This Privacy Policy explains how we, UAB Penkios dukros (hereinafter Penkios dukros, "us", "we", "our") collect, use, share, and protect personal data, and what privacy rights you have.

This Privacy Policy applies to all natural persons who use, have used, have expressed an intention to use the Penkios dukros services, or are otherwise related to us and (or) our services. This Privacy Policy also applies to employees and representatives of Penkios dukros clients.

This Privacy Policy applies to personal data of natural persons, it does not apply to legal persons’ data. The Privacy Policy is made public on Penkios dukros website

Specific categories of personal data and actions taken with respect to your personal data may differ depending on which website or system you use, but Penkios dukros will not process personal data beyond the scope described in this Privacy Policy.


Penkios dukros are controllers of your data. You can find the contact details of the data controller on the Contacts page.



When you visit our website or interact with our emails, we use cookies to collect certain information automatically from your browser through the use of cookies and pixels from tools such as Google Analytics and Google Ads. Our use of cookies is discussed in more detail in our cookies policy which is available here.

The information we collect automatically includes:

  • persistent identifiers (IP addresses, browser type, Internet Service Provider (ISP), referrer URL, exit pages, operating system, date/time stamp);
  • usage data (information how you interact with our web page);
  • approximate location (e.g., nearest city or town);
  • log data (our web servers keep log file that record data each time a device access them).

We use this information for conducting analytical and profiling activities, which include improving the efficiency of our internal processes and procedures and overall quality of the products and services that we provide, and creating customer profiles to prepare relevant products and services.

Legal basis for collecting this information is our legitimate interest to improve our offerings. Where we use cookies to collect and process this information, legal basis is your consent.

2.2. Remarketing

We use LinkedIn and Facebook tags on our website. These tools allow us to analyse the interaction between our websites and these social networks. Personalised user data may be used for remarketing purposes on these platforms. The legal basis for the use of this data for remarketing purposes is your consent, which you express by accepting our privacy policy.

2.3. Management of client relationships and related processing

In order to carry out the activities of Penkios dukros and to communicate with our customers, we need to collect certain personal data from our employees and customer representatives.

If you act in the capacity of an employee or a representative of a client (or a potential client) and communicate with us or otherwise have relations with us, we may process your contact and other details such as first name, last name, job title, organization, phone number, email address, payment identifiers, and any other personal information you provide to us in your communication (alone or in combination with other data we source) for various purposes relating to our business activities, such as:

  • to enter into a sales or service contract with you or the organization for which you work;
  • to communicate with you in relation to the contract we have entered into with you or with the organization for which you work;
  • to bill and collect money owed to us by you (or the client you represent). This includes sending you emails, invoices, receipts and alerting you if we need to clarify information about payments;
  • to follow up after correspondence (live chat, email or phone inquiries);
  • to communicate with you about our products and provide customer support;
  • to verify financial transactions and undertake compliance screening checks;
  • to cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data;
  • to protect personal property or ensure safety, and pursue remedies available to us and limiting our damages;
  • to share content of your communication with our customer services representatives to ensure we deliver high-quality service, assist in the training and development of Teltonika representatives, and generally improve our customer service to you.

We may collect personal information about you (e.g., your position, specialty and publications) from publicly-available resources and combine it with personal data we have collected about you, to enhance our customer profile of you in support of our sales and marketing activities.

Depending on the specific actions we take during use of your personal data, processing of your personal data is based on one of the following legal bases, i.e.:

  • when processing is necessary for the performance of a contract or in order to take steps at prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary for the purposes of the legitimate interests pursued by us or a third party. Most commonly, we process personal data to pursue legitimate interests of improving, maintaining, providing, and enhancing our technology, products, and services, and ensuring the security of the products and services, as well as supporting our marketing activities;
  • when you give us your consent.

2.4. Provision of our services

When you use our services, the data controller of your personal data is generally your employer or other entity which is using our products and services. In these cases, we generally act as the data processor in accordance with the data processing agreement concluded as part of our agreement with the customer regarding provision of service.

We use your personal data in order to enable you to use our services and functionality of Penkios dukros services. We may also use the personal data to conduct usage analysis, implement improvements, and make business decisions. The personal data may also be used to provide you with service support and ensure stability of our service.

The legal bases we rely on to process data for the above-mentioned purposes are the necessity to perform contract (when we seek to ensure availability and functionality of our services) and our legitimate interests to improve our services (when we conduct usage analysis).


We put our best efforts to keep your data safe and always require the high level of security and confidentiality from our employees, partners and service providers. We will only disclose your personal information to third parties in compliance with the law, including in the following circumstances:

3.1. Analytics

Penkios dukros uses third-party web analytics services on the website, such as Google Analytics. These analytics services may collect information about your activities on our sites to help us analyse how visitors use our website, improve usability and customer experience. Google Analytics may record clicks, mouse movements and scrolling activity, other activities that you voluntarily complete on our Sites. You can learn more about the data collected by Google's tools here. Also, you can opt-out of Google Analytics by installing Google’s browser add-on.

We use LinkedIn and Facebook tags on our websites. These tools allow us to analyse the interaction between our websites and the most popular social networks.

3.2. Subcontractors

Penkios dukros shares your personal data with other partners when services are provided by partners authorized by Penkios dukros.

Your personal data may also in some cases be shared with various types of professionals providing services to us, such as auditors, lawyers, financial consultants and other service providers.

3.3. Corporate transactions

If we are participating in a corporate transaction such an acquisition or a sale or are otherwise involved in any capacity in any such transaction, your personal data may be shared with entities involved in the transaction, including sellers, buyers, or other investors, as well as consultants related to the relevant transactions.

3.4. For legal reasons

In response to a legal request, if we have a good-faith belief that the response is required by law, we may share your personal data with public authorities, courts, legal officers, government entities, law enforcement agencies etc.


We retain personal data where we have an ongoing legitimate business or legal need to do so, and our retention periods will vary depending on the type of data involved. The criteria used to determine our retention periods generally include:

  • the length of time we have an ongoing relationship with you (for example, for as long as you keep using our services);
  • whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them).

Some types of personal data have a set retention period, i.e.:

  • data collected via website analytics will be stored up to 26 months;
  • cookies are usually valid for up to 24 months. You may delete them anytime;
  • we may keep Customer‘s data associated with the use of Service for up to 12 months.

In some cases, personal data may be stored for a longer period if storage of personal data is required in order to protect our or any third parties’ legitimate interests, e.g., in case of a legal dispute.


As the data subject, you have the right to:

  • obtain confirmation as to whether or not personal data concerning is being processed, and, if that is the case, access to the personal data;
  • request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
  • object to processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • withdraw your consent;
  • request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it;
  • request the transfer of your personal information to another party in certain formats, if practicable;
  • make a complaint to a supervisory body. If you are domiciled in the EU and you think your privacy rights were breached, you may lodge a complaint with the data protection authority of the country of your domicile. You may find the list and contact details of EU data protection authorities here.

We review our Privacy Policy regularly and we will place any updates on this web page. You are required to acquaint yourself with any changes to it.


If you have any privacy-related questions, complaints, or issues, please send an email to rezervacijos@penkiosdukros.lt. When submitting a request, please identify yourself and specify your request.

You can also contact us by writing to this address:

„Penkios dukros“, UAB, Vilniškių k. 8A, Vilniškės, LT-15100 Vilniaus r.