Privacy policy

Privacy Policy

1.             What Does This Privacy Policy Mean?

This privacy policy (hereinafter the ‘Privacy Policy’) provides information on the processing of your personal data carried out by UAB “SPA EUROPE” (hereinafter ‘the Company’) for the purposes specified in this Privacy Policy. All the persons whose personal data are processed by the Company shall hereinafter be referred to as the ‘Customers’. Privacy Policy also provides certain responsibilities of the Customers that must be complied with when visiting the website www.spaeurope.eu (hereinafter the ‘Website’). 

2.             About us

UAB SPA EUROPE, legal entity number 305568675, office address at Pagrindinė St. 1A, Varputėnai, LT-80242 Šiauliai region, data of the company are collected and stored in the Register of Legal Entities of the Republic of Lithuania. Contact details for personal data matters: info@spaeurope.eu

3.             What Personal Data we do process?

Personal data are any information about the Customer collected by The Company that may be used for the Customer identification and is stored electronically or in any other manner.

Personal data include any information, including the Customer’s name, surname, address and IP address, which is collected by the Company about the Customers for the purposes indicated in this Privacy Policy, or during a meeting with the Customer, or in the agreement with the Company.

Personal data shall also include publicly available personal information of the Customers accessed by the Company when the Customer contacts the Company via any social media networks or performs active actions on social media accounts of the Company.

4.             Personal Data Processed in relation to the Purchasing of Goods of the Company (either through this Website or other means)

5.             Direct Marketing

We will send offers for the sale of goods and provision of services of the Company, newsletters and other advertising material to persons who are at least 14 years old and have provided their contact details and have expressed a wish to receive information about the goods and/or services offered by the Company via electronic communication means (e-mail, phone, text messages), also ask for their opinion on provided services and purchased goods, and notify them of the Company news. The Company will process the following personal data for direct marketing purposes: name, surname, phone number, e-mail address (data necessary in order to be able to send you direct marketing messages). 

Your data processed on the basis of consent will be used for direct marketing purposes for 3 (three) years as of the receipt of your consent. 

If you are our Customer and have not objected to receiving direct marketing messages of the Company, we will send you messages about goods and services similar to those purchased by or provided to you by e-mail on the basis of our legitimate interest. In this case, your data will be processed for direct marketing purposes for 1 year after the last purchase of the product or service.

You have the right to refuse direct marketing at any time by contacting us via e-mail info@spaeurope.eu

6.             Contact Us 

There are several ways how you can contact t us: by phone, e-mail, via the Website’s contact form or via social media accounts. We review and reply to all messages by ourselves. If you contact us, we can process the following personal data: name, surname, e-mail address, phone number, date, your nickname used in social media networks, and text of messages.

Such data will be processed in order to answer your questions. If you do not provide your contact details, we will not be able to contact you.

Electronic messages will be stored for 1 (one) year as of the receipt of the message for the purpose of defending the legal requirements of the Company. For this purpose, we process correspondence and related personal data in pursuit of the legitimate interest of the Company (protection of legal claims). 

All personal data provided by you in the course of communication with us will be used only for the aforementioned purposes and to review messages and administer and manage the communication flows. We undertake not to use your personal data without your express consent in any publications in such a way that would allow identifying you.

Please note that we may have to contact you by post, e-mail or phone. Please notify us of any changes of your personal data.

7.             Social Media

Currently, we have the following account on social media: 

- the account Spa Europe – hot tub and sauna manufacturer on social network Facebook (privacy notice of this social network is made available at https://www.facebook.com/privacy/explanation); 

The information you provide to us on social media (including messages, the use of the Like and Follow fields, and other communications) is controlled by the social network manager. We recommend reading the privacy statements of third parties and contact service providers directly if you have any questions about the ways they use your personal data. 

We process the information contained in our account for the purpose of administering the account with your consent. We do not store this information separately for this purpose.

8.              Transfers of personal data to third countries 

Data controllers of social media network Facebook are established in third countries that are not recognised by the European Commission as providing adequate level of protection (no adequacy decision has been adopted). 

Data of the data subjects situated in the European Union are processed by the data controller Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland). Information on how you can exercise your rights as a data subject can be found at https://en-en.facebook.com/privacy/explanation/ and help.instagram.com/519522125107875/?helpref=uf_share. In the event of a complaint about Meta Platforms Ireland Limited's processing of your personal data or the exercise (non-exercise) of your rights as a data subject, you have the right to complain to Meta Platforms Ireland Limited's supervisory authority, the Irish Data Protection Commission or the State Data Protection Inspectorate.

9.              Participation in the Selections

For the purpose of candidate selection (handling applications, evaluation of the candidates) the Company processes the following personal data of the candidates: name, surname, current workplace and position, email address, phone number, desired job position, data of receipt of application, education, qualifications, work experience, other information provided in the resume / recommendation / motivational letter, the desired salary. The processing of this information is based on the consent of the applicant expressed by submitting his application to the Company. 

Based on our legitimate interest to select best applicant, we can contact your previous employers in order to verify information about your qualifications, professional abilities and subject characteristics (for example, work results, relationships with clients and/or colleagues, your work evaluation, etc.). Your current employer can be contacted only after receipt of your specific consent (which can be withdrawn anytime by contacting us via email provided in this Privacy Policy). Based on our legitimate to select the best applicant, we can also collect information from your public profiles on the professional social networks.

Based on our legitimate interest, we will process the data on the person indicated by the candidate (name, surname, e-mail, telephone, information provided by the person) - former or current employer or person providing the recommendation, the information provided by him / her for the purpose of selection. We will erase this data at the end of the selection.

Personal data is stored until the completion of the particular selection process and erased within 3 working days after the completion of the selection procedure. In the event a separate consent of the candidate is received, the personal data is stored for 3 years from the receipt of the consent in order to offer the candidate to participate in the future candidate selections.

10.           Performance of Agreements to which the Company is a party

The Company processes personal data of employees of its suppliers or service providers or other partners (legal persons) and data of suppliers, service providers, or other partners (natural persons) in order to perform the agreement concluded between the Company and its suppliers, service providers, or other partners. The following personal data of employees of the aforementioned persons are processed: name, surname, position, employer, communication data and any other data related to the performance of the agreement. The following personal data of the suppliers, service provider, or any other partners are processed: name, surname, date of birth or personal identification code, address, bank account number, any other information related to the performance of the agreement.

The basis for the processing of data of employees of service providers, suppliers or other partners of the Company is the legitimate interest of the Company (Article 6 (1) (f) of the GDPR). We receive your data not only directly from you (data subject), but also from the customer, service provider or supplier you are an employee of.

If you provide services or sell goods as a natural person, the Company will process your personal data on the basis of performance of the agreement (Article 6 (1) (b) of the GDPR).

Personal data indicated in this section will be processed as long as the agreement is in effect. If personal data are indicated in the agreement, they will be stored for 10 years as of the date of expiration of the agreement. We will also process these personal data when they are specified in the agreements and its enforcement documents for the purpose of archiving, fulfilling the legal obligation provided for in the Index of Terms of Retention of General Documents approved by the Archivist of the Republic of Lithuania in 2011 March 9 by order No. V-100, 10.37 clause. For this purpose, we will keep the contract and its execution documents for 10 years from the date of conclusion or expiry of the contract (if the contract is of an ongoing nature). We will store personal data for the same number of years for the purpose and basis of the Company’s legitimate interest in defending legal claims. In the latter case, the recipients of your personal data may be courts, state institutions resolving disputes, parties to a dispute, lawyers and other entities providing legal services, depending on which remedies you (data subject) or the Company choose.

11.           Protection of Confidential Information of the Company and Business Continuity of the Company

In order to ensure the protection of the confidential information of the Company, the continuity of the Company's business, to protect information systems from hacking and data theft, viruses, dangerous websites, malware, copyright infringement through technical and Internet access and computer network from heavy loads, the Company can view its employees' correspondence with any correspondence counterparties and information stored in any electronic equipment of the Company. To achieve these goals, the Company processes the following personal data of its employees and persons who send or receive emails from employees: e-mail address, name, surname, date of the sender or recipient, content of information contained in electronic work tools.

Data collected for the protection of confidential information and information systems of the Company against intrusion and data theft, viruses, dangerous websites, malware, copyright infringement through technical and Internet access and computer network from heavy loads are stored for the purpose of defending legal requirements for 4 years, taking into account the provisions established in Paragraph 9 of Article 1.125 of the Civil Code of the Republic of Lithuania. In order to defend legal claims, data may be provided to data recipients (data controllers) such as courts, law enforcement authorities, public dispute resolution authorities, parties to a dispute, lawyers and other entities providing legal services.

In cases when the employee's employment contract with the Company expires, the content of the employee's e-mail box is available for the Company for 1 month from the end of the employment relationship for the purposes of business continuity, the e-mail box is deleted after this period.

12.           Protection of rights and legitimate interests of the Company (exercise of rights in courts or other dispute resolution bodies)

On the basis of its legitimate interest to exercise its rights, including in the events of civil disputes in courts, the Company processes the names, surnames, personal codes, case circumstances, other information related to the case, publicly available information of the persons involved in the case or their employees. The data may be transferred to law enforcement authorities, lawyers or bailiffs performing recovery. Data is destroyed 1 year after the final resolution of the case and full satisfaction / enforcement of the Company's claims (if the claims are satisfied)

13.           Cookies 

Cookies are used on the Website. A cookie is a small text file in alphanumeric format that we place with your consent on your browser or hard disk. We use different cookies for different purposes. Cookies also help us to differentiate you from other users of the Website, thus providing a more pleasant experience of using the Website and allowing us to improve the Website.

Most browsers allow you to reject all cookies, and some browsers allow you to reject only third-party cookies. So you can take advantage of these opportunities. However, please note that blocking all cookies will have a negative effect on the use of the Website, and without cookies you will not be able to use all the services provided on the Website. More information is available at AllAboutCookies.org or www.google.com/privacy_ads.html.

We use the cookies described below, for a detailed list of which you will find HERE[A1] .

(a) Absolutely necessary cookies.

These cookies are necessary for the Website to work. The basis for the use of such cookies is Paragraph 4 of Article 73 of the Law on Electronic Communications of the Republic of Lithuania. These cookies are necessary for the operation of the Website and cannot be disabled on our systems. We ensure the quality and security of the visit. These can be cookies, which, for example, saves your shopping cart when you browse through different pages of the Website.

(b) Analytical and / or performance cookies.

These cookies allow us to identify and count visitors to the Website and to track how visitors navigate our Website. This helps us improve the performance of the Website, such as ensuring that users can easily find what they are looking for. Cookies are not intended to identify or influence your browsing experience while you are visiting the Website. If you do not agree to the use of these cookies, you will not be recorded in the visit statistics. The basis for the processing of the data collected by these cookies is your consent.

(c) Functional cookies.

These cookies are used to identify you when you return to our website so that we can tailor the content provided to your needs, remember the information relevant to you. The basis for the processing of the data collected by these cookies is your consent.

(d) Commercial cookies.

We use our own and third-party cookies to display personalized advertising on our own and other websites. This is called "remarketing," which is based on browsing activity, such as the products you search for and view.

Facebook icon plugin is used on the Website.

14.           Disclosure of Data

We can disclose information about you to our employees, service providers such as debt administration or recovery companies, persons or subcontractors providing marketing, IT, or any other services if it is reasonably required for the respective purposes, as indicated in this Privacy Policy.

Furthermore, we can disclose information about you: 

●               if we must do this under the law;

●               in order to sell a part of the Company’s activities or assets, where we disclose your personal data to the potential buyer of the activities or a part thereof;

●               having sold the activities of the Company or a substantial part thereof to third parties. 

Except in cases provided in this Privacy Policy, we do not transfer your personal data to any third parties. 

Please note that the list of recipients and categories of recipients provided in the Privacy Policy may change; other recipients of your personal data may appear during the processing of your personal data, including intermediaries, marketing service and (or) IT service providers or subcontractors. Also, if you wish to be notified of any changes to the recipients of your personal data, please inform us via e-mail provided in this Privacy Policy indicating in the e-mail as follows: “I wish to receive information on the changes to the recipients of my personal data, name, surname”. 

15.           Security of Your Personal Data

Your personal data will be processed pursuant to the requirements set forth in the General Data Protection Regulation, the Republic of Lithuania Law on Legal Protection of Personal Data and other legal acts. In the course of processing of your personal data, we implement organisational and technical measures that ensure the protection of personal data from accidental or unlawful destruction, alteration, disclosure and any other unlawful processing.

16.           Your Rights

This section contains information about your rights related to the processing of your personal data carried out by us and cases where you can exercise these rights. If you would like to receive more information on your rights or to exercise them, please contact us via e-mail indicated in this Privacy Policy.

The Company will provide information on actions taken on a request with regard to implementation of your rights without undue delay and in any event within 1 (one) month of receipt of the request. In consideration of the request complexity and the number of received requests, the aforementioned term may be extended for 2 (two) further months. In this case, we will notify you of such term extension and reasons for it within 1 (one) month as of the receipt of request. The Company will refuse to implement your rights only in cases provided for in the legal acts.

16.1.       Right to Withdraw Consent

If you have given us your explicit consent to the processing of your data, you can withdraw it at any time. Withdrawal of consent shall not affect the lawfulness of the processing of data carried out prior to the withdrawal of consent.

16.2.       Right of Access to Your Personal Data

We want you to fully understand how we use your personal data and not to experience any inconvenience because of that. You can contact us at any time and ask if we process any of your personal data. If we store or use your personal data in any way, you have the right to access them. If you wish to do this, please submit a written request to us at the address indicated in this Privacy Policy and confirm your identity. Please comply to the fairness and reasonableness principles when submitting such request. 

16.3.       Right to Request More Information

We hope that you will understand that it is very difficult to discuss all possible methods of collection and use of personal data. We try to provide as explicit and comprehensive information as possible and undertake to update this Privacy Policy if there are any changes to the personal data use process. Nevertheless, if you have any questions about the use of your personal data, we will be happy to answer them or will provide you with all additional information that we can disclose. If you have any specific questions or did not understand the provided information, please contact us.

16.4.       Additional Rights

Below, you will find information about your additional rights that you can exercise in compliance with the following procedure.

(a)          You have the right to request us to rectify any inaccuracies of data held by us. In this case, we may ask you to confirm the rectified information.

(b)          You have the right to ask us to erase your personal data. This right will be implemented in cases provided in Article 17 of the General Data Protection Regulation (EU) 2016/679.

(c)          You have the right to ask us to restrict the processing of your personal data or to object to their processing:

●           during the period required for us to verify the accuracy of your personal data when you submit claims with regard to data accuracy;

●           in cases of unlawful collection, storage or use of your personal data where you decide not to request the erasure of data;

●           when we do not need your personal data anymore, but you need them for the establishment, exercise or defence of legal claims;

●           during the period required to determine if we have an overriding legal basis to continue processing your personal data if you exercise your right to object to the processing of your personal data.

(d)   You have the right to the portability of data that is processed by automated means and that we have received from you in a structured, commonly used and computer-readable format under your consent or for the purpose of agreement conclusion. If you exercise this right, we will transfer a copy of the data provided by you to you or the data controller of your choice.

(e)          You have the right to object to use of your personal data by us:

●           in cases where we use such data in order to implement our legitimate interests, but we do not have an overriding legal basis to continue using your personal data; or

●           at any time when we use your personal data for direct marketing purposes. In such case, the data will not be used for these purposes anymore; however, they may be used for other legitimate purposes.

17.           Complaints

If you believe that your (as data subject’s) rights have been and/or may be violated, please promptly contact us via e-mail indicated in this Privacy Policy. We ensure that as soon as we receive your complaint, we will contact you within the reasonable period and inform you about the complaint handling process, and then about its result.

If the handling results are unsatisfactory to you, you will be able to submit a claim to the supervisory authority – the State Data Protection Inspectorate (L. Sapiegos str. 17, Vilnius, www.vdai.lrv.lt, phones (8 5) 271 28 04, 279 1445).

18.           Liability

You are responsible for the accuracy, correctness and completeness of your data submitted to us. In case of any changes to the data submitted by you, you must promptly notify us about that by e-mail. We will in no way be responsible for the damage incurred by you due to the provision of inaccurate or incomplete personal data or failure to notify us about changes to them.

19.           Amendments to the Privacy Policy

We may update or amend this Privacy Policy at any time. Such updated or amended Privacy Policy will come into effect as of its publication on our Website.

After making an update to the Privacy Policy, we will notify you about any changes that we consider material by publishing them on the Website. Updated on’ date indicated below shows the date of the latest update to the Privacy Policy.

The latest update to the Privacy Policy was made on [2023-01-25].