SPEEDWINNER – Privacy Policy
We are SPEED MATTERS UAB (“SPEED MATTERS”, “we”, “us”, or “our”), a company registered in Lithuania with legal entity code 306575217 and address J. Tumo-Vaižganto 4-3, 01108 Vilnius, Lithuania.
We really care about your privacy. We provide you with this privacy policy which explains how we process, protect your personal data, what your rights we ensure, and provides other information about the processing of information about you.
SPEED MATTERS processes personal data in accordance with the provisions of the General Data Protection Regulation No. 2016/679 (EU) (“GDPR”) and the requirements of other applicable legal acts, as well as the instructions of the authorities.
This policy applies to all persons that use http://speedwinner.com („Website”), use our products or mobile applications developed by SPEED MATTERS (jointly – „Products”), visit our accounts on Facebook, LinkedIn, Youtube and Instagram social networks („Social Accounts”), view the information provided by us, order and use the services we offer, contact us by phone, e-mail, chat channels, other electronic means, express interest in our offers and news or apply for other issues. When we provide you with Website, Products, services, and Social Accounts, we act as a controller of your personal data.
If you order our products and services, use our Products, Website or Social Accounts, contact us, subscribe to our newsletter, we consider that you have read and agree to the terms of the privacy policy and the purposes, methods, and procedures for the use of personal data set out therein. If you do not agree with the privacy policy, you may not interact with us.
SPEED MATTERS also periodically organizes various surveys, games, competitions, promotions, and other campaigns. We would like to point out that these are subject to separate privacy policies of the platforms on which they are organized, so please familiarize yourself with them before participating in such surveys, games, competitions, or promotions. SPEED MATTERS will also provide separate rules and privacy notices for such surveys, games, competitions, promotions.
WHAT IS PERSONAL DATA?
The term “personal data” means any information or set of information by which we may directly or indirectly identify you, such as your name, email address, telephone number, etc.
We do not knowingly collect personal information from children under 14. If you become aware that your child has provided us with personal information without your consent, please contact us at contact@speedmatters.com.
Certain types of sensitive personal data are subject to additional protection under the GDPR. These are listed under Article 9 of the GDPR as “special categories” of personal data (e. g. personal data revealing racial, ethnic origin, political opinions, sexual orientation, etc.). Please note that we will not intentionally collect and will not process any special categories personal data of yours. If such data would be accidently communicated to us, we will immediately delete hereof without giving any notice to you.
WHEN, HOW AND WHY SPEED MATTERS PROCESSES IT?
We must have legal basis for processing personal data. Without having one, we will not process your personal data since we respect the rule of law and your privacy. We process personal data to offer and provide our services, to fulfil our contractual obligations, as well as pursuing our or third parties’ legitimate interest, in compliance with legal regulations or obligations. Moreover, we may process your personal data after receiving your consent for such processing.
We process your personal data:
When you provide us with personal data, for example, register on the Website, the Products, order our services, products, contact us by e-mail or telephone, etc.;
When you use the Products and the Website, Social Accounts, we automatically collect your personal data, such as the history of use of the services, your IP address, the history of your visits to the Website, your choices, open URL links, etc.;
When we receive personal data from other parties, for example, when we receive information from public registers, state or local government institutions or bodies, our partners, other third parties, such as payment institutions, about payments made, etc.;
When your personal data, with your consent, is provided to us by other persons, including companies using our services or those providing services to us, for example, when such companies indicate your contacts, refer to you as an authorized person, etc.
The person providing personal data to us, both when providing his/her personal data and personal data of other persons (such as employees, representatives), is responsible for the correctness, completeness, and relevance of such personal data, as well as for the consent of the other person. SPEED MATTERS may ask you to confirm that you have the right to provide us with personal data (for example, by filling in service order or registration forms). If necessary (for example, a person inquires us about receiving his/her personal data), we will identify the provider of such data.
HOW DO WE USE YOUR PERSONAL DATA AND WHAT PRINCIPLES DO WE KEEP?
SPEED MATTERS collects and processes only such personal data as is necessary to achieve the processing purposes.
When processing your personal data:
We comply with the requirements of current and applicable legislation, including GDPR;
We process your personal data in a lawful, fair, and transparent manner;
We collect your personal data for specified, clearly defined and legitimate purposes and do not process them in a way incompatible with those purposes, except to the extent permitted by law;
We take all reasonable steps to ensure that personal data that is inaccurate or incomplete, in accordance with the purposes for which they are processed, would be rectified, supplemented, suspended, or destroyed without delay;
We hold them in such a form that your identity can be established for no longer than is necessary for the purposes for which the personal data are processed;
We do not provide personal data to third parties or disclose them, other than as set forth in this privacy policy or applicable law;
We ensure that your personal data are processed securely.
WHAT PERSONAL DATA SPEED MATTERS WILL PROCESS AND FOR HOW LONG?
1. Purpose of the processing of personal data:
Participation in the surveys and competitions held via the Website and/or the Products.
Personal data being processed:
Name, surname, e-mail address, country, city, information about the fishing interests, feedback about products purchased, personal data related to prizes previously won.
Personal data processing period:
During the period of the survey or competition and 5 years after the registration to it, or until the revocation of the consent (when data are processed based on consent).
Legal basis for the processing of personal data:
Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR). Consent of the data subject to such data processing (Article 6(1)(a) GDPR).
Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR).
2. Purpose of the processing of personal data:
Service quality management and services related communication.
Personal data being processed:
Name, surname (if required), username, e-mail, password, phone number, relationship with the represented legal entity, history of use of services and account, choices and content related to services and account, information required to resolve service quality issues, the content of the request and the response to the request.
Personal data processing period:
During the issue administration period and 5 years after the end of the issue administration or last contact.
Legal basis for the processing of personal data:
Consent of the data subject to such data processing (Article 6(1)(a) GDPR). Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR).
3. Purpose of the processing of personal data:
Profiling for ensuring better experience when using the services and products.
Personal data being processed:
E-mail, social profiles data, country, location data, data about products and services used by you, data gathered while using our products and services, other data.
Personal data processing period:
5 (five) years from the date of the last use of the services and products unless consent given to us would be withdrawn prior to this term.
Legal basis for the processing of personal data:
Consent of the data subject to such data processing (Article 6(1)(a) GDPR).
4. Purpose of the processing of personal data:
Execution of direct marketing campaigns.
Personal data being processed:
E-mail, social profiles data, data gathered while sending news to you.
Personal data processing period:
5 (five) years unless consent given to us would be withdrawn prior to this term.
Legal basis for the processing of personal data:
Consent of the data subject to such data processing (Article 6(1)(a) GDPR).
5. Purpose of the processing of personal data:
Provision of the secure and efficient use of our Website and Products.
Personal data being processed:
Type of computer/mobile device, unique mobile device ID, IP address, user’s mobile operating system and version, mobile browsers user uses, preferred language and user’s references while user uses the Website and/or Products, information on user’s location.
Personal data processing period:
During the period of use of the account and 5 years after the last login to the account.
Legal basis for the processing of personal data:
Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR).
6. Purpose of the processing of personal data:
Execution of financial operations, accounting.
Personal data being processed:
Name, surname, e-mail, phone number, position, place of work, address, relationship with the represented legal entity, account number, credit institution, payment information, debt information, data transferred by the company collecting the contributions and confirmations of payments.
Personal data processing period:
According to the regulatory legal acts, as well as in accordance with the Index of General Document Storage Periods approved by order No. V-100 of the Chief Archivist of the Republic of Lithuania of 9 March 2011.
When the data does not fall within the above-mentioned storage area – the period of validity of the contract/cooperation between the parties and 10 years after the end of the contract/relationship (last contact).
Legal basis for the processing of personal data:
Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR). Data processing is necessary for to fulfil a legal obligation imposed on the data controller (Article 6(1)(c) GDPR). Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR).
7. Purpose of the processing of personal data:
Management and analysis of use of electronic information channels (the Products, the Website, Social accounts) toupdate, modify, improve, tailor, customize, or otherwise adjust Products and the Website,ensure functionality and security, quality improvement.
Personal data being processed:
IP address, data collected by cookies and other similar technologies, device ID,the type of mobile device,device operating system (iOS, Android), information about the Products or the Websitebeing opened,date and time of connection, information about the region in which the Products or the Website is opened, usage data, diagnostic data.
Data collected through the integration of Social Accounts.
Personal data processing period:
Website and Products data are stored as described in this privacy policy.
Website and Products data that is not included in the cookie information is stored for a maximum of 1 year from the date of collection, unless the person revokes his/her consent (when the data are processed based on consent.Information in Social Accounts is stored according to the conditions set by the owner of this network.
Legal basis for the processing of personal data:
Consent of the data subject to such data processing (Article 6(1)(a) GDPR). Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR).
SPEED MATTERS guarantees that all stored data will be deleted after the expiry of the retention periods or anonymized so that the person is no longer identified by it. SPEED MATTERS may store your data for a longer period (if it is required to protect our legitimate interests, in case of a legal dispute, or if we are obligated to do so by law).
SPEED MATTERS also may anonymize the data previously provided by you so that it would no longer be possible to link the data to you and further use it for surveys of the market, improving user’s experience and usability when using SPEED MATTERS products and services, creation of the maps of depths, bathymetric maps and analysis water bodies and other purposes, including the commercial ones, as it is decided by SPEED MATTERS. The anonymized data may also be used for conducting business analysis and we reserve a right to share such data with partners who help us to achieve such goals.
In some cases, SPEED MATTERS may send you messages and/or reminders related to ordering or providing our services, for example, in the provision of services, the Products updates. Such notices are necessary for the proper provision of our services and are not considered as promotional messages.
8. Purpose of the processing of personal data:
Reservation of the products of SPEED MATTERS.
Personal data being processed:
Name, surname (if required), username, e-mail, details of payment of reservation fee, data related to the products reserved (list of products, names, descriptions, quantities, prices), shipping details.
Personal data processing period:
During the period of the reservation and 5 years after the purchase of reserved product.
Legal basis for the processing of personal data:
Data processing is necessary for the conclusion and performance of the contract (Article 6(1)(b) GDPR). Legitimate interests of the data controller or a third party (Article 6(1)(f) GDPR).
YOUR GEOLOCATION DATA AND SOCIAL MEDIA:
With your consent, we may collect your geolocation data on the Products or Website. This data helps us deliver a better, more tailored services. You can withdraw your consent on sharing geolocation data with us at any time by changing the settings on the Products or your mobile device. If you do not give your consent, you will still be able to use the Products and the services, subject to some limitations in functionalities. We will use the above data to analyze your engagement with the Products, to assign you to a specific profile and analyze the behavior of similar profiles.
When you log in to your account using your social media account, we will receive (unless you change your settings within your social media account), your public profile information (i. e. your name, e-mail, and profile picture, etc.).
WHAT WE HAVE TO SAY ABOUT DIRECT MARKETING AND PROFILING?
SPEED MATTERS also carries out direct marketing and profiling (with your consent, of course). For more information, please see Direct Marketing Notice and Profiling Notice available on the Website and Products.
WE CARE ABOUT YOUR RIGHTS
Remember that you ALWAYS have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (when such processing is based on your consent).
You have:
The right to be informed.
The right to access the information related to your personal data.
The right not to be subject to a decision based solely on automated processing, including profiling.
The right to rectification of your personal data, the right to be forgotten.
The right to restrict the processing of your personal data.
The right to object the processing of your personal data.
The right to data portability.
P.s. there are some limitations and preconditions provided by law. If this is the case, we will make a reasoned statement regarding this situation.
If our answer disappoints you, you have the right to lodge a complaint with a State data protection inspectorate of the Republic of Lithuania or other competent supervisory authority. However, we seek to solve every situation peacefully, so we kindly ask you to contact us first!
If we delete your personal data at your request, we will retain only copies of information that is necessary to protect the legitimate interests of us and others, to comply with requirements of the applicable legislation, to resolve disputes, to identify disruptions, or to comply with any agreements you have with us.
HOW TO EXERCISE YOUR RIGHTS?
Contact us by e-mail address contact@speedwinner.com.
Your rights implementing appropriate actions will be carried out by SPEED MATTERS as soon as possible, but no later than within 1 (one) month from the date of your referral. If necessary, the specified period may be extended by a further 2 months, depending on the complexity and number of applications. In this case, we will notify you of such an extension within 1 month of receiving the request.
If you have any questions regarding the processing of personal data, please contact us by e-mail address contact@speedwinner.com.
DO WE SHARE YOUR DATA WITH OTHERS?
SPEED MATTERS will only transfer your personal data as described in this privacy policy.
SPEED MATTERS may only transfer your personal data to:
Our partners (such as professional service providers, accountants, legal consultants, audit firms etc.), service providers (IT, cloud or hosting, cybersecurity, telecommunication, payment, insurance etc.). Moreover, we may transfer your data to our marketing partners, operators of survey platforms, operators of social media platforms. We will control and shall always remain responsible for the use of your personal data. The list of our service providers and partners is provided to you on demand (you have to make a written request to the email address indicated in this Privacy Policy);
State or local government institutions and authorities, law enforcement and pre-trial investigation institutions, courts and other dispute resolution institutions, other persons performing functions assigned by law, in accordance with the procedure provided for by legislation of the Republic of Lithuania. We provide these entities with mandatory information required by law or specified by the entities themselves;
Other third parties, such as payment institutions, other data processors, etc.;
If necessary, to companies that intend to buy or would buy our business or would conduct joint activities with us or would cooperate in another form, as well as to companies established by us.
By using our website, you (the visitor) agree to allow third parties to process your IP address, in order to determine your location for the purpose of currency conversion. You also agree to have that currency stored in a session cookie in your browser (a temporary cookie which gets automatically removed when you close your browser). We do this in order for the selected currency to remain selected and consistent when browsing our website so that the prices can convert to your (the visitor) local currency.
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store – you can read more about how Shopify uses your Personal Information here.
We normally process personal data within the European Economic Area (“EEA”), but in some cases your personal data may be transferred outside the EEA. Your personal data will only be transferred outside the EEA under the following conditions:
Data are transferred only to our reliable partners who ensure the provision of our services to you;
Standard contractual clauses (approved by European Commission) have been signed with such partners, which ensure the security of your personal data;
The European Commission has decided on the eligibility of the country in which our partner is established, i.e., an adequate level of security is ensured; or
You have given your consent to the transfer of your personal data outside the EEA.
SPEED MATTERS KNOWS THAT SECURITY OF YOUR PERSONAL DATA IS PRIORITY
Your personal data are processed responsibly, securely and is protected from loss, unauthorized use, and alteration. We have put in place physical and technical measures to protect the information we collect from accidental or unlawful destruction, damage, alteration, loss, disclosure, as well as from any other unlawful processing. Security measures for personal data shall be determined considering the risks arising from the processing of personal data.
Although we will do our best to protect your personal data, we cannot guarantee the full security of personal data shared or transmitted to the Website or Products. However, once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our employees and partners cooperating with us have made a written commitment not to disclose or distribute your personal data to third parties.
ABOUT THE COOKIES
Cookies are small files that are stored in the browser of visitor’s device when you browse websites. Other technologies, such as pixels, local storage, etc. may be used for similar purposes. Cookies are widely used to make websites work or to function better and more efficiently. In this policy, all the above technologies are referred to as “cookies”.
SPEED MATTERS uses cookies to analyze information flows and user behavior, to promote trust and ensure security, as well as to ensure the proper functioning of the Website, the Products its improvement, memorization of your chosen settings, to personalize the content displayed to you, to link the Website, the Products or to Social Accounts.
You can choose whether you want to accept cookies. If you do not agree to cookies being stored on the browser of your computer or other device, you can mark it in the cookie acceptance bar, change the settings of the browser you are using and disable cookies (all at once or one by one or in groups). To opt out of cookies on your mobile device, you must follow the official instructions for that device. You can control and/or delete cookies as you wish – for details, see http://www.youronlinechoices.com/ and http://www.AllAboutCookies.org. You can delete all cookies that are already on your computer, and you can set most browsers to prevent them from being placed. But if you do this you may have to manually adjust some preferences every time you visit the Website or the Products while some services and functionalities may not work.
OTHER
Website and Products may contain links to third party websites, applications, or social network accounts. This privacy policy does not apply to third party websites, applications, or services. Please review their privacy policies before submitting your personal data to these third parties. We do not control and are not responsible for the third parties’ content, services, or data processing
WE MAY AMEND THIS PRIVACY POLICY FROM TIME TO TIME
We will inform you about such changes via notifications in the Products or the Website, or your email address provided during the registration. Your continued use of the Website and the Products after such modifications will constitute acknowledgement of the modified privacy policy. Amendments to the privacy policy will take effect seven (7) calendar days after the publication.
If you continue to use the Products, the Website, order services from us, contact us after we have changed the terms of the privacy policy, you will be deemed to have agreed to the changed terms of the privacy policy.
OUR CONTACTS
If you want to contact SPEED MATTERS for any questions, do not hesitate to do so via:
Mail: J. Tumo-Vaižganto 4-3, 01108 Vilnius, Lithuania;
or
Email: contact@speedwinner.com
Updated: January 21, 2024
