Privacy Policy

We are aware of the particular importance we attach to the protection of your personal data, and we only collect and process your data that is 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.

When 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 with the requirements for the processing of personal data set out in other legal acts.

1. What is this document?

1.1. By reading this privacy policy (“Privacy Policy”), you will learn how and for what purposes we process your personal data, where we obtain it, to whom we provide it, where we store it, and what your rights are as a personal data subject.

1.2. 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.

1.3. This Privacy Policy applies to all individuals whose data we process.

2. Who are we?

2.1. We are Master Class LT, UAB, whose legal entity code is 302309920 and whose registered office address is Jogailos g. 4, LT-01402 Vilnius. In accordance with the provisions of the legislation, we are the controller of your personal data.

2.2. For more information on any of the matters covered by this Privacy Policy, please contact the company’s administration, which can be contacted by email at info@masterclass.lt.

3. What principles do we follow?

3.1. When processing your personal data, we:

a) we will comply with the requirements of current and applicable legislation, including the GDPR;

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

(c) we will collect your personal data for specified, explicit 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 provide personal data to third parties and will not disclose it to the public, except as specified in the Privacy Policy or as required by law;

(g) we will ensure that your personal data is processed in such a way that appropriate technical or organisational measures are taken to ensure adequate security of 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 received in the following ways:

(a) when you provide them to us. You provide us with your personal data when you send us your CV, cover letters, register on our websites, communicate with us by phone, email or during meetings, answer questionnaires, complete assignments or tests. If you contact us in writing or by email, we will keep the details of the correspondence.

(b) when you use websites operated by us. When you use the websites we operate, certain information (such as the Internet Protocol (IP) address of the type of web browser you are using, the number of visits, the number of pages viewed on the website, the amount of time spent on the website, 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. We may combine the personal data we receive from you with data collected by us from other public or accessible sources. For example, we may combine the personal data you provide with data obtained through the use of cookies on websites, data collected in the course of providing our services to you, or with data lawfully obtained from third parties. In exercising your rights, you will always be able to request the rectification of erroneous personal data.

5. FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

5.1. We process your personal data for the following purposes:

a) For the purpose of providing services to our customers. We process your personal data in order to provide our services to you and to others: to find and select candidates who match our clients’ needs, to assess the suitability of candidates for the job we offer, and to introduce candidates to employers.

For this purpose, we process your personal data obtained from you (e.g. data provided by you in your CV, data collected during communication, etc.), collected through your use of our and other websites, and/or obtained from other persons (e.g. recommendations from current or former employers or acquaintances, social networks, mass media, etc.).

For this purpose, we provide or transfer your data to our clients – employers who are looking for employees. Together with us, they will be the controllers of your personal data. We will not transfer more of your personal data to our clients than we process on the basis of this Privacy Policy. We have entered into contracts with our clients, under which both parties undertake to protect your personal data.

For this purpose, we will keep your data for 10 years from the date you last provided us with your data or updated it, unless we have your separate consent to keep your data longer.

(b) for the purpose of administering the Candidate Database. After the end of the specific selection to which you have submitted your data, we process your personal data in order to offer you future job and career opportunities, to find and select candidates who match the needs of our clients, to assess your suitability for the job offered and to present candidates to employers.

For this purpose, we process the same personal data as for the purpose of providing the services, provide it to the same persons and keep it for the same period of time as set out in paragraph 5.1(a).

(c) for direct marketing purposes. We process your personal data with your consent in order to offer you our own goods and services, those of our affiliates and our partners and to improve our services.

For this purpose, we process the following personal data:

- - name, surname, email address.

For this purpose, we obtain your personal data from:

- - Your own.

For this purpose, we keep your data until the end of the contract with you, unless we have your consent to keep your Personal Data longer.

(d) for the purpose of administering the work and activities of the Company’s employees. To the extent that we are obliged or permitted to do so by law, we process the personal data of our employees. We process the personal data of our employees in accordance with the procedures set out in the Employee Personal Data Processing Schedule.

(e) for the purpose of contract enforcement. We process personal data in order to identify the customer or supplier, to carry out the activities of selling products, solutions, providing services, to process and administer the customer’s or supplier’s orders, to invoice the customer or accept the supplier’s accounting documents, to resolve problems with the scope of the product, solution or services provided to the customer, and to fulfil the Company’s other obligations as a seller or buyer, or as a provider or purchaser of services or products.

For this purpose, we process the following personal data:

- - name, surname, date of birth, personal identification number (personal identification number of a resident of the Republic of Lithuania or personal identification number of a citizen of a foreign country or other identification number), age, address of residence, telephone number, e-mail address.

For this purpose, we obtain your personal data directly from data subjects when a potential customer or supplier represented by the data subject seeks to enter into a contract with the Company or in the course of the performance of a contract concluded between the customer or supplier represented by the data subject and the Company.

f) for the purpose of selecting candidates for positions offered by the Company in the Company. We process your personal data in order to find and select candidates to work for us who meet our needs and to assess the suitability of the candidates for the job offered.

For this purpose, we will keep your data for 3 years from the date you last provided us with your data or updated it, unless we have your separate consent to keep your data longer.

g) For the purpose of administering the database of candidates for employment with the Company. After the end of a specific selection process in our Company to which you have submitted your data, we process your personal data in order to offer you future job and career opportunities, to find and select candidates who match the needs of our Company, and to assess whether you are suitable for the job offered.

h) For the purpose of debt management.

For this purpose, we process your name, surname, telephone number, email address and residential address.

For this purpose, we obtain your personal data directly from you, from publicly available sources (e.g. population register, data provided by third parties, etc.) and from third parties.

For this purpose, we provide or transfer your data to debt management and/or debt collection companies.

For this purpose, we store your data until the end of the administration of the debt (debt liquidation) and in accordance with the limitation periods set by law (the Civil Code of the Republic of Lithuania and others).

(i) for the purpose of improving the websites we manage and to offer you a better and more tailored service. We use your personal data, including the personal data we receive when you use our websites, to improve and develop these websites and to offer you better and more tailored services. For this purpose, we use the personal data we receive from you, the personal data we receive from you when you use our websites and the personal data we receive from others.

For information on how we use cookies and similar technologies, please see Section 7 of this Privacy Policy.

5.2. We do not process your personal data for any other purposes that are incompatible with the purposes listed above.

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 offers and information about goods and/or services from us, our affiliates and partners that we think may be of interest to you.

6.2. For this purpose, we process the following personal data: name, surname and email address.

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

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

6.5. 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 company marketing and sales purposes. In this case, we will use your personalised data.

6.6. 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 personal data processing activities. You can do this in the following ways:

(a) to notify the unsubscription in the manner specified in the e-notifications and/or offers (e.g. by clicking on the “unsubscribe” link in the newsletter, etc.); or

(b) by coming to us and making a request. The request must clearly state your name. If you wish to withdraw your consent in this way, we may ask you to provide proof of identity;

c) send us a request to the e-mail address specified in this Privacy Policy. The request must clearly state your name and surname 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.

6.7. If you withdraw your consent, we will endeavour to stop processing your personal data for the purpose of direct marketing as soon as possible.

6.8. 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 want us to do this as well, you must make a separate request.

7. How do we use cookies?

7.1. We collect information about you using 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 websites, save personal browsing history, preferences, customise content, speed up searches on websites, create a user-friendly and friendly website environment, and make the website more efficient and reliable. Cookies are a common practice in web browsing that make it easier to use a website.

7.2. We may collect the following information through cookies: IP address, browser type, demographic data.

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

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

(b) analysing the use of websites;

c) so that we can improve and develop the websites to better meet your needs;

(d) service development; and

(e) targeted marketing guidance.

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. information about your use of websites, personal data you provide, etc.).

7.5. The following cookies may be used on websites:

a) technical cookies – these are cookies that are essential for the operation of websites;

(b) Functional cookies – these are cookies that, although not essential for the operation of websites, significantly improve the performance, quality and user experience;

(c) analytical cookies – these are cookies that are used to compile a statistical analysis of the navigation patterns of visitors to websites; the data collected by these cookies is used anonymously;

(d) Targeting or promotional cookies – these are cookies that are used to show you offers or other information that may be of interest to you;

(e) social network cookies – these are cookies that are necessary to use information from websites in your social profile account.

7.6. Full details of the cookies used on websites, their purpose, validity and the data used are set out in the table below:

Name	Purpose	Period of validity
_ga	Used by Google Analytics to measure the user’s visit goals, to report website activity to website operators and to improve the user’s experience when visiting the website	2 years
_gat	Used by Google Analytics to collect statistical information about website traffic (information about the browser used, computer, visits, time spent)	Before closing the browser window
_gid		Before closing the browser window
collect	“Information collected by Google Analytics about the device used by the visitor	Before closing the browser window

7.7. You can give your consent to the use of cookies in the following ways:

(a) by not deleting them and/or changing the settings on your internet browser so that it does not accept cookies;

(b) by clicking on the “I accept” link (bar) on the websites about cookies;

7.8. You can withdraw your permission 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 how to refuse them, please visit http://AllAboutCookies.org or http://google.com/privacy_ads.html.

7.9. In some cases, in particular for technical and functional cookies, disabling, not accepting or deleting cookies may slow down your browsing, restrict the functionality of certain websites, or even block access to websites.

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 and the 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 authorities or prosecuting authorities.

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

8.3. The above service providers are limited in their ability to use your data and cannot use it for purposes other than to provide services to us.

8.4. A non-exhaustive list of the persons and categories of persons to whom we transfer your personal data is set out in Section 1 of this Privacy Policy separately for each personal data purpose.

9. How long do we keep your personal data?

9.1. We will not keep your personal data for 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 store outdated, irrelevant personal data, so that only relevant information is stored when it is updated (e.g. when your account is revised, information is changed, etc.). Historical information is kept where it is necessary for the purposes of the law or for the conduct of our business.

9.3. Section 5.1 of the Privacy Policy specifies the retention periods of your personal data separately for each purpose of personal data use.

10. How do we protect your personal data?

10.1 The data we collect from you will be located within the European Union, but may be transferred or stored outside the EU. It may also be processed by our or our suppliers’ staff working outside the EU. When we transfer your data outside the EU, 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. Although we take great care to protect your personal data, we cannot guarantee the security of the data when you transmit data to websites – you bear the risks associated with transmitting data to websites. Once we receive your data, we will apply 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 serious threat to your rights or freedoms, we will inform you immediately upon becoming aware of it and identifying the information accessed.

11. External websites

11.1. Websites may contain links to external websites, such as those of our business partners or websites that advertise our goods and/or services. If you follow such links to any of these websites, please note that these websites 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 through these websites or 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 in accordance with the GDPR and the Law on Legal Protection of Personal Data of the Republic of Lithuania. As a personal 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;

(d) require the destruction of personal data when they are no longer necessary for the purposes for which they were collected;

(e) require the destruction of personal data where the processing is unlawful 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 consent previously given;

(g) to request 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 them;

(h) require the provision, where technically feasible, of your personal data collected pursuant to your consent or for the purposes of the performance of a contract, in an easily readable format, or request that it be transmitted 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) fulfilling the legal obligations imposed on us;

(b) national security or defence;

(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 other persons.

12.3. You may submit claims relating to the exercise of your rights to us in person, by post or by electronic communication. Upon receipt of your request, we may ask you to provide proof of identity, as well as other additional information we require in connection with your request.

12.4. Once we have received 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 provide the response.

12.5. If we deem it necessary, we will suspend the processing of your data, with the exception of storage, until your request is resolved. If you lawfully withdraw your consent, we will cease processing your personal data immediately, but no later than 30 calendar days, except in the cases set out in clause 12.2 of this Privacy Policy and in the cases provided for by law, i.e. where we are obliged to continue to process your personal data by applicable law, by a legal obligation incumbent on us, by a judicial decision or by a binding order from the authorities.

12.6. If we refuse to comply with your request, we will clearly state the reason 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 the 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 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 can lodge a complaint with our supervisory authority, the State Data Protection Inspectorate, although we will endeavour to resolve any disputes with you in the first instance.

14. How will this Privacy Policy be amended?

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

15. How to contact us?

15.1. Please send all documents related to this Privacy Policy to the contacts below:

- by post – Master Class LT, UAB, Jogailos g. 4, LT-01402, Vilnius;
- by email – info@masterclass.lt.

Date of publication of the Privacy Policy 29 October 2025