PRIVACY POLICY

PRIVACY POLICY OF THE MB “AKROBATIKOS NAMAI” WEBSITE www.poleflame.lt

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1. ABOUT

1.1. This Privacy Policy sets out the conditions for the processing of personal data of visitors to the website www.poleflame.lt and other data subjects by MB “Akrobatikos namai”, legal entity code 304989956, registered office address Jurgio Matulaičio Sq. 11-69, LT-05111 Vilnius, email address info@poleflame.lt (hereinafter also referred to as the “Controller” or “we”). The effective date of the current version of this Privacy Policy is indicated at the top of this webpage.

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1.2. When processing personal data, we will comply with the requirements of applicable legislation; we will process personal data lawfully, fairly and transparently, for clearly defined and legitimate purposes; we will seek to ensure that inaccurate personal data is, where necessary, corrected, supplemented and, in the cases provided for, erased; we will store personal data only for as long and in such a form that the identity of the data subject can be determined no longer than is necessary for the purposes for which the data is collected, processed and stored; and we will apply appropriate technical and organisational security measures.

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1.3. The website contains links to third-party websites that are not managed by the Controller and are not used for the provision of the Controller’s services, such as partner or informational websites. The Controller is not responsible for the privacy policies applied by such third parties, their personal data processing activities, or the consequences thereof. We recommend that in each case you independently review the privacy policies and personal data processing terms of third-party websites.

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1.4. The website may also contain links to external registration or enquiry tools, such as Google Forms, shortened links, such as bit.ly, as well as to the registration and membership administration system used by the Controller, operating on the Wix platform, such as the client area or the Spaces by Wix mobile application, through which your personal data is collected on our behalf as the data controller. In such cases, personal data is processed in accordance with this Privacy Policy, while the providers of external tools act as our service providers / data processors, as referred to in clauses 2.9 and 3.1, with their privacy policies also applying additionally in respect of the processing of technical data, such as IP address and cookies.

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2. PERSONAL DATA PROCESSED AND PURPOSES OF DATA PROCESSING

2.1. Submission of enquiries regarding services. The Controller processes data provided by a visitor through the contact form, for example via https://www.poleflame.lt/kontaktai. Such data includes, or may include, name and surname, email address, telephone number and the content of the message. The data is processed so that the Controller can respond to the submitted enquiry and provide information about the project regarding which the enquiry was made. Legal basis: steps prior to entering into a contract / Article 6(1)(b) of the GDPR — processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.

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2.2. Administration of pre-contractual relations. If communication with the client continues after the submission of an enquiry regarding the purchase of services, the Controller may additionally receive and process data necessary for the provision of the service. The data processed includes name, surname, email address, telephone number, and the content of messages or correspondence. Such data may also be processed for the purpose of properly maintaining accounting records, for example issuing and storing invoices. Legal basis: conclusion and performance of a contract / Article 6(1)(b) of the GDPR; compliance with legal obligations, accounting / Article 6(1)(c) of the GDPR.

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2.3. Website traffic analysis and content improvement. In order to understand which sections of the website are of greatest interest to visitors, the Controller analyses the visitor’s IP address, the type of device and browser used, browsing duration, pages viewed, referral traffic source and similar data. Such data is collected using Google Analytics and other statistical tools. Analytical cookies are placed on the visitor’s device only after receiving their consent through the cookie management tool. Legal basis: legitimate interest / Article 6(1)(f) of the GDPR and/or consent / Article 6(1)(a) of the GDPR, depending on the configuration of the tools used and the selected cookie management mode. The data helps the Controller assess the functionality of the website, optimise content and improve the user experience. More information about the use of cookies is provided in the section of this Privacy Policy entitled “What cookies are used on this website?”

 

2.4. Public communication of activities. The Controller publishes information about its activities, including the services offered, cooperation with clients and partners, client reviews and visual material, such as photographs and videos, which may contain personal data. The data processed may include name, surname, image, statements or opinions about the services. This information may be published on the website, social media accounts or other publicly accessible communication channels. Legal basis: consent of the data subject / Article 6(1)(a) of the GDPR or legitimate interest / Article 6(1)(f) of the GDPR, where publication is necessary in order to substantiate the Controller’s reputation and transparently inform the public or clients about the services provided. Data subjects: employees, clients, buyers and partners.

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2.5. Conclusion and performance of contracts with clients and partners. The Controller processes the personal data of clients, service providers and freelance specialists necessary for the conclusion and performance of contracts and the administration of mutual obligations. The data processed may include name, surname, email address, telephone number, company representation data, invoice details, place of service provision, communication content and signed documents. Legal basis: conclusion and performance of a contract / Article 6(1)(b) of the GDPR. Data subjects: clients, consultants, service providers and suppliers of goods.

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2.6. Recruitment and selection of personnel. The Controller processes personal data of job candidates received on the basis of job advertisements, cover letters, CVs or other submitted documents. The data processed includes name, surname, contact details, information about education, work experience, language skills, references, salary expectations, place of residence and other information related to the job offer. During the selection process, correspondence or interview content may also be processed. Legal basis: consent of the data subject / Article 6(1)(a) of the GDPR; steps prior to entering into an employment contract / Article 6(1)(b) of the GDPR; compliance with legal obligations, such as documenting employment conditions and formalising the employment contract / Article 6(1)(c) of the GDPR. Data subjects: job candidates.

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2.7. Direct marketing. The Controller analyses the behaviour of website visitors in order to assess advertising effectiveness, create audiences and display personalised offers through third-party platforms, such as Google Ads, Meta/Facebook Pixel and LinkedIn Ads. The data processed may include the visitor’s IP address, geographical location, browser type and version, operating system, referral source, visit duration, page views, browsing path and frequency. This data is obtained using marketing cookies and tracking tools, which are placed on the visitor’s device only after receiving their consent through the cookie management tool. This data is processed on the basis of consent, for the purpose of creating audiences based on user behaviour on the website, displaying personalised advertising on third-party websites or social networks, and improving campaign targeting and content. Legal basis: consent / Article 6(1)(a) of the GDPR. More information about the use of cookies is provided in the section of this Privacy Policy entitled “What cookies are used on this website?”

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2.8. Registration for training sessions, events and memberships through external forms. In order to administer registrations for training sessions, events, memberships or other activities, the Controller may collect personal data through external online forms and registration systems to which users are redirected from the website or social media accounts, for example Google Forms, the Wix platform registration and membership system used by the Controller, and the Spaces by Wix mobile application. The data processed may include name, surname, email address, telephone number, selected membership type or class, participation periods, payment information, where applicable, and other information voluntarily provided by the person in the registration form or account settings. This data is processed in order to accept and administer registrations, conclude and perform contracts for membership or participation in classes, communicate about class times, schedules or changes, administer payments and maintain accounting records. Legal basis: conclusion and performance of a contract / Article 6(1)(b) of the GDPR, as well as the Controller’s legitimate interest in effectively organising and administering activities / Article 6(1)(f) of the GDPR, where registration is not yet considered the beginning of a contractual relationship, such as a waiting list or preliminary registration. For this purpose, data may be collected through systems of service providers engaged by the Controller, such as the Wix platform or Google Forms, while certain technical data, such as IP address and cookie identifiers, may be processed in accordance with the privacy policies of those service providers.

In addition to the data already listed, when using the Wix platform membership and registration system and the Spaces by Wix mobile application, additional user account data may be processed, such as profile photo, language preferences, time zone and account settings, as well as contact details where provided, participant activity data, including registration and cancellation history, information about attended classes, booking changes, membership plan information, upcoming bookings, purchase history and the history of actions performed on the platform, such as submitting a booking or ticking acceptance of the terms of service. Certain technical data, such as IP address, device type, operating system, app version or location data, where permission has been granted, may be automatically collected by the platform provider in accordance with its privacy policy.

Payments are processed through Wix Payments. The payment service provider processes the data necessary for payment execution in accordance with its own privacy policy. The Controller does not access or process full payment card details. The Controller can see only limited payment data in the system, such as name, surname, card type and the last four digits of the card number.

The coaches or teachers engaged by the Controller to conduct classes use the Wix Owner application for activity administration, which is not accessible to clients. Coaches/teachers act as persons authorised by the Controller and may see only as much participant data as is necessary to organise and provide a specific class. They may have access to the participant’s name and surname, email address, telephone number if provided, profile photo if uploaded, membership status, upcoming bookings, participation history and the selected class level. This data is used only to confirm or cancel a class, prepare for the class according to the number and level of participants, record attendance and ensure proper provision of the service. Coaches/teachers do not use this data for any other purposes, do not copy it, do not store it separately and do not transfer it to third parties, and access it only in accordance with the procedure established by the Controller.

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2.9. In addition to the purposes specified in this Policy, the Controller may also process personal data where this is necessary in order to comply with legal obligations applicable to us, for example under accounting, tax or consumer protection legislation. Legal basis: compliance with a legal obligation / Article 6(1)(c) and (d) of the GDPR.

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3. DATA RECIPIENTS AND THIRD PARTIES

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3.1. The Controller may transfer your personal data to service providers engaged by us to the extent necessary for the provision of specific services. Such service providers may include, for example, website hosting providers, content management tool providers, server maintenance service providers, email and newsletter sending platform providers, courier services and other partners necessary for our activities, including providers of online forms, registration and client area platforms, such as the platform provided by Wix.com Ltd. and the Spaces by Wix mobile application, as well as shortened link management services, such as bit.ly. In all cases, we take the necessary measures to ensure that the data processors engaged by us provide appropriate protection of personal data, maintain confidentiality and apply technical and organisational security measures compliant with the GDPR.

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3.2. In certain cases, data may also be disclosed where this is necessary in order to comply with legal obligations applicable to us, for example accounting, tax or consumer rights protection requirements, as well as where necessary to protect your vital interests or those of other natural persons, or to establish, exercise or defend legal claims.

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3.3. Our marketing and sales team, responsible for improving content quality, adapting services and optimising marketing decisions, has access to statistical data about website visitors or newsletter sending analytics. For this purpose, information is collected about how many visitors accessed the website, what information was most relevant to them, which browsers and devices they used, what content they read most frequently and from which regions they connected. Such data is collected on the basis of our legitimate interest in improving the functionality of the website and the user experience.

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3.4. For statistical analysis purposes, we use third-party tools such as Google Analytics, provided by Google Inc. in the USA. This company has committed to applying data protection measures that comply with EU legal requirements. More information about Google’s data processing terms can be found here. Any visitor may also disable Google Analytics data collection by using this tool.

 

4. WHAT COOKIES ARE USED ON THIS WEBSITE?

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4.1. Cookies are small text files stored on the user’s device when they visit a website. Cookies allow the website to recognise the user’s device, save their settings, analyse traffic and ensure functionality.

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4.2. Cookies help improve the browsing experience, adapt content to the user, ensure the technical operation of the website, and carry out analytical and marketing activities.

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4.3. Our websites may use the following types of cookies:

Strictly necessary cookies — ensure the operation of basic functions, such as login or website security. They are used without prior consent.

Functional cookies — allow the website to remember the user’s choices, such as language or region.

Statistical cookies — help us understand how users interact with the website by collecting anonymous information.

Marketing cookies — are used to track visitor behaviour and provide personalised advertising or content on other platforms.

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4.4. The website may also use third-party cookies placed by service providers such as Google Inc., Meta Platforms Inc. or others. These cookies may be used for analytics and marketing purposes.

 

4.5. Information about the use of cookies by these parties and their privacy provisions can be found on the websites of the respective service providers.

 

4.6. Where information collected through cookies is transferred outside the European Economic Area, we ensure appropriate safeguards, for example by transferring data to countries recognised as providing an adequate level of data protection or by using the standard contractual clauses approved by the European Commission.

 

4.7. Legal basis for the use of cookies:

 

4.7.1. Strictly necessary cookies are used on the basis of our legitimate interest / Article 6(1)(f) of the GDPR, ensuring the operation and security of the website.

 

4.7.2. All other cookies, including functional, statistical and marketing cookies, are placed only after receiving your explicit and informed consent / Article 6(1)(a) of the GDPR.

 

4.7.3. Consent is obtained through the cookie management notice displayed when the website is opened.

 

4.8. How can you manage cookies? When you open the website, you are given the option to accept all cookies, select specific categories or reject non-essential cookies. You can change your choices or withdraw your consent at any time through the cookie settings management tool available in the website footer. You can also delete or block cookies in your browser settings. Please note that this may affect the functionality of the website.

 

4.9. The validity period of each cookie depends on its nature: some cookies are valid only during the session, while others may be stored on your device for a longer period, for example one year.

 

4.10. Cookies used on the website: https://support.wix.com/en/article/cookies-and-your-wix-site

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5. DATA RETENTION PERIOD

 

5.1. Data submitted through contact forms on the website or by email, where the data subject does not give consent to receive marketing information, is stored for no longer than 1 year from the last contact. If the person later enters into a contract or gives consent for marketing, the data is stored accordingly in accordance with clauses 5.2 or 5.4 of this Policy.

 

5.2. Personal data of data subjects, including representatives of natural and legal persons, collected for the purpose of performing contracts with clients and partners, is stored for 10 years after the end of contractual obligations, in accordance with the document retention index approved by the Chief Archivist of Lithuania.

 

5.3. Personal data contained in sales documents for goods or services and in accounting records is stored for 10 years from the date of the financial transaction or performance of the contract.

 

5.4. Data of newsletter subscribers, such as email addresses, is stored for 3 years from the receipt of consent or for a shorter period if the person unsubscribes from newsletters or withdraws consent earlier. After the expiry of the retention period and in the absence of renewed consent, the data is deleted.

 

5.5. Personal data obtained with consent for public communication of activities, such as reviews, photographs or videos, is stored for the period specified in the consent. If the consent does not specify otherwise, the data is stored for as long as it is relevant for the purpose of public communication of activities, but no longer than until the person withdraws consent or requests deletion of the data, unless there is a legal basis to continue storage for a longer period, for example for the implementation of legal claims or dispute resolution.

 

5.6. Data of job candidates is stored only for as long as the selection process is ongoing. If a candidate gives consent to store the data for longer, it is stored for up to 6 months from the receipt of consent.

 

5.7. Website statistics and analytics data, for example through Google Analytics or other tools, is stored for up to 2 years and thereafter only in aggregated, anonymised form.

 

5.8. Cookie validity periods depend on their type, purpose and provider settings. Some cookies are valid only during the browsing session and are deleted when the browser is closed, while others may be stored on the user’s device for a longer period, from several months to several years. Specific validity periods are indicated in the cookie table referred to in clause 4.10 of this Privacy Policy.

 

5.9. The fact of the data subject’s consent, the date of withdrawal and related evidence are stored for 2 years from the withdrawal of consent or from the end of the retention period of the related data. If such evidence is necessary for a dispute or investigation, it may be stored for longer, until the purpose is achieved.

 

5.10. After the expiry of the specified retention periods, personal data is deleted or anonymised in such a way that the identity of the data subject can no longer be determined. In cases where legislation requires certain documents or records to be stored for a longer period, the data may be archived, ensuring restricted access and use only for the purposes established by law, such as accounting, tax or legal claims. Archived data is not used for active operations or marketing and is stored using appropriate technical and organisational security measures.

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6. SOCIAL NETWORKS

 

6.1. The website may contain links to the Controller’s social media accounts on platforms such as Facebook, Instagram and YouTube. You can familiarise yourself with the data protection principles of each platform in the respective platform’s privacy policy. We recommend reviewing their privacy terms before interacting with these accounts.

 

6.2. We currently have and use the following social media accounts:

on Facebook — @Flame – pole dance namai, whose privacy policy can be found here;

on Instagram — @poledancevilnius, whose privacy policy can be found here;

on YouTube — channel @flamenamai, whose privacy policy can be found here.

 

6.3. We recommend familiarising yourself with the privacy policies of third parties and contacting the service providers directly if you have any questions about how they process your personal data.

 

7. VISITOR RIGHTS AND HOW TO EXERCISE THEM

 

7.1. By contacting the Controller by email at info@poleflame.lt, you may exercise the right to:

      7.1.1. access the personal data processed about you;

      7.1.2. request the correction of inaccurate or incomplete personal data;

      7.1.3. request the erasure of personal data, the “right to be forgotten”, where there is no legal basis for retaining it;

      7.1.4. object to the processing of personal data and withdraw consent where the data is processed on the basis of consent;

      7.1.5. request restriction of the processing of personal data in the following cases:

           7.1.5.1. where the data subject contests the accuracy of the data — for the period during which the accuracy of the data is verified;

           7.1.5.2. where the processing is unlawful, but the data subject does not agree to the deletion of the data;

           7.1.5.3. where the Controller no longer needs the data, but it is required by the data subject for the establishment, exercise or defence of legal claims;

           7.1.5.4. where the data subject has objected to processing based on legitimate interest — until such objection is assessed;

      7.1.6. receive a copy of the data you have provided and, where technically possible, transfer it to another data controller, the right to data portability.

 

7.2. If you believe that your personal data is processed in violation of applicable legislation, you have the right to lodge a complaint with the State Data Protection Inspectorate, L. Sapiegos g. 17, LT-10312 Vilnius, https://vdai.lrv.lt/. A complaint may also be lodged with any other supervisory authority of a European Union Member State in which your habitual residence or place of work is located, or where the alleged infringement occurred. Before submitting a complaint, we recommend that you first contact us by email at info@poleflame.lt.

 

7.3. The data subject may exercise their rights in accordance with the provisions of applicable European Union and Republic of Lithuania legislation, including the General Data Protection Regulation of 27 April 2016, GDPR.

 

7.4. The Controller will retain only such copies of personal data as are necessary in order to comply with legal obligations, for example under accounting or other legislation, fulfil obligations imposed by public authorities, establish, exercise or defend legal claims, protect the legitimate interests of third parties, resolve disputes or ensure the performance of agreements concluded between the data subject and the Controller.

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8. CHANGES TO THE PRIVACY POLICY

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8.1. This Privacy Policy may be updated periodically in order to reflect changes in our activities, legislation or data processing practices.

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8.2. All updates will be published on this website. We will inform you additionally about material changes, for example where the purposes of data processing, legal bases, rights of data subjects or similar matters change, by email or by another direct means, if we process your contact details.

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8.3. We recommend that you periodically review this Privacy Policy and familiarise yourself with any changes.

 

9. SUGGESTIONS AND CONTACTS

If you have any questions or suggestions, please contact us at info@poleflame.lt.

Details and contact information of MB “Akrobatikos namai”:

legal entity code: 304989956;

registered office address: Jurgio Matulaičio Sq. 11-69, LT-05111 Vilnius;

email address: info@poleflame.lt;

telephone number: +37062894969.