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Privacy policy

PRIVACY POLICY

Updated on November 3, 2023

We are delighted that you are visiting this website - we are ready to help address your skin concerns and achieve beautiful skin results! We value every collaboration and every customer, so we take your data privacy very seriously. We strive not only to handle and care for your personal data fairly and legally but also to communicate about it as transparently and clearly as possible.

Therefore, in this Privacy Policy, we present:

  • What personal data of yours we process
  • For what purposes we process them
  • On what basis we process them
  • How long we retain them
  • And other relevant information for you

    • Please read this document carefully, as each time you visit the www.odapro.eu website, our Facebook accounts "ODA PRO," regardless of the device you use, whether you are using our services, or purchasing goods or services from UAB "ODA GROUP" through other sales channels of UAB "ODA GROUP," you agree to the terms described in this Privacy Policy. If you do not agree to these terms, we regretfully ask you not to visit our website and not to use our content and/or services.

    This Privacy Policy may change without separate notice, so please check each time you visit our website.

    If you are a person under the age of 14, you can contact us and use our services, but you cannot provide us with your personal data for direct marketing purposes (e.g., subscribing to newsletters) without the consent of your parents or other legal guardians.

    WHO WE ARE?

    Our details:

    • UAB "ODA GROUP"

    • Company code 306318183

    • Registered address: Jonavos g. 7, LT-44192 Kaunas

    • Mobile number: +370 688 86100

    • Email: hello@odapro.eu

    WHY AND WHAT DATA DO WE COLLECT ABOUT YOU?

    In order to conclude service and other agreements, fulfill our contractual obligations, and manage our clients, we may collect:

  • Name, surname
  • Personal identification number
  • Residential or domicile address
  • Bank account number
  • Individual activity certificate or business license number
  • Name of the company, institution, organization you represent, and your position
  • Loyalty card number (applicable only to cosmetologists)
  • Email address
  • Phone number
  • Signature
  • Communication history (on social media, in writing, or by email)

    • To manage the online store and process customer orders when purchasing without registration, we collect:

  • Name, surname
  • Phone number
  • Email address
  • Delivery address for goods
  • Company name and additional information (we do not require this data; you can provide it at your discretion)

    • To manage the online store and process customer orders when the customer registers on the website, we collect:

  • Name, surname
  • Phone number
  • Email address
  • Purchase history
  • Encrypted password
  • Delivery address for goods
  • Company name and additional information (we do not require this data; you can provide it at your discretion)
  • Customer data related to skin condition (complaints, allergic reactions, skin type, products used for the skin, skin problems, and data on the condition of the skin)

    • If you are a winner of contests, promotions, or other games organized by us on social media, we collect:

  • Name, surname
  • Phone number
  • Address to which the prize is sent

    • For video surveillance purposes, we collect:

  • Video data of individuals entering the surveillance area

    • To process your requests, inquiries, questions, and complaints, we collect:

  • Name
  • Email address
  • Phone number
  • Content of the request, inquiry, or complaint, and information related to it
  • Communication history

    • For direct marketing purposes to provide you with relevant information and news about us and our services, we collect:

  • Email address

    • For employee and trainee recruitment purposes, we may collect:

  • Resume
  • Motivational letter
  • Name, surname
  • Date of birth
  • Residential address
  • Phone number
  • Email address
  • Education, qualification
  • Names of current or past employers
  • Information about the type of work the person wants to perform
  • Other information provided by the candidate at their discretion
  • If you decide to contact us (by email, phone, or message on social media), we will record the fact of your inquiry and may retain the communication content along with your contact information and our responses.

    • For debt administration purposes, the Company may collect the customer's (or supplier's):

  • Representative's name, surname
  • Residential or domicile address
  • Phone number
  • Email address
  • Bank account number and bank name
  • Debt amount

    • The Company may obtain personal data from data subjects or other sources (e.g., population register, data provided by third parties) and link it with other information we receive from or about you. We may also receive information about you from third-party social media services when you log in through accounts such as "Facebook."

    You have the option not to provide us with certain information, but in such cases, we may not allow you to use our services as we cannot guarantee their quality. We emphasize that we do not collect or process excess personal data. All the data we collect is necessary to ensure proper and tailored service provision.



    BASIS OF DATA COLLECTION AND STORAGE DURATION

    To create service and other contracts, fulfill contractual obligations, and administer our clients, we collect data:

  • to fulfill a contract (Article 6(1)(b) of the Regulation),
  • when fulfilling legal obligations (Article 6(1)(c) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 10 years after the termination of the contract, the last collaboration, or the date of negotiations for the contract.

    To reserve your visit time, we collect data:

  • to conclude a transaction (Article 6(1)(b) of the Regulation).

    • We retain this data for 1 year from the last visit date.

    To perform a facial skin analysis when ordering a consultation with a cosmetologist or dermatologist, we collect data:

  • to conclude a transaction (Article 6(1)(b) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 3 years from the last visit date.

    To create an individual procedure plan and perform facial and body procedures, we collect data:

  • to conclude a transaction (Article 6(1)(b) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 3 years from the last visit date.

    To create an individual cream, we collect data:

  • to conclude a transaction (Article 6(1)(b) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 3 years from the last visit date.

    To administer the online store and process customer product orders, we collect data:

  • to conclude a transaction (Article 6(1)(b) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 3 years from the last date the customer used the online store services or accessed the website content.

    To organize training and other events, we collect data:

  • to conclude a transaction (Article 6(1)(b) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 5 years from the date of the respective event.

    If you are a winner of contests, promotions, or other games organized by us on social media:

  • to conclude a transaction (Article 6(1)(b) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data until the completion of the transaction.

    For video surveillance purposes, we collect data:

  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for up to 30 calendar days from the date of video recording, except when there is reason to believe that a crime or other unlawful actions have been recorded (until the end of the relevant investigation and/or case review).

    To process your requests, inquiries, questions, and complaints, we collect data:

  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 10 years from your last contact date.

    For direct marketing purposes, we may collect data:

  • with your consent (Article 6(1)(a) of the Regulation),
  • for cosmetologists, direct marketing is subject to the Law of the Republic of Lithuania on Electronic Communications, Article 69.

    • We retain this data for 5 years from the date of obtaining consent, or when direct marketing is carried out in accordance with Article 69 of the Law on Electronic Communications – until the individual expresses disagreement with direct marketing. Remember that you can do this at any time by contacting us at hello@odapro.eu or by phone at +370 688 86100.

    For employee and intern selection for our job and internship positions, we collect data:

  • with your consent (Article 6(1)(a) of the Regulation),
  • based on legitimate interests (Article 6(1)(f) of the Regulation).

    • We retain this data for 3 months from the end of the application submission period.

    For debt administration purposes, personal data is stored until the end of debt administration (debt liquidation) and taking into account the limitation periods set by legal acts (the Civil Code of the Republic of Lithuania and others).



    DISCLOSURE OF YOUR PERSONAL DATA?

    We disclose your personal data only to reliable third parties and only to ensure the high-quality provision of our services and the proper implementation of the purposes of personal data processing. Specifically, your data may be disclosed to:

  • Google (Google Analytics and AdWords services): Data is transferred to the USA and stored under the "Privacy Shield" program. Learn more here.
  • Facebook, Inc.: Data is transferred to the USA and stored under the "Privacy Shield" program. Learn more here.
  • Our partners providing delivery services:
  • DPD Lietuva: Review their data protection policy here.
  • Lietuvos paštas (Lithuanian Post): Review their data protection policy here.
  • Our partners providing electronic banking, electronic payments, payment services, and debt collection services:
  • Paypal: Review their data protection policy here.
  • Paysera: Review their data protection policy here.
  • Omnisend (newsletter sending platform): Review their privacy policy here.
  • Our partners providing information technology, electronic communications, advertising, auditing, legal, and other services.
  • State supervision and law enforcement institutions.

    • If a customer (or supplier) fails to pay for the services or goods provided in a timely manner, by the decision of the company, personal data for debt administration and debt collection purposes may be transferred to a third party - a debt management company.

    We will provide these service providers with only the personal information necessary to perform the specific service.

    HOW WE PROTECT YOUR PERSONAL DATA?

    Yes, we take all appropriate measures to protect your information. However, no website, online operation, computer system, or wireless connection is entirely secure. While we commit to making every effort to protect your personal data, we cannot guarantee the absolute security of the data transmitted on our platform. By transmitting any information, you assume the associated risk. Upon receiving your personal data, we will apply strict procedures and security measures regarding such data.

    YOUR RIGHTS

    Every data subject, meaning each of you whose data is processed in our operations, has the following rights:

  • To request confirmation whether we process your data and, if so, request access to the processed data and related information.
  • To request correction or, depending on the purposes of data processing, supplementation of incomplete personal data.
  • To request the deletion of information we have about you if it is used unlawfully.
  • To request the limitation of the processing of personal data if there are disputes about data accuracy, objections to data processing, refusal to delete unlawfully processed data, or if data is needed to express, enforce, or defend legal claims.
  • To request the transfer (receipt) of the data provided by you under the contract or with consent and processed by us through automated means, in a commonly used electronic format.
  • To object or withdraw consent to the processing of your personal data when it is processed or intended to be processed for direct marketing purposes, including profiling, as far as it is related to such direct marketing.
  • To express disagreement regarding the use of personal data when it is done in accordance with our or third-party legitimate interests.
  • To file a complaint with the State Data Protection Inspectorate (see www.ada.lt).

    • If you no longer want your personal data to be processed for direct marketing purposes or if you have any other request or instruction related to the processing of your personal data, please contact us at hello@odapro.eu.

    THIRD-PARTY WEBSITES, SERVICES, AND PRODUCTS ON OUR WEBSITE

    This website may contain third-party advertising panels, links to their websites, and services that we do not control, and we are not responsible for the security and privacy of the information collected by third parties. You should read the privacy policies applicable to third-party websites and services that you use.

    COOKIES

    This website uses strictly necessary, functional, analytical, and targeting (commercial) cookies (known as "cookies" in English), which help display our website, ensure its functionality, and facilitate convenient navigation. More information on how cookies work can be found on the website www.cookiecentral.com.

    The information related to cookies is not used to personally identify you, and the collected data is under our control. These cookies can be used for the following purposes:

  • Ensure smooth and efficient operation of the website.
  • Anonymously collect statistical information about how and which records you view.
  • Save your preferences chosen during your visit.
  • Collect reliable information about the use of the website, allowing us to determine whether the website meets the needs of users and improve it accordingly.

    • The legal basis for the processing of data created during the use of cookies is the legitimate interest of the Company. We do not link the visitor's IP address and email address with data that could identify the visitor. This means that each visitor's browsing session will be recorded, but the visitor to the www.odapro.lt website will remain anonymous.

    Strictly necessary, functional, and analytical cookies are a condition for using our website. If you refuse these types of cookies, we cannot guarantee how our website will function when you visit it. You can control the use of targeting (commercial) cookies by changing your browser settings.


    MANAGING AND DELETING COOKIES

    When using your browser to access our provided content, you can always configure your browser to accept all cookies, reject all cookies, or be notified when a cookie is sent. Each browser is different, so if you don't know how to change cookie settings, check its help menu. Your device's operating system may have additional cookie controls. If you don't want information to be collected through cookies, use a simple procedure available in many browsers that allows you to decline the use of cookies. To learn more about managing cookies, visit: https://www.allaboutcookies.org/manage-cookies/.

    DESCRIPTION OF COOKIES USED ON OUR WEBSITE

    Cookie Categories

    Cookie Name

    Cookie Purpose

    Cookie Storage Period

    Strictly Necessary Cookies

    cookies_choice

    Used to set cookie consent preferences

    Analytical Cookies

    _ga, _gid, _gat, _gcl_au

    Google Analytics cookies for evaluating website usage patterns. Note: IP anonymization is enabled for privacy. Google Analytics Privacy Policy

    Targeting (Commercial) Cookies

    _hjid, _hjIncludedInSample, Shopify-*****, _landing_page, _orig_referrer, _s, _shopify_fs, _shopify_s, _shopify_sa_p, _shopify_sa_t, _shopify_y, _y, _shopify_ga, tracked_start_checkout, utag_main

    Cookies for statistics, buyer behavior, and ensuring proper store functionality

    Note: Our website may also contain links to other individuals', companies', or organizations' websites. We are not responsible for the content of such websites or their privacy principles. Therefore, if you click on a link from our website to other sites, you should separately inquire about their Privacy Policy.

    CONTACT US

    If the Privacy Policy is unclear or if you have questions, requests, or complaints, let's talk! Send your inquiries via email to: hello@odapro.eu


    NOTIFICATION

    ABOUT THE PROCESSING OF PERSONAL DATA FOR PRODUCT TESTERS

    THIS NOTIFICATION IS INTENDED FOR INDIVIDUALS FILLING OUT THE EVALUATION FORM FOR THE TESTED PRODUCT. WE WANT TO INFORM YOU ABOUT THE PURPOSE OF COLLECTING YOUR PERSONAL DATA AND HOW WE INTEND TO PROCESS THEM.

    Who is your data controller?

    Your personal data is collected and managed by UAB "Oda group," company code 306318183, address Jonavos g. 7, LT-44191, Kaunas. For any questions related to personal data protection, please contact us via email at hello@odapro.eu.

    What personal data do we collect and for what purposes?

    All personal data provided by you expressing your interest in testing products and filling out the evaluation form (name, surname, age, signature, your answers to the questionnaire, which may include information related to your skin condition (e.g., data about allergic reactions, skin type, products used for the skin, skin problems, and its condition)) as well as your contact details (email address, phone number, address for product delivery) are used exclusively for the purpose of product testing, aiming to create and deliver products that meet the needs of our customers. All this personal data is collected and processed with your consent (General Data Protection Regulation Article 6(1)(a) and Article 9(2)(a) (applicable to health data)). We emphasize that we do not disclose or use your personal data for any other purposes.

    How long will we keep your personal data?

    We retain all the above-mentioned personal data for 6 months while the product development process is ongoing. After this period, personal data is securely destroyed.

    To whom may we disclose your personal data?

    Your personal data may be processed by companies within the Oda group that we engage in our product development process. Access to personal data may also be granted to these data recipients and processors: IT service providers overseeing and servicing our email system and IT infrastructure.

    What rights do you have as a data subject?

    In accordance with the provisions of the General Data Protection Regulation, you have the following rights:

    • Request access to your processed personal data;
    • Request correction of inaccurate, incomplete, or incorrect personal data;
    • Request the deletion of your personal data in cases and order provided by law;
    • Request restriction of the processing of your personal data in cases and order provided by law;
    • The right to object to the processing of your personal data;
    • The right to appeal to the State Data Protection Inspectorate if you believe that your personal data is processed unlawfully.

    For questions regarding the processing of your personal data, the implementation of your rights as a data subject, security measures applied, and any other data protection-related matters, please contact us via email at hello@odapro.eu.