This privacy policy ("Policy") establishes the main security measures for visitors, customers, their representatives, beneficiaries of the website of the operator of the crowdfunding platform "Röntgen" UAB "Trečia diena" ("Röntgen" or "we") the personal data processing conditions of the persons and candidates offered to Röntgen ("Your") job positions.

The controller of your personal data is:

UAB „Trečia diena“

Juridinio asmens kodas: 304211859

Gynėjų g. 14-120, Vilnius, Lithuania

When this Policy is updated, the new version is always published on the Röntgen website. If you have any questions related to the protection of your personal data or the provisions of this Policy, you can contact us at any time by e-mail. by mail [email protected].

  1. Processing of personal data for the purpose of providing crowdfunding services
    1. Röntgen, as a provider of crowdfunding services, processes the data of its customers, their representatives and persons securing customer obligations for the purpose of providing relevant services.
    2. When providing crowdfunding services, we are guided by the regulation (EU) 2020/1503 and contracts concluded with clients (or persons securing their obligations).
    3. In order to properly provide crowdfunding services, we also process your personal data for the following purposes related to the provision of crowdfunding services:
      1. for the implementation of money laundering and terrorist financing prevention requirements (as provided for in applicable legislation and our internal policies)
      2. for the collection of debts owed to us or our customers (in accordance with concluded agreements)
      3. for the implementation of other requirements applicable to our activities.
    4. For the above purposes, we process the following personal data of customers (their representatives) and persons securing customer obligations:
      1. contact data (residential address, e-mail address, telephone number, etc.);
      2. data used by the customer to log in to the customer account on the Röntgen website (customer user ID, password, etc.);
      3. data on the client's (financier's) knowledge and experience in the field of investment;
      4. financial data (personal credit rating, financial obligations, income, property data, loans, information about transactions concluded on the Röntgen platform, their volume, etc.);
      5. data on the data subject's relations with legal entities (positions in the represented company, data on the person's participation in the control of legal entities, etc.);
      6. other data that are necessary for the provision of Röntgen services.
    5. Röntgen receives the above-mentioned personal data directly from you (when you provide them) or from other sources (e.g. state databases, such as the systems administered by JV "Registrų centras", etc.). Also, if you choose to connect to the platform through your existing Facebook or Google account, we will receive your main identification data from these platforms (these platforms will inform you separately about the scope of the transmitted identification data). We emphasize that in all cases, the processing of relevant data is carried out in order to ensure the proper provision of crowdfunding services.
    6. Personal data collected for the purpose of providing crowdfunding services are stored for 10 years from the date of execution of the transaction, submission of the relevant application or execution of the operation, except in cases where legal acts determine longer storage periods for such data.
  2. Processing of personal data for statistical purposes
    1. Regulation (EU) 2020/1503 requires Röntgen to publish statistical data on the crowdfunding services provided by Röntgen on its website. Accordingly, for this purpose we process your personal data, such as information about the amount of concluded transactions, the amount of investments, etc.
    2. It should be noted that your data mentioned above is processed in such a way that it is not possible to identify a specific data subject (data is depersonalized).
    3. Atitinkamų asmens duomenų saugojimo terminas priklauso nuo Röntgen atžvilgiu taikomų teisės aktų reikalavimų, reglamentuojančių Röntgen pareigą skelbti statistinius duomenis
  3. Processing of personal data for the purpose of administering your requests
    1. When you contact Röntgen (by e-mail, phone, by submitting requests via social network accounts or in any other way), the personal data you provide will be processed for the purpose of administering the respective requests. Such processing is based on ensuring the quality of the services provided, as well as on the fulfillment of various legal requirements and/or the protection of our legitimate interests.
    2. The basis for processing the specified data is normally Röntgen's legitimate interest. In some cases, the basis for the administration of your requests or complaints may be the fulfillment of legal requirements.
    3. When submitting requests, comply with at least the minimum requirements for the protection of personal information - do not specify redundant personal data that is not necessary for the intended purpose, i.e. i.e. for the placement of a query, complaint, letter or request.
    4. The personal data you provide is usually stored for up to 3 years, unless a different storage period is determined by circumstances such as the need to protect the rights and legitimate interests of Röntgen or other persons, for the investigation of a complaint or the resolution of a dispute. The storage period may also vary depending on the legal requirements, so your personal data may be stored for a longer period of time.
  4. Processing of personal data when applying for the job positions offered by Röntgen
    1. Röntgen processes your personal data (CV, cover letter, etc.) when you submit the relevant information when applying for a job position offered by Röntgen. Accordingly, the basis for such processing of your personal data is your consent, expressed by submitting your personal data.
    2. When sending us your personal data for the purpose of ongoing or future selections, please comply with at least the minimum data protection requirements and do not provide redundant information that is not related to your candidacy.
    3. The retention period of the data you provide depends on the duration of Röntgen's recruitment for a specific job position. After the relevant selection, Röntgen will process your personal data only if you express your separate consent.
  5. The website uses cookies
    1. When you visit our website (, we can process your IP address, as well as other network data, if you provide it. Such data is collected with the help of cookies and/or similar technological solutions on the basis of user consent. Cookies are small files that are sent to the Internet browser you are using and stored on your device (e.g. computer or phone). Cookies are transferred to your computer the first time you visit our website.
    2. For this reason, our website can "remember" your actions, options, and operations for a certain period of time. Thus, the purpose of cookies is to ensure convenient, safe operation of the website, as well as to analyze the habits of website visitors. This allows us to better adapt the website to the needs of its visitors. Some types of cookies (necessary and analytical cookies) are necessary for the proper functioning of the website, so if these cookies are refused, the website may not function properly.
    3. According to their duration, cookies are divided into short-term session cookies (deleted after the visitor ends the browsing session) and long-term cookies (stored for a longer period of time). Cookies can also be classified according to whether they belong to a first party (for example, a website administrator) or another - a third party (for example, organizers of online advertising).
    4. Bendrovės interneto svetainėje naudojami žemiau pateikiami slapukai:
    5. The name of the cookie





      3 months

      Used by Facebook to provide advertising products such as third-party offers


      1 year

      Used by Google Analytics to distinguish users


      1 day

      Used by Google Analytics to distinguish users


      By closing the browser

      Technical cookie


      By closing the browser

      Apsauga nuo csrt atakų


      By closing the browser

      Language option


      By closing the browser

      To get the number of visitors

    6. You can control the use of cookies by changing your web browser settings. Every browser is different, so if you don't know how to change your cookie settings, we recommend that you familiarize yourself with its user manuals and instructions.
    7. If you do not want cookies to collect information, refuse the use of cookies in the browser settings. However, some types of cookies (for example, essential cookies) are necessary for the proper functioning of the website, so if these cookies are refused, the website may lose functionality. More useful information about cookies, how to control and delete them, can be found on the website
  6. Your rights as a data subject
    1. As a data subject, you have the following rights in relation to your personal data:
      1. get familiar with your personal data and how it is handled;
      2. require the correction of incorrect, inaccurate or incomplete data;
      3. request deletion of your personal data;
      4. request to limit the processing of your personal data;
      5. demand to transfer your personal data to another data controller or submit it directly in a form convenient for you;
      6. disagree with the processing of your personal data, if they are processed on the basis of legitimate interest;
      7. revoke the given consent to the processing of your personal data.
    2. To exercise your rights as a data subject, contact us in writing (e-mail [email protected]): specify a specific right, detail the scope of its implementation, and also provide your contact details (e.g. name, surname, e-mail e-mail address - with which you registered on our platform, phone number). If we lack information in order to properly analyze your request, we will contact you immediately. Please note that we implement your rights as a data subject in accordance with the General Data Protection Regulation and other legal acts regulating the protection of personal data and the guidelines of competent authorities.
    3. If you believe that Röntgen is processing your personal data illegally or in violation of your rights related to the processing of personal data, you have the right to contact the State Data Protection Inspectorate. However, before contacting the State Data Protection Inspectorate, we encourage you to contact us immediately (by email [email protected]). In this way, we will be able to find together the most operative and optimal solution to the problem for both parties.
  7. Asmens duomenų gavėjai
    1. In the course of its activities, Röntgen may use certain data processors (service providers, for example, companies providing data storage services, companies developing and maintaining software, companies providing debt administration services, companies providing communication services, etc.), to whom your personal data may be transferred. data.
    2. Your personal data is transferred to the respective service providers only when and to the extent necessary for the provision of their respective services.
    3. Röntgen may also provide your personal data to the following data recipients:
      1. to state institutions and registries (Bank of Lithuania, Department of Statistics, notaries, courts, bailiffs, law enforcement institutions, lawyers, etc.);
      2. for persons administering joint data files of debtors (e.g. UAB "Creditinfo Lietuva");
      3. payment and other service providers and financial institutions whose services are used by Röntgen in the course of its activities;
      4. to other companies when it is necessary for financial accounting, auditing, risk assessment or service provision;
      5. to other third parties related to the provision of our services and/or who have a legal basis to receive this data;
    4. In all cases, reasonable efforts are made to ensure that personal data is not lost or used illegally while implementing the requirements of legal acts.
    5. Please note that for the performance of Röntgen's activities, it is not necessary to transfer your personal data to recipients located outside the European Union (EU) / European Economic Area (EEA). However, if in exceptional cases part of your data needs to be transferred to a data recipient located outside the EU/EEA, Röntgen will implement the requirements specified in the General Data Protection Regulation and will take reasonable measures to ensure the security of this transferred data.