JSC BIRIU KROVINIU TERMINALAS (herein further – the BKT) intends to ensure that customers, visitors of website and other persons, personal data of which we are processing, would fully trust us and our services and would be transparently informed on how we process their data. Therefore, it is very important that you carefully read the Privacy Policy, wherein you will find the information about how we collect and use your personal data.
When using the BKT website as well as the services offered by the BKT or providing the BKT with your personal data on other grounds you agree to the provisions of the present Policy. The Privacy policy regulates how the BKT process the personal data that can be provided by you during your visit in our company, on the BKT website www.bkt.lt (herein further – the Website), having contacted with us by e-mail or telephone, as well as those that are received by the BKT in the course of performance of contracts with partners or customers-legal persons, if you are a member of their staff or repetitive .
The controller of the processed personal data is JSC BIRIU KROVINIU TERMINALAS (code of legal person 141544519, registered domicile address: Nemuno g. 163, Klaipėda, Lithuania, details about the company are compiled and processed by the Register of Legal persons under the State Enterprise Centre of Registers, e-mail: [email protected], telephone number +370 46 304 400).
The Privacy Policy shall be applied irrespective of the devices used by a visitor to log on the Website.
We inform that the BKT may engage other persons to process personal data and for this purpose to transfer information about persons to other legal persons subject to the terms and conditions stipulated in the Privacy Policy.
The present Privacy Policy has been prepared pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), herein further – the GDPR), the Law of the Republic of Lithuania on Legal Protection of Personal Data, other legislation of the European Union and the Republic of Lithuania.
Definitions:
Personal data – any information associated with a natural person (personal data subject), whose identity is known or who can be directly or indirectly identified by using such details as personal identification code, one or several attributes of physical, psychological, economic, cultural or social nature that are inherent to the person.
Personal data processing means any operation performed with personal data: collection, recording, accumulation, storage, classification, grouping, merging, alteration, disclosure, making available, use, logical and/or arithmetic operations, search, dissemination, destruction or any other operation or a set of operations.
Subject of personal data means a natural person, whose personal data are gathered by the Company.
Other terms used in the Privacy Policy shall have the same meaning as defined in the legislation.
SECTION II
COLLECTION AND USE OF PERSONAL DATA
We collect the following types of data:
the data provided by you when you are communicating or maintain legal relationships with us, buying the BKT services or registering for the services, applying to us with a request to provide information;
video data;
those, which is generated when you use our network and services (e.g. are sending an e-mail or visiting our website);
those, which is received by us from other sources, e.g. from other service providers or publicly available registers.
You are not obligated to disclose personal data to us, however, if you choose not to do so, we may not be able to provide you with certain services.
By providing your personal data, you assume the responsibility for their accuracy, correctness and completeness. In the event of change in your personal data, you must immediately inform the BKT thereof. The BKT will not be held liable for the damage incurred to the person and (or) the third persons, which has resulted from the fact that you have provided incorrect and (or) incomplete personal data or have not made a request for their supplementation and (or) modification upon their change.
The BKT shall gather and further process the following personal data about you, which is provided by you or obtained by the BKT through performance of contracts with partners or customers -legal persons:
personal data of the vessels’ crew members: name, surname; rank; date of birth; place of birth; details of personal ID document (number, date of expiry); declaration of personal belongings; details of seamen’s book (number, date of expiry), details of special categories– maritime Declaration of Health, nationality.
personal data of family members of the crews: name, surname, date of birth; details of personal ID document (number, date of expiry).
personal data of persons entering the BKT territory: name, surname; position; nationality; document type; document number; company name; photograph; e-mail address; telephone number; licence plate number and make of vehicle; date of issue and date of expiry of a permit; time of entry, time of departure.
The BKT shall gather and further process the following personal data about you that is provided by you indirectly through ordering services or visiting the Website, i.e. such data is automatically gathered from your computers and (or) mobile devices when you visit the Website:
visitor’s name, surname, e-mail address, IP address, comments made in the website, other details that have been voluntary shared by the visitor when browsing a website (cookies);
when commenting on the Website, the visitor is asked not to disclose special categories of personal data (e.g., information on racial or ethnic background, political opinions, membership in professional associations, physical or mental health). If for some reason a visitor decides to provide the BKT with personal data of special categories or other confidential information, such an action shall be deemed to constitute the visitor’s explicit consent allowing the BKT to collect and use such data and information for the purposes indicated in the present Privacy Policy.
The BKT shall gather and further process the data subjects’ video data that is recorded by our video surveillance devices during your visit in the BKT territory. In the course of video surveillance only video data shall be processed.
CCTV surveillance field covers the territory of the port area that is rented and the port quay that is utilised by the BKT, the border zone, the perimeter of the border zone, the gates of entry to the territory, car parks, stevedoring and cargo handling sites, the perimeter of buildings, the railways and accesses to the railway gates:
CCTV location
Surveyed territory
Number of cameras
Duration of video records, days
Audio recording
Nemuno Street 24, Klaipėda
Controlled camera
1
30
Not recorded
Nemuno Street 168, Klaipėda
Controlled camera
12
30
Not recorded
Nemuno Street 168, Klaipėda
Perimeter
18
30
Not recorded
Nemuno Street 168, Klaipėda
Entry
7
30
Not recorded
Nemuno Street 168, Klaipėda
Exit
4
30
Not recorded
Nemuno Street 168, Klaipėda
Quay № 101
1
30
Not recorded
The Company provides video records to State Enterprise Klaipėda State Seaport Authority pursuant to the procedure and in cases stipulated in art. 6 of Order Nr. V-143 of Director General of SE Klaipėda State Seaport Authority, dated 03-07-2015 „Technical requirements for Klaipėda State Seaport gate technical control system for vehicles and pedestrians”; data is also provided to law enforcement authorities.
Storage of personal data:
Personal information of a data subject shall be stored no longer than required for accomplishment of the objectives set out in the present Privacy Policy;
Personal data shall be protected from loss, unauthorized use and tampering. Physical and technical measures have been implemented to protect all information collected for the purpose of provision of services. Data shall be stored for 3 years. Upon expiry of this period, the data shall be deleted irretrievably;
Storage of personal information for a longer period than the one referred to in art. 14.2 of the Privacy Policy is allowed only in the event of a reasonable suspicion of unlawful actions (in regard of which an investigation is being carried out) or when the data is indispensable for the appropriate resolution of a dispute, complaint or subject to other special grounds provided for by law.
The grounds for lawful processing of personal data:
when a legal obligation requires so, i.e. when we are obligated by applicable mandatory legislation of the European Union and the Republic of Lithuania mandatory to process your personal data;
when data processing is necessary in order to conclude and (or) perform a contract with the person;
the person gave a consent to his/her data processing for one or a number of particular purposes;
personal data have to be processed in order to implement the Company’s legitimate interest.
The purposes of personal data processing:
for proper provision, processing and administration of services;
for identification of visitors of the Website;
for implementation of the requirements of the international and national legislation and statutory and regulatory enactments regulating the port security and the port regime;
the BKT carries out video surveillance in order to ensure compliance with the procedure and the regime of the port territory use: to prevent terrorism, unauthorised entry of persons and the passage of arms, incendiary devices and explosives to the territory of seaports of the Republic of Lithuania, ships, port facilities, restricted areas, to reduce threats to the security of passengers, ships, their crews and port infrastructure and superstructure facilities (terminals), as well as to ensure the control of the port complex zone under the customs supervision, the protection of ownership rights, to guarantee the safety and security of property of the Company and its customers;
to give answers to received inquiries/requests;
to inform about organised events, social initiatives and other activities of the BKT;
to ensure possibility to carry out statistical and other analysis, which allows for the continuous development of the contents of the Website.
The data transfer:
BKT shall not transfer a data subject’s personal data to the third persons without his/her separate consent except when this is necessary for law enforcement, judicial or pre-trial investigation authorities due to their current investigations, or in other cases stipulated by legislation and the present Privacy policy.
SECTION III
RIGHTS OF DATA SUBJECTS
The legislative acts on data protection confer certain rights to the data subject, who may freely exercise them, and the BKT must ensure such a possibility to the data subject. A data subject has the following rights:
The right of access to his/her personal data being processed by the BKT. A data subject has the right to receive confirmation from the BKT whether the BKT processes personal data, as well as the right to access to the data subject’s personal data processed by the BKT and the information on the purposes of data processing, the categories of processed data, the categories of data recipients, the time limits of data processing and the sources of acquisition of the data;
The right to have personal data rectified. In the event of change in the data provided by the data subject or, if in the data subject’s opinion, the information about him/her being processed by the BKT is inaccurate or incorrect, the data subject is entitled to require to have this information changed, clarified or rectified;
The right to request the data to be erased (the right to be forgotten). Under certain circumstances defined in legislation (e.g., when personal data is processed unlawfully, when the grounds for data processing ceased to exist), a data subject has the right to request the BKT to delete his/her personal data;
The right to recall a consent. Where processing of the data subject’s data by the BKT is based on the data subject’s consent, the latter is entitled to recall his/her consent at any time and the data processing based on the data subject’s consent will be cancelled;
To require that the processing of your personal data be restricted. A data subject has the right to require the Company to limit the data processing, when:
the data subject contests the accuracy of the data for a period enabling the data controller to verify the accuracy of the data;
processing of personal data is unlawful and the data subject does not agree to erasure of the data;
The BKT no longer needs the personal data for the processing purposes, however they are needed for the data subject in order to bring, enforce or defend legal requirements;
The data subject objected against his/her data processing pending verification whether the BKT’s legitimate reasons prevail over the data subject’s reasons.
to request that your personal data be transferred to another data controller (the right to data portability).
the right to disagree to data processing, when the processing is based on legitimate interests. A data subject has the right to disagree to personal data processing, when processing of the personal data is carried out on the grounds of the BKT legitimate interests;
the right to lodge a complaint. If, in the data subject’s opinion, the BKT processes his/her data in breach of the requirements of the data protection legislation, he/she should contact the BKT directly. If the data subject is not satisfied with the method of problem solution proposed by the BKT or, in his/her opinion, the BKT has not taken necessary actions concerning the data subject’s request, the data subject shall have the right to lodge a complaint to the State Data Protection Inspectorate at the address: A. Juozapavičiaus g. 6, 09310 Vilnius, by e-mail: [email protected].
In order to exercise their rights, the data subjects are invited to fill-in an Application form (enclosed thereto) and to send it by e-mail at: [email protected] . The BKT informs that if in doubt of the person’s identity, the BKT may require additional information in order to properly identify the person.
Having received the data subject’s request and having considered its contents and the scope of the issue, the BKT designated employee will contact the data subject within 5 working days at the latest and shall inform him/her about the time limits as well as the legal and technical possibilities for exercising of the data subject’s rights.
SECTION IV
COOKIES
When you visit our website, the BKT may process the visitor’s IP address, the network and location details, when the visitor provides them. The data is collected by means of cookies and other similar technologies on the grounds of consumer’s consent. A cookie is a small text file that a website saves on your PC when you visit the site.
Cookies are intended to ensure efficient and secure functioning of the website and to analyse your preferences in order to make the functioning of the Website convenient and effective and to meet your needs and expectations.
The following cookies are used on the BKT Website:
Cookie
Functions of the cookie
Purpose of data processing
Moment of installation
Expiration time
pll_language
Saves the language setting selected by the visitor
This cookie is used to save the visitor’s language setting
Upon visiting the website
1 year
_ga
The cookie is used to gather statistics of the website
IP addresses and unique ID numbers are used to generate statistical data; Measuring of the results is made through Google analytics
Upon visiting the website
2 years and 2 months
_gat
The cookie limits the frequency of queries through Google
Does not record any information about the user
Upon visiting the website
1 minute
_gid
The cookie is used to gather statistics of the website
This cookie gathers and updates information on visited website pages. For more information, visit: https://cookiepedia.co.uk/cookies/_gid
Upon visiting the website
2 days
Cookies may be used only subject to consent of a respective visitor of the website. When visiting the BKT Website, a visitor can choose whether he/she wants to enable cookies. Cookies can be controlled and (or) deleted according to your preferences. In most browser settings, one can choose which cookies to enable and to disable, as well as to check, which cookies are stored, as well as to delete individual cookies, to block third-party cookies, to block cookies from specific websites, to block all cookies from being sent, and to delete all cookies when closing the browser. To learn more about the methods for cookies control, one can visit websites of the browsers you are using:
If a visitor of the website does not accept cookies on its computer or other device, he/she may at any time recall a consent to use them by changing the settings and deleting the saved cookies. Please note that if cookies are completely blocked, the BKT Website may not work properly.
We inform that the Website also uses the essential cookies that ensure functionality of the Website and the use of which do not require your separate consent.
SECTION V
PERSONAL DATA PROTECTION
By implementing appropriate technical and organizational measures, the BKT protects the personal data of a data subject from loss, unauthorised use, unauthorised access, disclosure or tampering.
Having assessed the risk and detected a data security breach that may pose a serious threat to persons, the BKT shall immediately inform the relevant persons thereof.
Pursuant to the procedure stipulated in legislation of the European Union and the Republic of Lithuania the BKT shall be held liable for a data security breach that may pose a serious threat to persons.
SECTION VI
FINAL PROVISIONS
The present Policy may be modified and updated as the need arises, in view of the changes implemented by the BKT and other factors. The updated Privacy Policy shall be published on the Website.
The Privacy Policy shall apply as of 1 June, 2020.