Privacy Policy

This privacy policy provides information on the processing of personal data carried out by companies belonging to the MEDIAFON group – how they collect, process and store personal data. We recognise the importance of personal data protection and therefore respect the privacy of our customers and other data subjects (hereinafter referred to as 'data subjects') and safeguard their personal data.

The MEDIAFON group of companies comprises:

  • UAB "MEDIAFON",
  • Mediafon Datapro, UAB,
  • Mediafon Carrier Services, UAB,
  • Mediafon Technology, UAB,

hereinafter, all MEDIAFON companies are collectively referred to as the 'MEDIAFON Group', and each individually as the 'Company' or 'data controller'.

The controller of your personal data is the company within the MEDIAFON Group to which you have provided your personal data in connection with a contractual relationship involving you, or whose services you (or the legal entity you represent) intend to use or are using, and/or which determines the purpose and methods of personal data processing.

1. Purposes, categories and legal bases for the processing of personal data

1.1. Conclusion and performance of contracts with customers, compliance with accounting requirements

Legal basis for data processing Categories of data
Performance of a contract (Article 6(1)(b) of the GDPR), compliance with legal obligations (Article 6(1)(c) of the GDPR) Conclusion and performance of contracts with customers (natural and legal persons): the customer's, their employee's or representative's first name, surname, position, email address and/or telephone number, date of birth or personal identification number, and requests relating to the provision of services. For the purposes of concluding and performing contracts with natural persons, other personal data may also be processed. The categories of a client's personal data processed in a specific case depend on the nature of the contract being concluded and performed. In any event, only as much personal data is processed as is necessary to fulfil the contract or to comply with legal requirements. Compliance with accounting requirements: when issuing and receiving invoices, the following personal data is processed: first name, surname, address and other data, if requested by the customer. When administering received invoices, the personal data that must be provided in accordance with the requirements set out in legislation is processed.

1.2. Processing of personal data of shareholders, beneficiaries, management bodies, other bodies and their members for the purposes of internal administration and the fulfilment of legal obligations

Legal basis for data processing Categories of data
Compliance with legal requirements (Article 6(1)(c) of the GDPR)

First name, surname, personal identification number, date of birth, residential address and other personal data required to be processed by law. In fulfilling obligations relating to the provision of information on ultimate beneficial owners to the State Enterprise Centre of Registers via the JADIS subsystem, the following data is processed: the director's first name and surname, the shareholder's first name and surname, address, date of birth, personal identification number, address, number of shares held, and the nominal value of the shares held.

In the course of performing duties relating to the provision of information on ultimate beneficial owners, the following data is processed by the State Enterprise Centre of Registers in the JANGIS subsystem: the director's first name and surname; the personal data of the ultimate beneficial owners: first name, surname, date of birth, personal identification number, and address. the name of the country, the name(s) of the country (countries) of residence for tax purposes, and the beneficiary's ownership and/or control rights and their scope. In the case of an indirect beneficiary, data is processed for all legal entities through which the legal entity is controlled: name, company registration number, legal form, registered office, ownership rights held and their scope.

Legal obligations relating to the Company's management and other bodies include their formation, the organisation of their activities, the submission of data on the Company's management bodies and their members to public registers and their registration, and compliance with other legal requirements.

1.3. Video surveillance for the purpose of protecting property

Legal basis for data processing Categories of data
Legitimate interest in protecting property (Article 6(1)(f) of the GDPR) Video recordings showing individuals entering the video surveillance area.

1.4. Handling and processing enquiries and complaints

Legal basis for data processing Categories of data
Performance of a contract (Article 6(1)(b) of the GDPR), compliance with legal obligations (Article 6(1)(c) of the GDPR) First name, surname, telephone number, email address, residential address, date of birth, content of the enquiry: the incident in respect of which the enquiry is being made to , its circumstances, date, location, your request, claim or feedback, the product, and any other information provided in the enquiry; other documents and/or data submitted with the enquiry: e.g. details of the purchase receipt, photographs.

1.5. Recording of events in photographs and video footage

Legal basis for data processing Categories of data
Consent (Article 6(1)(a) of the GDPR), performance of a contract (Article 6(1)(b) of the GDPR), compliance with legal obligations (Article 6(1)(c) of the GDPR) or legitimate interests (Article 6(1)(f) of the GDPR) Photographs and video recordings depicting individuals participating in events organised by MEDIAFON (images of visitors, recordings of their actions), as well as the organisers.

We process personal data when you take part in events or other activities organised by us, or when you organise events or other activities for us. To avoid the possibility of being photographed or filmed, participants in events organised by the MEDIAFON group of companies may choose not to attend or may otherwise clearly express their objection.

1.6. Recruitment for job(s) or internships, assessment of candidates, administration of the database of job applicants (interns) and the provision of job offers

Legal basis for data processing Categories of data
Consent (Article 6(1)(a) of the GDPR) First name, surname, date of birth, details of place of residence, email address, telephone number, information on work experience, education, professional development, skills, other information provided by the job applicant in their curriculum vitae (CV), cover letter (if provided) or other job application (internship) documents, employers' feedback on the job applicant (intern), references: the person providing the reference or recommendation, their contact details, the content of the reference or recommendation, assessment information, and other information to the extent that it is necessary for the selection process for a specific job position and to the extent permitted by applicable legislation.

We obtain the personal data of candidates for employment (trainees) either from the candidates themselves or from recruitment agencies, online job search portals and/or other entities providing job search, selection and/or intermediary services.

1.7. Debt recovery in the event of non-fulfilment of obligations

Legal basis for data processing Categories of data
The data controller's legitimate interests in recovering debts (Article 6(1)(f) of the GDPR) Personal data of debtors and representatives of legal entities: first name, surname, address, telephone number and email address.

1.8. Promoting awareness on social media

Information that you provide on the Facebook, Instagram and/or LinkedIn accounts of the MEDIAFON group of companies or its affiliated companies (including posts, use of the 'Like' and 'Follow' buttons, and other communications), or which is collected when you visit these accounts on Facebook, Instagram and/or LinkedIn, is controlled by the social media platform operator; we therefore recommend that you read the privacy policies of these social media platform operators. When managing an account, the MEDIAFON group of companies or a company belonging to it selects the appropriate settings, taking into account the target audience and the objectives of business management and promotion. By allowing you to create an account, the social media platform operator may have restricted the ability to change certain settings, and so we cannot influence what information the social media platform operator collects about you.

Generally, the social media platform operator processes your personal data for the purposes set out by the operator, in accordance with the operator's privacy policy. However, when you use the social network, interact with the MEDIAFON group of companies or a company belonging to it on the social network, visit your account on the social network, or view posts on it, the Company receives information about you. The scope of the data received depends on the account settings we have chosen, agreements with the social network operator regarding the subscription to additional services, and the cookies set by the social network operator.

Legal basis for data processing Categories of data
Legitimate interests in promoting awareness (GDPR Article 6(1)(f)), consent (GDPR Article 6(1)(a)) Posts, 'Likes', 'Follows' and other information provided on social media profiles.

1.9. Use of cookies

Cookies are small text files that are automatically created whilst you are browsing our website and are stored on the device you are using (computer or mobile phone). Cookies are used to ensure that the website functions, or functions better and more efficiently.

Cookies do not normally contain any information that could directly identify you, but the personal information we process may be linked to your use of a computer or other device, including browsing our websites and other information obtained and stored through cookies. 

There are several ways to manage your cookies: 

External sources 

We use Google Analytics on our website to find out how visitors use the content of the website. Google Analytics uses a set of cookies to collect information and report on website usage statistics to Google, without personally identifying individual visitors. 

You can read more about Google’s privacy policy here. 

If you do not want your browser to use Analytics, you can install the Google Analytics Opt-out Browser Add-on. 

Browser settings 

Many web browsers, and add-ons designed specifically for this purpose, allow users to refuse or delete cookies. The steps vary depending on the specific browser and its version. You can find up-to-date information on how to block or remove cookies on the websites of the browser providers themselves, such as Chrome, Firefox, Internet Explorer and Safari. Please note that deleting or disabling cookies in advance will not prevent you from continuing to use our website properly. 

Cookies on our website 

Necessary cookies. To make the website easier to use, necessary cookies activate basic functions such as browsing pages and accessing protected areas of the website. Without these cookies, the website will not function properly. 

Name 

Provider 

Purpose 

Expiry 

cookieDirective 

Mediafon.com 

Remembers whether consent has been given for the use of cookies. 

24 h 

session cookie (e.g. carrierservices / datapro) 

Mediafon.com 

Used to save a session ID during a single visit. Does not collect private information. Required for the website to operate. 

Until end of session 

_ga 

Google 

The main cookie used by Google Analytics; it allows the service to distinguish between different users without personally identifying individual visitors. 

2 years 

_gat 

Google 

Used by Google Analytics to limit the rate of requests. 

24 h 

_gid 

Google 

Used by Google Analytics to distinguish users. 

24 h 

Third-party websites. We may work with third parties (commonly referred to as service providers) who, with our permission, may place third-party cookies on our websites, in our service locations, or in our applications and tools. These service providers help us serve you better, faster and more reliably. Please note that third-party cookies are subject to the privacy policies of those third parties, and we do not accept any responsibility for their privacy practices. 

1.10. Processing of personal data for other purposes

Companies belonging to the MEDIAFON group may process personal data for other purposes, as set out in the Privacy Policy published on the website of the relevant company within the MEDIAFON group or in the register of activities of the specific MEDIAFON group company.

Furthermore, for each specific purpose, a company belonging to the MEDIAFON group of companies may process categories of personal data other than those specified in this privacy policy. In such cases, priority is given to the information set out in the privacy policy of the relevant company belonging to the MEDIAFON group of companies or in the register of activities of the specific MEDIAFON group of companies.

2. Where do we obtain personal data from, and in what circumstances do we transfer your personal data?

In most cases, personal data is provided directly by the data subject themselves. In some cases, we may obtain personal data from third parties – recruitment agencies, online job search portals and/or other entities providing job search, recruitment and/or intermediary services.

Your personal data may be disclosed to state and local authority bodies and other persons performing functions assigned to them by law, where such an obligation is provided for in legislation. We transfer your personal data upon request or in order to pursue our legitimate interest in establishing, exercising or defending legal claims.

Where necessary to achieve the relevant purposes, your personal data may be transferred to the following third parties:

For the purposes of contract performance and compliance with legal requirements

  • to other companies within the MEDIAFON Group, where they perform functions necessary to achieve the relevant purpose;
  • to third parties who assist us in operating and administering the provision of our services to you (for example, companies providing software maintenance and support services). In each case, we provide the data processor with only as much data as is necessary to carry out a specific task or provide a specific service. The data processors we engage may only process your personal data in accordance with our instructions and may not use it for other purposes or disclose it to other parties without our consent. Furthermore, they are obliged to ensure the security of your data in accordance with applicable legislation and the written agreements concluded with us;
  • couriers, delivery service providers and their staff, where necessary to deliver parcels sent to you (for example, parcels containing documents);
  • other third parties, where necessary to fulfil the relevant purpose, for example, to competent public authorities or law enforcement agencies (the police or supervisory authorities, etc.), but only upon their request and only where required by applicable legislation or in the cases and in accordance with the procedures provided for by law, in order to safeguard our rights, the safety of our customers, employees and assets, and to assert, submit and defend legal claims.

The transfer of personal data for the purposes of conducting recruitment for a job or jobs, assessing candidates, managing the database of job applicants and making job offers

We may transfer your data to third parties for processing where this is necessary to fulfil the specific purpose for which we process personal data. These may include third parties who provide us with services relating to recruitment, candidate assessment and internal administration (database software suppliers, database administration service providers, data centre, hosting and cloud service providers, etc.).

When the Company processes personal data for the purpose of recruitment for a job or jobs, or for internships, the Company may also transfer the personal data of candidates for employment or traineeships to other companies within the group to which the Company belongs, provided that they are involved in the assessment processes for managerial staff or trainee candidates. When the Company processes personal data for the purpose of administering the candidate database, the Company may transfer the personal data of candidates for employment or traineeships to other companies within the group to which the Company belongs, provided that the candidate in question may be suitable for a position at these companies or for a traineeship at these companies.

If personal data is provided in connection with the recruitment process for a position or positions at companies located abroad (in other EU Member States) or is processed in a database of candidates for employment at companies located abroad, it may be transferred to companies abroad that are seeking to recruit staff for a position or positions.

Your personal data is processed within the European Union and the European Economic Area. However, data may be transferred outside the European Union or the European Economic Area where such a transfer is necessary for the conclusion and performance of contracts and the proper provision of services. In such cases, measures are taken to ensure that any transfer of personal data outside the European Union and the European Economic Area is carried out appropriately and that data subjects' rights to privacy are protected to the greatest extent possible. The transfer of personal data outside the European Union and the European Economic Area is governed by the requirements of Chapter V of the GDPR.

3. What rights do data subjects have and how can they exercise them?

You have the right to access your personal data and to know how it is being processed; to request that the personal data provided be rectified, supplemented or erased; and to have the processing of your personal data suspended (withdraw your consent). You also have the right to request that the data controller restrict the processing of your personal data, the right to data portability, the right to lodge a complaint with the State Data Protection Inspectorate (contact details are available on the website www.ada.lt) and the right to object to the processing of the personal data you have provided. Information on the procedure for exercising these rights is available from your data controller via email at:

Data Controller Email address
UAB "MEDIAFON" dataprotection@mediafon.lt
Mediafon Datapro, UAB dataprotection@mediafon.lt
Mediafon Carrier Services, UAB dataprotection@mediafon.lt
Mediafon Technology, UAB dataprotection@mediafon.tech

4. How long do we retain personal data?

We retain personal data for no longer than is necessary for the purposes of data processing or as required by law, where the law provides for a longer retention period. Personal data may be retained for longer than specified at if required by law, or where necessary for the company to defend itself against claims, complaints or legal proceedings brought against it, as well as where personal data is required for an investigation or as evidence in civil, administrative or criminal proceedings.

Purpose of data processing Data retention period
Conclusion and performance of contracts with customers, compliance with accounting requirements Accounting and tax documents are retained in accordance with the time limits set out in legislation, on the basis of compliance with statutory requirements. Other purchase data is retained for 5 years from the date of the purchase transaction.
Processing of personal data of shareholders, beneficiaries, management bodies, other bodies and their members for the purposes of internal administration and the fulfilment of legal obligations For no longer than is necessary for the purposes of data processing or as required by law, and in accordance with the time limits set out therein.
CCTV surveillance for the purpose of protecting property 14 (fourteen) days, unless the recordings contain information necessary to achieve a specific purpose. In such cases, the recording will be retained until the identified issue has been resolved or the relevant investigation has been completed.
Handling of enquiries, requests and complaints 12 calendar months from the date of submission of the enquiry, request or complaint.
Documentation, organisation and administration of events In the case of events for employees, personal data is retained for 3 years from the date consent is given or for as long as the consent remains valid. If the legal basis for data processing is the performance of a contract, the data retention period is as specified in the contract. Where personal data is processed on the basis of a legitimate interest, it is retained for the duration of the employment relationship. In the case of other events, photographs and video recordings are retained for 3 years from the date on which consent is given or for as long as the consent remains valid. If the legal basis for data processing is the performance of a contract, the data retention period is as specified in the contract. Other participants' personal data is retained for 6 months after the end of the event, unless a different period is specified in the event notice.
Conducting the selection process for job(s) (internships) and assessing candidates Until the end of the selection process. With the candidates' consent – for up to 3 months. Upon expiry of this period, the data is destroyed. LINKEDIN RECRUITER LITE is stored for as long as permitted by the LinkedIn platform.
Debt recovery in the event of non-fulfilment of obligations Personal data is retained for the duration of the reminder period and until the debt is recovered; in cases where the debt is recovered – for the duration of the contract and for 10 years after the end of the contract and the fulfilment of obligations , debt recovery or the issuance of a statement confirming that debt recovery is not possible.
Promoting awareness on social media Information on the retention periods for personal data is set out in the privacy policies of social media platforms.
Use of cookies Data is retained in accordance with the timeframes specified in the list of cookies.

5. Amendments to the privacy policy

This privacy policy may be updated and amended. Updates and amendments will be communicated by publishing the revised text of the privacy policy on the website.

Effective from 01 August 2026.

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