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VIDEO SURVEILLANCE (CCTV) PRIVACY POLICY

1. WE CARE ABOUT PROTECTION OF YOUR PRIVACY
1.1. To ensure that your personal data are always secure with us and that the data processing complies with the current personal data protection laws, our internal policies, guidelines and procedures, we have been implementing the respective measures. 
 
1.2. It is very important that your personal data are processed in a transparent manner, therefore this Video Surveillance (CCTV) Privacy Policy describes how and where we process your personal data in connection with the surveillance by video cameras. 
 
2. WHY DO WE COLLECT PERSONAL DATA?
2.1. Video surveillance shall be carried out for the following purposes:
2.1.1. protection of property on the premises against damage and loss;
2.1.2. protection of property, health and life of other persons;
2.1.3. prevention of the third parties’ unlawful activities on the premises.
 
3. WHAT ARE THE SOURCES WE COLLECT PERSONAL DATA FROM?
3.1. We collect personal data using the technical measures, i.e. video cameras and similar technologies.
 
4. WHO WE PROVIDE YOUR PERSONAL DATA TO
4.1. Service providers.
4.1.1. To fulfil our obligations, we are transferring your personal data to the undertakings which provide us the services, for instance, security companies. Such undertakings may process your personal data under our instructions only and they may never use them for other purposes. Moreover, both the laws and our cooperation agreement require such undertakings to ensure the security of your personal data.
 
4.2. Group companies.
4.2.1. Usually, we do not share personal data with the other companies of AB “Avia Solutions Group”, but if it becomes necessary for reaching the goals and for the purpose of the principle of legitimate interests, your personal data are likely to be transferred to the associated companies of AB “Avia Solutions Group”.
 
4.3. Law enforcement institutions, public and local authorities.
4.3.1. In order to fulfil our legal obligation, we may transfer your personal data to the law enforcement institutions, public and local authorities at their request. Moreover, we may transfer your personal data to the law enforcement institutions, public and local authorities in pursuit of our legitimate interest: to establish, exercise and defend legal claims.
 
5. WHERE ARE YOUR PERSONAL DATA PROCESSED?
5.1. We always aim at processing your personal data in the EU and EEA Member States. Your personal data shall not be transferred to or processed in the countries outside the EU and EEA.
 
6. HOW LONG ARE YOUR PERSONAL DATA STORED FOR?
6.1. Personal data shall not be stored for a period longer than 30 (thirty) calendar days, except for the cases, where the records contain information necessary to reach a goal. In this case, the record shall be stored until the issue detected is eliminated or a relevant investigation is completed.
 
7. YOUR RIGHTS
7.1. The data protection legislation grants you the following rights in connection with the processing of your personal data:
7.1.1. Right of access to personal data.
7.1.1.1. You have the right to request us to confirm if we process the personal data related to you and to request the access to personal data that we are processing.
 
7.1.2. Right to rectification.
7.1.2.1. We would like to inform you that due to the nature of surveillance by video cameras the data may not be rectified.
 
7.1.3. Right to object to the processing of the personal data, where the grounds for the processing are the legitimate interests of the Company.
7.1.3.1. You have the right to object to the processing of your personal data in the cases, where the grounds for the processing are our legitimate interests; however, if we have compelling grounds that the data must be processed, we will process the personal data irrespective of your objection.
7.1.3.2. We would like to inform you that due to the nature of surveillance by video cameras we cannot guarantee that your right to object to the processing of your personal data may be fully exercised as the data are collected automatically and if you are not an object of video cameras, you will not be able to do your tasks or receive our services.
 
7.1.4. Right to erasure.
7.1.4.1. Under certain circumstances, you have the right to erasure of your personal data. This provision, however, shall not be applied if such data must be processed under legal acts.
7.1.4.2. We would also like to inform you that due to the nature of surveillance by video cameras the data of a specific person may be impossible to erase.
 
7.1.5. Restriction of the data processing.
7.1.5.1. Under certain circumstances, you have the right to restrict the processing of your personal data.
7.1.5.2. We would like to inform you that due to the nature of surveillance by video cameras we cannot guarantee that your right to restrict the processing of your personal data may be fully exercised as, in this case, the personal data are collected automatically and if you are not an object of video cameras, you will not be able to do your work or receive our services.
 
7.1.6. Right to lodge a complaint.
7.1.6.1. You have the right to lodge a complaint with a supervisory  authority (State Data Protection Inspectorate, A. Juozapavičiaus g. 6, 09310 Vilnius; tel. (+370 5) 271 2804, 279 1445; e-mail: ada@ada.lt), where you believe that we improperly process your personal data or improperly exercise your rights. When making a complaint it is recommended to follow a memo for persons intending to address the State Data Protection Inspectorate regarding the complaint
 
7.2. We are entitled to refuse to provide the processed personal data or exercise the other right in the event where certain circumstances referred to in other applicable legal acts or reasons, in the presence whereof we may refrain from the provision of such data or from exercising the other right, are identified.
 
8. CONTACTS
8.1. Should you wish to exercise your rights or have other questions related to video surveillance, do not hesitate to contact us by e-mail gdpr@jetms.aero or telephone No +370 5 252 5662 or physically arrive at the address Smolensko g. 10, Vilnius, Republic of Lithuania (address the person’s response to the data record management).
 
8.2. Should you decide to exercise any rights referred to in this notification, you must provide a document certifying the person’ identity alongside an application or you shall confirm your identity under the procedure prescribed by laws or by electronic means enabling the appropriate identification of a person. Where the personal information is inquired by a representative, a proper and valid document certifying the representation and a document certifying the person’s identity shall be provided.