PRIVACY POLICY

We are aware of the particular importance we attach to the protection of your personal data and therefore we collect and process only the data necessary for the performance of our activities. We process personal data lawfully, transparently and fairly, for predefined purposes and only to the extent necessary to achieve those purposes. When we process personal data, we aim to keep it accurate, secure, confidential, properly stored and protected.

In processing your personal data, we comply with the requirements of the General Data Protection Regulation ("GDPR"), the Law on Legal Protection of Personal Data of the Republic of Lithuania, as well as the requirements for the processing of personal data set out in other legal acts.

1. WHAT IS THIS DOCUMENT?

1.1 This privacy policy ("Privacy Policy") sets out the privacy terms and conditions for your use of the Website. For the purposes of this Privacy Policy, the "Website" refers to the website autoplius.lt and/or the Autoplius.lt mobile application, which can be downloaded from the Apple App Store and Google Play.

1.2 Please read this Privacy Policy carefully to find out how we process your personal data, where we obtain it from and what your rights are as a personal data subject.

1.3 If you use the Website, you have read and understood this Privacy Policy and the purposes, methods and procedures for processing your personal data as set out herein.

1.4 As used in this Privacy Policy, "personal data" means any information from which you can be identified, whether directly or indirectly. Personal data includes name, surname, date of birth, postal or e-mail address, location data and internet identifier, characteristics specific to you, etc.

1.5 This Privacy Policy applies to all persons who visit the Site, as well as to actions you may take on the Site.

2. WHO ARE WE?

2.1 The Website is managed and administered by UAB "Diginet LTU", legal entity code 126222639, address Saltoniškių 9b, Vilnius. The contact telephone number of the person responsible for the protection of personal data is +370 5 2525 008, e-mail address is [email protected].

2.2 In accordance with the provisions of legislation, we are the controller of your personal data.

3. WHAT PRINCIPLES DO WE FOLLOW?

3.1 In processing your personal data we:

 (a) comply with the requirements of applicable and valid legislation, including the GDPR;

 b) process your personal data in a lawful, fair and transparent manner;

 c) collect your personal data for specified, clearly defined and legitimate purposes and will not further process it in a way that is incompatible with those purposes, except to the extent permitted by law;

 d) we will take all reasonable steps to ensure that personal data which are not accurate or complete in relation to the purposes for which they are processed are rectified, supplemented, suppressed or erased without delay;

 (e) we will keep them in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;

 (f) we will not disclose personal data to third parties or make them public, except as provided in the Privacy Policy or applicable law;

 (g) we will ensure that your personal data is processed in such a way as to ensure, by appropriate technical or organisational measures, adequate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

4. HOW DO WE COLLECT YOUR PERSONAL DATA?

4.1 We process your personal data obtained in the following ways:

 (a) when you provide personal data to us. You provide us with your personal data and other information when you use the Website, write to us or communicate with our customer service team by phone or email, submit your complaints and/or queries, subscribe to our newsletter or otherwise;

 b) when you use the Website. When you use the Site, certain information (e.g. the type of web browser you use, the number of times you visit the Site, the pages you view on the Site, etc.) is collected automatically;

 c) when we receive your personal data from other persons in accordance with the procedure established by law and/or this Privacy Policy.

4.2 To the extent permitted by applicable law, we may combine the personal data we have received from you in connection with your use of the Site with:

 (a) the personal data we have obtained from you through the use of other websites operated and managed by us (www.skelbiu.lt, www.cvbankas.lt, www.aruodas.lt, www.ntzemelapis.lt, www.kainos.lt, www.paslaugos.lt, www.autoistorija.lt) or the mobile applications of those websites;

 (b) collected by us from other public or accessible sources (e.g. We may combine the personal data you provide with data obtained through the use of cookies on the Website or with data lawfully obtained from third parties).

5. WHAT PERSONAL DATA DO WE PROCESS AND FOR WHAT PURPOSES?

5.1 We process your personal data for the following purposes:

 (a) for the purpose of registration, identification and provision of services. You provide us with your personal data when you use the Website, register on the Website (create an account), upload content that you have created on the Website (e.g., ads, descriptions of ads, photos of goods or services that you buy or sell, etc.). We also process your personal data when you register on or use the Website as a representative and/or contact person of a legal entity. Personal data processed for this purpose includes:

Categories of data	Name, e-mail address, telephone number, place of residence (city), IP address, mobile phone number, other content you have created and uploaded to the Website (e.g. text of an advertisement, photo, etc.)
Legal basis for processing the data	Contract (Terms of Use)
Term of processing	5 years from the date of your last login to your account
We receive data from	From you; from third parties (including but not limited to banks or payment service providers, mobile operators).
We provide or transfer the data	To users of the Website when a buyer and seller seek to contact each other by telephone and/or email in relation to advertisements placed on the Website.

 

(b) for the purpose of providing paid services, payment, accounting and billing control, debt management and debt collection. You provide us with your personal data when you subscribe to paid services provided by us on the Site. Personal data is processed for this purpose:

Categories of data	Name, surname, e-mail address, telephone number, VAT number, details of the provision of services (e.g. start date, end date, duration, status, etc.), details of the services ordered and used and the charges for them, details of invoices issued and payment information (e.g. e.g. services rendered, date, number of invoice, amount due or paid, method of billing and payment of invoice, date of payment, status of payment, data relating to debt (e.g. date of incurrence of debt, amount of debt, type of debt, etc)
Legal basis for processing	Contract (Terms of Use)
Time limit for processing	10 years from the date of receipt of payment for the service
We obtain the data from	From yourself; from third parties: your mobile operator, bank or electronic money institution where you have an account;
we provide or transfer the data	to your mobile operator, bank or electronic money institution where you have an account; to the data necessary for the payment of the service, where it is necessary to identify you as a user of the Website who subscribes to a paid service on the Website; to debt collection companies that act as intermediaries in the recovery of the debt, and then only to the extent necessary for the initiation and execution of the recovery of the debt.

 

(c) for the purpose of quality assurance and communication. You provide us with your personal data by writing to us, emailing us or communicating with our customer service team by telephone (telephone conversations are recorded) with your complaints, queries about the Site or our services. Personal data is processed for this purpose:

Categories of data	Name, surname, e-mail address, telephone number, place of residence (address), content of the complaint and/or request made in writing (e.g. date and content of the letter, etc.), by e-mail (e.g. date and content of the e-mail, etc.), by telephone (e.g. telephone number, record of the call, date, time and duration of the call, data provided during the call, etc.)
Legal basis for processing	Contract (Terms of Use), as well as our legitimate interest in evaluating the feedback of our customers in order to improve the quality of our activities and services, consent to the recording of telephone conversations.
Duration of processing	2 years from the date of your enquiry to us, in the case of written enquiries 2 years from the date of your enquiry to us, where the enquiry is made in writing, by email 2 years from the date of your enquiry to us, where you make the enquiry by telephone, the recording of the telephone conversation is kept for 3 months.
We obtain the data from	From you; we may create personal data ourselves in the course of carrying out an enquiry or analysing a complaint (e.g. after receiving your complaint, we contact our staff about the actual circumstances of the complaint and record them, etc.); from third parties.
We provide or transfer the data	To mobile operators, banks and payment institutions, payment intermediaries.

(d) for direct marketing purposes. We process your personal data with your consent in order to provide you with newsletters, offers, including personalised offers, and information about our, our affiliates' and our partners' services and/or goods, or other information to improve our services. If you have consented to the use of your data for this purpose by registering on or using the Website (e.g. by placing an advertisement), we will not only process your personally identifiable data for this purpose, but also analyse your behaviour on the Website and the history of your orders for services, in order to get to know you better and to tailor our offers according to your needs and to provide you with other tailored benefits. For this purpose, we use automated data analysis and decision-making, including profiling, which, by grouping together data that identifies you and/or data about the services you have ordered on the Site, your behaviour on the Site, can provide you with relevant, interesting and useful offers and other information. Personal data is processed for this purpose:

Categories of data	Name, telephone number, e-mail address, details of the services ordered on the Website (e.g. date and time of services ordered, name of the services, quantity of services, type of services ordered), history of personalised offers made to you by and information about the use of these offers
Legal basis for processing the data	Your consent to receive newsletters, offers, including personalised offers, and information
Duration of processing	2 years from the date of your consent to receive newsletters, offers, including personalised offers, and information
We receive data from	From you, including through your use of the Website.
We provide or transfer the Data	To companies providing newsletter services, business management information systems, and the administration of the Site itself.

Please see Section 6 of this Privacy Policy for more details about the processing of personal data for direct marketing purposes.

(e) for the purpose of providing and administering the Virtual Number Service and ensuring Customer privacy. We provide a "virtual number" service to our Clients, the authors of the advertisement. This "virtual number" service allows us to automatically forward your calls addressed to our contact telephone number indicated on the advert to our Client, the author of the advert. Customers' personal telephone numbers are not provided with the adverts, including to protect the privacy of our Customers, so you can only contact us via our contact (virtual) number regarding Customer adverts of interest. Therefore, for the purpose of providing and administering the virtual number service and to ensure Customer privacy, the following personal data will be processed:

 

Data categories	Telephone number, information about the time of the call, whether or not the Customer answered the call
The legal basis for processing the data	Our legitimate interest
Duration of processing	Up to 2 years from the date of your call, unless we are processing the data for longer in order to resolve a dispute between us or to preserve evidence of it
We receive data from	Your own
We provide or transfer the data	To the author of the advertisement - the Client

When we process your personal data on the basis of our legitimate interest (Article 6(1)(f) of the GDPR), you always have the right to object to such processing by us. We will evaluate your objection and will not process your personal data unless we believe that our processing is carried out for compelling legitimate reasons which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Information about your rights and how to exercise them is set out in section 12 of this Privacy Policy.

f) For the purpose of providing the Vehicle History Check System Services. In order to improve the quality of our vehicle history checking services, we will pass on the vehicle listing data you submit to the Website to the administrators of vehicle history checking systems. It should be noted that your contact details and free-form comments about your advert are not transferred to the vehicle history check systems. We make every effort to reduce the amount of personal data transferred before transferring the data, e.g. de-personalisation of the vehicle registration numbers visible in the photographs of the advertisement.

Data categories	Content created by you and uploaded to the Website (photos and technical data of the car, motorcycle or other vehicle, e.g. mileage information, technical parameters).
Legal basis for processing the data	The legitimate interest of the operators of the vehicle history checking systems in collecting all relevant information on the history of a particular vehicle at different stages of its use, and in providing detailed information to persons interested in . It is in the legitimate interest of persons purchasing reports from vehicle history checking systems to have access to the historical technical data of the vehicle of interest, to ascertain the accuracy of its technical condition, accidents or mileage data.
Time limit for processing the data	The specific time limit shall be determined by the operators of the vehicle inspection systems. The time limit is based on the average age of the vehicles sold.
The data is obtained from	Your own data (data provided in the advertisement on the Website)
We provide or transfer the data	Vehicle history check system operators.

 

g) For the purpose of ensuring the functionality of the Website, as well as for the purpose of improving the Website and offering you better and more tailored services. We use your personal data, including personal data and cookies that we receive when you use our Website, to improve and develop the Website and to offer you better and more tailored services.

For this purpose, we use the personal data we receive from you, generated by your use of the Website and/or received from others.

Please see section 7 of this Privacy Policy for more information on how we use cookies and similar technologies.

 h) for other purposes as set out in our Personal Data Processing Rules and/or other internal documents, where we are required to process your personal data by law or where there is a legitimate interest.

5.2 We do not ask for or process special categories of personal data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or health data, or data concerning your sex life and sexual orientation. In the event that you provide us with such data through the Website, or otherwise (in writing, by email, by telephone), it will be deemed to have been provided with your consent. Accordingly, we will process this data together with other data that you have provided in the ways set out in point 5.1 of this Privacy Policy, unless the data cannot be separated from each other or would require a disproportionate effort.

6. DO WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING?

6.1 With your additional consent, we may use your personal data for the purpose of direct marketing in order to provide you with newsletters, offers, including personalised offers, and information about our, our affiliates' and our partners' services and/or products that we think may be of interest to you. However, we will only use your personal data for this purpose with your additional consent.

6.2 For this purpose, we process your personal data as set out in clause 5.1 (d) of the Privacy Policy.

6.3 You can choose whether you allow us to use your personal data for direct marketing purposes. You can do this by:

 (a) by registering on the Website, placing an advertisement on the Website or by ticking the consent text "I agree to receive newsletters, offers by email" in the Settings/Notifications section of your account or by leaving it unticked at any time after registration;

 b) when registering on the Website, posting an advertisement on the Website or at any time after registration, by ticking the consent text "I agree to receive newsletters, offers by telephone" in the Settings/Information Notifications section of my account, or by not ticking it;

6.4 By granting us the right to process your data for the purpose of direct marketing, you also grant us permission to contact you for this purpose by appropriate means of communication (e.g. email, telephone, SMS) or other means of communication (e.g. Skype, Viber, etc).

6.5 We may combine the information we hold about you with information held by third parties.

6.6 If you consent to the use of your personal data for direct marketing purposes, we may use your personal data to analyse and improve the effectiveness of our websites, advertising and market research, and for other corporate marketing and sales purposes. In this case, we will use your personalised data.

6.7 Even if you have given your consent to the processing of your personal data for direct marketing purposes, you can easily withdraw this consent at any time for all or part of the processing. To do so, you can:

 a) Change the settings in the Settings/Information Notifications section of the Website to indicate that you no longer want your personal data to be used for direct marketing purposes and untick the boxes next to "I agree to receive newsletters, offers by email" or "I agree to receive newsletters, offers by telephone" or

 (b) to notify your unsubscription in the manner indicated in the newsletters, offers received by e-mail (e.g. by clicking on the link "Unsubscribe from newsletters, offers" or similar in the newsletters, offers or by replying to the "Unsubscribe" text message in the text messages received by telephone); or

 (c) send us a request by email to[email protected] . The request must clearly state your name and other registration details (if any). If you wish to withdraw your consent in this way, we may ask you to provide proof of identity.

6.8 If you withdraw your consent, we will endeavour to stop processing your personal data for direct marketing purposes as soon as possible.

6.9 Withdrawal of consent does not automatically oblige us to destroy your personal data or to provide you with information about our processing of your personal data, so if you wish us to do these things as well, you must make a separate request.

7. HOW DO WE USE COOKIES?

7.1 We collect information about you through the use of cookies and similar technologies. Cookies are small files that are temporarily stored on your device's hard drive and allow us to recognise you on subsequent visits to the Site, save your browsing history, preferences, customise the content, speed up searches on the Site, create a user-friendly and friendly Site environment, and make the Site more efficient and reliable. Cookies are a common practice on websites that make it easier to use the website.

7.2 Cookies allow us to collect the following information: your IP address, the type of web browser you are using, the number of times you have visited the Site, the pages you have viewed on the Site, the amount of time you have spent on the Site, your demographics, and, if you have come to the Site from a third-party website, the URL link of the page.

7.3 We use the information we receive via cookies for the following purposes:

 (a) to ensure the functionality of the Site (e.g. to enable you to personalise the Site);

 b) to help us improve and develop the Site to better meet your needs;

 c) to develop our services and to analyse the use of the Site;

 d) for targeted marketing.

7.4 We may, without prejudice to the law, combine information obtained through the use of cookies with information obtained about you by other means (e.g. combining information about your use of the Site with personal data you have provided).

7.5 The Website may use the following cookies:

 (a) technical cookies - these are cookies that are necessary for the operation of the Website;

 b) functional cookies - these are cookies which, although not essential for the operation of the Website, significantly improve its performance, quality and user experience;

 c) analytical cookies - these are cookies that are used to compile a statistical analysis of the navigation methods of visitors to the Website; the data collected by these cookies is used anonymously;

 d) targeting or promotional cookies - these are cookies used to display offers or other information that may be of interest to you;

 e) social networking cookies - these are cookies that are necessary for you to use the Site information in your social profile account.

7.6 You can give your consent to the use of cookies by clicking on the "I agree" link (bar) on the Site about cookies.

7.7 You may withdraw your consent to use cookies at any time. You can do this by changing the settings on your web browser so that it does not accept cookies. How you do this depends on the operating system and web browser you are using. For detailed information on cookies, their use and your options for refusing them, please visit http://AllAboutCookies.org or http://google.com/privacy_ads.html.

7.8 In some cases, in particular for technical and functional cookies, disabling, not accepting or deleting cookies may slow down the speed of your browsing on the Internet, restrict the functioning of certain functions of the Website, or block access to the Website.

8. WHO DO WE PROVIDE YOUR PERSONAL DATA TO?

8.1 We guarantee that your personal data will not be sold, provided or otherwise transferred to third parties without lawful basis, or used for purposes other than those for which they were collected. We will not transfer your personal data in any way other than in accordance with this Privacy Policy or applicable law. However, we reserve the right to disclose information about you if we are required to do so by law or if we are requested to do so by lawful law enforcement authorities or prosecuting authorities.

8.2 We may transfer your personal data to companies that assist us in our business activities, including direct marketing and other companies within the Baltic Classifieds Group. We require such partners to process your data only in accordance with the instructions we have given them and the applicable data protection legislation. We enter into contracts with these individuals which oblige the parties to strictly comply with the requirements for the protection of personal data.

8.3 We may disclose the data we collect about you to the following third parties:

 (a) third party service providers (e.g. technical service providers in the performance of our contracts with these service providers, including the performance of services for sending newsletters or other marketing activities);

 (b) to third party service providers whose services we generally use for data storage, telecommunications and website hosting purposes;

 (c) providers of vehicle history checking systems;

 d) other companies within the Baltic Classifieds Group group of companies, insofar as this does not conflict with the requirements of mandatory legislation applicable to us.

8.4 The above service providers are limited in their ability to use your data and may not use it for purposes other than to provide services to us or for the purposes specified in the data provision agreement.

8.5 A list (non-exhaustive) of the persons and categories of persons to whom we transfer your personal data is set out in clause 5.1 of this Privacy Policy, separately for each purpose for which we use personal data.

9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

9.1 We will keep your personal data for no longer than the purposes of processing or the law requires, unless a longer retention period is specified in the law.

9.2 We aim not to keep outdated, irrelevant personal data, so only relevant information is retained when it is updated. Historical information is retained if required by law or for the purposes of our business.

9.3 Section 5.1 of the Privacy Policy sets out the retention periods for your personal data separately for each of the purposes for which it is used.

10. HOW DO WE STORE YOUR PERSONAL DATA?

10.1 The data we collect from you will be located in the territory of the European Economic Area (EEA) and in the countries for which the European Commission has adopted an adequacy decision (Safe Countries), but may also be transferred to, or stored in, countries outside the EEA and the aforementioned Safe Countries. In exceptional cases, they may also be processed by our, the Baltic Classifieds Group's group of companies' or our suppliers' personnel outside the EEA or the safe countries. When we transfer your data outside the EEA or safe countries, we will take all necessary steps to ensure that your data is processed securely and in accordance with this Privacy Policy.

10.2 Unfortunately, the transmission of information over the internet is not completely secure. Whilst we take great care to protect your personal data, we cannot guarantee the security of the data when you transmit data to the Site - you assume the risks associated with the transmission of data to the Site. Once we receive your data, we will implement strict procedures and security measures to protect your data from unauthorised access.

10.3 In the unlikely event that we become aware of a breach of security of your personal data which may pose a significant threat to your rights or freedoms, we will notify you immediately upon becoming aware of it and determining what information has been accessed.

11. EXTERNAL WEBSITES

11.1 The Website may contain links to external websites, such as those of our business partners or websites that advertise our services and/or goods. If you follow such links to any of these sites, please note that these sites and the services available through them have their own separate privacy policies and we do not accept any responsibility or liability for these policies or for the personal data, such as contact or location data, collected on these sites or through the provision of services. Please review these policies before submitting personal data to these websites or using any services.

12. WHAT RIGHTS DO YOU HAVE?

12.1 When processing personal data, we ensure your rights under the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a data subject you have the following rights:

 (a) to know (be informed) about the processing of your personal data;

 b) to have access to your personal data that we process;

 c) to request the rectification or supplementation of your personal data, or the correction of inaccurate or incomplete personal data;

 d) require the destruction of personal data when it is no longer necessary for the purposes for which it was collected;

 e) require the destruction of personal data where they are processed unlawfully or where you withdraw or withhold your consent to the processing of personal data, which is necessary;

 (f) to object to the processing of personal data or to withdraw your prior consent;

 g) require the suspension (other than storage) of the processing of your personal data in the event of disputes or to verify the lawfulness of the processing, the accuracy of the data, or where we no longer need your personal data, but you do not want us to delete it;

 h) require the provision, where technically feasible, of your personal data collected pursuant to your consent or for the performance of a contract in an easily readable format, or request that it be transferred to another controller.

12.2 We will endeavour to guarantee the exercise of your rights as a data subject and to provide all the conditions for the effective exercise of those rights, but we reserve the right not to comply with your requests where it is necessary to ensure

 (a) compliance with legal obligations imposed on us;

 (b) national security or defence;

 (c) public order, the prevention, investigation, detection or prosecution of criminal offences;

 (d) important economic or financial interests of the State;

 (e) the prevention, investigation and detection of breaches of official or professional ethics;

 (f) the protection of your rights and freedoms or the rights and freedoms of others.

12.3 You may make requests to us in relation to the exercise of your rights, including the rights set out in paragraph 12.2 above:

 (a) in person or by post to our registered office at Saltoniškių 9b, Vilnius, Lithuania;

 b) by e-mail to [email protected]

   Upon receipt of your request, we may ask you to provide proof of identity, as well as any additional information we require to fulfil your request.

12.4 Upon receipt of your request, we will respond to you no later than 30 calendar days from the date of receipt of your request and the submission of all the documents necessary to respond.

12.5 If we believe there are grounds, we will suspend the processing of your data, except for storage, until your request has been resolved. If you lawfully withdraw your consent or request deletion of your data, we will take steps to delete your personal data without undue delay, but at the latest within 30 calendar days, unless applicable law, a court decision or binding authority order requires us to continue processing it (see also 12.2).

12.6 If we refuse to comply with your request, we will clearly state the grounds for such refusal.

12.7 If you disagree with our actions or our response to your request, you may complain about our actions and decisions to a competent public authority.

13. WHO CAN YOU COMPLAIN TO?

13.1 If you wish to make a complaint about our processing, please submit it in writing, providing as much information as possible, using the contact details provided at the end of this policy. We will co-operate with you and endeavour to resolve any issues promptly.

13.2 If you believe that your rights under the GDPR have been infringed, you may lodge a complaint with our supervisory authority, the State Data Protection Inspectorate, for further information and contact details please visit the Inspectorate's website (https://vdai.lrv.lt/). Although, first and foremost, we aim to resolve any disputes promptly and amicably with you.

14. HOW WILL THIS PRIVACY POLICY BE AMENDED?

14.1 Any changes to our Privacy Policy will be posted on the Website. We will notify you of any changes where necessary. New terms of the Privacy Policy may also be posted on the Site and you may need to read and agree to them in order to continue using the Site and/or our services.

15. HOW TO CONTACT US?

15.1 Please send all documents relating to this Privacy Policy to or contact us at the contacts listed below:

 (a) by post - UAB "Diginet LTU", address Saltoniškių g. 9b, LT - 08105 Vilnius;

 (b) by email - [email protected]

Date of publication of the Privacy Policy 20 August 2025