Privacy policy

LTG LINK Privacy notice

Last updated on 17 March 2022


Private limited liability company LTG Link (hereinafter referred to as “LTG Link” or “Company” or simply “we”) stores and processes information about you in accordance with the General Data Protection Regulation of the European Union (hereinafter - GDPR ) and other regulatory enactments governing the protection of data. This LTG Link Privacy Notice (hereinafter - "Privacy Notice") gives details about this.

1. What is provided in this Privacy Notice?

In this Privacy Notice, we provide answers to the most important questions about how we collect, use and store information about you. Please read this important information carefully and from time to time visit our website at www.ltglink.lt and read the latest version of the Privacy Notice updated there.

2. Who is responsible for protecting your information?

UAB LTG Link, legal entity code: 305052228, registered address: Geležinkelio st. 16, Vilnius, e-mail address: info@ltglink.lt, telephone No: 8 700 55 111

3. Why and what information do we collect about you?

3.1. Why do we collect information about you?

  • We conclude and execute a passenger transport contract with you or your children (wards), as well as provide related services (e.g. ticket sales or refunds), fulfill the related tax obligations

3.1. What information do we collect about you?

  • Name, surname, email address, telephone number, method of payment, payer's bank account number, other information related to the payment, information on purchased tickets and travel details (ticket number, travel route, train number, arrival and departure stations, travel time, travel durration, seat number, wagon and its class, fare, benefits granted, ticket number), time ticket card information, information on additional services (bicycle, extra luggage, animal transport)
  • Information about the disability

3.1. Why do we have the right to collect the information you provide?

  • We enter into a contract with you and fulfill our contractual obligations (Item b of Paragraph 1 of the GDPR), we must collect information in accordance with the law (Item c of Paragraph 1 of Article 6 of the GDPR).
  • Processing of data is necessary for reasons of important public interest on the basis of the regulatory enactments of the Republic of Lithuania (Item g of Paragraph 2 of Article 9 of the GDPR, Law of the Republic of Lithuania on Transport Privileges)

3.1. How long do we use or store information about you?

  • During the validity of the contract and for 1 year after the purchase of the ticket.
  • 1 year from the request for return of the electronic ticket



3.2. Why do we collect information about you?

  • We conclude and execute train rental and passenger carriage route agreements with you, fulfill the related tax obligations

3.2. What information do we collect about you?

  • Name, email address, telephone number, signature, amount due, amount of guarantee deposit, method of payment, payer's bank account number, other information relating to the payment, contract and contractual information, date of contract, time and route of the rented train, information contained in the acceptance-transfer deed, other information related to the conclusion and performance of the contract

3.2. Why do we have the right to collect the information you provide?

  • We enter into a contract with you and fulfill our contractual obligations (Item b of Paragraph 1 of Article 6 of the GDPR), we must collect information in accordance with the law (Item c of Paragraph 1 of Article 6 of the GDPR)

3.2. How long do we use or store information about you?

  • During the term of the contract and for 10 years after the end of the contract



3.3. Why do we collect information about you?

  • We enter into and execute contracts with you for the acceptance, processing, transportation and issuance of parcels, and fulfill the related tax obligations

3.3. What information do we collect about you?

  • Consignors‘ and consignees‘: name, surname, city, contact telephone number, signature, service receipt, service receipt number, number and route of the train carrying the parcel, date of acceptance and receipt of the parcel, type of parcel, amount paid for the consignment, details of the document submitted (power of attorney) (when the parcel is picked up by the consignee's representative), request / complaint on packaging damage and information contained therein, written refusal to pick up the parcel

3.3. Why do we have the right to collect the information you provide?

  • We enter into a contract with you and fulfill our contractual obligations (Item b of Paragraph 1 of Article 6 of the GDPR)

3.3. How long do we use or store information about you?

  • 2 years from shipment



3.4. Why do we collect information about you?

  • We store and issue: found items, items removed from the electronic storage, items from oversized luggage / long-term storage room

3.4. What information do we collect about you?

  • Signature of the person requesting the release of the found items: name, surname, address, telephone number, date of loss of the items, circumstances of the loss, type of packaging of the items, quantity, amount paid for storage costs, signature
  • Signature of the person requesting the release of the items left in the electronic storage or oversized luggage / long-term storage room: name, address, telephone number, section number, locker number, receipt number, type of packaging, quantity and amount paid for the storage of the items, signature

3.4. Why do we have the right to collect the information you provide?

  • We enter into a contract with you and fulfill our contractual obligations (Item b of Paragraph 1 of Article of the GDPR)
  • We have a legitimate interest (to ensure the storage and transfer of found items to their owners) (Item f of Paragraph 1 of Article 6 of the GDPR)

3.4. How long do we use or store information about you?

  • 1 year from the date of application



3.5. Why do we collect information about you?

  • Through the hotline channels, you provide us with information on possible fraud, corruption, other criminal offenses, breaches of law, and violations of employment duties.

3.5. What information do we collect about you?

  • If the person provides the information by telephone not anonymously - the data provided by the person himself/herself -  name, surname, etc., the content of the message sent, the telephone number from which the call was made, the start, end, duration of the call and other personal data if indicated by the person when providing information
  • If a person provides information by email or via the website www.litrail.lt - email address and additional information, if the person provides the information not anonymously - name, surname, telephone number, content of the message

3.5. Why do we have the right to collect the information you provide?

  • We have a legitimate interest (to prevent fraud, corruption, other criminal offenses, violations of law, employment duties and other violations - to prevent the committed acts, to take measures to prevent future acts, etc.) (Item f of Paragraph 1 of Article 6 of the GDPR)

3.5. How long do we use or store information about you?

  • 1 year from the date of receipt of the information



3.6. Why do we collect information about you?

  • We enter into and execute contracts for the provision of advertising services with you, and fulfill the related tax obligations

3.6. What information do we collect about you?

  • Name, surname, email address, telephone number, signature, amount payable, method of payment, payer's bank account number, other information related to the payment, contract and information in the contract, contract date, advertising layout, information on the place of advertising, information contained in the deed of acceptance and transfer, other information related to the conclusion and performance of the contract

3.6. Why do we have the right to collect the information you provide?

  • We enter into a contract with you and fulfill our contractual obligations (item b of Paragraph 1 of Article 6 of the GDPR), we must collect information in accordance with the law (Item c of Paragraph 1 of Article 6 of the GDPR)

3.6. How long do we use or store information about you?

  • During the term of the contract and for 10 years after the end of the contract



3.7. Why do we collect information about you?

  • We maintain relations with the natural or legal persons you represent

3.7. What information do we collect about you?

  • Name and surname, personal identification number and (or) date of birth, residence address, power of attorney, term and number of the power of attorney, signature, contact with the represented person, position, position, telephone number, email address, login name to our systems, all information you provide to the Company (e.g. information about the person you represent, contracts entered into, etc.) and, as far as the performance of the contract is concerned, communication with you, any other information that may be required for the proper performance of the contract

3.7. Why do we have the right to collect the information you provide?

  • We have a legitimate interest (in maintaining relations with the persons you represent) (Item f of Paragraph 1 of Article 6 of the GDPR)

3.7. How long do we use or store information about you?

  • During the term of the contract and for 10 years after the end of the contract



3.8. Why do we collect information about you?

  • After the travel, we invite you to take part in a survey asking for your opinion on the quality of services provided, your experience during the travel
  • If you consent to the survey, we also ask for opinions about offers, services or your needs
  • Surveys help us to improve the quality of our services and develop services that meet your needs

3.8. What information do we collect about you?

  • In order to contact you and find out your opinion and evaluation, we collect the following data from you: name, surname, email address.
  • You can unsubscribe from surveys at any time by clicking the unsubscribe link in the survey email.
  • Other demographic data in surveys are collected and used for statistical information / analysis purposes only.

3.8. Why do we have the right to collect the information you provide?

  • We have a legitimate interest in inquiring about the quality of services after the travel (Item f of Paragraph 1 of Article 6 of the GDPR) or we have the consent to use the information about you for direct marketing and surveys (Item a of Paragraph 1 of Article of the GDPR, paragraph 1 of Article 81 of the Law of the Republic of Lithuania on Electronic Communications).

3.8. How long do we use or store information about you?

  • 2 (two) years from the date of receipt of your consent or until you withdraw this consent.



3.9. Why do we collect information about you?

  • We carry out direct marketing by sending you newsletters via email
  • In the newsletters we provide special offers on ticket discounts for local train travel, advertisements or announcements about promotions, services that are related to the activities of both the Company and the Company's partners

3.9. What information do we collect about you?

  • For communication with newsletters, we collect the following personal data from you: name, surname, email address
  • You will find opt-out and settings management features at the bottom of each newsletter

3.9. Why do we have the right to collect the information you provide?

  • We have consent to the use of information about you for direct marketing purposes (Item a of Paragraph 1 of Article 6 of the GDPR, Paragraph 1 of Article 81 of the Law of the Republic of Lithuania on Electronic Communications)

3.9. How long do we use or store information about you?

  • 2 (two) years from the date of receipt of your consent or until you withdraw this consent



3.10. Why do we collect information about you?

Communicating with you, organizing contests, games on our social networks:

3.10. What information do we collect about you?

  • We will manage the data of your social network account provided by you on our accounts - account name, account profile picture, reactions ("likes") to the published information, comments you have left on our account (e.g. if you share photos or videos in comments)
  • For the purpose of organizing games and competitions, we will process your personal data as described in this privacy notice
  • You can exercise the right to object to the processing of personal data on social networks in accordance with the procedure established by social network managers

3.10. Why do we have the right to collect the information you provide?

  • We will process the personal data you provide on the basis of a legitimate interest - to keep you informed of what's going on, to communicate with our followers and visitors to our social pages, to tailor the information we provide and other account activity to the needs of the account visitors.

3.10. How long do we use or store information about you?

  • The personal data you provide in connection with certain activities on social networks is processed and stored in accordance with the procedures and terms set by the social network operators, and we cannot influence this in any way.



3.11. Why do we collect information about you?

  • We will invite you to participate in competitions and games.

3.11. What information do we collect about you?

  • We will collect the following personal data for participation in competitions and games: name, surname, email address, telephone number and other data which we will inform about in the conditions of the competition. This is necessary for us to be able to fulfill our contractual obligations to you. If we are unable to use your data, you will not be able to participate in the competition and win. In the case of winning prizes, we process personal data in order to comply with the legal requirements applicable to us

3.11. Why do we have the right to collect the information you provide?

  • We have your consent (Item a of Paragraph 1 of Article 6 of the GDPR)

3.11. How long do we use or store information about you?

  • 6 months after the end of the competition.



3.12. Why do we collect information about you?

  • You submit an inquiry, request, suggestion or complaint to us by general email address, in the form provided on the website or through other electronic communication channels

3.12. What information do we collect about you?

  • Name and surname, email address, telephone number, subject of the request, time of receipt of the request, content of the request, annexes to the request, history of correspondence, other information provided in connection with the submitted request, reply to the request

3.12. Why do we have the right to collect the information you provide?

  • We have your consent (Item a of Paragraph 1 of Article 6 of the GDPR), we must collect information in accordance with the law (Item c of Paragraph 1 of Article 6 of the GDPR), we have a legitimate interest (to examine your inquiries, requests or complaints) (Item f of Paragraph 1 of Article 6 of the GDPR)

3.12. How long do we use or store information about you?

  • 1 year after last application
  • 2 years after submitting a complaint



3.13. Why do we collect information about you?

  • We record telephone conversations to ensure the quality of the services provided, to provide accurate information about the services provided and to provide advice, and to examine inquiries, complaints and requests.

3.13. What information do we collect about you?

  • Telephone number, records of telephone conversations and data provided during calls customer service, to provide accurate information about the services provided and to provide advice, to ensure the appropriate quality of customer service, to examine requests, inquiries or complaints under Itemf of Paragraph 1 of Article 6 of the GDPR).

3.13. Why do we have the right to collect the information you provide?

  • We have a legitimate interest (to ensure the quality of

3.13. How long do we use or store information about you?

  • 1 year after talking to you



3.14. Why do we collect information about you?

  • We ensure the safety of your health, life and the property of the Company and your property - in cases when you are in filmed premises or trains of the Company

3.14. What information do we collect about you?

  • Video material (in some cases, the image is recorded with the audio)

3.14. Why do we have the right to collect the information you provide?

  • We have a legitimate interest (security of property and persons) (Item f of Paragraph 1 of Article 6 of the GDPR)

3.14. How long do we use or store information about you?

  • Up to 30 days



3.15. Why do we collect information about you?

  • We investigate railway disasters, traffic accidents or incidents

3.15. What information do we collect about you?

  • Name, surname of  witness of a railway disaster, traffic accident or incident, as well as name, surname, sex, age, sobriety, actions of the person who suferred during the railway disaster, traffic accident or incident, as well as name, surname  of the those responsible for the railway disaster, traffic accident or incident, and all other information which we must process under Annex 2 to the Regulations for the Submission of Notices on Railway Disasters, Traffic Accidents and Incidents, and for the Investigation of  Railway Disasters, Traffic Accidents and Incidents and Liquidation of Consequences Thereof, approved by order of the Minister of Transport and Communications of the Republic of Lithuania No 3-531(1.5 E) of 23 December 2015

3.15. Why do we have the right to collect the information you provide?

  • We must collect information in accordance with the law (Item c of Paragraph 1 of Article 6 of the GDPR, Regulations for the Submission of Notices on Railway Disasters, Traffic Accidents and Incidents, and for the Investigation of  Railway Disasters, Traffic Accidents and Incidents and Liquidation of Consequences Thereof, approved by order of the Minister of Transport and Communications of the Republic of Lithuania No 3-531(1.5 E) of 23 December 2015)

3.15. How long do we use or store information about you?

  • 10 years after a railway disaster, traffic accident or incident



3.16. Why do we collect information about you?

  • You use wireless internet connection on our trains

3.16. What information do we collect about you?

  • IP address, operating system version and settings, device name and settings (MAC, type, etc.), session start time and duration, query terms, and any information stored using cookies applied to the visitor's device, the name and version of the browser used, the action, and the date and time it was performed, URL-address connected, the protocol used to connect, the application used, the port number of the connection to be connected, the amount of data downloaded / sent during the connection, other service data used to establish the connection

3.16. Why do we have the right to collect the information you provide?

  • We enter into and execute a contract with you (Item b of Paragraph 1 the Regulation)

3.16. How long do we use or store information about you?

  • Up to 1 year



3.17. Why do we collect information about you?

  • We ensure the efficient and secure operation of our website and seek to know how individuals use the services we offer on the website so that we can improve them and create new ones.

3.17. What information do we collect about you?

  • IP address, version of the operating system, settings of the device you are using, the start time and duration of the session, the terms of the requests you enter on our website, and any information stored using cookies applied to your device (see Item 11 of the Privacy Notice)

3.17. Why do we have the right to collect the information you provide?

  • We have a legitimate interest (to monitor the quality of our services, to improve and create new services, to ensure that the Company's website operates in a high-quality manner and safely and that persons who visit it find relevant information) (Item f of Paragraph 1 of Article 6 of the GDPR)

3.17. How long do we use or store information about you?

  • Up to 1 year



3.18. Why do we collect information about you?

  • We can participate in legal proceedings related to you

3.18. What information do we collect about you?

  • All information mentioned in this Privacy Notice, documents sent to you and their attachments, documents submitted by you and their attachments, procedural documents, court rulings, resolutions, judgements

3.18. Why do we have the right to collect the information you provide?

  • We have a legitimate interest (to defend the rights of the Company in legal proceedings) (Item f of Paragraph 1 of Article 6 of the GDPR)
3.18. How long do we use or store information about you?

  • 10 years after the end of the contract with you or 10 years after the end of legal proceedings



3.19. Why do we collect information about you?

  • You submit a request to enforce the rights of data subjects under the GDPR and we ensure the performance of the request

3.19. What information do we collect about you?

  • Depending on what personal data you provide: name, phone number, address, date of birth, email address, table number, legal partner code, copy of identity document, request for exercise of data subject's rights, date of request, place of request, specified method of replying to the request, content of the request and other information provided in the data subject's request, reply to the data subject, other information related to the exercise of the data subject's rights.

3.19. Why do we have the right to collect the information you provide?

  • We have a legal obligation (to ensure the exercise of the rights of data subjects (Chapter III of the GDPR)

3.19. How long do we use or store information about you?

  • Applications are kept for 5 years from the date of the reply.

4. Processing of personal data of children

4.1. Only persons over 14 years of age can become registered users, participate in the loyalty programme and express consent to direct marketing. Individual loyalty programs or contest conditions may provide for a different, higher minimum age limit for participants.

4.2. If we have reasonable grounds to suspect that we are processing data from individuals under the age of this section, we will remove the data from those databases.

5. What information you must provide us and why?

Please review the answer to item 3 above - you must provide the information about you that is necessary to:

5.1. enter into contracts with you and fulfill contractual obligations;

5.2. enter into contracts with the persons you represent and fulfill contractual obligations;

5.3. give you access to wireless internet on our trains.


If you do not provide the specified information, we will not be able to enter into contracts with you and / or the persons you represent and fulfill contractual obligations.

6. Where do we get information about you?

Most of the information is provided by you, but we can get some of the information from:

6.1. the legal entities that you represent or where you are employed at;

6.2. joint-stock company „Lithuanian Railways“ (for the purposes specified in items 3.5, 3.14, 3.15).

7. Who do we pass on information about you to?

We will only transfer or share information about you to/with our partners, service providers, and the following entities to the extent necessary and permitted by applicable law, including for the reasons listed in Item 3:

7.1. parent company of UAB LTG Link, i.e. AB Lithuanian Railways, and its subsidiaries (data may be transferred for all purposes specified in item 3);

7.2. banks performing settlement operations (data shall be transferred for the purpose specified in Clause 3.1);

7.3. courts, supervisory, law enforcement and other public authorities (data may be transferred for all purposes listed in the answer to question 3);

7.4. lawyers, notaries, bailiffs, auditors, consultants, IT maintenance service providers, electronic communications service providers, insurance companies, companies providing archiving services and other services to the Company (data may be transferred for all purposes provided in the answer to question 3).


Please note that the Company selects as data processors only those persons who have provided the Company with a sufficient guarantee that they apply appropriate technical and organizational measures to ensure the safe processing of personal data and the appropriate level of data protection in accordance with applicable legislation of the European Union.

8. Will your data be transferred outside the European Economic Area?

In most cases, personal data are processed and transferred within the European Union and the European Economic Area, but where necessary for the provision of certain services, data may be transferred and processed outside those territories, provided that an adequate level of protection of personal data is observed. Where permitted by law and for the reasons set out in Section 7 of this Privacy Notice, we disclose information about you:

8.1. on the basis of the European Commission's decision on adequacy, meaning that the European Commission has recognized the country in which the third party is established and / or operates as ensuring an adequate level of protection of personal data;

8.2. we have signed a contract with a third party based on the Standard Contract Terms approved by the European Commission;

8.3. we have received the permission of the State Data Protection Inspectorate;

8.4. by using, where possible, other possible personal data protection measures and allowable derogations.


9. What rights do you have?

The GDPR and other regulatory enactments give you rights, provide for cases when you can exercise them, the procedures you must follow, as well as the exceptions when you may not exercise those rights. When permitted by law, you may:

9.1. access your personal data, i.e. receive a notification confirming whether LTG Link processes your personal data and, if so, request access to the processed data and related information;

9.2. provide us with a request to correct inaccurate, incorrectly used information or to supplement it when it is incomplete;

9.3. provide us with a request to delete information we hold about you if we use it illegally;

9.4. provide us with a request to restrict the processing of available information about you when you dispute the accuracy of the data or object to the processing of the data, do not consent to the deletion of your illegally processed data, or you need the data to claim, enforce or defend legal claims;

9.5. to object to the use of data when we process your data in the legitimate interests of LTG Link and / or third parties;

9.6. provide us with a request to transfer (receive) data which you have provided to us under a contract or consent to the processing of data and which we process by automated means in a shared electronic form;

9.7. object to being subject to a fully automated decision, including profiling, if such a decision is likely to have legal consequences or similar significant effects on you;

9.8. revoke the consents given to us regarding the use of your information when we use the data on the basis of your consent;

9.9. lodge a complaint with the supervisory authority, in particular in the Member State where you are domiciled or where the suspected violation of the GDPR has been committed, and apply for legal remedies. The supervisory authority in the Republic of Lithuania is the State Data Protection Inspectorate (L. Sapiegos st. 17, Vilnius; email: ada@ada.lt), but first we recommend that you contact us and we will try to resolve all your requests together with you.

10. How can you exercise your rights?

To exercise your rights under Item 9 of this Privacy Notice, you must:

10.1. personally deliver the application for the exercise of the data subject's rights (hereinafter - the Application)   to the Company's headquarters, Passenger Information Centre or to the Data Protection Officer at the addresses specified in Item 14 of this Privacy Notice (the Application must be accompanied by an identity document);

10.2. send the Application to the Company or the Data Protection Officer at the postal addresses specified in Item 14 of this Privacy Notice (a copy of the identity document certified by a notary or in other procedure established by regulatory enactments must be attached to the Application);

10.3. submit the Request to the Company or the Data Protection Officer at the email addresses specified in Item 14 of this Privacy Notice (the request submitted by email must be signed with a secure electronic signature).

11. Do you profile me and make automated decisions?

The company may profile you for statistical purposes. Also, in order to prevent the sending of unsolicited marketing offers, we classify you according to the date of conclusion of the contract, the term of the contract, the status of the contract, your age.

12. Does your website leave cookies on my computer or device?

Yes, we use cookies as shown in the table below. Cookies are small text files stored on the browser of your device (e.g. computer, mobile phone, tablet) when you browse websites. Other technologies, including data stored on your browser or device, identifiers associated with your device, and other software, may be used for similar purposes. Cookies are widely used to make websites work or perform better and more efficiently.


Compulsory cookies are cookies that are necessary for the proper functioning of the website. They allow you to use certain features of the website, such as securely signing in to an account created on the website. Cookies are used to ensure the technical functioning of the website.

If you disable cookies in your browser, some features of the website may not work at all or in full.




Optional cookies that you can manage and refuse



13. How can you manage cookies?

By visiting the website (www.ltglink.lt) you can choose whether you want to use cookies. You can manage cookies on the website itself and (or) delete them according to your browser preferences. You can opt out of the use of optional cookies on the website, but the website may be not fully functional, for example, you will not be able to use the chat window assistance when purchasing.


You can choose which cookies you would like to accept and which you would like to reject in your browser settings. You can delete all cookies already on your computer, and in most browsers you can prevent cookies from being saved. The location of these settings depends on the browser you are using.


If you do not agree to the storage of cookies on your computer or other device, you can revoke your consent at any time by changing the settings on the website and deleting the stored cookies in your browser. If you choose to delete cookies, keep in mind that all your options will be removed as well. In addition, many websites (including www.ltglink.lt) may not function properly if cookies are completely blocked. For these reasons, we do not recommend disabling compulsory cookies.


How do I delete cookies from my device?


In order to prevent the processing of your personal data with the help of cookies, you can change the settings of your Internet browser so that cookies are not accepted, or delete the stored cookies.

You can change your cookie settings at any time in your browser. All browsers have the ability to delete cookies. More detailed instructions depend on the browser you are using, you can find them in the options menu of the browser you are using:

More information on https://www.allaboutcookies.org/


We reiterate that removing or blocking the cookies used may affect the operation of the website and some of its functionalities, as well as may adversely affect your use of the services available on the portal.

To learn more about cookies and how to manage or remove them, simply visit https://www.allaboutcookies.org/ and your browser's help page.

14. How to contact the Company or the Data Protection Officer?

If you have any questions, comments or complaints about how we collect, use and store information about you or would like to exercise your rights as a data subject, you can contact:

14.1. The company by, address: Geležinkelio st. 16, Vilnius, phone No: 8 700 55 111, email info@ltglink.lt

14.2. Data Protection Officer, address: Prūsų st. 1 Vilnius, email dap@ltg.lt

Documents

If you want to download our privacy policy press here.