Baltic Way Ltd (“Company”) respects your privacy and are committed to protecting it through our compliance with this policy and any applicable laws when you use this website (“Site”).
Company offers online video and travel services (“Services”).
This policy applies to information we collect:
- On the Site.
- In email, text, and other electronic messages between you and the Site.
- Other Services we provide
This policy may change from time to time. Your continued use of the Site or Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
GDPR Lawful Bases for Processing Personal Data of Data Subjects
- In order to perform pursuant to one or more legal agreements (contracts) with you,
- With your consent, and
- Pursuant to a Legitimate Interest, in which Baltic Way considers the purpose it has for Processing your Personal Data, whether the Processing is necessary for that Purpose, and whether your own personal interests as a Data Subject outweigh Baltic Way purpose in Processing your Personal Data.
(As a reminder, if you are not a Data Subject providing your Personal Data to Baltic Way from within the European Union, GDPR does not apply to you.)
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Site and Services, including information:
- By which you may be personally identified, such as name, postal address, email address, or telephone number (“personal information”);
- That is about you but individually does not identify you, such as your company name and job title; and/or
- About your Internet connection, the equipment you use to access our Site, and usage details.
(Under GDPR, Baltic Way collects Personal Data from Data Subjects from within the EU, and Personal Data is considered to be broader and to include more categories of information than how we generally refer to “personal information” in this policy. We will be specific when we are discussing GDPR and activities we undertake related to Personal Data under GDPR.)
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you use the Site using cookies and other tracking technologies described and discussed with more detail below. Information collected automatically may include usage details, email address, IP addresses, and information collected through cookies and other tracking technologies.
- From third parties, for example, our business partners and third-party service providers who we believe in good faith are providing or sharing with us data in compliance with applicable laws or with whom you have authorized either these third parties or us or both to collect and use the data.
Information You Provide to Us
The information we collect on or through our Site or Services may include:
- Information that you provide by filling in forms on our Site. This includes without limitation information provided at the time of subscribing to the Services, and when you report a problem with our Site.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Details of transactions you carry out through our Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Site.
- Your search queries on the Site.
You also may provide information to be published, displayed, or transmitted (hereinafter “posted”) on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, “Interactive Content”). Your Interactive Content is posted on and transmitted to others at your own risk; we cannot control the actions of other users of the Site with whom you may choose to share your Interactive Content. Therefore, we cannot and do not guarantee that Interactive Content will not be viewed by unauthorized persons.
Usage Details, IP Addresses, Cookies, and Other Technologies
As you navigate through and interact with our Site and Services, we may automatically collect certain information about your equipment, browsing actions, and patterns, including without limitation:
- Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
- Information about your computer and Internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and does not identify any individual*. It helps us to improve our Site and Services and to deliver better and more personalized future services by enabling us to do things such as:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Site according to your individual interests.
- Speed up user searches.
- Recognize you when you return to our Site.
- Provide better services in the future.
(*The information referred to above may still constitute Personal Data under GDPR even though more generally Baltic Way does not try to identify any individuals beyond recognizing them when they return to the Site in order to provide and/or to enhance the experience described in 2. to 5. above; however, to the extent this information is not anonymized or pseudonymized to the extent that it no longer qualifies as Personal Data, Baltic Way will comply with GDPR with respect to Processing any such Personal Data.)
The technologies we use for this automatic data collection may include:
- Web beacons. Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us. However, to the extent the information we collect by automatic means constitutes Personal Data under GDPR either before or after we collect it, our processing of that Personal Data will comply with GDPR.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and their content to you.
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your subscriptions to the
- Services, including expiration and renewal notices.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Site or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Site.
In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Disclosure of Your Information
We may collect and disclose anonymous and aggregated information about our users and subscribers, and other information that does not identify any individual without restriction for the purposes of product research, to improve our Services and for other commercial purposes.
- We share your personal information with trusted third parties who are our technology suppliers and partners where we have agreements to provide services with or in conjunction with Baltic
- Way Services that our marketing research indicates you have sought if not actually requested, such as Google Analytics. Baltic
- Way is committed to working with suppliers and partners who comply with similar and equally protective undertakings of privacy and confidentiality.
- We share your personal information with third parties who perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, including software systems for customer relationship management, customer service and support solutions, email campaign marketing.
- These third parties comply with similar and equally protective undertakings of privacy and confidentiality.
- As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your personal information will be disclosed to such entity. Also, should any bankruptcy or reorganization proceeding ever be brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
When we share Personal Data under GDPR with our partners, we will do so pursuant to GDPR appropriate Data Processing Addendum or Data Sharing Agreements as appropriate given the nature of the parties’ respective roles under GDPR (i.e. Data Controllers to Data Processors versus co-Data Controllers).
We may also disclose your personal information:
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MOTH, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us.
For those users of our Services and Site Outside of the European Union and for which GDPR does not apply, we have created the following mechanisms and practice to provide you with the following control over your information:
- Promotional offers from the company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, as an account holder or subscriber at any other time you can unsubscribe from emails by using the Unsubscribe link at the bottom of the email.
GDPR Process for Exercising Data Subject’s Rights in Personal Data
For those users of our Services and Site from within the European Union and for which GDPR applies, we have created the following mechanisms and practices to provide you with the following control over your personal information that comprises GDPR Personal Data:
What are your rights?
By law, if any of your personal information/Personal Data provided to Baltic Way is subject to GDPR in the European Union, you have a number of rights when it comes to your personal information/Personal Data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
IMPORTANT: When you contact Baltic Way to exercise your rights described below, it is very important for security verification and other purposes that you use any email address that you know is associated with the personal information/Personal Data about which you are contacting Baltic Way.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
Most importantly, PLEASE UNDERSTAND that if you are a paid/unpaid subscriber to a Baltic Way Service, many types of personal information/Personal Data are necessary for Baltic Way to maintain and continue your account, along with the subscription to any Services which that personal information/Personal Data is associated. If the personal information/Personal Data can no longer be used by Baltic Way for that purpose, it may necessitate terminating the account and/or subscription (without any refund) and discontinuing access to and the use of the Service and/or Site to which the personal information/Personal Data is associated. We will use reasonable efforts to advise you of any such adverse consequences of restricting or removing our ability to maintain accounts and subscriptions by requests related to Personal Data, e.g. removal, restriction, blocking, etc.
Baltic Way Retention of Personal Data Under GDPR and Other Applicable Laws
We only retain your personal information/Personal Data for as long as is necessary for us to use your information as described above or to comply with our legal obligations and legitimate interests. Please be advised that this means that we may retain some of your personal information/Personal Data after you cease to use our Services. For instance, we may retain your data as necessary to meet our legal obligations, such as for tax and accounting purposes.
When determining the relevant period in which we retain or establish/revise periods for retaining personal information/Personal Data, we will take the following factors into account:
- Our contractual obligations and rights in relation to the information involved;
- Legal obligation(s) under applicable law to retain data for a certain period of time or with respect to pending or anticipated legal actions;
- Our legitimate interest where we weigh your interest in controlling your Personal Data and against our lawful purpose in processing your Personal Data;
- Statutes of limitations under applicable law(s);
- If you have made a request to have your information deleted; and
- Guidelines issued by relevant data protection authorities.
Otherwise, pursuant to GDPR, we will securely erase your personal information/Personal Data once there is no lawful basis or legal obligation to store or process it.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site. The information you share in public areas may be viewed by any user of the Site.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information generally and in compliance with applicable laws, we cannot guarantee the security of your personal information transmitted to our Site or via our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or via the Services.