Privacy policy
We care about protection of Your personal data, therefore, we comply with the requirements laid down in the EU’s General Data Protection Regulation (the ‘Regulation’) and other legal acts on the processing of personal data. As part of implementation of applicable requirements, in this Privacy Policy we provide information on the personal data processing carried out by Kauno grūdai, AB and its subsidiaries.
The information below covers the personal data processing for the specified purposes and in the specified cases: (i) selection of candidates for jobs; (ii) implementation of the loyalty programme and direct marketing; (iii) video surveillance; (iv) managing the Quality Line by recording telephone calls; (v) implementation of legal acts on sanctions; (vi) managing complaints, enquiries and feedback; (vii) communication by email; (viii) use of social networks; (ix) concluding agreements with individuals; (x) concluding agreements with legal persons; and (xi) protecting the Company’s reputation and increasing the visibility of its activities.
This Privacy Policy also describes Your (the data subject’s) rights, data storage terms, conditions of transferring data to their recipients, and other terms of the personal data processing for the above purposes, applied to such processing in accordance with the Regulation.
A data controller that determines the purposes and means of processing of Your personal data can be Kauno grūdai, AB (reg. company No 133818917, address H. ir O. Minkovskių g. 63, Kaunas, Lithuania, info@kaunogrudai.lt), KG mažmena, UAB (reg. company No 302602745, address H. ir O. Minkovskių g. 63, Kaunas, Lithuania, info@kaunogrudai.lt), Šlaituva, UAB (reg. company No 134019827, address Linksmakalnio k. Sodų g. 7, Kauno r. sav., Lithuania, slaituva@gmail.com), Baltic fumigation service, UAB (reg. company No 300094020, address H. ir O. Minkovskių g. 63, Kaunas, Lithuania, info@fumigation.lt), Grybai LT, UAB (reg. company No 302765404, address Zibalų g. 37, LT–19124, Širvintos, Lithuania, infogrybai@kaunogrudai.lt), and related company Agro logistic service, UAB (reg. company No 303014392, address H. ir O. Minkovskių g. 120, Kaunas, Lithuania, info@agrols.eu) (hereinafter collectively referred to as the ‘Companies’ and each individually as the ‘Company’). You will be informed, by the method specified below or another method convenient for You, about the specific processing purpose in respect of which each Company acts in the capacity of the data controller.
Selection of Candidates for Jobs
If You have sent to us Your CV, motivational letter or other documents/data for participation in the selection for jobs, such personal data provided voluntarily as well as other personal data as specified below will be processed for the purpose of such selection.
We will process Your personal data for the selection purpose until a decision on hiring a specific candidate is taken, the person‘s probation period ends, or we decide to end the selection without selecting anyone, however, no longer than for six months after receipt of the data.
We will process Your personal data on the basis of Your consent to take part in the selection. You provide Your personal data for the selection voluntarily, however, without such provision we will not be able to assess the suitability of Your candidacy.
Please be aware that we may exercise the right under the personal data protection legislation and apply to Your previous employers for their opinion about Your qualifications, professional skills and professional qualities. In addition, we can look at the candidate‘s account in a professional social network. However, we will not approach Your current employer unless You give us Your consent.
We may transfer Your personal data for processing to third parties that assist us in performing the selection of candidates or provide services related to the selection and evaluation of candidates and internal administration to us. Such service providers are obligated to ensure protection of Your personal data according to the law and under contracts with us.
The Company that is specified in the job advertisement or to which You have submitted Your CV and other data will act in the capacity of a data controller.
Loyalty Programmes and Direct Marketing
If You are a customer of the Company or the Companies, if You participate in a loyalty programme or have expressed Your agreement to receiving direct marketing materials, the personal data that You have voluntarily submitted including e-mail address and telephone number will be used for sending You information about goods and services, news, promotional campaigns, events or other direct marketing information using the contact details provided as well as through social networks, media channels and other similar e-communication channels.
Direct marketing information will be sent to You by e-mail without Your consent only if You are a customer of the Company or the Companies. Such marketing will be conducted based on a statutory right.
Your personal data will be processed for the purpose of direct marketing for 5 years as from the day of receipt of Your consent or after the expiry of relations between You and the Company.
In each e-mail sent to You, we will provide you with an option to unsubscribe from direct marketing communication. You may also reject it or withdraw Your consent by contacting the Company using its contact details.
KG mažmena, UAB, is the data controller responsible for the personal data processing for the purposes of loyalty programme. The Company that You are a customer of and to which You have given Your consent to direct marketing is the data controller responsible for the personal data processing for the purposes of direct marketing.
Video Surveillance
The data controller Kauno grūdai, AB conducts video surveillance for the purposes of ensuring the safety of property and persons (applicable to all surveillance cameras used) and for the purpose of control and quality assurance of the food production process (applicable to all surveillance cameras used to monitor the food production process).
The footage is stored by the Company for 30 days, except in cases where there are grounds for believing that an offence, a violation of work discipline, a criminal act or another unlawful act has been recorded. In such a case, the footage is stored until the end of relevant investigation and/or trial. Footage of the food production process is stored for 3 months.
Video surveillance is conducted for the purpose of a legitimate interest. Data subjects are informed by means of warning signs about sites where video surveillance is conducted.
Footage data can be submitted to a pre-trial investigation institution, public prosecutor or court in administrative, civil or criminal cases, as evidence, or in other cases prescribed by the law. Companies providing security services may also have access to the video recordings.
Management of Quality Line (recording of telephone calls)
Kauno grūdai, AB has established a Quality Line with the assigned telephone No +37063680888 which consumers and customers can call to report deficiencies in the goods‘ or services‘ quality and to provide feedback. The telephone number is published on the Companies‘ websites and provided on product packages. Calls on this telephone number are recorded for the purposes of management of the Quality Line.
Such processing of personal data is carried out with the data subjects’ consent. Prior to the start of the recording, the caller is informed about it and is asked to continue the call only he/she consents to the recording. Otherwise, in case of termination of the call, the data subject may apply to the Company by email, post or another method convenient for them.
Recordings of telephone conversations will be kept for one month from the day of the conversations and will be automatically deleted afterwards.
Kauno grūdai, AB is the data controller responsible for the processing of personal data as described above.
Compliance with legal acts on sanctions
In compliance with Lithuanian, European Union and international legal acts governing sanctions, we run checks on individuals and legal persons to determine whether we can cooperate and establish business relationships with them. For this purpose, we process personal data such as first name, surname, date of birth and nationality of our counterparties, their management, shareholders and beneficiaries as well as information on imposition of sanctions. We receive such data from potential counterparties and from national and international databases and other publicly available sources. We have outsourced the data checking activity to an external service provider. The Company with which a potential counterparty can establish a business relationship acts in the capacity of a data controller.
Management of Appeals, Enquiries and Feedback
If You have sent an appeal, enquiry or feedback to the Company’s e-mail address or submitted it by any other means, Your voluntarily submitted personal data will be processed for the purposes of management of the appeal, enquiry or feedback.
If Your appeal is related to a potential dispute, alleged damage etc., Your personal data may be stored for a maximum period of 10 years. If personal data is not related to a potential dispute, they will be deleted within a shorter period of time.
Processing of Your personal data will be based on an expression of Your will, i. e. a consent. In certain cases, however, a legal act may become the basis for subsequent storage of the appeal.
The Company that received your appeal, enquiry or feedback is the data controller responsible for the processing of personal data for this purpose.
Communication by Email
In case of communication by email, processing of Your personal data will be based on an expression of Your will, i. e. a consent to communicate by email and to provide certain data. If You maintain communication with the Companies as an employee of companies with which we have, or can have, a contractual relationship, a legitimate interest is the basis for processing the data provided by You by email. Also, performance of statutory obligations can also be the basis of data processing in individual cases.
Apart from conclusion and performance of a contract, data provided by You during email communication are also processed for internal administration purposes.
Your email address, content of communication and related data will be processed according to the principle of proportionality. These data will be seen first of all by the person with whom you will communicate by email directly. In certain cases Your communication can be accessed and processed by other employees for the purposes of investigation of potential violations of legal acts or internal rules, implementation of the latter, protection of confidential information, protection of the Company‘s IS from hacking, data theft, viruses and malware, protection of the Company‘s pecuniary and non-pecuniary interests (business reputation, image etc.), ensuring continuity of the Company‘s activities, employee substitution etc.
The Company with whose employee/representative you communicate with is the data controller responsible for the processing of personal data for this purpose.
Use of Social Networks
Any information that You provide on social media (including posts, clicking on ‘Like’ and ‘Follow’ etc.) is controlled by the manager of the relevant social network.
Kauno grūdai, AB has the following social network accounts:
• on Facebook, whose privacy notice is published at https://www.facebook.com/privacy/explanation; and
• on LinkedIn, whose privacy notice is published at https://www.linkedin.com/legal/privacy-policy.
We recommend that You should read third-party privacy notices and contact service providers directly if You have any questions as to the use of Your personal data by them.
Conclusion and Performance of Contracts with Individuals
Personal data processed for the purpose of concluding and performing contracts with individuals are stored for 10 years after the end of the contractual relationship. Your personal data will be processed on the grounds of the contract concluded with You, also in order to take actions at Your request prior to its signature. We may ask Your consent to certain actions; furthermore, a duty may arise for us to perform legal obligations, e. g. under tax legislation. For this purpose, we will process the personal data that You have provided prior to conclusion and during performance of the contract. We will not be able to conclude the contract if we do not receive such data from You.
If You express a wish to buy goods from the Company on deferred payment terms, Your personal data will be processed in order to assess Your creditworthiness and determine whether we can grant a commercial credit to You. Apart from the data received from You directly, we will also get them from Creditinfo Lietuva, UAB, which issues reports on the person‘s rating, probability of default, risk class, outstanding debts, debt repayment history and creditors. Creditinfo Lietuva, UAB collects these data from debt recovery companies and Your creditors, e. g. leasing and insurance companies, electricity and other utility service providers, and sellers of goods/services. We can get information on Your assets and liabilities from VĮ Registrų centras as well. Your creditworthiness data can be evaluated also after conclusion of a contract with deferred payments if You ask us to increase the credit limit or are in arrears with payments.
The personal data required for the creditworthiness assessment are processed under Article 6(1)(b) of the Regulation, i. e. in order to take steps at the request of the data subject prior to entering into a contract. Without such processing, we would not be able to make the assessment and take a decision on concluding a contract on deferred payment terms.
The Company with which the contract is concluded is the data controller responsible for the personal data processing for this purpose.
Conclusion and Performance of Contracts with Legal Persons
Personal data processed for the purpose of concluding and performing contracts with legal persons are stored for 10 years after the end of the contractual relationship. The data are processed on the ground of a legitimate interest. Without processing personal data on representatives of the counterparty, we would not be able to conclude the contract with the relevant legal person.
The Company with which the contract is concluded is the data controller responsible for the personal data processing for this purpose.
Protecting the Company’s Reputation and Increasing Visibility of Its Activities (taking photos during events)
Photographers can take photos and make video recordings during events held by the Company. Your participation in an event at which photos are taken and video recordings are made means that You agree to such activity and the posting of the photos/videos on social networks such as Facebook, Instagram and LinkedIn as well as making them available within the Company. The purpose of such personal data processing is protecting the Company‘s reputation, increasing its visibility, and publicity of the event. The term for publishing photographs and posts on social networks is 5 years.
If You do not wish to be photographed or filmed during the Company‘s event, You must clearly state such objection to the photographer. You can also express Your objection to the taking of Your photographs/filming to Kauno grūdai AB’s Data Protection Officer or the Company‘s employee that has invited You to the event, or by emailing the Company.
The Company that has organised the event and is inviting You is the data controller responsible for the personal data processing for this purpose.
Transfer of Personal Data to Data Recipients
Your personal data may be transferred to:
• Providers of IT, server, postal, archiving, marketing, accounting and other services as well as subcontractors;
• Notaries, bailiffs, solicitors, consultants, auditors, debt recovery companies and companies to which debts are sold/assigned;
• Law enforcement bodies, supervisory bodies, courts, other dispute resolution authorities and other persons performing statutory functions;
• Potential or existing transferees of our business or any part thereof, or consultants and other persons authorised by such transferees, and other participants in reorganisation.
The Companies form part of AB Akola Group (formerly AB Linas Agro Group) therefore, we may transfer Your data, for the purpose of internal administration and on the ground of a legitimate interest, within AB Akola Group. The structure of the Group and changes therein are published on https://www.akolagroup.lt.
Personal Data Protection Principles That We Follow in the Processing of Personal Data
The personal data provided by You as well as the data received from other sources are collected and used according to the following principles:
• Your personal data are processed lawfully, fairly and in a transparent manner in relation to the data subject (the principle of lawfulness, fairness and transparency);
• Your personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (the principle of limitation of purpose);
• Your personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (the principle of data minimisation);
• Your personal data are accurate and, where necessary, kept up to date (the principle of accuracy);
• Your personal data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (the principle of storage limitation);
• Your personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (the principle of integrity and confidentiality).
Exercise of the Data Subject’s Rights
Please be aware that You have the following rights as a data subject:
• The right of access to Your personal data and the right to be informed about their processing;
• The right to obtain from us the rectification of inaccurate data concerning You;
• The right to obtain from us the erasure of Your personal data. This right can be exercised in the cases listed in Article 17 of the Regulation;
• The right to obtain from us the restriction or discontinuation of the processing;
• The right to transmit the data that are processed by automated means and which we have received from You on the ground of Your consent or for the purpose of concluding a contract;
• The right to object to the processing of personal data concerning You as stated in Article 21 of the Regulation, in particular where the data are processed on the ground of a legitimate interest;
• The right to withdraw Your consent to the personal data processing if You have given such consent;
• The right to file a complaint to the State Data Protection Inspectorate (L. Sapiegos g. 17, 10312 Vilnius).
We must establish Your identity in order to enable You to exercise Your rights as a data subject. Otherwise it would be impossible to verify that the applicant is actually the person whose data are being processed, and the exercise of Your rights will be impossible.
We may refuse to consider Your request for the exercise of Your rights, or may request a fee therefor, if the request is clearly unjustified or excessive as well as in other cases prescribed by the law.
If You wish to exercise Your rights as a data subject, or have any questions as to the processing of Your personal data, please write to duomenu.apsauga@kggroup.eu or send a letter to the address of the relevant Company to the address provided in this Privacy Policy above.
Information on the personal data processing carried out by AB Akola Group is provided here. In the cases specified in this Privacy Policy, Kauno grūdai, AB is a data controller jointly with other companies of the Group.
We can update or amend this Privacy Policy at any time. Such updated/amended Privacy Policy will enter into effect upon its publication on www.kaunogrudai.lt. The date of the last update is provided at the end of this Privacy Policy. Please ensure that You have read the current version of this document.
Last update: 26 January 2024