Privacy Policy
- General information about the privacy policy
- Key terms and abbreviations
- Purposes of personal data processing
- Legal basis for the processing of personal data
- Receipt and provision of personal data
- Profiling and automated decision-making
- Personal data retention periods
- Your rights regarding the processing of personal data and the procedures for exercising them
- Procedure for exercising your rights
- Contact Us
- Document versions
General information about the privacy policy
This Privacy Policy (hereinafter – the Policy) provides information on how “Man ramu”, UAB (legal entity code 306362692; registered office address: Verkių St. 31B-2, Vilnius, Republic of Lithuania; listed in the register of insurance brokerage firms maintained by the Bank of Lithuania (https://www.lb.lt/lt/finansu-rinku-dalyviai?list=75); e-mail address: info@manramu.lt; hereinafter – Man ramu, We, or the Company) processes the personal data of clients and other data subjects, as well as information regarding the procedure for exercising data subjects’ rights.
Man ramu processes personal data in compliance with 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 – GDPR), the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other applicable legal acts. We adhere to the principles of good practice for insurance brokers and pay special attention to the protection of the personal data we process.
This Policy may be updated in the event of changes to legal requirements or the services provided by the Company. The latest version of the Policy is published on the website https://manramu.lt/.
Additional information regarding the processing of customers’ personal data may be provided in contracts and other documents related to the Company’s services, as well as on the website https://manramu.lt/.
Please note that if you provide us with information about any person other than yourself, your employees, partners, or insured persons, you must ensure that they are informed about how their data will be used.
This Privacy Policy outlines how We process your personal data and that of our other clients: what personal data we collect and process, to whom we transfer it, where we obtain it, the purposes for which we use it, and how we ensure its security and your right to privacy.
Please note that this Privacy Policy applies only to the activities of “Man Ramu”. Since this website and/or using Our services may contain links to third-party websites, for example, when ordering the Company’s services and making payments, links may be provided to the websites and/or electronic banking systems of banks or other companies providing payment services, we draw your attention to the fact that these services are subject to the privacy policy of the relevant third party, as the data is provided, respectively, and processed, not by the Company, but by this third party. Therefore, we recommend that you familiarize yourself with the privacy policies of those companies/websites before submitting your personal data. “Man ramu” is not responsible for any data provided when visiting other websites or communicating with other companies.
Key terms and abbreviations
The data controller is “Man ramu”, UAB, an insurance brokerage firm that conducts insurance intermediation activities in cooperation with insurance companies, offering insurance products—such as motor third-party liability, vehicle (CASCO), property, and travel insurance—sourced from those insurance companies. The insurance companies are independent data controllers.
Client, Data Subject, or You – a natural person whose personal data is processed by the Company (a potential, current, or former Client, or any other person related to the insurance brokerage service, a representative of such persons, or another related person, as well as persons visiting the Company’s website or otherwise interested in the Company’s services).
Personal data – any information directly or indirectly related to a Client whose identity can be established.
Processing of personal data – any operation or set of operations performed on personal data (including collection, recording, sorting, structuring, storage, adaptation or alteration, consultation, use, etc.). – any operation or set of operations performed on personal data (including collection, recording, sorting, structuring, storage, adaptation or alteration, consultation, use, etc.).
Services refer to the products and services we provide as an insurance brokerage firm listed in the register of insurance brokerage firms maintained by the Bank of Lithuania.
Performance of a contract – means the processing of your personal data for the purpose of fulfilling the contract concluded between you and us (for example, to provide services to you) or, at your request, taking appropriate steps prior to entering into such a contract.
Legal requirements – means the processing of your Personal Data where necessary to comply with legal obligations applicable to us (for example, responding to court orders or complying with statutory requirements).
Purposes of personal data processing
Personal data is essential for the Company’s operations. The Company processes personal data lawfully, fairly, and transparently in relation to the data subject, and solely for specified, explicit, and legitimate purposes; it does not process personal data in a manner incompatible with those purposes. The volume of data processed is adequate and limited to what is necessary to achieve these purposes, and personal data is stored in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed.
The company processes personal data:
- Sutarčių su potencialiais klientais sudarymo ir/ar kitų veiksmų atlikimo prieš sudarant sutartį tikslu (siekiant pažinti, identifikuoti ir patvirtinti Klientą) Bendrovė tvarko asmens tapatybės ir veiklos duomenis, draudžiamo objekto duomenis, įmokos duomenis, kontaktinius duomenis bei kitą pateiktą informaciją.
- For the purpose of contract execution, the Company processes personal identity and activity data, insurance policy data, insured object data, payment data, contact data and other personal data provided by the Client or submitted on behalf of the Client, or generated by the Company while providing services to the Client.
- To provide a response to your inquiry submitted via the Company’s website or other communication channels, the Company processes personal identity details, contact information, and other data provided by the Client or on the Client’s behalf, as well as data generated by the Company while providing services to the Client.
- For the purpose of processing communications, and in order to accurately respond to your inquiry and maintain a record of the correspondence, the Company processes the contact details (such as email address and phone number), name, surname, and other information provided by the person making the inquiry. If additional documents are submitted with the inquiry, the Company will review them to address the questions raised. We recommend that you do not provide data that is not necessary for the processing of your inquiry. Should additional information be required to prepare a response, a Company employee will contact you to specify what information is needed.
- For the purpose of fulfilling legal requirements, the Company processes personal data only in accordance with court orders or other legal requirements.
- For the purpose of social media communication, the Company processes your data when you contact us via third-party social networks (e.g., LinkedIn, Meta, etc.) or use social media features integrated into the website, thereby granting us access to certain information from your social media account (such as your name, email address, photo, gender, date of birth, messages, or liked pages). If you post information while interacting with us on social media or using social media integrations, that information may be made publicly available online, depending on the privacy settings you have selected. On some social networks, you can control which of your posted information is made public. To learn more about controlling your privacy settings and how third-party social networks process your personal information, please consult the privacy policies and terms of use of those social networks.
- For direct marketing purposes—provided you consent to receive information about the services, offers, promotions, discounts, or other items we provide—the Company will process the consenting individual’s first name, surname, telephone number, and/or email address. You are not obliged to subscribe to these services; however, to enable us to provide you with the most attractive offers and the latest relevant information, you will need to provide us with your contact details (first name, surname, telephone number, and/or email address) and give your consent, which you may withdraw at any time.
Legal basis for the processing of personal data
The Company processes your personal data always based on a lawful basis for processing this information:
- The aim is to perform a contract to which the Client is a party or to take steps (at your request) to enter into a contract.
- To safeguard the Company’s legitimate interests, taking into account your interests and fundamental rights (for example, when we use personal information provided to us by clients to provide services, but the information used is not necessary for the performance of a contract to which you are a party).
- Performance of legal obligations imposed on the Company (e.g., when the Company is required to collect certain information about its Clients for accounting or tax purposes, or when we are obliged to provide information to courts or other institutions).
- In limited cases, we base the processing on your consent—for example, when we need to obtain your consent to send you marketing communications.
We process only the personal data necessary to achieve the purposes described above. If you provide incorrect or incomplete data, we will be unable to properly provide services to you.
Receipt and provision of personal data
We typically collect personal data directly from the data subject—when they provide such data to the Company (either directly or through the Company’s partners)—as well as from government institutions, registers, and other legitimate sources, to the extent necessary to achieve the defined purposes. The sources may vary depending on the purpose for which the Company processes personal data; however, in all cases, we adhere to the principle of data minimization and collect only the amount of personal data necessary to achieve the specific purpose.
When processing personal data, we always adhere to confidentiality requirements. Personal data may be disclosed to third parties only in compliance with personal data protection requirements, in justified cases, only to recipients with a legal basis for receiving such data, and only to the extent necessary to achieve the established purposes. When a personal data processor acts on behalf of the Company, the Company takes all necessary measures to ensure that the processor has implemented appropriate organizational and technical security measures and maintains the confidentiality of the personal data.
Methods of obtaining personal data:
- Directly from the data subject when they contact the Company regarding services—for example, upon becoming Our Customer and/or providing Us with information electronically, etc.
- From third parties and/or publicly accessible registers or other sources, to the extent provided for by applicable legal acts—for example, from state registers, institutions, agencies, other legal and natural persons, etc.
In certain cases, we may receive personal data when you insure another person. In such an instance, you are required to inform that person and obtain their consent; when we receive such data, we proceed on the assumption that you are doing so with that person’s knowledge and consent.
The Company may also receive your data when another person (the policyholder) concludes an insurance contract for your benefit as the insured person. The Company proceeds on the assumption that, in such cases, the policyholder acts with the knowledge of the insured persons and at their request or with their consent.
Methods of personal data transfer:
The Company may disclose and/or transfer your personal data only in compliance with legal requirements and confidentiality principles to the following categories of recipients:
- To our partners, insurance companies or other persons who are a necessary part of the provision of our products and services. These partners act as independent data controllers and are themselves responsible for compliance with data protection requirements. Be sure to read their privacy policy.
- To business partners providing specialized services or collaborating with us (for example, IT service providers maintaining our systems, accounting service providers, and the like). Under contracts concluded with the Company, these service providers are required not to use or disclose your personal information except as necessary to provide services on our behalf or to comply with legal requirements. These service providers properly safeguard your data, and any processing of the data is limited to the purposes for which the data was collected.
- To state institutions and other third parties, if the Company is required to do so by law or if it is necessary for the performance of a contract to which the data subject is a party. (For example: for the purposes of administering insurance contracts and insurance events, your personal information may be provided to various registers and data system administrators, such as the State Enterprise REGITRA, the State Enterprise Centre of Registers, etc.)
- For commercial banks and other financial institutions—for example, for the direct transfer of payments to insurers’ accounts.
- For pre-trial investigation institutions, courts, bailiffs, notaries, etc., when the Company is required to do so by legal requirements (for example, in response to official inquiries or requests from state authorities, when investigating unlawful acts, etc.)
- At the Client’s request or based on another legal ground, personal data may be disclosed, taking into account the Client’s contractual obligations to other parties, such as banks, leasing companies, or other financial institutions.
We never provide our services directly to children and never knowingly collect data directly from children.
Profiling and automated decision-making
In some cases, we may use automated decision-making, which means a decision that is made based solely on the automated processing of your personal data (using software code or an algorithm that does not require human intervention), for example to assess insurance risk or the insurance premium to be paid and so that Man Ramu can provide you with the best and most suitable insurance offers for you.
If you do not wish for your personal data to be processed in the manner described above, you may request a manual review of the accuracy of the automated decision and have the right not to be subject to a decision based solely on automated processing. You may contact us by phone at +370 655 04005 or by email at info@manramu.lt.
Personal data retention periods
We retain personal data for no longer than is necessary for the purposes for which they were collected or as required by applicable laws. The retention period for personal data depends on the contracts concluded, the Company’s legitimate interests, and/or legal requirements (for example, limitation periods for insurance-related matters specified in legislation governing insurance activities, civil law provisions, requirements of legislation governing accounting, etc.).
If the legal acts of the Republic of Lithuania do not specify a retention period for Personal Data, the Company shall determine this period, taking into account the legitimate purpose of data retention, the legal basis, and the principles of lawful processing of Personal Data.
Your rights regarding the processing of personal data and the procedures for exercising them
As a data subject, you have the right to contact “Man ramu” regarding questions related to the processing of your personal data; specifically, you have the following rights:
- Teisę gauti informaciją apie duomenų tvarkymą ir teisę susipažinti su duomenimis, tai yra gauti informaciją apie tai, ar Bendrovė tvarko Jūsų asmens duomenis ir, jei taip, susipažinti su savo tvarkomais asmens duomenimis.
Jūs turite teisę gauti informaciją apie tai, kokius asmens duomenis Mes tvarkome, iš kur jie surinkti, kokiais tikslais tvarkomi, kiek laiko saugomi, kam teikiami ir kt. Pažymėtina, kad Jūsų teisę susipažinti su duomenimis gali riboti teisės aktai, kitų asmenų privatumo apsauga ir su Mūsų verslu ir praktika susijusios priežastys. - The right to request the correction of data if inaccurate or incorrect data concerning you is being processed.
- The right to request the deletion of data (the “right to be forgotten”), i.e., to request the deletion of some or all of your personal data being processed in cases where it is determined that the Company lacks a legal basis for processing them or where other grounds provided for in legal acts exist.
- The right to restrict data processing—that is, you have the right to request that the processing of your personal data be restricted for a certain period, with the exception of storage. This might apply, for example, in a situation where you believe that such processing is unlawful and/or that the data concerning you is inaccurate, and we need to verify this and rectify the situation.
- The right to data portability—that is, in certain cases, you have the right to request the transfer of personal data concerning you that you have provided to us in a commonly used and machine-readable format, and the right to request that it be transmitted to another data controller.
- The right to object to data processing. This right applies when the Company processes your personal data based on legitimate interest or your consent. You have the right to withdraw your consent to the processing of personal data if the processing was based on consent. Withdrawing consent does not affect the lawfulness of data processing based on consent carried out prior to the withdrawal.
- The right to lodge a complaint with the State Data Protection Inspectorate (https://vdai.lrv.lt/lt/veiklos-sritys-1/skundu-nagrinejimas/) if you believe that the Company is processing your personal data in violation of your rights and legitimate interests as established in applicable legislation.
Jūsų teisių įgyvendinimo tvarka
The rights specified above will be exercised only after the Company receives your written request to exercise them and verifies your identity. A written request may be submitted to us by regular mail or via email at info@manramu.lt. Requests submitted in this manner must be signed with a qualified secure electronic signature. Signing the request with a qualified secure electronic signature enables the Company to properly identify you and ensure that the requested information is disclosed only to the intended recipient. The Company does not accept scanned copies of requests that are not signed with a qualified secure electronic signature; therefore, if you do not possess a qualified electronic signature, you may submit your request using other methods specified in this section.
Upon receipt of your request, the Company will assess its content and the feasibility of verifying your identity. To ensure data security, we may ask you to verify your identity using an alternative method. Requests regarding the exercise of your rights under the GDPR are processed within one month. Depending on the complexity of the request and the volume of requests received, this period may be extended by a further two months. If the processing of your request is delayed, we will inform you of this in writing.
Contact Us
If you have questions regarding the processing of your personal data or wish to exercise your rights, you may contact us by email at info@manramu.lt or at the following address: “Man ramu”, UAB (legal entity code 306362692, registered office address: Verkių St. 31B-2, Vilnius, Republic of Lithuania).
„Man ramu“, UAB · Įmonės kodas 306362692 · Verkių g. 31B-2, LT-09108 Vilnius
info@manramu.lt · +370 655 04005
„Man ramu“ veiklą prižiūri Lietuvos bankas