Cookie Policy

This Cookie Policy constitutes an explanation of the personal data processing with Cookies of a capable natural person (“User”, “you”, “your”), who uses our Website according to the Terms of Use.

Supplemental terms and conditions or documents that may be posted on the Website are hereby expressly incorporated herein by reference. We reserve the right to change this Cookie Policy occasionally, without prior notice and your consent.

Other terms used in this Cookie Policy, but not defined, have similar meanings to those in the Privacy Notice and Terms of Use.


I. Terminology

Cookies. Refers to small text files that are placed on your computer by the Website that you visit. Websites use cookies to help users navigate efficiently and perform certain functions. Cookies that are required for the website to operate properly are allowed to be set without your permission. All other cookies need to be approved before they can be set in the browser.


Cookies have the following types:

  • Strictly Necessary. Strictly necessary cookies allow core website functionality such as user login and account management. The website cannot be used properly without strictly necessary cookies;
  • Performance. Performance cookies are used to see how visitors use the website, e.g. analytics cookies. Those cookies cannot be used to directly  identify a certain visitor;
  • Targeting. Targeting cookies are used to identify visitors between different websites, e.g. content partners, and banner networks. Those cookies may  be used by companies to build a profile of visitor interests or show relevant  ads on other websites;
  • Functionality. Functionality cookies are used to remember visitor  information on the website, e.g. language, time zone, enhanced content;
  • Unclassified. Unclassified cookies are cookies that do not belong to any other category or are in the process of categorization.
  • Cookie Banner. A special message (banner) is used to grant permission to use cookies and block them at the request of the User. Allows you to consent and set cookies.


II. Data Subjects' Rights

Right to access personal data. You can receive information regarding specific personal data that has been collected about you, as follows:

  • Purpose of the processing;
  • Categories of personal data concerned;
  • Recipients of categories of recipients to whom the personal data has been, or will be, disclosed;
  • The envisaged period for which the personal data will be stored or the criteria used to determine that period;
  • The existence of the right to rectification, erasure, or restriction of processing personal data concerning you or to object to such processing;
  • The right to complain to a supervisory authority;
  • Where personal data is not collected from you, any available information as to the source;
  • The existence of any automated decision-making, including profiling as well as the significance and envisaged consequences of such processing for you;
  • Where personal data is transferred outside of the EEA (which consists of EU member states and Iceland, Lichtenstein, and Norway), you have the right to be informed of the appropriate safeguards in place and to request a copy of them.

Right to rectification of personal data. You can correct your personal data if it has been changed or incorrectly collected.

Right to erasure (deletion) of personal data. You can ask us to delete personal data.

Right to restrict processing of your personal data. You can temporarily restrict the processing of personal data.

Right to personal data portability. You may receive personal data in a human and machine-readable format for transmission to another controller.

Right to object. You may object to data processing if the Company:

  • Process personal data for direct marketing purposes, including profiling related to direct marketing.
  • Process personal data that we consider necessary for its or a third party’s legitimate interest.

Right to reject automated individual decision-making (profiling). You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects.

Right to withdraw consent. You can withdraw your consent on personal data processing if the Company uses this ground for processing.

Right to opt-out from Marketing/Send Out. You can withdraw your consent on personal data processing for marketing and send-out purposes.

Right to ask a question and/or claim data processing. You are allowed to ask us any question according to data processing or privacy legislation.


III. Personal Data. The Company may process and store worldwide personal data with Cookies including, but not limited the following:



Date and time of the request; ∙ IP address (masked);

Files that were clicked and downloaded;


Location:  country, region, city, approximate latitude and longitude (Geolocation);

Links to an outside domain that were clicked;


Browser version, browser plugins, operating system version, device identifier   (User-Agent header);

Pages generation time;

Language of the visited page; ∙ Campaigns;


Title of the page being viewed;

Site Search;


Screen   resolution of user's device;



URL   of the page that was viewed prior to the current page;

URL of the page being viewed.


IV. Cookies

List of Cookies. Precise lists, categories, and providers of used Cookies are designated on the Cookie Banner. We may make changes from time to time without your consent to the list of Cookies.

Consent on Cookies. You consent to the use of Cookies by clicking the appropriate  button at the first appearance of the Cookie Banner. At the same time, the User can  choose which Cookies will be used and later change the settings.

Withdrawal of consent. The User may not consent to the use of Cookies by clicking on the appropriate button at the first appearance of the Cookie Banner or later withdraw such consent. Only Strictly Necessary Cookies will be collected and processed in this way.


V. Other Tracking Technologies

Web beacons. A small tag is placed on the Website to track how the User interacts with the content.

Tracking Pixels: A 1×1 pixel graphic used to track User behavior, site conversions,  web traffic, and other metrics similar to a cookie. They’re usually hidden and embedded in everything from banner ads to emails. 

Tracking Tags. Also known as UTM codes is a piece of code added to a website  URL to provide better analytics about web traffic and user behavior.


VI. Personal Data Protection. The Company protects your personal data in several organizational and technical ways:

  • We do not have direct access to most of your personal data collected through  cookies;
  • We do not combine personal data to which we have access with personal data from other sources, which may affect your ease of identification of you.
  • Training employees in cyber security and data privacy;
  • Strong password requirements.


VII. Disabling of Cookies

Disabling in general. To delete cookies from your computer and phone, you need to change your browser settings.

Settings in our cookie banner. You can opt out of our cookie banner by clicking on the “Delete all cookies” button.

Disabling in browsers. Below are links to instructions for deleting cookies in the  most used browsers:

  • Safari;
  • Google Chrome;
  • Opera;
  • Firefox;
  • Microsoft Edge;
  • Vivaldi;
  • Brave.


VIII. Personal Data Breach Notification

Notifying the Data Protection Authority. In the event of a data breach, in most cases, our co-controllers shall notify the Data Protection Authority, accompanying it with materials about the issue.

Notifying. However, in cases where the data breach seriously threatens your rights and interests, our processor and/or co-controllers shall inform you about it. In addition, our processor and/or co-controllers shall document information about each fact of the outflow of personal data in our internal register.


IX. Miscellaneous

Effective date. This version of the Cookie Policy is valid from the Effective date.

Governing Law. This Cookie Policy shall be governed by and construed under the laws of the Republic of Lithuania, without giving effect to any principles of conflict of laws.

Disputes. All disputes or claims about this Cookie Policy are resolved within 30 business days of negotiation, if negotiation doesn’t work the court of the Republic of Lithuania under Lithuanian law must resolve it. The defeated party should pay all reasonable court and attorneys’ fees and costs.

Changes. We may make changes from time to time without your consent. The new version will be valid from the time of the changes noted at the beginning of this Cookie Policy.

Languages. This Cookie Policy is available in English. If there are any differences between the English and any other translated versions, the English version shall prevail.  


X. Contact Information

Direct Contact. You can contact us electronically via email at [email protected].  We will give you an answer as soon as possible, but no more than 30 calendar days.

Contact DPA. The User can ask DPA any question about his personal data or make a complaint through the following link: The timing and procedure for responding depend on the internal policies of DPA.

Contact Processors and Co-controllers. The User can make inquiries or complaints to our Processors and Co-controllers via any available means of contact on their websites. The timing and procedure for responding depend on the internal policies of our Processors and Co-controllers.


X. Legal information


Company   Name:       Sapion Solution UAB

Company   Number:   306182986

Legal   Address:           Eišiškių Sodų 18-oji g. 11,   LT-02194 Vilnius, Lithuania

Email:                            [email protected]