Privacy Policy

Essential Phosphates UAB, as owner of the „Coenza“ brand, provides you with the following information in accordance with: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "GDPR") (the "Regulation"), the Law on the Protection of Personal Data of the Republic of Lithuania (the "Act"), any other applicable legal regulation.

Pursuant to this Privacy policy (the "Privacy policy"), the controller of your personal data is Essential Phosphates UAB.

Contact information with regard to data processing matters:

Address: Mokslininkų str. 12, Vilnius, Lithuania;
Contact phone No.: +370 647 29747;
E-mail address: info@coenzalabs.com.

THE FOLLOWING TERMS ARE USED IN THIS PRIVACY POLICY:

Personal data – means any information relating to an identified or identifiable natural person.
Person / Data subject – means natural person (data subject) whose data is processed.
Data processing – means any operation or sequence of operations performed by automated or non-automated means on personal data or sets of personal data.
Data processor – means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; for the purposes of this Privacy policy, the data processor is the service provider engaged by Essential Phosphates UAB and acting on behalf of Essential Phosphates UAB.
Data controller – means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Privacy policy, the data controller is Essential Phosphates UAB, legal entity code 304832983.
Regulation – means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

HOW DOES ESSENTIAL PHOSPHATES UAB COLLECT YOUR PERSONAL DATA?

Essential Phosphates UAB receives your Personal data in the following manner:

by contacting you in writing, by email or by telephone, the content of the correspondence or conversations may be stored;
when negotiating with you and / or entering into contracts with you, when you order goods or services from Essential Phosphates UAB;
when you provide certain data on the Essential Phosphates UAB website www.coenzalabs.com (the "Website");
when you create a personal account on the Website;
while you use the Website;
when you visit Essential Phosphates UAB office premises.

HOW DOES ESSENTIAL PHOSPHATES UAB PROCESS YOUR PERSONAL DATA?

Purpose of processing of Personal data	Personal data processed	Time limits for processing Personal data	Legal basis for processing Personal data	Data recipients
Fraud prevention; actions in order to prevent fraudulent activity (account deletion).	The necessary in order to detect and prevent fraud activity, to identify the defaulting party and to restrict the defaulting party’s ability to log in to an account or register a new account.	No longer than 3 years from the date of deletion of the account, unless longer processing is necessary to comply with legal requirements and/or to protect the rights and legitimate interests of Essential Phosphates UAB.	The processing is necessary for the legitimate interests of the controller (Article 6 part 1(f) of the GDPR).	Access to Personal data may be granted to a company providing information technology services, a company providing website development and maintenance services, or legal advisers.
Implementation of account creation and use on the Website	Name, surname, email, phone number, company name, password.	The data is stored for as long as the person is a user of the account and for 3 years after the account is terminated. The account will be deleted if the person does not log in to the account for more than 3 years.The data related to orders placed on the basis of an account shall be stored in accordance with the procedures and under the conditions laid down for the purpose of "Conclusion and performance of contracts".	The processing is necessary for the performance of a contract to which the data subject is a party or in order to take action at the request of the data subject prior to the conclusion of the contract (Article 6 part 1(b) GDPR).	Access to Personal data may be granted to an information technology services company, legal advisers.
Ensuring the security of property and persons on the premises through video surveillance.	Image.	14 days from the date of data recording, unless a longer retention period is provided for by law.	The processing is necessary for the legitimate interests of the controller (Article 6 part 1(f) of the GDPR).	Access to Personal data may be granted to a company providing information technology services, the joint controller UAB Sanobiotec (company code 305534922, address: Vilnius, Mokslininkų g. 12, LT-08412).
Conclusion and performance of contracts.	Name, surname, job position, email, phone number, delivery address.	During the term of the agreement and up to 10 years after the expiry date.	The processing is necessary for the performance of a contract to which the data subject is a party or in order to take action at the request of the data subject prior to the conclusion of the contract (Article 6 part 1 (b) of the GDPR). The processing is necessary for compliance with a legal obligation to which the controller is subject (Article 6 Part 1(c) of the GDPR).	Access to Personal data may be granted to service providers (e.g. payment platforms, packaging, delivery, warehousing and other service providers), legal advisers.
Customer service and service quality improvement.	Audio recording and the data captured during the recording.	No longer than one month from the date of the conversation in question.	The Data subject's consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to a company providing information technology services.
Website management and administration.	Information regarding cookies used on the Website.	Depending on the data retention period set by the cookie in question, which is indicated on the Website.	The Data subject's consent to such processing (Article 6 part 1(a) of the GDPR). The processing is necessary for the legitimate interests of the controller (Article 6 part 1(f) of the GDPR).	Access to Personal data may be granted to a company providing information technology services, website development and maintenance services.
Implementation of enquiry form functionality on the Website.	Name, surname, job position, email, phone number, company name, data related to the order request, other information provided by the data subject.	No longer than 6 months from the receipt of the order, but no longer than until the Data subject withdraws his or her consent.	The Data subject's consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to the company providing information technology services, to the company providing website development and maintenance services, to the company administering the order form tool, and to persons engaged by it.
Direct marketing, sending of newsletters.	Name, surname, email.	A period of 3 years or until the Data subject withdraws consent.	The Data subject's consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to a company providing direct marketing services, a company providing information technology services.
Implementation of remote meeting booking functionality on the Website.	Name, surname, email, phone number, meeting time details.	No longer than period of 6 months after the date of the relevant remote meeting or until the Data subject withdraws consent.	The Data subject's consent to such processing (Article 6 part 1(a) of the GDPR).	Access to Personal data may be granted to the company providing information technology services, to the company providing Website development and maintenance services, to the provider of the Calendly booking tool and to the persons engaged by it.

In addition to the above: access to Personal data may also be granted to law enforcement or other authorities, as well as to companies of the Essential Phosphates UAB Group; if the Personal data is used or is to be used as evidence in a case or investigation, or if the Personal data is transferred to law enforcement authorities, or in any other case provided for by law, the Personal data may be retained for the period of time required to fulfil the purposes of the processing of the Personal data, and shall be deleted as soon as it no longer is required.

In the case of transfers of Personal data, Essential Phosphates UAB will take the necessary measures to ensure that the service providers (Data processors) would use the Personal data provided only for the purposes for which it was provided, ensuring appropriate technical and organisational security measures, in accordance with Essential Phosphates UAB instructions and the requirements of the applicable legislation.

Personal data managed by Essential Phosphates UAB is provided to data recipients outside the European economic area only after an adequate level of legal protection of Personal data has been ensured (e.g., on the basis of the EU Standard contractual clauses, the Privacy Shield system, the European commission's decisions on adequate protection of Personal data, or otherwise), or, in the absence of any other justification, after obtaining the authorization of the State data protection inspectorate, or with the consent of the Data subject.

In all of the above cases, Essential Phosphates UAB processes Personal data only to the extent necessary for the achievement of the relevant clearly defined and legitimate purposes.

ONLINE SALES (WEBSITE)

The website features e-commerce for “Coenza” brand products and merchandise.Accordingly, the Website provides you with the opportunity to perform a registration on the basis of which you are granted access to the services and functionalities provided by Essential Phosphates UAB on the Website.
Registration on the Website shall be deemed to constitute the conclusion of a contract between Essential Phosphates UAB and you for the provision of services on the Website.
You have the right to cancel your account registration at any time by contacting info@coenzalabs.com.

DIRECT MARKETING

Essential Phosphates UAB can, with your consent, provide direct marketing offers using the contact Personal data you have provided to us (email, phone number).

By checking the consent to the processing of Personal data for direct marketing purposes on the Website, as well as by entering your email in the newsletter subscription box, you express your consent to the processing of Personal data in accordance with the procedure and under the terms and conditions set out in this Privacy policy for direct marketing purposes.

You have the right to object to the processing of Personal data for direct marketing purposes by providing Essential Phosphates UAB with a free-form notice expressing your will to withdraw your consent to the processing of Personal data for direct marketing purposes.

Subscription to the newsletter is free of charge.

ENQUIRY FORMS (WEBSITE)

By completing the enquiry form on the Essential Phosphates UAB Website, you will be submitting an enquiry to Essential Phosphates UAB (including the Personal data you provide) regarding the goods and services offered by “Coenza”.

Completion of the enquiry form shall be deemed to be your expressed consent to the processing of the Personal data provided by you in accordance with the terms and conditions set out in this Privacy policy.

You may refuse the request (including the processing of the Personal data contained therein) by providing Essential Phosphates UAB with a free-form notice expressing your will to refuse the request.

Information on the processing of personal data by the operator of the functionality is contained in the respective Privacy policy of the operator, at: https://policies.google.com/privacy?hl=en

The enquiry function is free of charge.

BOOKING A REMOTE MEETING (WEBSITE)

By completing the remote meeting booking form on the Essential Phosphates UAB Website, you will make a remote meeting booking and provide Essential Phosphates UAB with the relevant Personal data.

Completion of the booking form constitutes your consent to the processing of the data provided in accordance with this Privacy policy.

You may cancel your reservation (including the processing of the Personal data provided in relation thereto) by providing Essential Phosphates UAB with a free-form notice expressing your wish to cancel your reservation.

Information on the processing of personal data by the operator of the functionality is contained in the respective Privacy policy of the operator, at: https://calendly.com/legal/privacy-notice

The booking function is free of charge.

COOKIES (WEBSITE)

The Website uses cookies.

The cookies used on this Website comply with the general legal framework for the protection of personal data, the General Data Protection Regulation (GDPR) No.679/2016 applicable in the European Union.

PROCESSING OF TELEPHONE CALL RECORDS

Essential Phosphates UAB, when recording telephone conversations and processing Personal data, complies with the Regulation, the law on electronic communications of the Republic of Lithuania, Essential Phosphates UAB internal procedures and other legal acts regulating the processing of Personal data and the protection of privacy.

In order to ensure the improvement of customer service and the quality of service provision, telephone conversations between you and an employee of Essential Phosphates UAB (generally, Essential Phosphates UAB sales managers) may be recorded in certain cases.

You will be informed regarding the recording of the content of the telephone conversation at the beginning of the telephone conversation, as soon as the telephone conversation has commenced, by asking a Essential Phosphates UAB employee to confirm your consent to the recording of the audio recording of the telephone conversation. Recordings of telephone conversations are made only with your consent (Article 6 part 1(a) of the GDPR) in accordance with the procedures and under the conditions set out in this Privacy policy.

Please note that you have the right to object to the recording and processing of the audio recording of a telephone conversation. In this case, the conversation will be continued without audio recording or the telephone conversation will be terminated by asking you to contact us by other means of communication (by e-mail or by visiting the address of Essential Phosphates UAB).

The audio recording of the telephone conversation shall record the voices of the participants in the telephone conversation and the Personal data provided by the individuals or by an employee of Essential Phosphates UAB during the telephone conversation.

SECURITY MEASURES

Technical security measures:

Personal data is stored in a secure system protected by firewalls, antivirus and other technical measures to prevent unauthorised access to the system;
The registration data of Website users is encrypted in order to provide additional protection against possible disclosure of Personal data;
Essential Phosphates UAB premises and territory have appropriate controls in place to protect the information and information technology equipment held or stored therein;
Essential Phosphates UAB premises and territory where information and/or information technology equipment is stored, shall be provided with an appropriate level of physical security and shall be organised in such a way that appropriate access control systems are implemented and that access is restricted to authorised persons only;
only authorised persons have access to Personal data, and the ability of unauthorised persons to read, copy, alter or otherwise modify Personal data is restricted;
other additional technical security measures stipulated in Essential Phosphates UAB internal procedures have been duly implemented.

Organisational security measures:

Essential Phosphates UAB employees who process Personal data are obliged to comply with Essential Phosphates UAB internal rules, procedures and policies governing and regulating the protection of personal data and the protection of information and information technologies;
information, access to information, its use, processing, storage and other processes related to information shall be carried out in strict compliance with the requirements and standards set by Essential Phosphates UAB;
access control is based on the need (necessity) of the activities and functions performed. Access control is based on the assumption that everything is generally prohibited except as necessary for the performance of the assigned function, specifically authorised in advance and approved;
access to Personal data is limited to a limited number of persons, and no unauthorised persons are allowed access to the Personal data processed;
Essential Phosphates UAB has a policy whereby computers are switched off and access is protected by passwords when leaving the workplace, and information containing Personal data is stored in a place inaccessible to third parties;
other additional organizational security measures stipulated in Essential Phosphates UAB internal procedures have been duly implemented.

TERRITORY OF PROCESSING OF PERSONAL DATA

As part of the processing of Personal data, the Personal data may be transferred outside the European Economic Area (EEA).

In this case, the following conditions and requirements shall be met:

- the conditions and requirements set out in the GDPR in relation to the transfer of Personal data outside the EEA are met;

- Essential Phosphates UAB engages the services of trusted business partners / service providers who take appropriate technical and organisational security measures and comply with GDPR requirements.

RIGHTS OF DATA SUBJECTS

You have the following rights in relation to your Personal data:

the right of access to data - you have the right to obtain confirmation as to whether or not Personal data relating to you are being processed, as well as access to your Personal data processed by Essential Phosphates UAB;

the right to rectification - your Personal data must be accurate and, where necessary, kept up to date;

the right to erasure - you have the right to request the erasure of the data relating to you if the data is no longer necessary for the purposes for which it was collected or processed for other purposes, if you withdraw your consent and there is no other legal basis for the processing of your personal data, if you do not consent to the processing of the data, if the processing is carried out for the legitimate interests of Essential Phosphates UAB and there are no overriding legitimate grounds for the processing of the data, or if the processing of your personal data was unlawful;

the right to restrict processing - you have the right to request the restriction of the processing of your Personal data until Essential Phosphates UAB verifies the accuracy of your Personal data processed. If you object to the processing where the processing is carried out for the legitimate interests of Essential Phosphates UAB, you have the right to request the restriction of the processing of your Personal data for a period of time until it has been verified that Essential Phosphates UAB legitimate reasons override your reasons. You have the right to request the restriction of the processing of your Personal data if, in the event of unlawful processing, you do not consent to the erasure of your data and instead request the restriction of its use, as well as if Essential Phosphates UAB no longer needs the Personal data for the purposes of processing, but the data is necessary for the establishment, exercise or defence of legal claims;

the right to object to processing - you have the right to object to the processing of personal data where the processing is carried out for the purposes of the legitimate interests of Essential Phosphates UAB, except where the processing is carried out for legitimate reasons which override your interests, rights and freedoms, or for the establishment, exercise or defence of lawful claims and interests;

the right to data portability - if personal data of individuals are processed by Essential Phosphates UAB by automated means, you have the right to receive the Personal data relating to you that you have provided to Essential Phosphates UAB in a format that is structured, commonly used and computer-readable;

the right to lodge a complaint with the State data protection inspectorate - you have the right to lodge a complaint with the State Data Protection Inspectorate in accordance with the procedure set out in the Law on Legal protection of personal data.

Essential Phosphates UAB has the right to make changes to this Privacy policy.

The latest version of the Privacy policy is available on the Website.