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Approved by 2023.04.07 order No. 2023/4-07 of Greta Radzevičienė, CEO of  Gym LT, UAB

                                            Privacy Policy

  1. What does this Privacy Policy means?

This Privacy Policy (hereinafter – the Privacy Policy) not only defines the conditions that must be adhered to by all visitors to the lemongym.lt website (hereinafter – the Website), users of the Lemon Gym app that can be downloaded from iTunes and Google Play (hereinafter – the App), Gym LT, LLC (hereinafter – Lemon Gym) service recipients, individuals who are actively engaged on Lemon Gym social media accounts, individuals who have agreed to receive Lemon Gym marketing material, individuals participating in Lemon Gym events, and candidates participating in Lemon Gym selection processes (hereinafter – Customers), but also provides the basic rules for the processing of personal data, which must be observed by the Customers.

Lemon Gym requires Customers’ personal data that can be collected in the following ways. In the Privacy Policy, we specify what can be expected when the company collects personal information about:

  • individuals who use Lemon Gym services or purchase goods distributed by Lemon Gym;
  • individuals who agree to receive Lemon Gym marketing material;
  • individuals who have contacted Lemon Gym;
  • Website visitors;
  • individuals who use the App;
  • social media users who in any way address Lemon Gym through Lemon Gym accounts in social media
  • or actively engage therein;
  • individuals who participate in Lemon Gym events;
  • job candidates.
  • About Lemon Gym

GYM LT, LLC, legal entity code 303472404, office address Kareivių str. 14, Vilnius, data on the company are collected and stored in the Vilnius branch of the Register of Legal Entities of the Republic of Lithuania. Data protection officer contact details- privatumas@lemongym.lt.

  • What is personal data?

Personal data is any information collected by Lemon Gym about the Customer hich may be used to identify the Customer, and which is stored electronically or in any other way.

Personal data includes any information, including the Customer’s name, surname, address, and IP address, which is collected by Lemon Gym about Customers for the purposes specified in this Privacy Policy or in the Customer’s separate consent or agreement with Lemon Gym.

This data also includes the Customer’s personal information in the public domain, with which Lemon Gym gains access to by the Customer contacting Lemon Gym via social media or being actively engaged on Lemon Gym social media accounts.

  • How Lemon Gym collects personal data?

Lemon Gym processes data:

  • received directly from the data subject (You), e.g., when you send us enquiries or messages using the contact details provided, sign cooperation agreements with us or send us your curriculum vitae (CV) when applying for vacancies, filling in questionnaires, registering on our websites or taking part in organized promotions;
  • generated, when You use our services, such as when You use our website and services, i.e. when You make phone calls, send text messages, visit our websites etc.;
  • received from other sources – institutions or companies, i.e. banks, publicly accessible registers, insurance companies, etc.
  • Personal data processed in the provision of services
Purpose of data processingThe personal data processedTerm of data processingBasis of data processing
Conclusion of contract, sale and provision of services.Name, surname, personal identification number, date of birth, e-mail address, place of residence (address), telephone number, purchase – related information (date of purchase, description of service, price, discount given), workplace, card number, type of subscription, duration, , the branches, where the services are provided, the number of visits and amount of remaining visits left, the expiry date of the subscription, invoice and its details, customers’ requests, the IP address (when the contract is concluded online), information on the return of goods or withdrawal from a contract, concluded by electronic communications.   Name, surname, date of birth, place of residence, e-mail address, telephone number, place of residence (address) of parents, (if the service recipient is a minor).  Documents confirming the conclusion of contracts are stored for 10 years from the date of termination of the contract.   A Customer’s account data are stored for five years from the day that the Customer logged into the account or made a purchase the last time.

Other data – 5 years from the date of last purchase.  
Performance of the contract   GDPR Article 6 point b of paragraph 1
When the service is provided to a minor – medical certificate (requirements for the service provider regarding children’s health). Without a medical certificate, Lemon Gym will not be able to accept minors for sports.  Customer membership period and one day after its expiration. In the case of a one-time visit – one day after the visit.Performance of the contract   GDPR Article 6 point b of paragraph 1  
In order to renew your membership, Lemon Gym has a right to request you provide a doctor’s certificate of illness, military service or pregnancy certificates. If You refuse to provide these documents, we will not be able to extend your membership, but other terms and conditions of the contract will remain unchanged.  Customers are only asked to show these types of certificates. If necessary, we can handwrite some information from the certificates – for example the date of issue, but we will not copy them.Performance of the contract   GDPR Article 6 point b of paragraph 1  
Debt administrationName, surname, personal identification number, date of birth, email address, telephone number, the amount of the debt and circumstances in which the debt was incurred and settled.  10 years after full debt repaymentLegitimate interest   GDPR Article 6 point f of paragraph 1  
Provision of services via using the AppName, surname, system ID, date of birth, sports club, gender, country, place of residence (address), postcode, email address, phone number, information on whether the Customer is a foreigner. This data is not necessary for the performance of the contract. The App is for Customers convenience.  Mobile app usage periodConsent   GDPR Article 6 point a of paragraph 1  
Customer identification for admission to Lemon GymIdentification by means of a personal document: name, surname, personal identification number.Membership periodPerformance of the contract   GDPR Article 6 point b of paragraph 1
Identification by means of a photo: name, surname, photo.Consent   GDPR Article 6 point a of paragraph 1
Identification by fingerprint: non-reproducible model data of a fingerprint of a Customer aged 18 years or older.    Consent   GDPR Article 6 point a of paragraph 1

We may also obtain data about you from your employers if you are the final recipient of the service, but the contract is between Lemon Gym and your employer.

  • Direct marketing
Purpose of data processing  The personal data processedTerm of data processingBasis of data processing
To send offers, newsletters and promotions to Customers and other interested parties via SMS messages and           emailsName, surname, telephone number, e-mail address, address, date of birth (required data, without which we will not be able to send you direct marketing communications); data confirming the right to participate in promotional campaigns, documents confirming fulfilment of promotional campaign conditions.  1 year after receiving consentConsent   GDPR Article 6 point a of paragraph 1   Republic of Lithuania law on electronic communications Article 81 paragraph 1  
Giveaways(loteries) and other games organization.Photos and video footage if Customers are participating in giveaways and other games. Winner place of residence (address)Until the winner is identified. Winner’s data – 1 year after the win.Consent   GDPR Article 6 point a of paragraph 1

You have the right to refuse direct marketing communications at any time by clicking the “unsubscribe” button on the Website home page or contracting us by e-mail privatumas@lemongym.lt.

If you are our active Customer and have not expressed an objection to receiving Lemon Gym direct marketing communications, we will send you e-mails, on the basis of our legitimate interest, regarding goods or services that are similar to the services provided to you or the products you purchase.

If you are 14 years old, you can express consent to direct marketing communications by yourself, however if you are under 14, we will ask for your parent’s consent. In this case we will ask You to provide the name, surname and e-mail address of your parent or guardian, so we can send an enquiry regarding this consent. The personal data listed in this point will be processed by Lemon Gym for one year after the receipt of consent and then deleted. 

Your e-mail address and telephone are provided to the Facebook and LinkedIn social media networks so that you are shown Lemon Gym advertising.

  • Personal offers
Purpose of data processingThe personal data processedTerm of data processingBasis of data processing
To send personalized offers, based on the data received from the CustomerName, surname, phone number, email address, place of residence (address), frequency of sport club visits, type of membership.1 year after receiving consentConsent   GDPR Article 6 point a of paragraph 1

You have the right to refuse to receive personalized offers at any time by contracting us by e-mail privatumas@lemongym.lt.

  • Participation in Lemon Gym events
Purpose of data processing  The personal data processedTerm of data processingBasis of data processing
To publicize Lemon Gym events with the aim to inform society about Lemon Gym events and promote Lemon Gym sports clubsThe fact of Customer participation, name and photo or video material3 years after receiving consent or participating in the event (depending on which event occurred later), aside from exceptions permitted by lawConsent   GDPR Article 6 point a of paragraph 1

You have the right to withdraw your consent to process photo or video material of you at any time by contacting us by e-mail privatumas@lemongym.lt or number 19193.

With your consent, your photographs may be published on Lemon Gym social media accounts and the Website.

Media representatives may only publish your photographs in accordance with the requirements of applicable laws, but Lemon Gym is not liable for the actions of media representatives.

  • Participation in selection processes
Purpose of data processing  The personal data processedTerm of data processingBasis of data processing
Participation in selection processes.Your CV and/or cover letter and/or other submitted information.Until the end of the selection process (we undertake to delete and/or destroy your personal data within five working days after an employment contract is signed with the successful candidate)  Consent   GDPR Article 6 point a of paragraph 1
  1. Assets and data protection
Purpose of data processing  The personal data processedTerm of data processingBasis of data processing
Property and persons protection in order to record, preserve and investigate evidence of incidents (property damage, theft, illegal acts, injuries, accidents, etc.)Video surveillance14 daysLegitimate interest   GDPR Article 6 point f of paragraph 1
  1. Dealing with enquiries and complaints
Purpose of data processing  The personal data processedTerm of data processingBasis of data processing
Handling enquiries via an emailYour name, surname, email address and the text of your correspondence.1 year after processing the requestPerformance of the contract and consent   GDPR Article 6 point b and a of paragraph 1
Handling enquiries via the websiteEmail address, name, nickname, phone number, Lemon Gym club, message and/or comment text.1 year after processing the requestPerformance of the contract and consent   GDPR Article 6 point b and a of paragraph 1
Handling enquires via the mobile phoneThe phone number you are calling from, call recording, call metadata – duration, time6 monthsPerformance of the contract and consent   GDPR Article 6 point b and a of paragraph 1

Any personal data you provide when you interact with us is only used for the purposes set out above and to view messages and administer and manage communication flows.

We undertake not to use your personal data in any publications in a way that could identify you without your explicit consent.

  1. Execution of Lemon Gym contracts with partners
Purpose of data processing  The personal data processedTerm of data processingBasis of data processing
Execution of contracts with suppliersThe name, surname, telephone number, email address, content and date of correspondence and other data relating to the performance of the contract of the suppliers’ or service providers’ employees (natural and legal persons).Until the end of the contract, and for 10 years after terminationPerformance of the contract   GDPR Article 6 point b of paragraph 1
Executing contracts with trainersName, surname, date of birth, criminal record, home address, photo, telephone number, e-mail, education (educational institutions, degree(s) obtained), level of honorarium, language skills and other relevant skills.Until the end of the contract, and for 10 years after terminationPerformance of the contract   GDPR Article 6 point b of paragraph 1  

Note – when processing the data of employees of a Lemon Gym service providers or suppliers, the processing is based on the legitimate interest of Lemon Gym.

  1. Website visitors

You can register and create an account on the Website if you are 18 years of age. All information that you provide to Lemon Gym by becoming a registered Customer will be stored and protected by Customer consent, in accordance with the Privacy Policy conditions. If, in our reasonable opinion, you have breached any provision of our Privacy Policy, we have the right to block the Customer account at any time.

If you know or suspect that an unauthorized person has found out your registration name or password, you must notify us as soon as possible by e-mail: privatumas@lemongym.lt

  1. Cookies

A cookie is a small file of letters and numbers that we store, with your consent, on your browser or the hard drive of your computer. We use different cookies for different purposes. Cookies also help us to distinguish you from other Website users, which ensures a more enjoyable Website experience for you and allows us to improve the Website.

Most browsers allow you to block all cookies, and with some browsers it is possible to only block third-party cookies. So, you can take advantage of these options. However, please note that blocking all cookies will have a negative impact on the use of the Website, and that without cookies, you will not be able to use all of the services provided on the Website.

We use the following cookies:

  • Strictly necessary cookies. These cookies are necessary for the Website to function. The basis for processing data with these cookies is the proper performance of the contract by the Customer visiting the Website, while Lemon Gym ensures the quality and security of the visit. These may include cookies that, for example, enable the Customer to log into and access secured Website zones, use the shopping cart function, or the other services.
  • Analytical and/or performance cookies. These cookies allow Lemon Gym to recognize and count Website visitors and monitor how visitors navigate through the Website when they use it. This helps Lemon Gym improve Website performance and ensure that users can easily find what they are looking for. The basis for processing data collected with these cookies is the Customer’s consent.

  • Functional cookies. These cookies are used to recognize Customers when they return to the Website so that Lemon Gym can adapt the content to the Customer’s needs and remember the information relevant to the Customer. The basis for processing data collected with these cookies is the Customer’s consent.

Detailed description of cookies:

Cookie namePurpose of data processing  The date of creationExpiry dateCookie type (necessary, analytical or functional[RA1] )
_hjSessionUserA Hotjar cookie that is set when a user first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. Expiration period: 1 yearFunctional
consents_functional (name of category)    
_fbpThis cookie is used by Facebook to identify the user Created at the time of the first login to the Website and valid for 2 daysFunctional
consents_essential (name of category)    
_gidRegisters a unique ID that is used to generate statistical data on how the visitor uses the website. This cookie expires after 1 day.Essential
_gaUsed by Google Analytics to distinguish unique users by assigning a randomly generated number as a client identifier. It’s important to note that the _ga cookie does not collect any personal information about website visitors. The information collected is anonymous and is used only for statistical purposes. Expires after 2 years by defaultEssential
consents_required (name of category)    
_hjIncludedInSessionSampleUsed to check if the visitor is included in the data sample defined by the site’s daily session limit. 30 minutes duration, extended on user activity.analytical
_hjfirstSeenIdentifies a new user’s first session. 30 minutes duration, extended on user activity.analytical
_hjAbsoluteSessionInProgressUsed to detect the first pageview session of a user. 30 minutes duration, extended on user activity.analytical
consents_analytics (name of category)    
PHPSESSIDThe PHPSESSID cookie is used by the PHP programming language to identify a user’s session on a website. When a user visits a website built with PHP, the server creates a unique session ID and sends it to the user’s browser as a cookie, typically named PHPSESSID. The cookie is deleted when the user closes their browser or logs out of the website.Essential
_hjSession_Holds current session data.
Ensures subsequent requests in the session window are attributed to the same session.
 30 minutes duration, extended on user activity.analytical
pll_languageStores language settings persistentFunctional
  1. Third party services

YouTube videos are provided on the Website. The service provider YouTube controls all information collected by individuals viewing the content that it owns. The YouTube Privacy Policy is available at https://www.google.co.uk/intl/en-GB/policies/privacy/ .

  1. Social media tools

Website links to our social media accounts. We currently have the following accounts:

•              on “Facebook“, whose Data Policy is available at https://www.facebook.com/privacy/explanation ;

•              on “Instagram“, whose Data Policy is available at https://help.instagram.com/155833707900388 ;

•              tinkle “LinkedIn“, whose Data Policy is available at    https://www.linkedin.com/legal/privacy-policy ;

•              tinkle “YouTube“, whose Data Policy is available at                            https://www.google.co.uk/intl/en-GB/policies/privacy/ .

We kindly recommend you to read the third party privacy notices and contact the service providers directly if you have any questions on how they use your personal data.

  1. Disclosure of your data

We may disclose information about you to:

  • our professional advisers and auditors;
  • notaries, if the contract or agreement with you requires notarial form;
  • bailiffs, entities providing legal and/or debt collection services,
  • creditors that take over the right to claim the debt;
  • joint debtor data file managers;
  • providers of data center, hosting, cloud, website administration and related services, companies that develop, provide, support and develop software, companies that provide information technology infrastructure and communication services;
  • companies, providing advertising and marketing services;
  • companies providing archiving, physical and/or electronic security, asset management and/or other business services;
  • public authorities as provided for by the law: the State Tax Inspectorate, the Centre of Registers, The State Social Insurance Fund Board (SODRA) and etc.;
  • law enforcement authorities upon their request or on our initiative if Lemon Gym suspects that a criminal offence has been committed, as well as courts and other dispute resolution authorities;
  • tax administrators.

Your personal data will not be transferred to a third country and/or international organization. Except for the cases provided for in this Privacy Policy, we will not provide your personal data to any third parties.

The list or categories of recipients referred to in the Privacy Policy is subject to change. If you wish to be informed of any changes in the recipients, to whom we can disclose your personal data, please notify us via email to privatumas@lemongym.lt  indicating “I wish to be informed of a change in the recipients to whom you can disclose my personal data, my name and surname.“

  1. Third party material and third-party websited

Our Website and App may contain advertising from third parties. These third parties are solely responsible for the content of such advertising and must ensure that it complies with all applicable laws and regulatory acts.

You can visit a third-party website at your own risk. We do not accept any direct or indirect liability for the content, the accuracy of the information, or opinions expressed on these websites, or for the quality of the goods and services offered.

Our informational material may contain information sourced from third-party websites. Material taken from a third-party website will be marked accordingly and may include a link to the original website. We do not accept any liability for any material that is taken or published on a third-party website that is provided as a link in the informational material we provide to you, or for any personal data used by said third party.

  1. Security of your personal data

Your personal data will be processed in accordance with the General Data Protection Regulation, the Republic of Lithuania Law on Legal Protection of Personal Data, and other statutory requirements. In processing your personal data, we implement organizational and technical measures which ensure the protection of personal data against accidental or unlawful destruction, modification and disclosure, as well as any other unlawful processing.

  • Your rights

This section provides information about your rights related to our processing of your personal data and the cases when you can exercise these rights. If you want to receive more information about your rights or exercise them, please contact us by e-mail: privatumas@lemongym.lt .

Lemon Gym will inform you without undue delay, but not later than within one (1) month of receipt of the request, of the actions taken upon receipt of your request for the exercise of your rights. s. Depending on the complexity of the request and number of requests received, this period may be extended for another two months. In this case, we will inform you within one (1) month of receipt of the request about this extension and the reasons behind it. Lemon Gym will only refuse to implement your rights in the cases provided for by legislation.

  • The right to withdraw consent. If you have provided us with explicit consent to the processing of your data, you may withdraw it at any time by e-mail: privatumas@lemongym.lt.
  • The right to obtain access to your personal data. We want you to fully understand how we use your personal data, and to not experience any inconveniences for this. You can contact us at any time and inquire whether we are processing any of your personal data. If we are storing and using your personal data in any way, you have the right to obtain access to them. If you would like to do so, please submit a written request to us by e-mail at: privatumas@lemongym.lt , and confirm your identity; in submitting such a request, please adhere to the principles of fairness and reasonableness.
  • The right to ask for more information. If you have any questions about the use of your personal data, we will be happy to answer them or provide any additional information that we can disclose. If you have any specific questions or did not understand the information provided, please contact us via e-mail :privatumas@lemongym.lt.
  • Additional rights

Below you will find information about your additional rights that you can exercise in accordance with the procedure below.

•              You have the right to ask us to rectify any inaccuracies in the available data. In this case, we may ask you to confirm the corrected information.

•              You have the right to ask us to delete your personal data. This right will be exercised in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679.

•              You have the right to ask us to restrict the processing of your personal data or to not process them:

  • for the period required to ascertain the accuracy of your personal data when submitting claims for data accuracy;
  • when our collection, storage or use of your personal data is unlawful, but you decide not to request that the data be deleted;
  • when your personal information is no longer required by us, but you need them to establish, exercise or defend a legal claim;
  • for the period required to determine whether we have a more substantial legal basis to continue processing your personal data if you have exercised your right to express an objection to the processing of personal data.

•              You have the right to portability of the data that we received from you with your consent or for the purpose of concluding a contract. If you exercise this right, we will transfer a copy of the data you submitted at your request.

•              You have the right to object to us using your personal data:

  • when we use this data in order to ensure our legitimate interests, but do not have a more substantial legal basis to continue using your personal data; or
  • any time when we use your personal data to send newsletters or for direct marketing purposes. In this case, the data will no longer be used for these purposes, but they may be used for other legitimate purposes.
  • Complaints

If you believe that your rights as a personal data subject, are and/or may be violated, please contact us immediately with a complaint by e-mail to privatumas@lemongym.lt. We assure you that upon receiving your complaint, we will contact you within a reasonable time and inform you of the progress of the complaint, and later – on the outcome.

If you are not satisfied with the results of the investigation, you can submit a complaint to the supervisory authority – the State Data Protection Inspectorate (contacts www.ada.lt ).

  • Responsibility

You are responsible for the confidentiality of your password and the data provided, as well as for any actions (data transfer, orders placed, etc.) that are taken on our Website and/or App by logging in with your login details. You may not disclose your password to third parties. If the services provided on our Website and/or App are used by a third party who logged into the Website and/or App with your login details, we consider that it was you who logged in. If you lose your login details, you must immediately notify us thereof by mail, telephone or e-mail.

You are responsible for ensuring that the data that you provided to us is accurate, correct and complete. If the data you submitted changes, you must inform us without delay by modifying the relevant data on the registration form or, if the data is not indicated on the registration form, by informing us thereof by e-mail. We will under no circumstances be liable for damages caused to you due to the fact that you provided incorrect or incomplete personal data or did not inform us of changes to them.

  • Changes to the Privacy Policy

We can update or change this Privacy Policy at any time. The updated or changed Privacy Policy will take effect from the moment it is posted on our Website and/or App. You should check it from time to time to make sure that the current version of the Privacy Policy is acceptable to you.

Upon updating our Privacy Policy, we will inform you about what, in our opinion, the key changes are by posting them on the Website and/or App. If you log into the Website and/or App after the notice is published, you are agreeing to the new requirements specified in the update. The “Last updated” date shown below indicates when the Privacy Policy was last updated.

The last update to the Privacy Policy was made on 2023[RA2] …


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