Privacy Notice

Regarding the Processing of Personal Data for Direct Marketing Purposes
Effective as of: 22 May 2025

In this privacy notice, we provide information about the processing of personal data by Mark ID, UAB (hereinafter referred to as Mark ID) for direct marketing purposes (sending newsletters, invitations to participate in surveys, use of pixels, etc.), i.e. we indicate what personal data and on what basis we process for direct marketing purposes, how long we store it, to whom we may transfer personal data and what rights data subjects have whose personal data we process for direct marketing purposes.

The terms used in this privacy notice (e.g. data controller, data processor, data subject, etc.) are understood as they are defined and interpreted in 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 (General Data Protection Regulation) (hereinafter referred to as the Regulation).

I. DATA CONTROLLER

The data controller for the personal data processing described in this Privacy Notice is: Mark ID, UAB, Company code: 305098955, Address: Žygio g. 97A, Vilnius, LT-08236, Lithuania, Email: [email protected], Website: https://marksign.eu

II. DATA PROTECTION OFFICER  

The Company has a designated Data Protection Officer. If you would like to inquire or find out how We process your personal data, if you intend to exercise your rights as a data subject, you can contact the Data Protection Officer designated by the Company directly by email: [email protected].

III. SOURCES OF PERSONAL DATA 

We receive the personal data that we process for the purpose of direct marketing (opt-in) directly from you when:

  • You subscribe to the Mark Sign newsletter on the news subpage of the Mark Sign website (here);
  • You choose to receive the newsletter on the Mark Sign self-service portal (here): a) in a pop-up window during login; b) during registration;
  • You indicate the need to receive the Mark Sign newsletter in the appropriate form, which you fill out and submit your personal data on the Mark Sign website.

We may also receive the personal data that we process for the purpose of direct marketing (opt-out) directly from you when concluding a contract for services provided by the Company. By providing personal data in this way, you are given a clear, free and easily implementable option to object to or refuse the use of your contact data for the purpose of direct marketing (opt-out).

Please note that the Company’s direct marketing (both opt-in and opt-out) includes the use of pixels. With the help of pixels, personal data is collected directly from the data subjects themselves (e.g. when they open a direct marketing message sent to their email).

We inform you that you are not obliged to provide us with any of your personal data and/or consent to the processing of personal data for the purpose of direct marketing, however, we inform you that without providing data and consent, we will not be able to send you personally (to your email inbox) news related to Mark ID activities.

IV. LEGAL BASIS FOR DATA PROCESSING

We process personal data for the purpose of direct marketing (“opt-in” method) based on the consent of the data subject (Article 6(1)(a) of the Regulation, Article 81(1) of the Law on Electronic Communications of the Republic of Lithuania).

You can express your consent to the processing of personal data for the purpose of direct marketing in the ways/channels specified in Section III of this privacy notice. You also have the right to withdraw the consent given at any time and demand the termination of further processing of your personal data for the specified purpose. You can withdraw your consent by writing a free-form request by e-mail to [email protected] or in the manner specified in each direct marketing message sent to you by e-mail. We inform you that the withdrawal of consent does not affect the lawfulness of data processing based on consent carried out before the withdrawal of consent.

We inform you that when providing services under contracts, we receive e-mail addresses from our customers (data subjects), which we may use for marketing of our similar services and newsletters, if the data subject does not object to such processing of personal data. Data subjects are given a clear, free and easily implementable opportunity to object to or refuse such use of contact data for the above-mentioned purposes when these data are collected (i.e. at the time of signing the contract) and, if the data subject has not initially objected to such use of data, when sending each e-mail. In such case, the Company processes personal data for the purpose of direct marketing, based on legitimate interest (Article 6(1)(f) of the Regulation, Article 81(2) of the Law on Electronic Communications of the Republic of Lithuania).

We would like to point out that the direct marketing carried out by the Company (both (opt-in and opt-out)) also includes the use of pixels (personal data collected with the help of the latter are processed for the same marketing purposes), therefore the consent given by the person or the unexpressed objection to the processing of personal data for the purpose of direct marketing also includes consent to the use of pixels for the same purposes.

V. SCOPE OF PERSONAL DATA PROCESSED

When sending direct marketing messages (newsletters, invitations to participate in surveys, etc.), we process the following personal data:

Identification data: name, surname;

Contact data: email address;

Other personal data: represented company (representatives of legal entities), content and date of sent messages, information about reading the received message, method/channel and date of giving consent to direct marketing.

VI. RETENTION PERIOD

We process and store personal data for the purpose of direct marketing (opt-in) for 5 years from the date of consent or until you withdraw your consent. We process personal data for the purpose of direct marketing (opt-out) for the period of validity of the Company’s service provision agreement concluded with you or until you object to the processing of personal data for the specified purpose.

VII. DATA SHARING

Personal data that we process for the purpose of direct marketing is not and will not be transferred to third parties (who act as independent data controllers), except in cases where legal acts oblige otherwise. Personal data is also not transferred outside the European Union and (or) the European Economic Area.

We also inform you that in certain cases we may use Google, Inc. and Meta Pixel services (products), the standard terms of provision (use) of which provide for the possibility of processing personal data (storage, storage, transfer, if necessary, etc.) in third countries. Nevertheless, Google, Inc.’s standard service agreements confirm that this company complies with the personal data protection requirements applicable in the European Union. In addition, we may use data processors who, in accordance with our instructions and to the extent determined by us, will process personal data to the extent necessary to provide their services. At the same time, we note that when using other data processors, we aim to ensure that the data processors have also implemented appropriate organizational and technical security measures and maintain the confidentiality of personal data (we sign data processing agreements with the data processors used).

VIII. DATA SUBJECT RIGHTS

We would like to inform you about your rights under the Regulation:

  • Right to access data. You have the right to request confirmation as to whether personal data concerning you is being processed and to request information about this data in accordance with the provisions of Article 15 of the Regulation.
  • Right to rectify personal data. In accordance with the provisions of Article 16 of the Regulation, you have the right to request the completion or rectification of inaccurate data concerning you.
  • Right to erase personal data. In accordance with the provisions of Article 17 of the Regulation, you have the right to request that specific data be erased in the circumstances provided for in the article.
  • Right to restriction of data processing. In accordance with the provisions of Article 18 of the Regulation, you may request the restriction of data processing in the circumstances provided for in the article.
  • Right to data portability. In accordance with the provisions of Article 20 of the Regulation, you have the right to request the receipt of the data provided to us and, in addition, to request that they be transferred to other data controllers/processors.
  • Right to object. In accordance with the provisions of Article 21 of the Regulation, you may object to the processing of your data at any time with effect for the future.
  • Right to withdraw consent. Pursuant to Article 7(3) of the Regulation, you have the right to withdraw your consent at any time.
  • Right to lodge a complaint with a supervisory authority. Pursuant to Article 77 of the GDPR, you have the right to lodge a complaint with the competent supervisory authority – the State Data Protection Inspectorate.

You may apply for the exercise of your data subject rights orally or in writing, by submitting a request in person, by post or by electronic means using the contacts specified in this privacy notice.

When submitting a request for the exercise of your data subject rights, you must confirm your identity. The methods of confirming your identity depend on the method of application: if you submit it by e-mail, the request must be signed with a qualified electronic signature; if the request is submitted by post (through postal service providers), then a copy of your identity document must be submitted with the request. Failure to do so will result in us being unable to accept your request and the data subject’s rights will not be implemented.

IX. CONTACT US

If you have any comments, questions or complaints regarding this privacy notice, you can contact us by e-mail: [email protected].

More information about the Company’s processing of personal data can be found on the Company’s website in the Personal Data Protection section.