Privacy policy

Recruitment of employee candidates and administration of the candidate database

If you have sent your CV, cover letter and/or other documents or information in order to take part in the advertised recruitment, the personal data you have voluntarily provided and the other personal data listed below will be processed for the purpose of carrying out the recruitment.

For the purpose of recruitment, we will process your personal data until we decide to recruit a specific candidate, his/her probationary period end, or we decide to close the recruitment without selecting any candidate, however, no longer than six months from the date of receipt of data.

If you give your consent, we will retain your CV and other data provided for the purpose of administration of the candidate database for a period of 1 year after the end of the recruitment process, so that we can contact you with a job offer or invitation for a new recruitment if we need to recruit a new employee. If you have expressed your preference that our Company does not make future job offers to you, we will retain your name and information about your preference not to receive job offers for 3 years.

We will process your personal data on the basis of your consent to participate in the recruitment process or your consent to the retention of your data in the candidate database. Providing your personal data for the purpose of selection is voluntary, but if you do not provide the requested data, we will not be able to assess your eligibility.

Please note that your previous employers may be contacted and asked for their opinion on your qualifications, professional skills and personal qualities, in exercise the statutory right regulating protection of personal data. However, your current employer will not be contacted without your consent.

We may transfer your data to third parties who assist us in the selection of candidates or who provide us with services related to the recruitment, assessment and internal administration of candidates. In each case, we provide the data controller with only as much data as is necessary to execute a specific order or provide a specific service. The data processors we engage may process your personal data only in accordance with our instructions and may not use them for other purposes. Moreover, they must ensure the security of your data in accordance with applicable legislation and data processing agreements concluded with us. We may also provide your data to companies in our group that are involved in the assessment of employee candidates and/or career decision-making processes.

Ensuring the Security of Property and Individuals

For the purpose of ensuring the security of property and individuals, the Company conducts video surveillance. Video surveillance is carried out on the basis of legitimate interest. Video recordings are retained for a period of 15 days. Access to the recordings is granted to the security service provider.

Direct marketing

If you are a customer of the Company or have opted in to receive direct marketing materials, your contact details will be used to provide you with information about our goods and services, newsletters or other direct marketing information.

If you are a customer of the Company, direct marketing may be sent to you in accordance with your statutory rights. You may object to this marketing approach by indicating this in the agreement you sign with our company and by using the contact details provided in this Privacy Policy.

Your personal data will be processed for the purpose of direct marketing for a period of 5 years from the date of your consent or the end of the Company’s relationship with you.

Each e-mail sent to you will include an option to opt-out of direct marketing messages. You can also refuse or withdraw your consent by contacting us using the contact details provided by the Company.

Managing complaints, enquiries or feedback

If you have submitted a complaint, enquiry or feedback to our Company, the personal data you have voluntarily provided will be processed for the purpose of their administration.

If your complaint relates to a potential dispute, potential damage or the enforcement of other legal obligations, your personal data may be stored for a maximum period of 10 years, until the general limitation period expires. Unless the personal data relates to a potential dispute or the performance of a legal obligation, it will be deleted after the reply to your letter.

The processing of your personal data will be based on the expression of your free will, i.e., your consent, however, in certain cases, a legal act may become the basis for the continued retention of your complaint.‍

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Communication by e-mail

The processing of your personal data provided in the course of electronic communication is based on your free expression to communicate by e-mail and to provide certain data, i.e., your consent.

If you communicate with the Companies as an employee of companies with which we have or may have a contractual relationship, the processing of your data in electronic communications may be based on legitimate interest. In addition, individual processing operations, such as tax returns, may also be based on the fulfilment of legal obligations.

In addition to the purpose of concluding and performing the agreement, your data shall also be processed for internal administration purposes.

Your e-mail address, the content of correspondence and related data are processed in accordance with the principle of proportionality. These data will be visible in particular to the person with whom you communicate directly by e-mail. However, in certain cases, your correspondence may be read and processed by other employees, for example, for electronic monitoring of the workplace, for the investigation of possible breaches of legislation or internal rules, for the enforcement of internal rules, for the replacement of an employee and for related purposes, and in similar situations.‍

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Drawing up and executing agreements with natural persons

Personal data processed for the purpose of concluding and executing agreements with natural persons shall be retained for 10 years from the end of the contractual relationship.

We will process your personal data on the basis of the performance of an agreement to which you are a party, as well as for the purpose of taking action at your request prior to the conclusion of the agreement.

We may ask for your consent for certain individual actions, and we may be required to comply with legal obligations, such as those provided under tax legislation.

For the purposes set out above, we will process the personal data that you directly provide before and during the conclusion of the agreement. If you do not provide this information, we will not be able to conclude and perform the agreement.

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Drawing up and executing agreements with legal entities

Personal data of counterparty employees and representatives processed for the purpose of concluding and executing agreements with legal entities shall be retained for 10 years from the end of the contractual relationship.

The ground for data processing is legitimate interest. Without processing the personal data of a party’s representatives, we would not be able to conclude and perform an agreement with the legal entity they represent.

Provision of personal data to data recipients

For the purposes of processing of personal data as set out in this Privacy Policy, the personal data processed may include:

- IT, server, mail, archiving, reporting, accounting and other service providers and subcontractors;

- notaries, judicial officers, lawyers, attorneys, consultants, auditors, debt collection companies and debt buyers and assignees;

- law enforcement and supervisory authorities, courts, other dispute resolution bodies and other persons exercising functions assigned to them by law;

- potential or actual successors to our business or part thereof or their authorised advisers or persons, and other participants in the reorganisation.

The Company is a member of the TMV Capital group, so we may transfer your data to other companies in the group for the purpose of internal administration on the basis of legitimate interest.

Please be informed that personal data are entered into a project management system whose owner and licensor is based in the USA, and the data entered into the system are thus transferred to that country. Standard Contractual Terms and Conditions and certification under the EU-US Data Privacy Framework are used to ensure the security of data transfers and compliance with the Regulation.‍

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Principles of personal data protection which we comply with

We comply with the following principles when collecting and using the personal data you entrust to us, as well as data received from other sources:

- your personal data are processed in a lawful, fair and transparent manner (principle of lawfulness, fairness and transparency);

- your personal data are collected for specified, explicit and legitimate purposes and shall not be further processed in a way incompatible with those purposes (purpose limitation principle);

- your personal data are adequate, relevant and only necessary for the purposes for which they are processed (data minimisation principle);

- the personal data processed are accurate and, wher;e necessary, updated (principle of accuracy);

- your personal data are stored in such a form that personal identification can be carried out no longer than is necessary for the purposes for which your personal data are processed (principle of storage limitation);

- your personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (principle of integrity and confidentiality).

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Implementation of rights of data subjects

We hereby inform you that you have the following data subject’s rights:

- the right to access your data and methods of processing thereof;

- the right to request the rectification of any inaccuracies in the available data;

- the right to request erasure of your personal data. This right shall be exercised in the cases provided for in Article 17 of the Regulation;

- the right to request that the processing of personal data be restricted or that the processing of personal data be prohibited;

- the right to the portability of data processed by automated means and which we have received from you with your consent or for the purposes of concluding an agreement;

- the right to object to processing, as provided for in Article 21 of the Regulation, in particular where the processing is based on legitimate interest;

- the right to withdraw your consent to the processing of your personal data if you have given such consent;

- the right to lodge a complaint with the State Data Protection Inspectorate (L. Sapiegos g. 17, 10312 Vilnius).

In order to exercise your rights as a data subject, it is necessary to establish your identity. If your identity has not been verified, it will not be possible to ascertain whether the person whose personal data is being processed is the person who is making the request, and therefore, your rights cannot be exercised.

A request from you to exercise your rights may be refused or an appropriate fee may be charged, if the request is manifestly unfounded or excessive, or in other cases provided for by law.

If you wish to exercise your data subject rights or have any other questions regarding the processing of your personal data, you can contact the Company using the contact details provided at the beginning of this Privacy Policy.

We have the right to update this Privacy Policy in light of changes in legislation, as well as changes in the Company’s operations. We recommend that data subjects regularly visit the website www.jpackaging.com to familiarise themselves with the latest version of the Privacy Policy.

9 May 2025

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