Privacy
Policy

This Privacy Policy sets out the order in which personal data about you may be collected and how it is processed when you use the UAB “Theoria” (“Theoria”) mobile application (“Application”).

WHO DOES COLLECT YOUR PERSONAL DATA?

The controller – Theoria – UAB “Theoria”, legal entity code 304050587, registered office address is at Didzioji st. 25, LT-01128 Vilnius, Republic of Lithuania.

WHAT KIND OF PERSONAL DATA DO WE COLLECT?

When you use our Application, we collect the following personal data from you:

• the information that you submit to us when registering a personal account on the Application: e-mail address;
• the information you provide to us by filling out or exchanging your profile data in your personal account: a photo;
• information related to your insights;
• other data that is collected with your consent and which is defined in detail at the time when you are asked for permission.

You are responsible for ensuring that your data is accurate and complete. Knowingly entering incorrect data is considered a violation of this Privacy Policy. We will under no circumstances be liable for any damage caused to you and (or) third parties due to the fact that you have provided incorrect and (or) incomplete personal data, or you have not requested the addition and (or) modification of the data after it has changed.

WHAT LEGAL BASIS DO WE COLLECT YOUR PERSONAL DATA?

Your personal data is handled, where appropriate, on the following legal grounds:

• with your own consent, to process personal data for one or more specific purposes specified in this Privacy Policy;
• managing your personal data is necessary to provide you the opportunity to create a personal account and use it to visit the Application;
• processing your personal data is necessary for the legitimate interests of Theoria or third parties.

WHAT ARE THE OBJECTIVES FOR COLLECTING YOUR PERSONAL DATA?

Our processed personal data is used exclusively for the purposes specified in this Privacy Policy. We use your personal data:

• to give you the opportunity to create a personal account and use it to visit the Application;
• to communicate with you;
• for statistical purposes.

We will not store your personal data collected more than 2 years after your last login to the Application. When personal data becomes unnecessary for the purposes of their processing or after the expiration of the prescribed retention period, it will be safely destroyed, except for the cases specified by law, when it must be transferred to the archives of the state.

WHY WE DISCLOSE YOUR PERSONAL DATA TO THIRD PARTIES?

We may disclose your personal data to our employees, brokers and other entities if it's reasonably necessary to achieve the purposes stated in this Privacy Policy.In addition, we may disclose your personal data:

• if we must do it according to law;
• to protect your rights or interests (including the provision of your data to third parties).

Except for the cases provided for in this Privacy Policy, we do not provide your personal data to any third parties.

PROTECTION OF PERSONAL DATA.

Your personal data will be processed responsibly and securely. By setting up the tools of processing of the personal data, as well as during the processing of the data, we implement appropriate technical and organisational measures for the protection of your personal data from accidental or unlawful destruction, damage, alteration, loss, disclosure, and any other unauthorized management.

The employees and partners of Theoria are in writing obliged not to disclose to third parties nor to distribute the information of Theoria customers gathered in Theoria workplace or by communicating with customers directly.

Please note that Theoria Social Networks is subject to applicable social networking cookie policies. As a result, if you are using the Social Networks, please review and comply with the relevant social networking cookie policies.

CHILDREN.

We do not provide any services for people under the age of 16, so we do not collect their personal data. If you are under the age of 16 years, do not use our services.

If we learn that we have collected personal information from a person under 16, we will delete that information.

YOUR RIGHTS.

You have the following rights regarding your personal data:

• the right to access to personal data;
• the right to rectification;
• the right to erasure (“right to be forgotten”);
• the right to the restriction of processing;
• the right to data portability;
• the right to disagree with the processing of your personal data, unless this data is processed on the basis of a legitimate interest pursued by Theoria or a third person to whom the data is provided and if the interests of the data subject are not more important;
• the right a complaint to The State Data Protection Inspectorate regarding the processing of personal data.

If you want to exercise your rights, you must personally contact Theoria by the following e-mail info@xwhy.lt with a request for the exercise of rights and at the same time to confirm your identity. Your identity is based on your e-mail address. Theoria will notify you within 30 calendar days after your request.

Theoria will provide you with the necessary information without any consideration whatsoever when implementing your rights. However, if it becomes clear that your application is manifestly ill-founded or disproportionate, in particular because of its repetitive content, Theoria is entitled to:

• require payment of a reasonable fee, considering the administrative costs of providing the information or ofthe reports or actions requested; or
• refuse to act on request.

HOW TO CONTACT US?

If you have any questions regarding your personal data, you can contact us by e-mail info@xwhy.lt or at Didzioji st. 25, LT-01128 Vilnius, Republic of Lithuania.

FINAL PROVISIONS.

We may change this Privacy Policy at any time without notice. If we make major changes to this Privacy Policy we will notify it on our Application. Nevertheless, you should regularly check the Privacy Policy we use to make sure its current version is appropriate for you.

This Privacy Policy is effective from 29 March 2022.