Privacy Policy

Aktyvus Photonics, UAB

 

The date of the last update: 2026/09/24

1.    GENERAL PROVISIONS

1.1.       We are committed to safeguarding your privacy and ensuring the security of your personal data. This privacy policy (“Privacy Policy”) explains how we collect and process your personal data, what rights you have in relation to such processing, and other relevant information about the processing of your personal data.

1.2.       This Privacy Policy clarifies the data processing activities undertaken by us when you utilise our website”), accessible at https://www.aktyvusphotonics.com/ (the “Website”, visit our social networking sites Facebook (www.facebook.com/aktyvusphotonics), LinkedIn (https://www.linkedin.com/company/aktyvus-photonics/), YouTube (www.youtube.com/@aktyvusphotonics3430) (“Social Accounts”), submit an inquiry and contact us by email or other electronic communication channels.

1.3.       In this Privacy Policy “personal data” (“Personal Data”) shall refer to any information or set of information from which we can directly or indirectly identify you, such as your name, surname, email address, telephone number, etc. For the purposes of this Privacy Policy, “You” shall mean means a visitor or user of the Website, a person who submits an inquiry or a job application through the Website, or a person who visits or interacts with our Social Accounts.

1.4.       In processing Personal Data, we comply with the requirements of the General Data Protection Regulation 2016/679 (EU) (“GDPR”) and the legislation of the Republic of Lithuania, as well as the instructions of the controlling authorities.

1.5.       Should you utilise the Website, visit our Social Accounts, or contact us, we consider that you have read and understood the Privacy Policy, and that You have been informed about the processing of Your Personal Data as described in this Privacy Policy.

1.6.       The Website and Social Accounts may contain links to, for example, websites of our partners or other projects of ours. This Privacy Policy does not apply to such external websites. We encourage you to review the privacy policies of any third-party sites or platforms before disclosing any personal information or proceeding further.

1.7.       This Privacy Policy is subject to change; therefore, we advise you to periodically visit the Website to review the latest version of the Privacy Policy published.

2.    WHO ARE WE?

2.1.       The controller of your Personal Data is Aktyvus Photonics, UAB, a private limited liability company incorporated in the Republic of Lithuania, legal entity code 305658343, address Mokslininkų str. 6A, LT-08412, Vilnius, Lithuania, the data is collected and processed in the Register of Legal Entities of the State Enterprise “Registrų Centras” (hereinafter referred to as the “Data Controller” or “Company” or “We”). We administer the Website and information accessible through it.

2.2.       If You have any questions regarding the processing of Your Personal Data or this Privacy Policy, You can contact us by email info@aktyvusphotonics.com.

3.    HOW DO WE RECEIVE YOUR PERSONAL DATA?

3.1.       We receive your Personal Data:

3.1.1.         directly from You when You provide Your Personal Data through the Website, including when You submit an inquiry or a job application, or when You otherwise communicate with us in connection with the Website;

3.1.2.         automatically when You use the Website, including through cookies and similar technologies, as further described in Section 9 of this Privacy Policy.

3.1.3.         through third-party services integrated into or used in connection with the Website, including the Odoo contact form embedded in the Website, Google services used in connection with the Website, and social media platforms when You interact with our Social Accounts.

3.2.       When You provide Personal Data about yourself or others (e.g., about your employees, agents), You are responsible for the accuracy, completeness, and timeliness of such Personal Data, as well as for obtaining the necessary consent or informing the individual whose Personal Data is being provided to us. In certain cases, We may request confirmation from You that You have the right to provide us with Personal Data, for example, by completing registration forms.

4.    WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?

4.1.       We process your Personal Data for the following purposes and in accordance with the following terms and conditions:

Purposes of personal data processing Processed personal data Personal data retention periods Legal grounds for personal data processing

Administration, operation, development and security of the Website and analysis of its use.

IP address, browser and device information, cookie identifiers and preferences, information about visits to and interactions with the Website, including pages viewed, links clicked, referral URLs, date and time of visits, and other technical information generated when using the Website.

Website data is stored as described in the Privacy Policy section “How do we use cookies?” and if not specified within the cookie information, for the duration up to 2 years following collection;

When processing data based on your consent, we shall do so for the duration of your consent. Should you withdraw your consent, we shall retain the data until the originally agreed upon period of consent has expired.

Consent of the data subject (Article 6(1)(a) of the GDPR);

Our legitimate interest in ensuring the security and proper technical functioning of the Website (Article 6(1)(f) of the GDPR).

Administration of our Social Accounts and communication with their users.

Social media username and profile information visible to Us, comments, reactions (information about clicks on “like” and “follow”), shares and other interactions with our Social Accounts, as well as the content and metadata of messages You send to Us through the relevant social media platform (photo, details of the message and the reply to the message (time of receipt, content, attachments), and any other information You provide).

Social Accounts store information according to the terms and conditions set by the owners of the social networks.

Consent of the data subject (Article 6(1)(a) of the GDPR);

Our legitimate interest in managing our Social Accounts, communicating with their users and presenting information about our activities (Article 6(1)(f) of the GDPR).

Communication with customers, potential customers and other interested parties, including inquiry administration and pre-contractual communication. The Website allows users to submit inquiries regarding our products and activities through a contact form provided via an embedded Odoo solution. Personal Data submitted through the form is transmitted to the relevant Company departments and is not stored on the Website. Following such transmission, the inquiry and further related communication are handled internally by the Company.

If provided: name, surname, email address, phone number;

Person represented (if you represent a company or another person), your relationship with the person represented;

Subject and content of the communication (message, reply) and any data necessary to address quality issues.

The data is stored for the duration of the communication and for up to 1 year after the end of the communication (last message).

When processing data based on your consent, we shall do so for the duration of your consent. Should you withdraw your consent, we shall retain the data until the originally agreed upon period of consent has expired.

Consent of the data subject (Article 6(1)(a) of the GDPR);

Our legitimate interests in responding to inquiries and communicating with persons interested in our products, activities or potential cooperation (Article 6(1)(f) of the GDPR);

Where the inquiry is submitted by an individual with a view to entering into a contract with Us, the processing is necessary for taking steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) of the GDPR).

Assessment and selection of candidates applying for vacancies through the Website.

Name, surname, contact details (email address, phone number, address), CV, information about education, qualifications and professional experience, information contained in the application and other information voluntarily provided by the candidate in connection with the recruitment process.

Personal Data is retained for the duration of the relevant recruitment process and 3 months after the selection, if the candidate’s consent is obtained to retain the data after the selection;

When data is received not specifically for selection purposes – it is retained for 1 (one) year from the date of receipt.

The processing is necessary for taking steps at Your request prior to entering into an employment contract (Article 6(1)(b) of the GDPR) when you submit your candidacy for our proposed job position;

Your consent (Article 6(1)(a) of the GDPR), where Your Personal Data is retained for future recruitment opportunities.

Establishment, exercise and defence of legal claims relating to the processing activities described in this Privacy Policy.

Personal Data relevant to the relevant complaint, claim or dispute, including contact details (email address), correspondence and information concerning the circumstances giving rise to the claim or dispute;

Data provided by the person: name, surname, phone number, address, job title, person represented (if You represent a company or another person), relationship with the person represented.

During the resolving of the dispute and for the period of 10 years following the conclusion of the dispute procedure (or, in the case of a judicial dispute, after the final judgment has become final);

Requests and correspondence from data subjects shall be kept for the period of 2 (two) years following the conclusion of the processing of the request.

The processing is necessary for compliance with a legal obligation imposed on the controller (Article 6(1)(c) of the GDPR) in accordance with the GDPR and other legislation;

Our legitimate interest in establishing, exercising or defending legal claims (Article 6(1)(f) of the GDPR).

4.2.       You have the right to object to or withdraw your consent to the processing of your Personal Data at any time when such processing is based on consent.

4.3.       Where You contact Us regarding our products, activities or potential cooperation, We may use the contact details You provide to respond to Your inquiry and to continue the communication initiated by You. Such communication is not used for direct marketing purposes unless We have a separate lawful basis to do so.

4.4.       You have the right to amend and update the information we hold about You. In some cases, it is necessary for us to have accurate up-to-date information pertaining to You and We may request that You confirm the accuracy of information we hold about You.

5.    SOCIAL ACCOUNTS

5.1.       We post information regarding our Website, activities, services offered, changes to said services, and other news on our Social Accounts. Additionally, we may post advertisements or communicate with you through them to respond to your inquiries.

5.2.       It is important to bear in mind that users of Social Accounts are subject not only to this Privacy Policy, but also to the privacy policies, rules and terms of use of the operators of the social networks on which the Social Accounts are located. When You interact with us on the Social Accounts and provide certain information (for example, by messaging us and commenting on our posts), We may see public information about your profile (such as your name, image, email, etc.) depending on the privacy settings you have selected. This information, for example, a comment you have posted, may also be visible to other visitors to a particular Social Account, depending on the privacy settings You have selected.

6.    HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE ADHERE TO?

6.1.       We respect Your privacy and only collect and process Personal Data that is necessary to achieve our stated purposes for processing Personal Data.

6.2.       In processing your Personal Data, we shall:

6.2.1.         comply with the requirements of applicable and valid legislation, including the GDPR;

6.2.2.         process your Personal Data in a lawful, fair and transparent manner;

6.2.3.         We collect your Personal Data for specified, clearly defined and legitimate purposes and We do not process it in a manner that is incompatible with those purposes, except to the extent permitted by law;

6.2.4.         We take all reasonable steps to ensure that Personal Data which is not accurate or complete in relation to the purposes for which it is processed is promptly rectified, supplemented, its processing is suspended, or it is destroyed;

6.2.5.         We retain them in a form which permits your identification for no longer than is necessary for the purposes for which the Personal Data is processed;

6.2.6.         We do not provide Personal Data to third parties and will not disclose it other than as set out in the Privacy Policy or applicable law;

6.2.7.         We ensure that your Personal Data is processed securely, by implementing technical and organizational security measures, and by restricting access to your Personal Data to those of our employees who need such access for the purposes of their job functions.

7.    TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?

7.1.       Where necessary for the purposes described in this Privacy Policy, We may disclose or otherwise make Your Personal Data available to service providers that assist Us in operating the Website and related services, including website hosting and administration providers, cloud and IT service providers, providers of website forms and security solutions, analytics and cookie-related service providers, and professional advisers, where necessary. 

7.2.       To enable us to publish content on Social Accounts, We disclose data to the following operators of social networking platforms:

7.2.1.         Meta Platforms Ireland Limited (Ireland) and Meta Platforms, Inc., (USA), (data is transferred in accordance with an adequacy decision issued by the European Commission; active participant of EU-U.S. Data Privacy Framework and Swiss-U.S. Data Privacy Framework);

7.2.2.         LinkedIn Ireland Unlimited Company (Ireland) and LinkedIn Corporation (USA) (data is transferred in accordance with an adequacy decision issued by the European Commission; active participant of EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework and Swiss-U.S. Data Privacy Framework);

7.2.3.         YouTube Inc. (USA) (data transferred in accordance with the EU Standard Contractual Clauses approved by the European Commission);

7.2.4.         Google Ireland Limited (Ireland) and Google LLC (USA) (data is transferred in accordance with an adequacy decision issued by the European Commission; active participant of EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework and Swiss-U.S. Data Privacy Framework).

Given that Aktyvus Photonics, UAB does not administer the aforementioned social networks listed above, but solely its own account on these social networks, You are invited to review the information regarding the storage of your personal data in the privacy documents of these respective social networks.

7.3.       We may disclose data to law enforcement and pre-trial investigation authorities, courts and other dispute resolution authorities, as well as to other individuals or entities performing functions mandated by law, in accordance with the procedure stipulated by the legislation of the Republic of Lithuania. We provide these entities with information that is required by law or as specified by the entities themselves.

7.4.       We may also transfer data, if necessary, to companies that would buy or acquire our business or engage in joint activities or other forms of cooperation with us, as well as to companies established by us.

7.5.       We generally process Personal Data within the EU / EEA, but in some cases your Personal Data may be transferred outside the EU / EEA. The transfer of your Personal Data outside the EU / EEA is based on:

7.5.1.         a data processing or supply agreement that describes such transfer and includes Standard Contractual Clauses for international transfers; or

7.5.2.         an adequacy decision adopted by the European Commission, which means that the European Commission has recognized the country in which the third party is established and / or carries on business as providing an adequate level of protection of personal data; or

7.5.3.         a specific authorization by the data protection supervisory authority to carry out such transfer; or

7.5.4.         your consent to the transfer of your Personal Data outside the EU / EEA.

8.    WHAT RIGHTS DO YOU HAVE?

8.1.       As a data subject, You have the following rights in relation to your Personal Data:

8.1.1.         to informed about the processing of your Personal data and to have access to your Personal Data, i.e., to receive a notice confirming whether We are processing your Personal Data and, if We are, to request access to the data processed and the information relating to it;

8.1.2.         to ask us to correct inaccurate or incorrect information We use or to supplement information where it is incomplete;

8.1.3.         to ask us to erase information We hold about You where there is a basis for erasure;

8.1.4.         to request us to restrict the processing of the information We hold about You where You contest the accuracy of the data or object to the processing of the data, You object to the erasure of your data which is unlawfully processed, or You need the data in order to assert, exercise, or defend legal claims;

8.1.5.         to object, on grounds relating to Your particular situation, he processing of Your Personal Data where the processing is based on our or a third party’s legitimate interests;

8.1.6.         to request us to transfer / receive data that You have provided to us under a contract or consent and that We process by automated means in a commonly used electronic format;

8.1.7.         to object to the application to You of a fully automated decision, including profiling, where such a decision may have legal consequences or a similar significant effect on You. Please note, that We do not make decisions based solely on automated processing, including profiling, which produce legal effects concerning You or similarly significantly affect You;

8.1.8.         to withdraw the consents, You have given us to use information about You where We are using the data on the basis of your consent, without affecting the lawfulness of processing based on consent before its withdrawal;

8.1.9.         lodge a complaint with the relevant data protection supervisory authority.

8.2.       The rights described above are subject to the conditions and limitations established by applicable data protection law. Depending on the circumstances, We may therefore be unable to comply with a request in whole or in part, in which case We will explain the reasons for our decision.

8.3.       If You wish to withdraw your consent for the processing of Personal data or to exercise any of your rights set out above, You may contact us by email at info@aktyvusphotonics.com. Please provide sufficient information to enable Us to identify the Personal Data concerned and understand Your request. In order to better understand your request, We may ask you to fill in the relevant request form, request a signed request with an advanced or qualified electronic signature, send the request by post or visit us in person.

8.4.       Where We have reasonable doubts concerning the identity of the person making a request, We may request additional information necessary to confirm that person’s identity.

8.5.       We do not typically charge any fee for exercising your rights. However, the law permits us to charge a reasonable fee or to refuse to comply with your request if it is manifestly unfounded or excessive.

8.6.       Upon receipt of your request or instruction regarding the processing of your Personal Data, We will provide You with a response within no later than 1 month from the date of the request and will execute the actions specified in the request or inform You why We refuse to do so. If necessary, the time limit may be extended by an additional 2 months due to the complexity and number of requests. In this case, We will notify You of the extension within 1 month of receiving the request.

8.7.       If Personal Data is erased at your request, We may retain copies of the information as necessary to protect our legitimate interests and those of others, to comply with obligations of public authorities, to resolve disputes, to identify disturbances or to comply with agreements.

9.    HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

9.1.       A cookie is a small text file that is stored in the browser or on your device (computer, tablet, mobile phone). In this Privacy Policy, we use the term “cookies” to refer to cookies and other similar technologies such as Pixel Tags, Web Beacons and Clear GIFs.

9.2.       We use cookies and similar technologies to ensure the proper and secure functioning of the Website, remember Your cookie preferences and, subject to Your consent where required, understand how visitors use and interact with the Website and enable certain third-party content and functionality.

9.3.       We may use the following categories of cookies:

9.3.1.         necessary cookies - cookies required for the proper and secure functioning of the Website and for storing Your cookie preferences. These cookies do not require Your consent;

9.3.2.         performance and analytics cookies - cookies that help Us understand how visitors use the Website and allow Us to analyse and improve its performance. These cookies are used only with Your consent;

9.3.3.         advertising cookies - cookies used in connection with advertising or third-party content, where applicable. These cookies are used only with Your consent.

9.4.       When You first visit the Website, only cookies that are strictly necessary for the operation and security of the Website may be placed on Your device without Your consent. Any cookies that are not strictly necessary will be used only after You have provided Your consent through the cookie banner, where such consent is required by applicable law.

9.5.       If you consent to the use of cookies, you agree that we and the relevant third parties may use your personal data collected through cookies. Based on your consent, the corresponding cookies will be stored on your device for their specific lifetime. For further details on the cookies we use and their lifetimes, please see p. 9.6.

9.6.       Cookies used on our Website:

9.7.       Subject to Your consent, We use Squarespace’s built-in analytics functionality to obtain aggregated information about the use and performance of the Website. The cookies used for this purpose are identified in the table above.

9.8.       The contact form available on the Website is provided through an Odoo solution embedded in the Website. When You use the contact form, Odoo may process technical information and place cookies necessary for the operation of the form, as specified in the table above. The form also uses a Google CAPTCHA solution designed to protect the Website and the contact form against spam, abuse and automated submissions. In connection with this functionality, Google may process technical information concerning Your device and interaction with the Website.

9.9.       Some third parties, such as social network operators, may use their own anonymous cookies to tailor the apps or applications they create to your needs. We do not control the use of these cookies. We recommend that you check the privacy policy of the third party for more detailed information.

9.10.    On the Website, you can manage cookies by selecting the options in the cookie bar or adjusting the settings of the browser you use. You can refuse the use of optional cookies, but this may result in some of the Website’s functionality not working and may slow down its performance. To manage cookies on your mobile device, please follow the official instructions for that device.

9.11.    Most internet browsers accept all cookies by default. However, you can adjust your browser settings related to the collection and storage of cookies. Information on how to do this in the most commonly used browsers can be found via the links provided below, as well as in your browser’s help section or your device’s user manual. Please note that changes apply only to the browser in which they were made. If you use multiple browsers, we recommend adjusting the settings in each one separately.

9.11.1.       Google Chrome: https://support.google.com/accounts/answer/61416?hl=en;

9.11.2.       Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy;

9.11.3.       Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences;

9.11.4.       Opera: http://www.opera.com/help/tutorials/security/privacy/;

9.11.5.       Safari: https://support.apple.com/kb/PH19214?locale=cs_CZ&viewlocale=en_US.

9.12.    Please note that browser help or information websites are not owned or controlled by us, and we are not responsible for the accuracy, availability or content of the information provided on them.

10.  HOW DO WE PROTECT YOUR PERSONAL DATA?

10.1.    Your Personal Data is processed responsibly and securely, safeguarded against loss, unauthorized use and alteration. We have implemented both physical and technical measures to protect the information we collect from accidental or unlawful destruction, damage, alteration, loss, disclosure or any other unauthorized processing. The security measures for Personal Data shall be determined taking into account the risks involved in the processing of Personal Data.

10.2.    Our employees are under a written obligation not to disclose or distribute your Personal Data to any unauthorized third party.

11.  CONTACT US

11.1.    If you have any questions, comments or complaints about how We collect, use and store information about You, or if You wish to exercise your rights as a data subject, You may contact us at: info@aktyvusphotonics.com.

11.2.    If You believe that the processing of Your Personal Data infringes applicable data protection law, You have the right to lodge a complaint with the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), located at: L. Sapiegos str. 17, LT-10312 Vilnius, Lithuania, email: ada@ada.lt, website: https://vdai.lrv.lt/. However, We encourage You to contact Us first so that We may seek to resolve Your concerns.

12.  FINAL PROVISIONS

12.1.    We may update this Privacy Policy from time to time to reflect changes in our Personal Data processing activities, the Website or applicable legal requirements. The current version of the Privacy Policy will be published on the Website. Where appropriate, We may also inform You of material changes by other reasonable means.