Privacy policy

General provisions

We are a Ruptela group of companies consisting of the following enterprises:

UAB “Ruptela” | Registration code: 301058543 | Address: Perkūnkiemio g. 6, Vilnius, Lithuania

Subsidiary companies:

M2M Wireless Limited | Registration code: 585056| Address:  The Black Church, st.Mary‘s place, Dublin D07 P4AX, Ireland

RUPTELA S.A. de C.V; | Registration code: RUP1905101IFA | Address: Avenida Sor Juana Ines de la Cruz No. 22, Venue No. 115, Colonia Tlalnepantla Centro, Tlalnepantla de Baz, Estado de Mexico

RUPTELA USA Inc. | Registration code: 32-0632872 | Address: St.Petersburg Fl 33702, Florida, USA

RUPTELA FZCO | Registration code: 4471 | Address: Office 6E A 312, Dubai Airport Free Zone, Dubai, UAE

(hereinafter referred to as ‘we’ or the ‘Ruptela’), address: Perkūnkiemio st. 6, Vilnius, Lithuania, tel. No .: +370 5 2045188, e-mail p .: [email protected] we understand that the protection of personal data is important for our customers, suppliers, partners, and other persons (hereinafter – data subjects) who cooperate or use Ruptela’s services. For this reason, we take all necessary measures to ensure the privacy of each data subject and the exercise of personal data protection rights.

You can contact our appointed Data Protection Officer by e-mail on all data protection issues: email [email protected]

This Privacy Statement provides all information about how we, as Data Controllers, process personal data, including information about the purposes and the legal basis of the personal data processing, what data is collected, how long it is stored, to whom disclosed, what rights as a Data subject you have, where you can ask how to exercise them or any other issues related to the processing of personal data.

The Privacy Notice applies to individuals who cooperate or use Ruptela’s services, visit our websites, social network accounts, or provide their data for other purposes.

The Privacy Notice is in accordance with 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 (hereinafter – GDPR or Regulation) and is an integral part of Ruptela’s approved Data Protection Policy.

How do we collect your data?

Depending on the nature of our cooperation, we process the following personal data:

• Received directly from the data subject (you), for example when you send us inquiries, share your experience or send us your CV in order to apply for a vacancy;
• Generated when you use our services or enter our territory, for example when you visit our website or enter our video surveillance field;
• Obtained from other sources, such as insurance companies, other third parties.

For what purposes and what personal data do we process?

Purpose of data processing	Legal basis for the processing	Categories of data	Data retention period
Execution of contracts with suppliers, subcontractors	GDPR Article 6 (1) (b) –  contract performance	Name, surname, personal identification code, date of birth, contact telephone number, e-mail of representatives of suppliers and subcontractors. postal address, address	10 years after the end of the particular contract
Video surveillance for Ruptela property protection and crime prevention purposes	GDPR Article 6 (1) (f) – legitimate interest, GDPR Article 6 (1) (c) – legal obligation	Image, other data visible in the video	14 days
Recording of phone conversations for the purpose of quality assurance	GDPR Article 6 (1) (f) – legitimate interest	Call metadata: time, duration, phone number. Call content.	6 months
Responding to queries sent though email or our website	GDPR Article 6 (1) (f) – legitimate interest	name, email address, contents of the messages submitted	1 year
Direct marketing	GDPR Article 6 (1) (a) – consent	Name, surname, e-mail, telephone number.	Until withdrawal of consent
Information collected through cookies on our websites	GDPR Article 6 (1) (a) – consent	The specific information collected by cookies can be found in the cookie control window	The duration of specific cookie can be found in the cookie control window
Debt administration	GDPR Article 6 (1) (f) – legitimate interest	Name, surname, personal identification number, amount of debt	5 years from the settlement of the debt
Evaluation of Job applicants	GDPR Article 6 (1) (a) – consent, GDPR Article 6 (1) (f) – legitimate interest	Name, surname, contact details, content of CV, cover letter.	Until the end of the selection
Execution of contracts with clients and partners	GDPR Article 6 (1) (b) –  contract performance	Name, surname, personal identification code, date of birth, contact telephone number, e-mail of representatives of suppliers and subcontractors. postal address, address	10 years after the end of the particular contract
User statistical data of „Device Center“	GDPR Article 6 (1) a- consent	Anonimysed statistical data- basic system parameters, used devices, configured funcionalities	1 year
Trusttrack, DMP, SP-Admin and Device centre programs users administration	BDAR Article 6 (1) b- performance of contract	User log in credentianls: user name, email address, full name, surname, encrypted password, company, assigned roles, IP address, logs- performed actions, end-user data.	Until the termination of a contract
Customer support delivery	GDPR Article 6 (1) b- performance of contract	Name, surname, company, contact details- phone, email address, problem, content of the communication	2 years

NOTE: We do not process the special categories of (sensitive) personal data, i.e., data related to your racial or ethnic origin, political, religious, philosophical or other convictions, membership in trade unions, health or sex life, nor do We process information about criminal records.

Ruptela as a Data Processor

As a data processor, We may process the personal data which is specified in personal data processing agreements concluded with our clients.

How do we protect your data?

Ruptela has implemented appropriate technical and organizational measures to ensure an appropriate level of security for data processing. The newest information on how we protect your data can be found here.

To whom do we provide your data?

Ruptela only uses those data processors who ensure compliance with the GDPR and the same level of security of personal data as set out in our personal data protection policy.

Here is a list of Ruptela data recipient categories:

• Companies providing data centers, hosting, cloud, website administration, and related services, software developing companies, companies providing information technology infrastructure services, companies providing communication services;
• Our legal and compliance counselors, external audit company
• Subcontractors;
• State institutions in accordance with the procedures provided by law;
• Law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offense has been committed, as well as courts and other dispute resolution bodies.

Do we provide your data outside the European Union and the European Economic Area?

We ensure that your data is processed in accordance with the requirements and standards established by the legal acts of the European Union. We use data centers within the EEA.

What rights do you have and how can you exercise them?

In accordance with the provisions of the GDPR, you, as a data subject, can exercise the following rights:

1. The right of access to personal data: request information on whether your personal data is being processed, and if personal data is being processed, you have the right to access your personal data.
2. The right to rectify personal data: submit a request to correct your personal data if you find that the personal data we process is incorrect, incomplete or inaccurate.
3. The right to data erasure (the right to be “forgotten”) – request the deletion of your personal data if you believe that your data has been processed illegally or fraudulently.
4. The right to restrict data processing: request to restrict (suspend) the processing of your personal data, except for the storage – in case, for example, you request the rectification of your personal data (while the accuracy of personal data is checked and/or corrected), when the personal data is processed unlawfully and you do not consent to the erasure of the data, you have expressed your consent to the processing of your personal data, etc.
5. The right to data portability: submit a request to transfer your personal data, which is processed by automated means, to you and/or another data controller in a systematic, commonly used, and computer-readable format.
6. The right to object data processing: to object to the processing of personal data where the processing is carried out on a legal basis or on a legal basis in the public interest.
7. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her
8. The right to withdraw the consent given to us at any time, with regard to the processing of personal data, for example, for direct marketing.

You can exercise your rights:

1. By sending us a free-form request to e-mail [email protected] The application must be signed using digital signature in order for us to verify your identity.
2. By sending the request via registered mail to the address Perkūnkiemio str. 6, Vilnius, Lithuania, the application must be signed. The application must be accompanied by a notarized copy of your identity document.
3. You can also exercise your rights through a representative. In this case, your representative must provide your name, contact details, a copy of an identity document certified by a notary, information about you, namely: name, surname, other data on the basis of which we could identify you as a data subject, as well as A notarized copy of the document supporting your representation.

The request must be legible, signed, name and surname of the data subject, address and other details of the data subject for the desired form of communication, information on which of the data subject’s rights and to what extent the data subject wishes to exercise it.

We will provide a response to your request no later than 30 (thirty) days from the date of receipt of the request. In exceptional cases requiring additional time, we will, after notifying you, have the right to extend the deadline for submission of the requested data or examination of other requirements specified in your request to 60 (sixty) days from the date your request was received.

Where to submit your questions about your personal data?

If you have any questions regarding the information provided in this Privacy Statement or the protection of your personal data and the exercise of your rights, please contact our Data Protection Officer in any way convenient for you:

• E-mail: [email protected]
• Address: Perkūnkiemio str. 6, Vilnius, Lithuania.

If it is not possible to find a solution that is suitable for both parties, you have the right to lodge a complaint with the State Data Protection Inspectorate at the address: L. Sapiegos str. 17, Vilnius, by e-mail: [email protected].

Final provisions of the Privacy Notice

The Privacy Notice is adjusted at the discretion of the Data Controller or in the event of a change in the requirements of the applicable legislation.

The current version of the Privacy Notice is published on the Website.

This Privacy Notice was last updated on 2021-05