Privacy policy

  1. WHAT DOES THIS PRIVACY POLICY MEAN?

In this Privacy Policy (Privacy Policy) we will provide information on how Closed Joint
Stock Company “GeoFace” (GeoFace) processes your personal data whenever you use our
mobile application or website (App), or other services run by GeoFace.

  1. ABOUT GEOFACE

Closed Joint Stock Company “GeoFace”, legal entity code: 304781617, registered office address: Brastos
g. 14, LT-47185 Kaunas, e-mail address:

[email protected]

, is a part of the AB Akola group Group of companies and is the controller of your personal data.

In some cases, GeoFace may be a joint controller of your personal data with other company(s) within the
AB Akola group.

  1. WHAT IS PERSONAL DATA?

Personal data is any information collected by GeoFace about a natural person and used to identify that
person. Personal data includes, among other things, the person’s first name, last name, address, and IP
address.

  1. WHAT KIND OF PERSONAL DATA DO WE PROCESS?

GeoFace processes your personal data for the following purposes:

4.1. For creating your App account

The following personal data will be processed by GeoFace to create your App account: your first name,
last name, email address, phone number, address, area (hectares) of fields owned, information as to
whether you are a farmer or an agronomist, company name and corporate ID number. This personal data will
be processed based on the agreement and will be kept for 2 (two) years after the last log-in to the App
account or will be deleted within 30 (thirty) days after deletion of the account.

4.2. For enabling your use of the App and technical support

The following personal data will be processed to enable your use of the App: your first name, last name,
email address, phone number, address, area (hectares) of fields owned, information as to whether you are
a farmer or an agronomist, company name and corporate ID number, farm name, farm field name, comments,
photos, types of problems emerging on the farm field, geographical location information (GPS data),
field boundaries and outdoor satellite images from open sources (if deemed to constitute personal data”
under the applicable laws), number of seedlings per each square meter and the following automatically
collected metadata: device information (including hardware type, operating system, version, etc.),
information about the program used (frequency of use, problems encountered, etc.). This personal data
will be processed based on the agreement and will be kept for 2 (two) years after the last log-in to the
App account or will be deleted within 30 (thirty) days after deletion of the account.

The personal data referred to above may also be processed if you contact a GeoFace manager or submit a
written request due to a technical problem with the App. In this case, the troubleshooting will be
carried out by a GeoFace employee with your permission logging into your account and carrying out the
necessary technical work.

4.3. For communicating with users of the App

GeoFace may send information or notifications to your email address or give notifications on the App
about any of its modifications, updates, problems, etc. To that end, the following personal data will be
processed: your first name, last name, email address and phone number. This personal data will be
processed based on the agreement and will be kept for 2 (two) years after the last log-in to the App
account or will be deleted within 30 (thirty) days after deletion of the account.

If you refer any emerging problem or issue regarding the App to us, your personal data, i.e., your first
name, last name, email address and other details contained in your request, will be processed by GeoFace
on the grounds of the legitimate interest to ensure the quality of the services provided. Such personal
data submitted for communication with users (for customer service purposes) will be kept throughout the
entire communication period and 2 (two) years thereafter.

4.4. For sending offers to customers

Based on your consent (given when registering or logging in to your account), the following personal
data will be processed by GeoFace for direct marketing purposes: your first name, last name, email
address and phone number (if given when registering). This personal data will be processed based on your
consent and will be kept for 3 (three) years after your consent is given. Each time you receive a direct
marketing communication, you will have an option to opt out of direct marketing communications by
notifying GeoFace via email or as otherwise specified by us.

For this purpose, GeoFace, as a joint data controller, processes personal data jointly with other
companies of the AB Akola group group, the following companies: the AB “Linas Agro” (legal entity code:
147328026, registered office address: Smėlynės g. 2C – 3, LT-35143 Panevėžys, e-mail address:

[email protected]

, the UAB “Dotnuva Baltic” (legal entity code: 261415970, registered office address: Parko g. 6,
LT-58350 Akademijos mstl, Dotnuvos sen., Kėdainių r. sav., e-mail address:

[email protected]

, UAB “Dotnuva Rent” (legal entity code: 161452398, registered office address: Parko g. 6, LT-58350
Akademijos mstl., Dotnuvos sen., Kėdainių r. sav., e-mail address:

[email protected]

on the basis of the concluded agreement of the joint data controllers.

4.5. Social media

Information communicated to GeoFace when visiting our social media sites (including notifications, use
of “Like” and “Follow” buttons or other communication) will be controlled by us
jointly with social media managers as joint controllers.

Currently, we maintain the following social media accounts:

Please read the third-party privacy policy and contact the service provider directly if you have
questions on how your personal data is used by them.

4.6. For making and performing contracts by GeoFace

GeoFace will process personal data of employees of its suppliers, service providers or partners (who are
legal persons) and personal data of its suppliers, service providers or partners (who are natural
persons) for performing contracts made between GeoFace and such persons. In that case, the following
personal data will be processed by GeoFace: your first name, last name, birth date, phone number, email
address, contents of correspondence, date and other details relating to the contractual performance.

If you are subject to App charging, GeoFace will process your bank account number, the details of your
assigned plan and your unique order number on the basis of the agreement.

Where personal data of GeoFace’s service provider or such service provider’s employee is processed, such
processing will be made on the grounds of GeoFace’s legitimate interest.

If you make a contract with GeoFace as a natural person, your personal data will be processed by GeoFace
based on the agreement.

Such personal data processing will continue for as long as the contract runs. Where your personal data
appears in the contract, it will be kept for 10 (ten) years after the end of the contract.

4.7. For collecting statistical information about how the App is used

Please be informed that GeoFace has a legitimate interest to use depersonalized data at its own
discretion and to anonymize personal data (time spent on the App, functionalities used, etc.) submitted
by you when using the App as well as to process such data for statistical and analytical purposes
seeking to improve the functionality and quality of the App and to offer additional services complying
with the legal requirements. GeoFace will ensure that this does not interfere with the operation of the
App or alter any personal data being processed.

4.8. Staff selection

GeoFace processes the following personal data of candidates for vacancies: name, surname, education,
work experience and other information provided by the person in his/her CV and cover letter. This
personal data is processed on the basis of legitimate interest for the purpose of selecting the
candidate and on the basis of your consent and is stored for 3 (three) months from the date of
recruitment.

If you are not selected for further selection, the CV shall be stored only with your separate consent
and, in the absence of consent, shall be destroyed within 1 (one) month of the end of the selection
process.

4.9. Verification of compliance with international sanctions and restrictive measures

The due diligence of business partners requires the completion of a Business Partner Familiarisation
Questionnaire and a Business Partner Declaration. For this purpose, GeoFace processes the following
personal data: for the person acting on behalf of the business partner: name, surname, position,
signature, for the representative of the legal entity: name, surname, date of birth, nationality,
residential address, telephone number, e-mail address, address of the business partner. the name,
surname, nationality, date of birth, the name, surname, date of birth, size of the shares, the name,
surname, date of birth, nationality, percentage of ownership, and the personal data contained in the
copies of the documents requested. In addition, information on the Data Subjects included in the
verification is collected from publicly available information sources, including but not limited to
public registers, public media and other sources.

The personal data referred to above is processed on the basis of legitimate interest for the purpose of
getting to know our partners and is retained for a period of at least 5 calendar years from the end of
the verification exercise.

For the processing of personal data GeoFace has used the data processing tool of the Data Processor UAB
“iDenfy” (legal entity code 304617621, address Gričiupio g. 7-212, LT-51372 Kaunas).

4.10. Fulfilling statutory obligations in relation to the organisation of activities

In order to ensure the proper implementation of its obligations, GeoFace processes the following
personal data of shareholders, members of the management body, final beneficiaries and other interested
persons: name, surname, personal identification number, place of residence, date of election, a copy of
the final beneficiary’s passport, information on the participation of the permanent beneficiary and
his/her relatives in political activities, personal data contained in the decisions, minutes and powers
of the Board of Directors and the General Shareholders Meeting. Personal data are processed in the
exercise of a legal obligation or legitimate interest and, in individual cases, on the basis of consent.

Personal data processed for this purpose shall be kept for the period provided for by law.


4.11. Implementing statutory obligations to detect irregularities and ensure sustainability

In order to ensure adequate protection of whistleblowers, prevention of corruption, implementation of
equal opportunities, protection of human rights and other sustainability factors, GeoFace processes the
following personal data of the persons concerned: name, surname, telephone number, e-mail address,
content of the notification or other informative text, evidence of the infringement provided by you:
video and/or audio recordings, photograph, screenshot, communication, etc. The personal data is
processed in order to comply with a legal obligation or legitimate interest.

Personal data processed for this purpose shall be kept for the period provided for by law.

4.12. Cookies

Whenever you use the App, we may download cookies on your device. Cookies are small, often encrypted
text files that we place temporarily on your browser or hard disc based on your consent. We use
different cookies for different purposes as they help us to identify you among other users of the App.
This allows us to make your experience of using the App far more pleasant and to improve it.

We use the following cookies:

    • Strictly necessary cookies.

These cookies are essential for the App to operate. They process data based on proper performance of the
agreement when you use the App, while we ensure the safety and quality of such use. The App will not be
operating properly without those cookies.

    • Analytical and/or performance cookies.

They allow us to recognize and count the number of the App visitors and to see how they move around the
App when they are using it. This helps us to improve the way our App works, for example, by ensuring
that the users easily find what they are looking for. Data collected by these cookies is processed based
on your consent.

    • Functionality cookies.

These cookies are used to remember choices you made in the past when you revisit our App to make it
possible for us to provide personalized or enhanced features that you select. They may allow us, for
example, to remember your username and password. Data collected by these cookies is processed based on
your consent.

Cookie name Data processing purpose/cookie use Creation moment Expiration time
Cookie type (strictly necessary/analytical/ functionality/marketing)
 Data used
_ga Tracking cookies from Google Analytics. This cookie is used to store statistical
information (number of unique user visits, visit duration, etc.).		 At the time of first entering the website In 2 (two years) Analytical cookie unique ID
_gid Tracking cookies from Google Analytics. This cookie collects information about
user behaviour on the website and allows to assess its popularity, reveals
wherefrom users come to the website, etc.		 At the time of first entering the website After 24 (twenty-four) hours Analytical cookie unique ID
_gat This Google Universal Analytics cookie is required to ensure browsing quality. At the time of first entering the website When the website window is closed Strictly necessary cooky
_cfduid This cookie is used by cdn services, such as CloudFare, to identify individual
users using a shared IP address and to apply security settings to each user.
This cookie does not identify any user ID in the web application or store any
personal identity information.		 At the time of first entering the website Functionality cookie Functionality cookie Anonymized user IP address
  1. HOW IS YOUR PERSONAL DATA PROCESSED?

Your personal data will be processed in accordance with the General Data Protection Regulation
(henceforth – GDPR), the Law of the Republic of Lithuania on Legal Protection of
Personal Data, and other legal requirements. We will process your personal data responsibly and
securely. When identifying personal data processing measures and during such processing, GeoFace will
implement appropriate technical and organizational measures to ensure that your personal data is
protected from accidental or unlawful destruction, damage, modification, loss, disclosure, or any other
kind of illegal handling and will adopt proper measures considering the risks involved in personal data
processing.

  1. WHO CAN WE DISCLOSE YOUR PERSONAL DATA TO?

We will not share your personal data with others unless otherwise specified in this Privacy Policy.

We may also transfer your data for the purpose of internal administration, on the basis of the Joint
Managers Agreement or with your consent, within the group of companies of the AB Akola group (UAB
“Dotnuva Baltic”, AB “Linas Agro”, UAB “Dotnuva Seeds”, UAB “Dotnuva Rent” etc.). The joint data
controllers have contractually defined the obligations applicable to the parties and will process the
personal data received in accordance with the applicable personal data protection requirements.

Group structure and changes:

Group Structure




.

We may disclose information about you to our employees, agents and such service providers as debt
administration/collection companies or companies providing marketing/IT services, or subcontractors if
it is reasonably required for the purposes stated in this Privacy Policy.

We may disclose your personal data to data processors who supply services/perform works to us, i.e., IT
service providers, auditors, lawyers, consultants, and who process your data in the name of GeoFace as a
data controller.

Data processors will be allowed to process your personal data based solely on our instructions and only
to the extent necessary. We will take all requisite steps to ensure that our data processors implement
appropriate organizational and technical measures to ensure safety and confidentiality of your personal
data.

Your data may be transferred to public institutions/bodies or to other persons who are statutorily
entrusted with certain responsibilities.

In addition, we may disclose your personal information in the following cases:

    • if required to do so by law;
    • seeking to protect our rights or interests (including the case when your personal data is
      transferred to others for debt recovery purposes);
    • when intending to sell any part of GeoFace’s business or assets or to reorganize GeoFace,
      and during such processes, we are asked to disclose your personal data to any (potential)
      buyers of such business or assets, or to other participants in the reorganization.
  1. WHAT ARE YOUR RIGHTS?

This section gives information about your rights associated with the processing of your personal data by
GeoFace and about how such rights may be exercised. If you want more information about your rights or
want to exercise them, please contact us at the email address given in this Privacy Policy.

7.1. Right of access to your personal data

In order for you to understand how we use your personal data and to suffer no inconvenience on that
account, you may contact us at any time to ask whether any of your personal data is being processed by
us. If your personal data is stored or used by us in whatever way, you have the right of access to such
data. In order for you to exercise such right, please send us a written request at the email address
given in this Privacy Policy. We may ask you to confirm your identity to grant your request. Please
observe the principles of reasonableness and good faith when submitting such request.

7.2. Right to withdraw consent

You have given us your explicit consent to process your personal data, which may be withdrawn by you at
any time by sending us an email at the address given in this Privacy Policy.

7.3. Right to request more information

We hope you understand that it is very difficult to discuss all possible ways how personal data may be
collected and used. Therefore, we try to provide as clear and complete information as possible and
update this Privacy Policy if changes are made to the use of personal data. Nevertheless, if you have
any questions regarding your personal data use, we will be happy to answer them or to provide you with
further information that we are allowed to disclose. Please contact us if you have any specific
questions or have not understood the information presented in this Privacy Policy.

7.4. Additional rights

Below, please find information about your additional rights that may be exercised by you as follows.

    • You have the right to request us to correct any inaccuracy of your personal data. In that
      case, we may ask you to confirm the information corrected;
    • You have the right to request us to erase your personal data. This right may be implemented
      in the cases described in Article 17 of the GDPR;
    • You have the right to request us to restrict/refrain from processing your personal data;
    • You have the right to data portability if processing of such data is carried out by
      automated means and we have obtained such data from you based on your consent or for the
      purpose of concluding an agreement. If you opt to exercise this right, we will transmit at
      your request a copy of the data submitted by you;
    • You have the right to object to processing of your personal data pursuant to Article 21 of
      the GDPR.
  1. HOW CAN YOU EXERCISE YOUR RIGHTS?

To enforce your rights, you may submit requests, complaints or claims to us in writing in any of the
following ways:

    • by sending an email to:

      [email protected]

      ;
    • by sending a letter to: Brastos g. 14, LT-47185 Kaunas;
    • by arriving to UAB „GeoFace“ Brastos g. 14, LT-47185 Kaunas;
    • by connecting our Data protection officer:

      [email protected]

      .

We will respond to your requests, complaints or claims in writing in accordance with the applicable laws
and will do our best to provide you with information within the shortest time possible but in no event
later than within 30 (thirty) days after receiving your request.

Whenever you contact us, we may process the following data you have submitted to us: your first name,
last name, email address, phone number, date, and the text of communication as specified in this Privacy
Policy. Please note that we may need to contact you by regular post or email or phone. If your personal
data changes, please let us know about such change.

If having received your request, complaint or claim we have doubts about your identity, we may ask for
your identity document.

If we fail to provide you with the necessary information and/or should you have complaints about how
your personal data is being processed, you may approach the Lithuanian State Data Protection
Inspectorate (

www.vdai.lrv.lt

) by filing a complaint.

  1. RESPONSIBILITY

You are responsible for ensuring that the data provided by you is accurate, correct, and complete. You
should immediately notify us by email if changes are made to the data you have submitted. Therefore, we
will not be held liable for any damage resulting from your failure to provide correct or complete
personal data or to give us notice of changes made to such data.

  1. CHANGES IN OUR PRIVACY POLICY

GeoFace may update or amend this Privacy Policy at any time. Such updated or amended Privacy Policy will
take effect from the date of being published on the App. You should check the App occasionally to make
sure that you find the current version of the Privacy Policy acceptable.

Each time our Privacy Policy is updated, we will inform you of all changes that we deem significant by
posting them to the App. Whenever you log in to the App after the publication of such notice, you will
consent to the new requirements indicated in the update. The “Update date” given below shows when the
Privacy Policy was last updated.

Update date: 2024-12-31