Unitrust Finance, Inc (RT Tax) (hereafter – RT Tax, we, our and so on), operating as the representative of the RT Tax trademark, in processing of Personal Data seeks to protect the privacy of all persons. We process Personal Data in accordance with the EU General Data Protection Regulation (hereafter, GDPR) and applicable national legislation and regulations (including USA). We confirm that RT Tax respects your privacy and undertakes to protect your rights to the lawful processing and protection of your Personal Data.
Data Controller – the controller of your Personal Data is Unitrust Finance, Inc (company code 70464217, registered address – 1219 Ogden Ave, Suite #C, Downers Grove, IL 60515, USA, the address at which operations are performed is 1219 Ogden Ave, Suite #C, Downers Grove, IL 60515, USA, email email@example.com, tel.: +1-312-889-0315), to which you provided your Personal Data regarding contractual or pre-contractual relations, or the Services of which you intend to use.
Representative of the Data Controller – UAB „Rinkos tinklas“ (company code 135927776, registered address Nemuno st. 13, Kaunas, Lithuania, the address at which operations are performed Ožeškienės g. 15, Kaunas, Lithuania, e-mail: firstname.lastname@example.org, tel.: +370 37 755211, +370 679 68858), which acts on behalf of the Data Controller.
Client (you) – the natural person who uses our Services, used the Services or has expressed the intention to use the Services.
GDPR – 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).
Data Processing – any operation performed with Personal Data (including collection, recording, storage, alteration, dissemination or other making available, querying, transmission and so on).
Services – any services offered or provided by RT Tax, including, but not limited to intermediation for the Client to refund taxes from foreign tax authorities (the list of countries from which you may refund taxes is available at the following web sites: www.rttax.com, www.mokesciugrazinimas.lt, www.nodokluatgriesana.lv, www.odzyskajpodatek.pl, www.recuperareataxelor.ro, www.vrashtanenadanaci.bg
Direct Marketing – activity performed by means of electronic mail, telephone or other direct way to offer persons services and (or) ask their opinion regarding offered services.
Web Sites – www.rttax.com, www.mokesciugrazinimas.lt, www.nodokluatgriesana.lv, www.odzyskajpodatek.pl, www.recuperareataxelor.ro, www.vrashtanenadanaci.bg
Why do we collect your Personal Data?
We collect and use your Personal Data so that (i) we can provide you the Services (concluding, carrying out the agreement), (ii) is necessary communication (provide you with notices, offers and information); (iii) to protect our and third-party rights and interests, (iv) we could carry out statistical analysis, according to the applicable legislation and other regulations. Legal basis for processing Personal Data is respectively, (i) necessity to perform agreement and mandatory statutory requirements related to tax refund; (ii) legitimate interest – to provide good customer service; (iii) legitimate interest – to protect our and third-party rights and interests and (iv) legitimate interest – to improve our business.
If you do not provide us your Personal Data, we will not be able to provide you our Services.
It should be noted that in order to receive tax refunds, i.e. to receive our Services, you do not have to agree to receive direct marketing notices.
Having your consent, we process your Personal Data for purposes of direct marketing. You may revoke your consent regarding direct marketing at any time.
How do we collect your Personal Data?
We receive most of the data from you directly, but we may also receive some data from other sources.
We may use the services of the third parties (partners / processors) to collect your information. In this case, you shall not submit your Personal Data directly to us, but to our partner who shall process the Personal Data to our best interests and in accordance with our instructions, strictly securing the confidentiality and integrity of Personal Data and shall take proper physical, organizational, administrative and technical measures to protect the Personal Data.
It should be explained that RT Tax usually receives Personal Data directly from persons with whom the data is associated, i.e. we receive your Personal Data:
- when you provide this data to us directly, e.g.: you make a request to us or our partners; you communicate with us (in person, by telephone or by email), you communicate with our partners, you complete a registration form, you leave us your contact information; you register, visit our web site and by other means;
- when you use our Services or web sites;
- when you report a problem or communicate with us regarding the quality of the Services,
- when you participate in discussion forums, social media pages, a web pages and so on.
In particular cases, we may receive your Personal Data not from you, but for example, from our business partners to whom you have provided your data, seeking to receive our Services; or from foreign state institutions administering tax refunds or other institutions, in cases when you did not provide (could not provide) all necessary documents for tax refund or from other sources when such duty is specified by legislation and regulations.
We can also receive your Personal Data when we sign various agreements to which you are not necessarily a party or a representative of a party (e.g., an agreement concluded in accordance with a power of attorney, an agreement with a legal entity in which contact persons or the data of representatives is specified, and so on).
What kind of Personal Data do we process?
Our main activity is associated with intermediation for Clients to refund taxes. We process your Personal Data so that we can provide and improve these Services. Correspondingly, the precise extent of the Personal Data we process depends on the Services you have ordered or on our relations with you as well as the requirements of the applicable legislation and regulations in the area of tax refunds of the country in which you want to refund taxes.
We also process the Personal Data of representatives of our own clients and service providers who are companies and natural persons.
We usually collect and process the following Personal Data:
- data to determine identity, such as first and middle names, surname, personal code, date and place of birth, taxpayer code (personal identification number, for example PPS, CPR, BSN, UTR or other), citizenship, data of a personal identity document (and copy), photograph;
- contact data, such as residential (and/or declared) address or address for correspondence (in Lithuania and foreign country from which you want to refund taxes), telephone number, email address, IP address;
- professional (work) data, such as data about an employer (former employer), work nature and place , work experience, salary, payments received, payments made, paid taxes, received allowances, incurred costs related to work, social insurance number (code), taxpayer number (code), data about business certificates or individual activity certificates as well as other data which are required to be provided to the tax authority in the state from which you want to refund taxes;
- data about family, such as marital status, information on spouse and minor children (dependants) (for example in some cases it might be necessary to submit the marriage certificate, child’s birth certificate or other documents which confirms the provided information;
- financial information, such as bank account numbers, banking details;
- other, such as dates of arrival and departure to the country, from which you want to refund taxes, information on visa and names, surnames of parents (when you want to refund taxes from USA) and other.
We do not process sensitive data (of special categories) associated with your health or political opinions except cases when such data is required by law or in special cases, when, for example, you disclose such data when using the Services (e.g., informing about payments received as compensation for illness).
We collect data about children and spouses only to the extent and only in the case when such collection is required by legal regulations and is necessary for the purpose of seeking to refund taxes to you (applying tax benefits/privileges and so on).
In addition, we clarify that the amount and volume of Personal Data processed and the documents you must submit to us are always subject to the requirements of the law of the country from which you seek a tax refund. The main documents that you must submit in order to receive our Services are listed on our Websites, arranged by each country.
In order to provide you with the Services, we may require you to submit filled in forms, notices, certificates issued by government authorities and / or your employer and other documents which are required for the tax refund under the law of the country concerned. If you are unable to submit them, we may obtain the necessary data and documents from authorized persons under your request and / or with your authorization.
In cooperation with you and having your request, we are always ready to explain to you why we require information in each case.
With whom do we share your Personal Data?
Because of the nature of the Services provided, we must share your Personal Data when performing everyday operations, seeking to refund taxes to you, because tax refunds are performed not by us, but by tax authorities in various states (in those from which you sought our services in order to refund taxes).
We may disclose your Personal Data:
- to our partners who assist us in providing the Services to You (collects documents, sends information, fills in declarations, etc.) and other Processors involved in providing you the high quality Services (eg. maintenance and development of websites);
- to foreign tax authorities administering tax refunds;
- to state institutions and other subjects which perform functions assigned to them by law;
- to authorised auditors, and to legal and financial consultants;
- when such disclosure is required by law, in compliance with laws and legal processes when we believe in good faith that disclosure of such information is necessary to protect your or our rights or to ensure the safety of other persons, or to respond to the requests of state institutions or officials.
In cases when you provide your Personal Data to our partners in your country of origin, country of residence or any other suitable location instead of directly providing them to us (Data Controller), and with regards to the fact that we are located in USA, your Personal Data shall be transferred to USA. For clarity, it should be explained that as we are located in USA, the data transfer of your Personal Data is necessary for the conclusion and performance of the agreement concluded between us for the provision of our Services.
We hereby state that we make use of partners, processors of Personal Data, only when we are certain that such partners guarantee the proper organisational, legal, technical and physical measures to ensure the security and lawful processing of your Personal Data. Such processing shall comply with the legal requirements of the GDPR and applicable law and shall ensure the protection of your rights.
Who can access your Personal Data?
Your Personal Data can be accessed only by persons having such a right inside RT tax or third parties contracted by us, or other persons (partners, processors) when such access is required or allowed by legislation and regulations.
When disclosing your Personal Data, we undertake to ensure that the recipient of the data follows the same Personal Data protection and processing measures as we do and the security, confidentiality and integrity of Personal Data shall be secured.
Processing activity performed by third parties is always governed by a written Contract or other specific conditions, regarding which we agree with such third-party processors.
It should be explained, that the data about you which we collect may be processed (including storage) beyond the borders of your country, the European Union and the European Economic Area, for example, the USA, New Zealand, Canada (depending on the country from which you are seeking to refund taxes). We may transfer your Personal Data based on an adequacy decision by the European Commission; standard data protection clauses elaborated by the European Commission; using other possible safeguards and derogations where it is allowed by the applicable laws, without prejudice to your legitimate interests.
For clarity, it shall be explained that the company (our partner) to whom you provided your documents, in order to receive our Services, shall be deemed to be our Processor. We may also transfer your Personal data to our data processors, such as TT Express UAB, which provides us with money transfer services, as well as Unidata, UAB, which provides us with back office services; also to UAB “Rinkos tinklas”, which provides call center services to us. In some cases, we may also disclose your Personal data to processors which provide archiving, IT maintenance and alike services.
What kind of rights regarding your Personal Data do you have?
We seek to ensure that the activity of Personal Data processing is honest and transparent, and also that all personal rights provided for in applicable legislation and regulations are constantly protected. We ensure that your Personal Data shall be accurate, adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
You have the following rights and you can use them at any time:
- the right of access to your own Personal Data. At your request, we will confirm if Personal Data associated with you is being processed or not, and we will provide information about the purposes of such processing, the categories and recipients of the processed Personal Data to whom the Personal Data is disclosed, or the categories of such recipients; we will provide notice to you what kind of Personal Data is being processed, and all information in our possession about the source of such Personal Data;
- the right to demand that we rectify inaccurate or incomplete Personal Data;
- the right to receive your Personal Data in a systematic, commonly-used and computer-readable format and the right, under certain conditions, to transfer such Personal Data to another controller (the right to data transferability);
- under certain circumstances the right to demand the deletion of Personal Data or to limit the processing of such Personal Data (e.g.: when such Personal Data is no longer necessary to achieve the purposes for which such Personal Data was collected and processed, you have revoked your consent and there is no other lawful basis for the processing of such Personal Data; the Personal Data is being processed unlawfully and so on);
- the right to object to the processing of Personal Data for certain purposes and under certain conditions;
- the absolute right to object that your Personal Data is processed for the purpose of direct marketing;
- if processing of Personal Data is based on your consent, you have the right at any time to revoke your consent in the same way in which you provided such consent (including in person, through partners, electronic mail, in your profile and by other means). Revocation of your consent will have no effect on the lawful processing of your Personal Data which was performed prior to such revocation.
- the right to present a complaint to the Supervisory authority.
Depending on special circumstances, there may be certain conditions or limitations on the implementation of your rights. We may be bound by laws or other regulations, on the basis of which we may not be able to immediately delete your Personal Data.
We implement your rights in the area of Personal Data protection free-of-charge (except such cases when requests are obviously unfounded or disproportional, first of all regarding the repetitive content of such requests).
How is your Personal Data stored?
We store your Personal Data in accordance with the GDPR and national legislation and regulations (including USA). In accordance with a general principle, your Personal Data is processed (including, stored) in such form that your identity would be identifiable not longer than necessary in order to achieve the purposes for which such Personal Data is processed.
Seeking to protect your Personal Data from unlawful access, unlawful processing or disclosure, unintentional loss, alteration or erasure, we apply measures necessary to comply with the requirements of applicable legislation and regulations. Such measures include technical measures, for example, selection of proper computer systems, computer security, data and file protection, also organisational measures, limitation of access to Personal Data, ensuring confidentiality and other measures.
For how long is your Personal Data stored?
The period for storage of Personal Data is specified by legislation and regulations or by us in accordance with legislation and regulations.
In some cases the specific period of the duty to store certain documents in which there are Personal Data is specified by legislation and regulations, for example, the period of storage of tax related documents is specified by the tax law in the state from which you are seeking to refund (or have refunded) taxes.
If the period of storage of Personal Data is not specified by legislation or regulations, the Personal Data shall be stored during the term of the agreement and 10 years after the after provision of services (after fulfilment of the agreement) or termination of business relations with you (termination of the agreement), taking into consideration the general statute of limitations. We shall store your consent to direct marketing for 5 years.
What kind of direct marketing activity do we perform?
We (directly or using our partners) may provide information about our Services to existing Clients, based on lawful interest.
Our information and direct marketing notices (for example, notices about the Services we provide) are sent to Clients, to whom Services are (were) provided, also who have expressed consent to receive direct marketing and/or offers.
We may send information to you about Services provided, new developments in the area of tax refunds, reminders to submit declarations or to submit requests for tax refunds.
In certain cases, you might be provided with information about changes in the contracts between us and/or changes in the area of tax refunds or data processing, or with information (or a reminder) regarding additional documents/data that are necessary for performance of Services, as well as systemic and other notices associated with the Services provided. Such informative notices are necessary when performing the contract made with you and (or) its annexes, providing you the services which you ordered, and such notices and information is not considered to be direct marketing notices.
The legal basis for the processing of your Persona data for direct marketing is your consent or our legal interest to offer Services.
It should be noted, that in order to receive tax refunds, i.e. to receive our Services, you do not have to agree to receive direct marketing notices.
How can you express consent to receive informational and/or direct marketing notices?
You may give consent to receive informational and/or direct marketing notices, expressing consent regarding direct marketing on the web site marking the appropriate box, confirming in the registration form your selection and by other means, from which it is clear that your wish to receive the offered information, or by requesting us to send informational notices in accordance with contracts made with us or in other ways.
Clients who already receive our informational notices will continue to receive such notices after GDPR comes into force.
Can you disapprove the use of your Personal Data for purposes of direct marketing?
You have the right at any time free-of-charge to disapprove the use of your Personal Data for purposes of direct marketing.
You have the right at any time free-of-charge to revoke your consent. If you wish to use this right, you must contact us by any convenient means, including but not limited to: in person, through our partners (to whom you applied in order to receive Services from us), by email, through your account (if you have such), in our Facebook page and by other means, from which we can understand that you no longer wish to receive our notices.
How can you communicate with us?
We invite you to contact us with questions, requests or comments regarding the processing of your Personal Data by email email@example.com.
In addition, you may contact us with questions by telephone, our web site (online help), blog, Facebook and other ways convenient to you.
You can also contact our Representative in the European Union on all matters (described below).
Our representative in European Union.
Since we are located in the USA and your place of origin or place of residence is in the European Union in order to facilitate your use of your rights, respond to your concerns and ensure compliance with the GDPR, we have appointed a representative in the European Union (ie Lithuania), which is UAB „Rinkos tinklas“ (company code 135927776, registered address Nemuno g. 13, Kaunas, Lithuania, the address at which operations are performed Ožeškienės g. 15, Kaunas, Lithuania, e-mail: firstname.lastname@example.org, email@example.com, tel.: +370 37 755211, +370 679 68858), which acts on our as data Controller behalf.
It should be explained that the Representative acts on our behalf and its appointment shall not prejudice our liability under GDPR.