by VšĮ Tomaga, legal entity code 301733229, registered at A. Goštauto g. 4-1, Vilnius, Republic of Lithuania
(hereinafter – the Company) in the processing of personal data for use on the 4 Million platform (hereinafter – the
During your use of the Platform (hereinafter you may be referred to as the User), the Company shall:
Protection of Personal Data of the Republic of Lithuania, and other legislation;
- Process your personal data accurately and honestly, to the extent necessary for the functioning of the Platform
and the protection of your rights and legitimate interests.
The Platform may only be used by registered users. Prior to registering, you must familiarize yourself with this
consent to them, you should not register with the Platform or, if you have already registered, you should cancel
If you register with the Platform, we will assume that:
- You agree to provide your personal data to the Company and do not object to our processing of such data for the
for the processing of specific data)
COLLECTION, PROCESSING AND USE OF PERSONAL DATA
- The Company shall have the right to organize and process the personal data (hereinafter – Personal Data)
provided by the User while using the Platform or obtained by the Company by other means. The Company shall
collect and store Personal Data by electronic means and, as necessary, shall provide extracts of such Personal
Data in other formats.
The Company shall collect and manage the Personal Data provided by you:
- To ensure proper delivery of services to you;
- For your registration and identification;
- For Platform data base administration purposes;
- To send newsletters and promotional games, quizzes, contests, etc.;
- For Platform operation and statistical purposes.
- You may be requested to provide your first name, surname and email address. After registering with the
Platform, you may also choose to provide your telephone number, photograph and place of residence. The Company
will receive your Personal Data directly from you. When registering, you must provide accurate registration
- If you register using your Gmail or Facebook account, your Gmail or Facebook account information may be
displayed on the Platform.
- The Company may use data not directly associated with the User for statistical purposes or data about the
Platform and its operation (for example, total visits to the Platform, total number of registered users, popular
activity, etc.). Such statistical data shall be collected and processed in such a way as to prevent the
disclosure of a User’s identity or other personal data that might allow determination of a User’s identity.
- Data may only be transferred to third parties in accordance with procedures established by law and after
obtaining the necessary consent, if required, from the User.
- By providing personal data you:
- Grant the Company the right to manage and process your Personal Data as provided for in this Privacy
You may withdraw your consent at any time and you may also cancel your registration on the Platform at
- You affirm that you have voluntarily provided your Personal Data and that you consent to the Company
and processing your data by electronic means on the Platform data base for 5 (five) years from your last
on the Platform;
- You have provided the Personal Data of third persons (e.g. relatives, etc.) with the consent of those
persons and you affirm that you are personally responsible for any data for such third persons;
- You consent that Platform users may view the Personal Contact Data provided by you and that such data
reviewed, copied and used to contact the User in accordance with procedures established on the Platform.
In managing User Personal Data, the Company:
- Shall use Personal Data to provide Platform services, develop the Platform and its functionality,
personalization, as well as submit suggestions to improve the Platform and present direct marketing
- Shall not disclose Personal Data or provide them to third parties, except when provided for by this
Policy or by law;
- May provide Personal Data to persons administering User debts (if the User uses payment services and
properly settle them) as well as to third parties engaging in the collection and publication of debtor
information and who then obtain the right to manage and administer such Personal Data and publicize
- When a User registers with and logs into the Platform, the system shall record the User’s computer IP address
and the date and time of login.
RULES FOR TRANSMITTING NOTIFICATIONS
- Company news notifications are meant to inform you about Platform news (improvements, ongoing events,
promotions, etc.) and about promotional events announced by the Company, its ongoing events, news and updated
- Notifications will be sent to you only after obtaining your consent or your non-objection during data
collection to the transmission of such information. You shall have the right to change the terms of notification
transmission at any time or cancel it entirely. In such an event, the Company shall no longer process your data
for this purpose.
- By subscribing to notifications, you permit the Company to process the personal data provided by you for the
purposes of direct marketing and the transmission of direct marketing offers of its partners. The Company
undertakes not to transfer to third parties the personal data you provided when subscribing to notifications,
except for the provision of information required for sending notifications to the company administering the
transmission of Company news.
- The following personal User data may be administered for the purposes of sending notifications and direct
marketing: name, email address, social media profile contact information. When organizing games and promotional
events, the Company may process data confirming the fulfilment of terms required to participate in such a game
or promotional event, to the extent it is related to participation in that promotional event or the right to
participate in the game.
- By granting the right to administer data for the purposes of news distribution, you grant permission to
provide you with information and promotional material from the Company to the email address or social media
account contacts (such as via a social media messaging network) provided by you.
- Upon receipt of your Personal Contact Data, the Company may use such data without your express permission for
the purpose of distributing its own news and for marketing conducted by the Company if you did not object to the
provision of such information at the time of data submission. You may refuse Company news and offers at any
- You shall have the right not to consent to the distribution of Company news and/or direct marketing offers
and refuse news distribution and/or direct marketing offers: by clicking the appropriate link on a notification
or email notice and informing the Company about your objection by email to [email protected], or by
calling the telephone number listed in the Company contact information. The Company shall endeavour to
discontinue the use of User data for the purposes of direct marketing as quickly as possible, but no later than
within 5 (five) business days.
- If you provide personal data using a social network or other internet service (Facebook, etc.), you consent
that Company offers may be sent to you at the email address provided on such social media. You may refuse such
- User data processed for the purposes of notification distribution and direct marketing shall be stored on the
Platform data base for no longer than 5 (five) years from the User’s last account login. Personal data shall be
administered for the purposes of promotional events (direct marketing games, quizzes, contests) for no longer
than 1 (one) year after the publication of the event results or winners.
CHANGING AND UPDATING PERSONAL DATA, REVIEWING PROCESSED DATA
- You shall have the right to change and/or update the information provided on the registration form, or delete
your registration, at any time. In this case, the User account will be deleted and registration data erased.
- Upon providing a document confirming your identity to the Company, or confirming your identity by a means
approved by law or by electronic communications that permit proper personal identification, you shall have the
right to review your personal data being processed by the Company and learn how they are being processed,
request a correction, delate your personal data or terminate the processing of your personal data when data are
being processed in violation of legal provisions, and to object to the processing of your personal data.
- You shall have the right to object to the processing of your personal data and to refuse to provide your
personal data. We note, however, that Personal Data may be necessary and required to definitively identity you
for the purposes of using the Platform and that, by failing to provide personal data and/or refusing to permit
- All requests to the Company related to your Personal Data must be submitted in writing (including any
notification to the general email or client services division email address listed in the Platform contacts).
The Company shall endeavour to respond to such requests as quickly as possible, but no later than within 30
(thirty) days from the receipt of the request and all necessary documents. Responses will be provided in a
manner acceptable to you. Responses will be provided to you free of charge 1 (one) time per calendar year. The
Company shall not provide personal data if you fail to confirm your own identity or if you request data about
another person, as well as in instances provided by law that limit the disclosure of data to the User.
COOKIES AND THEIR USE
- Small data files called cookies may be saved on your computer or mobile device to ensure proper functioning
of the Platform. This is also done by most large internet websites.
- A cookie is a small data file that the Platform saves on your computer or mobile device when you visit the
Platform. In this way, the Platform may “remember” your actions and choices (ex. your registration name,
language, your browser font size, and other display options) for a given period.
- Cookies allow an internet website to function more effectively and improve its services and, in addition,
that it may provide and ensure the high quality and effectiveness of Platform services, monitor User visit
habits, and keep track of statistics such as the number of visitors, visit flows, etc. (statistics not be
associated with a User’s personal information). Cookie information may consist of data about how a User uses the
Platform, his/her IP address, browser type, demographic data and whether the User arrived at the Platform via a
third-party website – via a URL link. If the User is a registered user, this may also include data about the
User’s user name and email address that may be processed when registering on the server. Without violating legal
provisions, the Company may combine information received using cookies with information obtained about a person
by other means, e.g. information about use of services.
- You may also receive cookies from the promotional display system used on the Platform.
- The Platform may use different types of cookies or similar technologies, each of which has a specific
function such as: (i) technical cookies that are required for the platform to function, (ii) functional cookies
that permit the retention of User options, (iii) analytical cookies for the monitoring of Platform statistical
information, (iv) targeted promotional cookies for the display of targeted promotional content, (v) third-party
cookies for the display of third-party content, (vi) social media cookies that permit the use of Platform
content via a social media account.
or altering the cookies saved on your browser, as well as by clicking the “I agree” tag provided on the Platform
information bar. User consent for cookie use shall be valid for 1 (one) year.
altering your browser data (by deleting cookies, opting for private browsing, etc.), as well as during
registration. To remove cookies from a mobile telephone or other mobile device you will need to follow user
instructions provided for the telephone or telephone application. Please note, however, that, in some instances,
the disabling of cookies, or rejecting or deleting cookies may slow internet browsing speed, limit the operation
of certain internet website functions, or block access to the Platform.
the website AllAboutCookies.org or at www.google.com/privacy_ads.html.
- The Platform uses the following cookies:
Data processing purpose
At each query
Saugoti pasirinktos lokalės kodą
Saving the selected location code
If third-party cookies are used by the Platform, such parties may collect both anonymous and personal
information about you for promotional purposes, and they may also use session cookies as well as permanent
therefore you are responsible for independently learning about the cookies and information used and collected by
third parties. You can remove third-party cookies according to instructions provided by the third parties.
INFORMATION SECURITY MEASURES
- In the processing and storage of your personal data, the Company shall take all measures to protect personal
data from accidental or illegal destruction, alteration, and disclosure, as well as from any type of illegal
processing. However, you must also concern yourself about the security and/or secrecy of your own data,
particularly when this concerns disclosure to third parties. Parents or guardians of minors shall be held
responsible for the secrecy and security of activities and/or data of such minors.
- To process your Personal Data, the Company shall implement the necessary organizational and technical
measures to ensure security and that may assist in protecting your Personal Data from accidental or illegal
destruction, alteration, and disclosure, as well as from any type of illegal processing. The Company’s security
assurance activities shall include, inter alia, the security of personnel, information, IT infrastructure,
internal and public networks, as well as office buildings and technical equipment.
- The Company employs software and other measures to protect the registration data of all Users. User
registration data may only be accessed by authorized persons.
- The Company shall only protect Personal Data to the extent required for the execution of objectives contained
(five) years from the date of last account login or upon deletion of an account by the User. The Company shall
not seek to store old or irrelevant User Personal Data, therefore upon any update of such data (for example,
when a User modifies or changes information on his/her account, etc.) only the current User information shall be
- Correspondence with Users shall be stored for no more than 1 (one) year from the date of correspondence. Data
for the purposes of directed marketing shall be stored for no more than 5 (five) years from the last User login,
unless a longer storage period is established or permitted by law.
SENDING INFORMATION OR CLAIMS
submitted in writing to:
Postal address: A. Goštauto g. 4-1, Vilnius, Lithuania
Email: [email protected]
- Queries, claims and other information must be presented in a manner that permits the Company to identify the
User to the extent required to prepare a response and transmit that response to the User.
the date of inclusion on the Platform.
User shall lose the right to use the Platform.