We care about personal data we process and compliance with legal provisions regarding the protection of personal data
is very important to us. We would like to notify you of our principles for collecting, processing, securing,
transferring and using personal data and inform you who you can turn to in matters related to personal data.
In accordance with the requirements of the 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), hereinafter referred
to as the “Regulation”, we inform as follows:
Personal Data Administrator
The Personal Data Administrator, hereinafter referred to as the “Administrator”, is:
Rose Lerer Cohen PhD.
The Administrator is responsible for the use of personal data in a safe manner, consistent with the purposes for
which it was collected and in accordance with the applicable law.
Contact with the Administrator – e-mail:
citizenoflithuania@gmail.com or
info@citizenoflithuania.com.
General Provisions
We use the personal data collected only for specific, legitimate purposes for which this data was collected.
The main purpose of personal data
processing is conclusion of the contract with the data subject to provide the data subject with the
consultancy, research, legal services seeking to reinstate the citizenship of Lithuania to data subject and his
minor children (if applicable).
The scope of personal data:
- your name, surname, birth date, sex, citizenship, place of birth, place of living, telephone number, email, data
about your marriage (all data in your marriage certificate), all data in the documents provided to
Administrator; - data about your parents (name, surname, birth date, birth place, citizenship, death data, marriage data, other
data required for the main purpose), all data in the documents provided to Administrator; - data about your ancestors (name, surname, birth date, birth place, citizenship, travel data, naturalization,
marriage data, death data, other data required for the main purpose), all data in the documents provided to
Administrator.
NOTE: data of data subjects who are deceased is not secured under the REGULATION (EU) 2016/679.
The purpose of data processing by the Administrator, the legal basis for processing and the storage
period:
- The purpose for data processing: Take action at the request of the data subject before
concluding a contract (e.g. preparing an offer).
Legal basis for processing: Article 6(1)(b) of the Regulation (“the performance of a contract”)
Storage period: The data is stored for the period necessary to complete, terminate or expire a contract
and for the period after which any legal claims may expire. - The purpose for data processing: The conclusion and performance of a contract with data subject
and his/her minor children (if applicable) (including providing appropriate quality of
services)
Legal basis for processing: Article 6(1)(b) of the Regulation (“the performance of a contract”)
Storage period: The data is stored for the period necessary to complete, terminate or expire a contract
and any settlements and for the period after which any legal claims may expire.NOTE: The data of minor children is processed only with the expressed consent of parent. In case
the consent is not issued, the data of children will not be processed.
NOTE: by signing the contract the data subject confirms that he has received consent
from his relatives to use and disclose the personal data of relatives to Administrator seeking the
main purpose set out in these Terms and conditions. - The purpose for data processing: Conducting direct marketing (directing messages to carefully
selected individual clients, in individual contact in order to obtain a direct response (reply))
Legal basis for processing: Article 6 (1)(f) of the Regulation (“legitimate interests pursued by the
Administrator”)
Storage period: The data is stored for the duration of the legitimate interest pursued by the Administrator and
for the period after which any legal claims may expire. In the event of an effective opposition to the use of
the data subject’s personal data, the Administrator will no longer process this data for direct marketing
purposes. - The purpose for data processing: Conducting marketing
Legal basis for processing: Article 6 (1)(a) of the Regulation (“the data subject’s consent”)
Storage period: The data is stored until the data subject withdraws the consent for further processing of their
data for marketing purposes.
(e) The purpose for data processing: Issuing, collecting and storing invoices and accounting documents
as well as keeping accounting books
legal basis for processing: Article 6 (1)(c) of the Regulation (“compliance with a legal obligation”) in
relation to Accounting Act, Personal Income Tax Act and Tax Administration Act.
Storage period: The data is stored for the period in which the provisions order the keeping of accounting books
and accounting documents (i.e. for 5 years, counting from the beginning of the year following the fiscal year to
which the data pertains) and for the period after which any tax liabilities may expire. - The purpose for data processing: Responding to complaints within the period of time and in the form
provided for by law
legal basis for processing: Article 6(1)(c) of the Regulation (“compliance with a legal obligation”)
Storage period: The data is stored for the duration of 1 year after the end of the warranty period or settlement
of the complaint, and then for the period after which any legal claims may expire. - The purpose for data processing: Expression of the opinion by the Client
legal basis for processing: Article 6 (1)(a) of the Regulation (“the data subject’s consent”)
Storage period: The data is stored until the data subject withdraws the consent for further processing of their
data for this purpose. - The purpose for data processing: Detection and prevention of misuse
legal basis for processing: Article 6(1)(c) of the Regulation (“compliance with a legal obligation”)
Storage period: The data is stored for the duration of a contract, and then for the period after which the
claims resulting from the contract expire. If the Administrator pursues claims or notifies competent authorities
– for the duration of such proceedings and “for 5 years from the beginning of the year following the fiscal year
in which operations, transactions and proceedings were finally finished, paid off, settled or expired”. - The purpose for data processing: Specifying, defending and pursuing claims raised by or against the
Administrator (including the sale of debt to another entity)
legal basis for processing: Article 6 (1)(f) of the Regulation (“legitimate interests pursued by the
Administrator”) in relation to Accounting Act.
Storage period: The data is stored
- for the period after which the claims resulting from a contract expire,
- if the Administrator pursues such claims in civil proceedings or in criminal or tax proceedings, the accounting proofs (which may contain personal data) must be kept “for 5 years from the beginning of the year following the fiscal year in which operations, transactions and proceedings were finally finished, paid off, settled or expired”,
- for the period in which the Administrator may incur legal consequences of non-compliance, e.g. be fined with an administrative penalty.
Data recipients
In order to perform a contract with data subject and to ensure the proper functioning of the Administrator’s website, he uses the services of third parties cooperating with him. Personal data is transferred to third parties only if and to the extent that makes it necessary to achieve the purpose of processing. Personal data provided to third parties may be used only for the purpose of the task ordered by the Administrator.
Personal data may be provided to the following recipients cooperating with the Administrator:
- governmental institutions of Lithuania – archives, Migration department under the ministry of interiors, Ministry of interior, Tax inspectorate;
- entities conducting translation, postal, courier and similar activities (e.g. courier brokers) – to the extent necessary to carry out ordered services to data subject, like translation of the documents, delivery of correspondence;
- selected entities acting on behalf of the Administrator when handling accounting, tax, advisory, legal matters – to the extent necessary to carry out a specific purpose of processing, and to carry out ordered services to data subject;
- entities providing technical assistance services provided to the Administrator and IT solution providers enabling the Administrator to operate (for example, software, e-mail and hosting providers) – the Administrator provides personal data to the trusted provider acting on his behalf only in the case and to the extent necessary to carry out a specific purpose of processing;
- providers of solutions which serve the purpose of expressing/publishing client opinions – to the extent necessary to express such opinions.
Transferring data outside the EEA
Personal data may be transferred outside the European Economic Area (including the European Union, Iceland, Liechtenstein and Norway) to Administrator, who is acting in Israel.
The rights of the data subject
- The processing of personal data does not require any consent if, among other things: the processing is necessary to perform a contract, or take actions before a contract is concluded, results from a legal obligation of the Administrator or is necessary to carry out the legitimate interest of the Administrator. If the consent is necessary to be able to process personal data for a specific purpose, the Administrator asks for such consent. The consent given can be withdrawn at any time.
- In the event of withdrawal of consent, the data will no longer be processed to the extent that the consent was granted, but the withdrawal of the consent will not affect the lawfulness of the processing, which was made on the basis of consent before its withdrawal.
- Pursuant to the principles set out in the Regulation, the data subject also has the right: to demand from the Administrator access to the personal data relating to them, rectify it, delete it (“to be forgotten”) or limit its processing, to object to the processing, as well as to transfer such data.
- If personal data is processed for direct marketing purposes, one can object at any time to the processing of this data for marketing purposes, including profiling, to the extent to which the processing is related to direct marketing.
- In order to perform the above rights, an application should be submitted to the Administrator by e-mail, letter or in person at the Administrator’s office; Administrator’s contact details can be found above. To make sure that the person submitting the application is entitled to submit it, the Administrator may ask for additional information confirming the identity of the person submitting.
- The provisions of the Regulation indicate to what extent each of these rights can be used. This will depend in particular on the legal basis and purpose of personal data processing by the Administrator. The above rights can be used free of charge not often than once per 12 months. In accordance with Article 12 of the Regulation, if the data subject’s demands are manifestly unjustified or excessive, in particular because of its continuing nature, the Administrator may charge a fee.
- The data subject has the right to lodge a complaint with the governmental supervisory body of the country where the data is processed.
Obligation or no obligation to provide personal data
Using the Administrator’s services and providing personal data to him is voluntary. However, the data subject is obliged to provide the data in connection with:
- concluding a contract with the Administrator – in this case, providing personal data is a contractual condition and the data subject is obliged to provide the required data if they want to conclude a contract with the Administrator. Each time, the extent of data required to conclude a contract is communicated to the data subject. Failure to provide this data results in failure to conclude such contract.
- implementing the obligations arising from the provisions of law on the Administrator – in this case, providing personal data is a statutory condition resulting from the provisions imposing on the Administrator the obligation to process personal data (e.g. in connection with the obligation to issue, collect and store invoices and accounting documents and keep accounting books). Failure to provide this data will prevent the Administrator from performing the indicated obligations, which will result in failure to conclude a contract.
Automated decision-making and profiling
Personal data will not be used for automated decision-making that will cause legal effects for the data subject, including for profiling.
Final Provisions
Administrator’s websites may contain links to other websites. Such websites operate independently of the Administrator and are not supervised by the Administrator in any way. The Administrator recommends reading privacy policies after going to other websites. The Administrator is not responsible for the principles of data handling on these websites.
Payments
We charge and collect payments in advance for the stamp duties required to pay on behalf of the client
Payment for our services rendered is to be made within 15 days from the date of invoice to the client.
Payments are non-refundable and we do not offer refunds or credits for partial months, quarters or years of service.
All prices quoted are exclusive of all taxes and duties imposed by taxing authorities where-ever they are located and the client is responsible for payments of all such taxes and duties.
The information about the fees for our services shall be presented to the client before the conclusion of the contract.