1) TIROLA, UAB
legal entity code: 302657873
Žalgirio str. 112A, Vilnius, Lithuania
Contact details of person responsible for data protection: phone +370652196340, e-mail firstname.lastname@example.org.
2) Facebook Int, the manager of social media platforms.
In certain data processing cases, we shall act jointly with the Platform Manager as joint controllers in accordance with Article 26 of the GDPR.
TIROLA, UAB (hereinafter referred to as “TIROLA”) shall manage the following accounts of social media networks:
2. Responsibility of Platform Managers
We can only exert limited influence over the data processing carried out by social media Platform Managers, such as the administration of members and the publication of information. Where we can influence and set the parameters of the data processing, we will, to the extent possible, ensure that the Manager of the social media platform processes the data in a privacy-friendly manner. However, in many places, we cannot influence the data processing carried out by the Manager of the social media platform and we do not know what data it processes.
The Platform Manager manages all IT infrastructure, sets its own data protection rules and maintains its own relationship with you as a user (if you are a registered user of a social media channel). In addition, the Manager is solely responsible for the details of your user account to which we have no access as a business.
3. Purpose and legal basis of data processing:
The purpose of our data processing on our accounts is to inform potential and existing customers about offers, products, services, news, and to interact with social media visitors on these topics answering their questions, positive feedback and criticism. The legal basis for this is Article 6(1)(1)(f) of the GDPR, i.e. the legitimate interest of us or of third parties, i.e. the carrying out of information about products and communication.
We reserve the right to delete comments if it proves necessary to do so. Examples of content subject to removal are: content violating the law or illegal content, hate comments, obscene comments (clearly of sexual content) or attachments (e.g. photographs or videos) that infringe, inter alia, copyright, personal rights, norms of the criminal code or ethical principles. Where appropriate, we share your content on our account and contact you via our social media platform.
4. Data recipients and categories thereof:
Data that you transmit to us through confidential channels (e.g. personal message, mail or e-mail) we do not normally transfer to third parties not related to TIROLA.
5. Data storage:
We delete or make completely anonymous any personal information that you send to us in secure messages in the form of enquiries (suggestions, positive feedback or criticism) no later than 90 days after we have provided you with a final response.
All of your public posts on our accounts and in our timeline will remain in place indefinitely, unless we delete them for the reason that the main topic is being updated, the post in question infringes the law, or you delete the post yourself.
We cannot influence when your data is deleted by the Platform Manager. In this regard, the data protection rules of each specific Platform Manager apply.
6. Joint controllers as defined in Article 26(1) of the GDPR
Article 26(1) of the GDPR (Joint Controllers) applies to certain relationships with a social network controller:
When a social Platform Manager uses user tracking methods, the Platform Manager and we act as joint data controllers. User tracking can be implemented regardless of whether you are registered on a social platform. The legal basis for the use of web tracking methods is Article 6(1)(f) of the GDPR. In accordance with this provision, our aim to optimise the operation of the social platform and the corresponding follower account is considered a legitimate interest.
For more information on data recipients and categories thereof, as well as the duration of data storage and the criteria for determining the duration of data storage, please refer to the privacy policies of the Platform Managers.
You can find out what your rights are to prevent the use of tracking methods by reading the privacy policies of the Platform Managers.
We can only partially influence or disable the statistical data provided to us by the social Platform Manager. However, we are monitoring that we are not given additional, optional statistics.
You should be aware: it cannot be excluded that your social platform provider uses your account and behavioural data to, for example, analyse your habits, personal relationships, interests, etc. In this respect, TIROLA cannot influence the processing of your data by the social Platform Provider.
7. Your rights as a data subject
Please be advised that you have the following rights:
To know your data and how they are processed (right of access);
Rectification or supplementation of incomplete personal data (right to rectification) in accordance with the purposes of processing personal data;
Erasure of its data (except storage) (right to erasure and right to “be forgotten”);
Request the controller to restrict the processing of your personal data (right to restriction);
The right to transfer data (right to data portability);
Where the processing is carried out on the basis of a legitimate interest or on the basis of your consent, to object to the processing of your data and, if you had already consented, to withdraw your consent at any time;
File a complaint with the State Data Protection Inspectorate;
You can exercise your rights as a data subject by contacting us using the details provided.