Last update: 2023-01-08

1. GENERAL INFORMATION

Your privacy and the security of your data are our priority, therefore, in this Privacy Policy (hereinafter referred to as the Privacy Policy), we want to explain to you how we process and store your personal data, what rights you have as a data subject, and provide other important information about the processing of your personal data.

The General Data Protection Regulation No 2016/679 (EU) (hereinafter referred to as the GDPR) sets out the basic principles and requirements for us and other data controllers regarding the processing of personal data. When processing your Personal Data, we comply with the requirements of the GDPR and the legal acts of the Republic of Lithuania.

The term “personal data” (hereinafter referred to as Personal Data), which is used in this Privacy Policy, corresponds to the definition in the GDPR and refers, among other things, to any information or set of information by which we can directly or indirectly identify you, for example, by your name, surname, e-mail address, telephone number, etc.

The Privacy Policy applies when you use Cargo Stream, a transport services management system administered by us, including the mobile version of Cargo Stream (hereinafter referred to as the Cargo Stream system) or when you visit our website available at: www.cargo.stream (hereinafter referred to as the Website), when you review the information provided by us, order the services we offer, use the services you have ordered, post information, get acquainted with information or exchange information in the Cargo Stream system, contact us by phone, e-communication channels, are interested in our offers or contact us with other questions. We also inform and communicate about our services on our social network accounts: LinkedIn social network, Facebook social network (hereinafter referred to as Social Accounts), so the information you provide there may also be processed.

If you order services from us and use them, visit our Social Accounts, contact us, subscribe to our news, we consider that you have read and familiarized yourself with the information provided in the Privacy Policy.

As we are constantly developing our services, we reserve the right to change this Privacy Policy at any time subject to the applicable regulations. Any changes will be published promptly on this page. Regardless of the aforementioned, you should check this page regularly for any updates.

 

2. WHO ARE WE?

We are UAB “Kelių sistemos”, a private limited liability company established in the Republic of Lithuania, legal entity code 305161754, address Gedimino pr. 33-1, Vilnius, Lithuania, (hereinafter – Cargo Stream or we) and we are the controller of your personal data.

The data controller determines for what purposes and in what means personal data are processed. The data processor processes personal data only on behalf of the data controller. The Company is considered a data processor when we act under the instructions of our customers (as data controllers) in order to provide them with our services.

 

3. WHY AND HOW DO WE COLLECT AND USE YOUR PERSONAL DATA?

3.1 To analyse and improve the Cargo Stream system

We collect, use and store the data that is necessary to analyse and improve the Cargo Stream system.

For this purpose, we collect, use and store your name, surname, username, password, email address, telephone number, name of the company you represent, workplace address, relationship with the legal entity you represent, job title, orders on the platform, bookings on the platform, warehouse timeslots’ bookings, correspondence on the platform, profile settings, file sharing, any other information that you provide.

Legal basis for the collection and use of data is the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract (Art. 6 (1) (b) of the GDPR).

We will process your Personal Data for the period of use of your account or for a period of 3 months from the last order, whichever is longer.

3.2 To handle queries, requests and complaints submitted by you

We collect, use and store the data that is necessary to handle queries, requests and complaints submitted by you.

For this purpose, we collect, use and store your name, surname, name of the company you represent, e-mail address, query, request or complaint, information, related to the query, request or complaint, communication with the Cargo Stream.

Legal basis for such collection and use is our legitimate interest to handle your queries (Art. 6 (1) (f) of the GDPR).

We will process your Personal Data for the period of use of your account or for a period of 3 months from the last order, whichever is longer.

3.3 To keep financial records

We collect, use and store the data that is necessary to carry out accounting-related duties.

For this purpose, we collect, use and store your name, surname, email address, telephone number, job title, name of the company you represent, workplace address, relationship to the legal entity you represent, payment account number, financial institution, payment information, debt information, data and confirmation of payments forwarded to you by the company that manages the collection of contributions.

This is necessary in order to comply with the legal obligations to which Cargo Stream is subject (Art. 6 (1) (c) of the GDPR).

We will process your Personal Data in accordance with the regulatory legal acts, as well as in accordance with the Order no. V-100 of 9 March 2011 of the Chief Archivist of the Republic of Lithuania, the Index of Terms of Storage of General Documents was approved.

When the data does not fall within the above-mentioned area of storage – the time of validity of the contract / cooperation of the parties and 10 years after the termination of the contract / relationship (the last contact).

3.4 To track visits to the Cargo Stream system for security purposes

We collect, use and store the data that is necessary to track visits to the Cargo Stream system for security purposes.

For this purpose, we collect, use and store your IP address, browser used, date and time of login, model and manufacturer of the mobile device, operating system of the mobile device (iOS, Android).

Legal basis for such collection and use is our legitimate interest to protect the Cargo Stream system and ensure its security (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose will be kept for 3 months.

3.5 To manage our social media profiles

If you are interested in our activity and follow our profiles on social media, we collect and use the following data about you in order to manage our social networking sites:

1. Full name;
2. E-mail address;
3. Gender;
4. Country;
5. Picture;
6. Message;
7. Time and date the message was received;
8. Content of the message;
9. Message attachments;
10. Response to the message;
11. Time of response to the message;
12. Information about our rating;
13. Comments on a post;
14. Post shares;
15. Information about post reactions.

We base such collection and use on our legitimate interest to manage our social media profiles (Art. 6(1)(f) of GDPR).

In order to manage our social media accounts, we receive and provide data to the following social media platform operators:

The following social media platform operators are established outside the European Economic Area, which may result in your data being transferred outside the European Economic Area. In these cases the personal data is protected by the operators entering into the EU Standard Contractual Clauses for the transfer of data as approved by the European Commission:

1. LinkedIn Corporation (USA);
2. Google LLC (USA);
3. Meta Platforms, Inc. (USA).

Personal data collected and used for this purpose are kept as long as you are registered on a specific social media network.

Joint Controllership with Facebook („page insights”)

Cargo Stream operates a so-called fan page on the social media platform of Facebook. Facebook and Cargo Stream are only jointly responsible for the processing of so-called “insights data” (Art. 26 (1) sentence 1 of the GDPR) insofar as this data is used for the creation of so-called “page insights” and only for the data collection phases from Cargo Stream’s fan page until its transmission to Facebook. For other data processing, Cargo Stream and Facebook are separately responsible for data processing.

Within the scope of their joint controllership, Cargo Stream and Facebook have entered into an agreement (so-called “page insights controller addendum“). The agreement covers the data processing that is collected and used in connection with a visit or interaction with our fan page, but only to the extent that this data is also (subsequently) processed for “page insights”. “Page insights” includes analysis services that help us to better understand interactions on our site. In this context, we do not receive any personal data from Facebook, but only an anonymous evaluation and illustration. Facebook provides more information on this on its help page for “page insights”. The information about data for “page insights” explains how “insights data” is collected and used to create “page insights”. This includes the following actions:

1. Views and interactions with a page, post, video, story, or other content associated with a page;
2. Subscribing or unsubscribing to a page;
3. Reactions to a page or a contribution (e.g. “like”; recommendation, share, comment, subscribe, etc.);
4. Hiding a page contribution or report it as spam;
5. Moving the mouse over a link to a page or the name or profile picture of a page to see a preview of the page contents;
6. Clicks on the website, phone number, “route planning” button or any other button on a page;
7. Views of an event of a page, reactions to an event (including the type of reaction), clicks on a link for event tickets;
8. Starting a messenger conversation with the page;
9. Views or clicks on articles in a website shop;
10. IP address as well as other information that is available on your end device in the form of cookies.

The processing of the data of the visitors of our fan page serves the purpose of providing the page as well as the statistical evaluation of the use of our page. This evaluation is made anonymous for Cargo Stream. The legal basis for data processing is Art. 6 (1)(f) of the GDPR. Our legitimate interests in the processing of personal data when visiting the site and the creation of the “site insights” consist of presenting the company and the Platform and, for example, contacting members and interested parties and providing information about products and promotions, as well as the collection of data for the creation of anonymous evaluations and illustrations about the use of our fan page.

If you wish to exercise your rights regarding your data (see bullet point 7. below), it would certainly be more effective for you to contact Facebook directly. If you still need help in exercising your rights, you can contact us. In accordance with our agreement, Facebook assumes primary responsibility for fulfilling the obligations for the joint processing of “insights data”. This includes fulfilling the following rights:

• The right to access (Art. 15 of the GDPR);
• The right to ratification (Art. 17 of the GDPR);
• The right to restrict processing (Art. 18 of the GDPR);
• The right to data portability (Art. 20 of the GDPR); and
• The right of objection (Art. 21 of the GDPR).

Facebook provides more details on how to exercise these rights in the “page insights data” information.

Joint Controllership with LinkedIn

Cargo Stream operates a so-called company page on the social media platform of LinkedIn. LinkedIn and Cargo Stream are only jointly responsible (Art. 26 (1) sentence 1 of the GDPR) for the processing of so-called “insights data” which enables us to receive anonymized statistics and insights about the ways visitors interact with our page. For other data processing, Cargo Stream and LinkedIn are separately responsible for data processing.

Within the scope of the joint controllership, Cargo Stream and LinkedIn have entered into an agreement (so-called “Page Insights Joint Controller Addendum”) in which the data protection duties are allocated between LinkedIn and Cargo Stream. The agreement stipulates the following:

• LinkedIn is responsible for enabling you to exercise your rights pursuant to the GDPR. In order to do so, you can contact LinkedIn online via https://www.linkedin.com/help/linkedin/ask/PPQ or via the contact details in the data protection guidelines. You can contact the Data Protection Officer of LinkedIn Ireland via the following link: https://www.linkedin.com/help/linkedin/ask/TSO-DPO. You can also reach out to us via the contact details mentioned below for the exercise of your rights relating to the processing of your personal data for insights. In such a case, we will forward your request to LinkedIn.
• LinkedIn and we have agreed that the Irish data protection commission shall be the responsible supervisory authority monitoring the processing for insights. You always have the right to lodge a complaint with the Irish data protection commission (see www.dataprotection.ie) or any other supervisory authority.

The processing of the data of the visitors of our LinkedIn company page serves the purpose of providing the page as well as the statistical evaluation of the use of our page. This evaluation is made anonymous for Cargo Stream (LinkedIn does not share personal data with us by providing us with the insights, we only have access to a summarized version of the insights; also, we are unable to make conclusions about individual members from the information in the insights). The legal basis for your personal data processing is Art. 6 (1)(f) of the GDPR. Our legitimate interests in the processing of personal data when visiting the site and the creation of the “insights” consist of presenting the company and the Platform and, for example, contacting members and interested parties and providing information about products and promotions, as well as the collection of data for the creation of anonymous evaluations and illustrations about the use of our company page.

3.6 To inform you about our services that may be relevant to you

We collect, use and store the data that is necessary to inform you about our services that may be relevant to you.

For this purpose, we collect, use and store your name, surname, name of the company you represent, e-mail address.

Legal basis for such collection and use are your consent (Art. 6 (1) (a) of GDPR) (Art. 69 (1) of Lithuanian Law on Electronic Communications), customer relationship (Art. 69 (2) of Lithuanian Law on Electronic Communications), legitimate interest (to send direct marketing communications) (Art. 6 (1) (f) of GDPR).

We will process your Personal Data for 5 years after the last use of our services or after you give your consent unless you withdraw your consent earlier.

3.7 To defend the rights and interests of Cargo Stream

If you get involved in a dispute with Cargo Stream or we need to carry out enforcement of our Rules for the Use of the Cargo Stream Transport Services Management System or otherwise defend, enforce, exercise and uphold our rights, we will collect and use all of your personal data held by Cargo Stream to the extent necessary to resolve a particular situation.

Legal basis for such collection and use is our legitimate interest to defend the rights and interests of Cargo Stream (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for 5 years after we identify the need to defend our specific rights and interests, and, in the case of a dispute, until the final execution of the binding decision of the authorised body.

3.8 To handle your requests related to personal data

If you use your statutory rights regarding your data (see 5 below), we will collect and use the data contained in your request in addition to any other personal data held by Cargo Stream for the purpose of examining the request, responding to it and, when necessary, taking necessary action.

Legal basis for such collection and use is our legitimate interest to exercise our members’ rights (Art. 6 (1) (f) of the GDPR).

Personal data collected and used for this purpose are kept for two years from the day we respond to your request.

4. TO WHOM AND WHEN DO WE TRANSFER YOUR PERSONAL DATA?

Cargo Stream transfers or shares personal data with service providers only insofar as necessary and allowed in accordance with applicable laws.

We may transfer your Personal Data to:

• For our partners or consultants such as server hosting, data centers, cloud, service, IT, payment, brokerage, auditing and accounting, legal, tax consulting services, claims administration, debt collection, analytics, direct marketing and marketing, email, short message sending, customer service, call center and other service providers. We require data processors to store, process and treat Personal Data with the same responsibility as we do and only in accordance with our instructions.
• In order to be able to post your content on social media accounts, we transfer Personal Data outside the European Economic Area to the following service providers:
  LinkedIn Corporation (USA) (data is protected by EU Standard Contractual Clauses for the transfer of data as approved by the European Commission);
  Meta Platforms, Inc. (USA) (data is protected by EU Standard Contractual Clauses for the transfer of data as approved by the European Commission).
• We constantly carry out and improve the Website, the services provided in order to protect the security and confidentiality of the Personal Data processed by us, as well as to be able to perform certain business-related functions that would help to make our services accessible and functional. For this reason, we send your profile data to service providers that provide cloud and hosting services, IT security, maintenance and technical services, and communication services. We transfer Personal Data outside the European Economic Area to the following service providers:Amazon Web Services, Inc. (USA) (data is protected by EU Standard Contractual Clauses for the transfer of data as approved by the European Commission);

  Google LLC (USA) (data is protected by EU Standard Contractual Clauses for the transfer of data as approved by the European Commission);

  Apple Inc. (USA) (data is protected by EU Standard Contractual Clauses for the transfer of data as approved by the European Commission);

  Microsoft Corporation (USA) (data is protected by EU Standard Contractual Clauses for the transfer of data as approved by the European Commission).

• To law enforcement and pre-trial investigation institutions, courts and other dispute resolution institutions to state or local self-government institutions and institutions, other persons performing the functions assigned by law, in accordance with the procedure provided for by the legal acts of the Republic of Lithuania. We provide these entities with information that is prescribed by law or specified by the entities themselves to be provided;
• Other third parties, such as financial institutions, payment institutions, etc.;
• If necessary, to companies that would intend to buy or purchase the Company’s business or carry out joint activities with us or cooperate with us in another form, as well as companies established by us.

5. WHAT RIGHTS DO YOU HAVE?

GDPR and other laws provide you with certain rights, procedures for implementation of and exceptions to these rights. When allowed by law, you can:

• Submit a request for confirmation that Cargo Stream is processing the data related to you. If we process the data related to you, request access to the data processed and related information;
• Submit a request to correct inaccurate or incorrect information used or to supplement it when it is not complete;
• Submit a request to delete the information we have about you if we use it illegally;
• Submit a request to restrict the processing of your information – if you dispute the accuracy of the data or object to the processing of the data, if you do not accept that your data would be deleted which was illegally processed, or if you need the data to claim, execute or defend legal claims;
• Object to collection, use and storage of your information at Cargo Stream – when we process data based on the our’s legal and / or third party interests;
• Submit a request to transfer (receive) the data that you provided to us under the contract or giving the consent and which we process by automated means, generally using electronic form;
• To withdraw any consents given to us regarding information used about you – when we use the data based on your consent;
• To lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence or place of an alleged infringement of the GDPR and seek a judicial remedy.

If you wish to exercise any of your rights set out in the previous section, you can contact us by emailing us at info@cargo.stream.

6. HOW DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

A cookie is a small text file that a website stores on your computer or mobile device when you visit it. Thanks to it, the website can “remember” your actions and preferences (e.g. registration name, language, font size and other display options) for a certain period of time, and you do not need to re-enter them every time you visit the website or browse its various pages. Other technologies, including data that we store in your browser or device, identifiers related to your device and other software, may be used for similar purposes. Cookies are widely used to make websites work or work better and more efficiently. For the purposes of this Policy, all of the above technologies are referred to as “cookies”.

We use cookies for the analysis of information flows and user behavior, to promote trust and ensure security, as well as to ensure the proper functioning of the Website, its improvement, memorization of the settings you have chosen, in order to personalize the content displayed to you, to link the Website to Social Accounts

You can choose whether you want to accept cookies. If you do not agree to the storage of cookies in the browser of your computer or other device, you can mark this in the cookie consent bar, change the settings of the browser used and disable cookies (all at once, one at a time or in groups). If you want to refuse cookies on your mobile device, you must follow the official instructions for this device. Please note that in some cases, refusing cookies may slow down the speed of browsing, limit the functionality of certain websites or block access to the website.

More detailed information is available at http://www.AllAboutCookies.org or https://www.google.com/privacy_ads.html.  You can disable the use of third-party cookies for advertising-related purposes by visiting the Digital Advertising Alliance website https://optout.aboutads.info/?c=2&lang=EN.

We may use mandatory cookies that are necessary to ensure the functioning of the Website, analytical cookies, functional cookies, which are designed to analyze the visit to the Website, remember users’ preferences and adapt them to the Website so that we can provide improved functionality, performance cookies, third-party cookies used by third parties, advertising cookies that are designed to show you personalized and general advertising.

 

• We use Google Analytics, an online analytics service provided by Google Inc., which allows you to analyze how you use the Website, compile reports based on this analysis, plan and predict the activities of the Website and services. Data collected by Google Analytics, usually transmitted and stored on a Google Inc server in the USA. We have implemented IP anonymity on the website, so in the EU Member States and other countries that have signed the Agreement on the European Economic Area, Google Inc would hide your IP address. You can change your browser settings to prevent Google Analytics from analyzing information. In this case, an opt-out cookie will be recorded for you. However, if you delete all cookies, the opt-out cookie may also be deleted. You can also prevent Google from capturing data created by a cookie based on your use of the Website and from managing such data by downloading and installing a browser plug-in from https://tools.google.com/dlpage/gaoptout?hl=en.
• We use Microsoft Clarity, a behavior analysis tool provided by Microsoft Corporation that turns user data into visual insights and shows which parts of the Site are of the greatest interest. The data collected by Microsoft Clarity, usually transmitted and stored on Microsoft Azure servers in the EU, such as Ireland or the Netherlands, and the United States.  You can disable Microsoft Clarity cookies and prevent the  collection of  information through the Digital Advertising Alliance website by selecting the Microsoft https://optout.aboutads.info/?c=2&lang=EN.

 

Cookies used on our Websites:

Name of cookie	Purpose of cookie	The moment of creation	Expiry date	Data used
wp-wpml_current_language	The selected language of the site	After visiting the site	24 hours.	Language chosen by the visitor
laravel_session	Visitor’s session data	After visiting the system	24 hours.	Unique visitor ID, temporary data necessary for the operation of the system
XSRF-TOKEN	Ensuring security	After visiting the system	24 hours.	Random number
This	Real-time connection functionality	After visiting the system	Browser session	Random number

 

The website uses third-party cookies:

• Google Analytics: https://developers.google.com/analytics/devguides/collection/gtagjs/cookie-usage#gtagjs_and_analyticsjs_universal_analytics_-_cookie_usage
• Microsoft Clarity: https://learn.microsoft.com/en-us/clarity/cookie-list

 

7. CONTACT US

If you have any questions, comments or complaints regarding how we collect, use and store information about you, we are ready to help you. If you need our help, please send an e-mail to info@cargo.stream.