<\/p>\n
Effective as of 8 June 2026<\/p>\n
UAB \u201cCofive\u201d, legal entity code 306626131, registered office address Gamyklos g. 31C, LT-89103 Ma\u017eeikiai, Lithuania, in the course of its activities, including but not limited to managing the website www.cofive.lt<\/a> and the \u201cCoFive\u201d training platform, hereinafter referred to as the \u201cPlatform\u201d, may process your personal data. By means of this Privacy Policy, UAB \u201cCofive\u201d seeks to inform data subjects about the processing of personal data that may be carried out by UAB \u201cCofive\u201d in the course of its activities, hereinafter referred to as the \u201cPrivacy Policy\u201d.<\/p>\n This Privacy Policy may be amended in light of changes in legislation and in the activities of UAB \u201cCofive\u201d; therefore, we recommend that you review it periodically. The current Privacy Policy is always published at https:\/\/cofive.lt\/privatumo-politika\/<\/a>. When using the Platform, the Privacy Policy applies together with the Cookie Policy, which you can review at https:\/\/cofive.lt\/slapuku-politika\/<\/a>.<\/p>\n If you have any questions regarding the processing of personal data or wish to receive more detailed information, please contact us by email at info@cofive.lt<\/a>.<\/p>\n What terms are used in this Privacy Policy?<\/p>\n Personal data means any information relating to a natural person \u2014 the Data Subject \u2014 whose identity is known or can be identified directly or indirectly by using certain identifiers, such as name, surname, one or more factors specific to the physical, physiological, psychological, economic, cultural or social identity of that person.<\/p>\n Processing of personal data means any operation performed on personal data: collection, recording, accumulation, storage, classification, grouping, combination, alteration, disclosure, publication, use, erasure or any other operation or set of operations.<\/p>\n General Data Protection Regulation means 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, repealing Directive 95\/46\/EC, hereinafter also referred to as the \u201cRegulation\u201d or the \u201cGDPR\u201d.<\/p>\n Data Subject means a natural person whose personal data is processed.<\/p>\n Data Controller means a natural or legal person who determines the purposes and means of the processing of personal data.<\/p>\n Data Processor means a natural or legal person who processes personal data on behalf of and in the interests of the Data Controller.<\/p>\n Client means a natural or legal person with whom UAB \u201cCofive\u201d has concluded an agreement for the provision of services using the functionality provided by the Platform.<\/p>\n User means a natural person, including but not limited to the Client\u2019s employees or representatives, for whom an account is created and access rights are granted on the Platform, or who visits the Platform to review publicly available information for which no account is required.<\/p>\n Other terms used in this Privacy Policy shall be understood as defined in the Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other legal acts regulating the processing of personal data.<\/p>\n Who is the controller of your personal data?<\/p>\n The controller of your personal data is UAB \u201cCofive\u201d, legal entity code 306626131, registered office address Gamyklos g. 31C, LT-89103 Ma\u017eeikiai, Lithuania, email address info@cofive.lt<\/a>, telephone number +370 674 80858 \u2014 the provider of an innovative business-to-business, or B2B, human resources management platform designed to optimise training and internal communication in business, hereinafter referred to as the \u201cData Controller\u201d or \u201cCofive\u201d, except in cases where you use the Platform to access your employer\u2019s training materials, complete knowledge assessment tests, sign documents, or receive information from your employer. In such cases, the controller of your personal data is your employer, and Cofive acts as the data processor.<\/p>\n What personal data does Cofive process, for what purposes, and on what legal basis?<\/p>\n Cofive, as a data controller, may process the following personal data:<\/p>\n For the purpose of preparing and concluding an agreement, including sending the agreement by email or inviting you to sign the agreement by electronic signature on a particular platform, Cofive may process the personal data of the person representing the Client and of the ultimate beneficial owner: name, surname, position, signature, email address, telephone number. These personal data may be processed on the basis of compliance with a legal obligation, as provided for in the Civil Code of the Republic of Lithuania when concluding agreements between legal entities, as well as in order to perform a task carried out in the public interest related to the implementation of sanctions, as regulated by the Law on International Sanctions of the Republic of Lithuania and by European Commission and\/or Council Regulations imposing economic, financial and other types of sanctions on natural and legal persons, which must be implemented by all natural and legal persons. Please note that the processing of certain personal data, for example your identification data, is necessary in order to comply with legal obligations. If you do not provide the required personal data, Cofive will not be able to conclude an agreement, as it will not be able to properly comply with its legal obligations.<\/p>\n For the purpose of providing you with Cofive newsletters, surveys, invitations and other information, Cofive may process your name, surname, email address and telephone number, provided that you have given your consent to such processing of personal data.<\/p>\n For the purpose of preparing documents, including but not limited to notices, claims, responses to received inquiries, and for the storage of correspondence, Cofive may process the following personal data when you contact Cofive or have another type of relationship with Cofive: name, surname, address, email address, telephone number, position and workplace, as well as other information provided by you and recorded in the correspondence. These personal data are processed on the basis of Cofive\u2019s legitimate interest, namely to ensure the possibility to assert, exercise or defend legitimate interests and to respond to received inquiries.<\/p>\n For the purpose of ensuring the operation of the Platform, preventing security incidents and investigating security incidents, the following personal data of Users may be processed: IP address, email address, User\u2019s name, surname, employer if the User has an account on the Platform, and the date and time of the visit to the Platform. These personal data are processed on the basis of Cofive\u2019s legitimate interest, namely to ensure the security, integrity and proper functioning of the Platform and to protect the Platform against unlawful access and abuse.<\/p>\n Cofive, as a data processor, when providing services to the Client by storing Users\u2019 personal data related to granting Users access to the Platform, assigned training, passed and\/or failed knowledge assessment tests, signed documents, reminders or other information sent to you by the Client, or by deleting personal data, processes the following personal data: name, surname, telephone number, email address, workplace, training date and title, date of completion of the knowledge assessment test, i.e. the date on which it was passed or failed. To find out the legal basis on which these personal data are processed and to exercise your rights as a data subject, please contact your employer, i.e. Cofive\u2019s Client.<\/p>\n How does Cofive obtain your personal data?<\/p>\n Usually, we receive your personal data directly from you when you contact Cofive, or from your employer, who is Cofive\u2019s Client. In order to ensure the implementation of international sanctions and to assert legal claims, your personal data may be obtained from publicly available sources, for example the State Enterprise Centre of Registers, the Financial Crime Investigation Service, and others.<\/p>\n To whom may Cofive transfer your personal data?<\/p>\n For the processing of your personal data, Cofive may engage third parties \u2014 service providers, or data processors: data centres, companies providing Platform hosting services, companies providing information technology maintenance services, companies providing advertising and marketing services, including newsletter distribution services, or other service providers to whom your personal data are disclosed only to the extent necessary for the provision of specific services.<\/p>\n The data processors engaged by us may process your personal data only in accordance with our clear instructions or directions and may not use them for other purposes or transfer them to other persons. In each specific case, only the necessary personal data or access thereto is provided to the data processor, i.e. only such personal data as are necessary to achieve the specific processing purpose or to provide the service. To ensure the security of your personal data, we engage only those data processors who undertake and are able to comply with appropriate data security requirements and confidentiality obligations.<\/p>\n Data may also be transferred to lawyers, accountants, auditors, state and municipal institutions and bodies performing functions assigned to them by law, law enforcement authorities and courts.<\/p>\n Where are your personal data processed?<\/p>\n We process and store your personal data only within the territory of the European Union \/ European Economic Area, or EU\/EEA. Currently, when processing your personal data, we do not transfer them to third countries. If there is a need to transfer data to third countries, we will inform you before such transfer is carried out and will ensure the lawfulness and security of the transfer, including the application of the necessary transfer mechanisms and security measures.<\/p>\n How long are your personal data stored?<\/p>\n The retention period for personal data is determined in accordance with the Index of Retention Periods for Internal Administration Documents, approved by Order No. VE-50 of the Chief Archivist of Lithuania of 24 September 2024, or taking into account the limitation periods for claims established by law, which are generally 10 years.<\/p>\n Personal data processed by Cofive as a data processor are processed for no longer than 90 days after termination of the agreement with the Client, or during the term of the agreement with the Client until the Client itself deletes the personal data or instructs Cofive to delete the personal data.<\/p>\n What rights do you have?<\/p>\n As a data subject, you have all rights established by the Regulation:<\/p>\n the right to be informed about the processing of personal data \u2014 to receive information as to whether we process your personal data and, where such personal data are processed, to access your personal data;<\/p>\n the right to request rectification of personal data if you determine that the personal data processed about you are inaccurate or incorrect;<\/p>\n the right to request restriction of the processing of personal data, except storage, where, after accessing the personal data, their accuracy is contested, until the accuracy of the data is verified, or where it is established that they are processed unlawfully, are no longer necessary for the data processing purposes determined by Cofive but are required by you for the establishment, exercise or defence of legal claims, or where you have objected to the processing of data based on legitimate interests, until it is verified whether Cofive\u2019s legitimate grounds override yours;<\/p>\n the right to request erasure of personal data, the \u201cright to be forgotten\u201d, except where your data must be retained on the basis of legal obligations applicable to Cofive or where the data are necessary for the establishment, exercise or defence of legal claims;<\/p>\n the right to object to the processing of personal data where such data are processed or intended to be processed on the basis of the legitimate interest pursued by Cofive and your reasons override such interest;<\/p>\n the right to receive personal data concerning you, which you have provided to Cofive, processed by automated means and where the processing is based on consent or on a contract, in a commonly used, machine-readable format, and to transmit those data to another data controller where technically feasible, i.e. the right to data portability;<\/p>\n the right to withdraw your consent to the processing of personal data at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal. You may withdraw your consent at any time by submitting a notice to Cofive \u2014 by clicking the link at the end of the email or by sending your request to Cofive by email at info@cofive.lt<\/a>.<\/p>\n You may exercise your rights yourself or through representatives. In order to exercise your rights, you may submit your request by email to info@cofive.lt<\/a>. When processing your request, we have the right and obligation to verify your identity, which we will always seek to establish in the simplest and most convenient manner for you. When submitting a request, you may confirm your identity in one of the following ways: if the request is submitted by electronic means, it must be signed with an electronic signature, or it must be submitted from the email address that you provided when submitting your inquiry on our Platform and\/or that we have in our database and by which we can identify you. Where there are reasonable doubts regarding the identity of the natural person submitting the request, we have the right to request additional information necessary to confirm your identity.<\/p>\n The request must be clear and must indicate your name, surname, information about which rights and to what extent you wish to exercise them, and information on how you would like to receive the response. If you submit the request by electronic means, the information will also be provided by electronic means, unless you request in advance that it be provided otherwise.<\/p>\n We endeavour to examine your requests and provide information to you as soon as possible, but in any event no later than within 30 calendar days from the date of receipt of the request. If, due to certain circumstances, for example due to the complexity of the request submitted, where assistance from engaged data processors is required, or due to a large number of requests being examined by Cofive, Cofive is unable to examine the request in time, the examination period may be extended by no longer than two months. We will inform you of this immediately once such circumstances become apparent.<\/p>\n Requests are examined and information and data are provided free of charge; however, in certain cases, we have the right either to refuse to exercise your rights, where the request is unfounded, disproportionate or repetitive, or the provision of information and data may be subject to a fee, taking into account the administrative costs of providing the information or communications or actions requested, in accordance with legal requirements and\/or Cofive\u2019s established fees, where obvious abuse of rights is identified, or where repeated unfounded requests are submitted for information, data, extracts, documents and the like.<\/p>\n If you believe that Cofive\u2019s actions or omissions infringe your rights or legal requirements, you have the right to lodge a complaint with the supervisory authority \u2014 the State Data Protection Inspectorate, whose contact details are available at www.vdai.lrv.lt<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":" Effective as of 8 June 2026 UAB \u201cCofive\u201d, legal entity code 306626131, registered office address Gamyklos g. 31C, LT-89103 Ma\u017eeikiai, Lithuania, in the course of its activities, including but not limited to managing the website www.cofive.lt and the \u201cCoFive\u201d training platform, hereinafter referred to as the \u201cPlatform\u201d, may process your personal data. 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