their views on the products or services provided. 

3. What kind of personal data do we collect?
4. 1. The Company collects and processes the personal data that you voluntarily provide when interacting with us through various channels, including but not limited to: registering on the Website, submitting inquiries via contact forms, requesting/performing services, participating in events, applying for job opportunities, or engaging in other business interactions. Such data may include: your name, surname, company name, job title, postal address, email address, phone number, order or service details, billing and payment information, account numbers, communication content, consent status (e.g. for direct marketing), and any other information you choose to provide voluntarily. Your personal data is processed for the purposes for which it was submitted and is retained for the duration of your relationship with the Company and for up to ten (10) years after its termination, unless longer retention is required by law or justified by legitimate interests (e.g. in the event of legal claims).
   2. The Company also collects certain personal data automatically when you interact with the Website or other digital services. This includes data such as your IP address, login time, device and browser type, operating system, referral URLs, browsing activity, and other technical usage information. These data are collected using cookies or other tracking technologies, and are processed to ensure the proper functioning of the Website, improve user experience, analyze usage trends, and for security purposes. Automatically collected data is retained for as long as necessary to achieve these purposes, and typically no longer than one (1) year unless otherwise required by applicable law or necessary for dispute resolution or security monitoring.

4. What purposes are your personal data processed for?
5. 1. The Company processes personal data for clearly defined and legitimate purposes, based on the nature of the interaction with the data subject. These purposes may include:

• identifying and managing users within the Company's information systems;
• facilitating registration and login to user accounts on the Website;
• administering service requests, purchases, and deliveries;
• issuing and managing accounting or legal documentation (e.g. invoices, contracts);
• maintaining communication with data subjects for service-related matters;
• fulfilling contractual obligations and pre-contractual measures;
• responding to inquiries and requests submitted via contact forms or other channels;
• organizing and managing participation in events;
• carrying out recruitment processes and managing candidate information;
• conducting direct marketing activities (only with the prior consent of the data subject);
• improving the Website's functionality, user experience, and security through technical and analytical data processing.

Each processing activity is performed in accordance with applicable data protection legislation, based on an appropriate legal basis such as consent, contract performance, legal obligations, or the Company’s legitimate interests.

5. How is your personal data handled?
6. 1. The Company ensures that your personal data will be: processed in a lawful, fair and transparent manner, collected for specified, clearly defined and legitimate purposes, and will not continue to be dealt with in a way incompatible with those purposes, adequate, appropriate and necessary only for the purposes listed above, for which they are processed, accurate and, if required, kept up to date, processed in such a way that appropriate technical and organizational measures ensure the proper security of personal data, including protection from unauthorized processing of data or unlawful processing of data and accidental loss, destruction or damage.

6. Your rights as a data subject.
7. 1. You have the following rights of the data subjects that we will enforce upon receiving your request (by e-mail info@invertus.pro, by mail, to K. Donelaičio g. 62-522, LT-44248 Kaunas.) with proper confirmation of your identity:
   2. 1. get acquainted with your personal data and how they are processed;
      2. request to correct inaccurate personal data relating to you;
      3. request that your incomplete personal data be supplemented;
      4. require the Company to delete personal data relating to you if:
      5. they are no longer needed to achieve the purposes for which they were collected or otherwise processed;
      6. You cancel the consent, and there is no other legal basis for processing your personal data;
      7. Personal data was processed illegally;
      8. And on the other grounds set out in the Regulation;
      9. To require the Company to limit the processing of your personal data;
      10. To receive personal data related to you that you submitted to the Company in a systematized, commonly used and computer-readable format (you also have the right to ask the Company to transfer your personal data to another data controller);
      11. Object to the processing of your personal data (e.g., for direct marketing purposes or in other specific circumstances).
   2. We inform you that, considering that your rights as data subjects are violated, you can file a complaint with the State Data Protection Inspectorate. More information about the State Data Protection Inspectorate and complaints can be found here: https://www.ada.lt/.
   3. For more information on the rights of the data subject, see http://www.invertus.pro/right-of-the-data-subject//.

7. Processing personal data for direct marketing purposes.
8. 1. The Company may send you newsletters, offers, event invitations, or other marketing communications via email or other electronic means only with your prior explicit consent, in accordance with Article 6(1)(a) and Article 7 of the General Data Protection Regulation (GDPR) and applicable national laws.
   2. For direct marketing purposes, the Company may process the following personal data: your name, surname, email address, phone number, and any other information you voluntarily provide (e.g. through contact forms, registration, participation in events, or while requesting services), provided that such processing is based on your consent.
   3. Your personal data used for direct marketing purposes will be processed until you withdraw your consent. You may opt out of receiving marketing communications at any time by clicking the “unsubscribe” link provided in our emails or by contacting us at info@invertus.pro. Upon withdrawal of consent, your personal data will no longer be used for direct marketing purposes.

8. What purpose is your personal data used for?
9. 1. Access to your personal data within the Company is granted only to those employees or authorized persons who need this information to perform their direct job responsibilities, and only under strict confidentiality obligations.
   2. The Company may disclose your personal data to third parties only under the following circumstances:
   3. 1. When required to comply with legal obligations or respond to lawful requests from competent public authorities (e.g. courts, law enforcement agencies, supervisory authorities), but only after verifying the legality and necessity of such a request;
      2. To external service providers (data processors) engaged by the Company to support its operational and administrative functions, such as:

• IT infrastructure and support providers;
• CRM, email marketing, and event management platform providers;
• Accounting and invoicing service providers, including UAB Advisera, which processes personal data necessary for financial and accounting purposes;
• Legal, audit, or compliance consultants;
• Recruitment and HR solution providers (for candidate data);
• Other partners and subcontractors acting on behalf of or for the benefit of the Company, under data processing agreements.

3. To business partners, only when necessary for the performance of a contract or based on your prior explicit consent (e.g. for joint events, integrations, or service delivery).

3. All data processors engaged by the Company are required to implement appropriate technical and organizational measures to ensure data processing is secure, lawful, and respects your rights as a data subject, in line with Article 28 of the GDPR.
4. These processors may only process your personal data according to the Company’s documented instructions and may not use the data for any other purposes.
5. Data processors engaged by the Company are not permitted to subcontract further processing to other processors without the Company’s prior written authorization, whether specific or general.
6. Your personal data may be transferred and processed outside the European Economic Area (EEA), including to third countries, only if one of the following applies:

• There is an adequacy decision by the European Commission;
• Appropriate safeguards are in place (e.g. standard contractual clauses);
• You have given explicit consent;
• The transfer is necessary for the performance of a contract or legal obligation.

In such cases, the Company ensures that your data remains protected in accordance with applicable data protection laws.

9. Used cookies.
10. 1. To ensure a smooth, secure, and personalized experience while browsing the Website, the Company uses cookies and similar tracking technologies. Cookies are small text files that are stored on your device when you visit the Website. They help us recognize your device, remember your preferences, and improve the overall functionality and performance of the Website.

Depending on their function and purpose, the cookies used on the Website can be grouped into the following categories:

• Strictly Necessary Cookies - These cookies are essential for the proper functioning of the Website and enable you to navigate and use its core features (e.g., session management, secure login). These cookies do not require your consent.
• Preference Cookies - These cookies allow the Website to remember your preferences (such as language settings or region) to enhance your user experience during future visits.
• Analytical/Performance Cookies - These cookies help us understand how visitors interact with the Website by collecting information such as page visit statistics, traffic sources, and user behavior patterns. Data collected is aggregated and anonymized. We use tools such as Google Analytics for this purpose.
• Marketing Cookies - These cookies are used to deliver personalized advertising or promotional messages and to track the effectiveness of our marketing campaigns. These are only used with your prior consent.
• Session Cookies - Temporary cookies that store information while you are actively browsing the Website. They are automatically deleted once you close your browser.
• Persistent Cookies - These cookies remain on your device for a specified period or until you delete them manually. They store your settings and preferences to enhance your experience on subsequent visits.

The Company uses only those cookies for which it has a legal basis (such as legitimate interest or consent, where required). Upon your first visit to the Website, a cookie banner will inform you about the use of cookies and, where necessary, request your consent. You may withdraw or modify your consent at any time via the cookie settings link or your browser preferences.

Details of each cookie used (name, type, purpose, expiration period, and provider) are provided in the Cookies Table: 

https://docs.google.com/document/d/1rLMYEGGAfgTy3X-V021rhag4gmGVnQz33f8YC2XjoKY/edit?usp=sharing 

10. Links on the site.
11. 1. The Website may contain links to external websites, including legal resources, partner platforms, and social media networks (such as LinkedIn, YouTube, Twitter, etc.). Please be aware that these third-party websites are not operated or controlled by the Company and are governed by their own terms of use and privacy policies.

The Company assumes no responsibility for the content, data processing practices, or privacy standards of such third-party websites. When accessing external links, we recommend that you carefully review the applicable privacy policies and terms of service to understand how your personal data may be collected and processed.

The inclusion of third-party links does not imply endorsement or any association between the Company and the operators of those websites.

11. Changes to the Privacy Policy
12. 1. The Company reserves the right to amend this Privacy Policy from time to time to reflect changes in legal, regulatory, or operational requirements. Any changes will be published on the Website, and the date of the latest revision will be indicated at the top of the policy.
    2. In the case of significant changes that materially affect your rights or the way we process your personal data, we will notify you clearly (e.g., by email or on the Website) and, where required, obtain your consent.