Privacy Notice

PRIVACY POLICY

Last updated: 26 August 2026

1. GENERAL PROVISIONS

EUROCASH1, UAB (legal entity code 225329030, registered office address: Ukmergės g. 219-1, LT-07152 Vilnius, Lithuania), which operates the website www.saugyklos.lt and provides services under the VAULTS1 brand (hereinafter referred to as “We”, the “Company” or the “Data Controller”), respects the privacy of its customers and website visitors and is committed to properly protecting their personal data.

This Privacy Policy explains what personal data we collect, for what purposes and on what legal grounds we use it, how long we retain it, to whom we may disclose it, and what rights you have.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the “GDPR”), the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania and other applicable legislation.

This Privacy Policy applies when you:

• visit www.saugyklos.lt;
• submit an enquiry or order an individual safe deposit box rental service;
• contact us by telephone, email or other means of communication;
• create or use a customer account;
• order additional services;
• use our vault facilities;
• consent to receive marketing communications;
• interact with our advertising on Google, Facebook, Instagram or other platforms.

2. CONTACT DETAILS OF THE DATA CONTROLLER

Data Controller: EUROCASH1, UAB
Legal entity code: 225329030
Address: Ukmergės g. 219-1, LT-07152 Vilnius, Lithuania
Email: info@saugyklos.lt
Telephone: +370 696 84 425
Website: www.saugyklos.lt

For any questions relating to the processing of personal data or the exercise of your rights, you may contact us using the email address provided above.

3. PERSONAL DATA WE PROCESS

Depending on how you use our website and services, we may process the following personal data.

3.1. Enquiry and Communication Data

When you contact us by telephone, email, through the website or via other channels, we may process:

• your first and last name;
• telephone number;
• email address;
• content of your enquiry;
• correspondence history;
• other information that you voluntarily provide.

Purpose: to respond to your enquiry, provide information and advice regarding our services, and provide you with an offer.

Legal basis: taking steps at your request prior to entering into a contract, performance of a contract, or our legitimate interest in properly administering customer enquiries.

3.2. Individual Safe Deposit Box Order and Contract Data

When you order or use individual safe deposit box rental services, we may process:

• your first and last name;
• date of birth;
• personal identification number, where necessary;
• details of your identity document and, where necessary, a copy of the document;
• residential or correspondence address;
• email address;
• telephone number;
• information about the selected vault location;
• safe deposit box size;
• rental period;
• contract start and end dates;
• customer account information;
• information regarding access granted to the vault facility;
• payment and transaction information;
• other information necessary for the provision of services.

Purpose: to enter into and perform an individual safe deposit box rental agreement, administer the customer relationship, provide access to the vault facility, process payments and ensure proper provision of the service.

Legal basis: entering into and performing a contract and compliance with legal obligations applicable to the Company.

3.3. Data Relating to Additional Services

If you order valuables transportation, personal assistant services or other additional services, we may additionally process:

• the address from which valuables are to be collected or another service delivery address;
• preferred date and time;
• first and last name of the contact person;
• telephone number;
• information regarding the declared value of the property;
• other information necessary to provide the specific service.

We use this data only to the extent necessary to organise and provide the service you have ordered.

Legal basis: entering into and performing a contract.

3.4. Payment Data

When paying for services, we may process:

• the payer’s first and last name or company name;
• payment amount;
• payment date;
• bank account or payment transaction information;
• invoices and other accounting data;
• information about the selected payment method.

Where payment is made through a bank, card payment processor, PayPal or another payment service provider, the relevant payment data may also be processed by that service provider in accordance with its own privacy policy.

Legal basis: performance of a contract and compliance with legal and accounting obligations applicable to the Company.

4. VAULT AND ACCESS SECURITY

Given the nature of the services we provide, we may process information necessary to ensure the security of customers, employees, premises and property located within those premises.

This may include:

• the date and time of a visit to the vault facility;
• access control system records;
• entry and exit information;
• security system event logs;
• video surveillance data.

Video surveillance is carried out for security purposes, prevention of criminal activity, and protection of individuals and property.

Legal basis: the Company’s legitimate interest in protecting customers, employees, premises and property and, where applicable, compliance with legal obligations.

Video recordings are generally retained for up to 30 calendar days, except where a particular recording is required to investigate an incident, suspected legal violation or dispute.

5. WEBSITE USAGE DATA

When you visit www.saugyklos.lt, our systems and technology partners we use may automatically receive certain technical information, such as:

• IP address;
• device and browser information;
• operating system;
• approximate geographical location;
• date and time of the website visit;
• pages visited;
• actions performed on the website;
• duration of the visit;
• referral source;
• advertising or campaign identifiers;
• cookies and other online identifiers;
• information as to whether you submitted an enquiry, placed an order or completed another conversion action.

This data is used for website functionality, security, statistics, evaluation of advertising effectiveness and, with your consent, advertising personalisation.

6. GOOGLE SERVICES

We may use services provided by the Google group on our website, including:

Google Analytics

Google Analytics helps us understand how visitors use the website, for example which pages they visit, how long they spend on those pages, which sources brought them to the website and what actions they take.

Analytics cookies and related technologies are used only after obtaining your consent where such consent is required.

Google Ads

We use Google Ads to run advertising campaigns and evaluate their effectiveness.

With your consent, Google Ads technologies may be used to:

• determine whether a visitor reached the website after clicking on an advertisement;
• record conversions, such as submitting an enquiry or placing an order;
• evaluate the effectiveness of advertising campaigns;
• create audiences for remarketing purposes;
• display more relevant advertising;
• limit the frequency with which the same advertisement is shown.

Cookies, advertising identifiers and other similar technologies may be used for these purposes.

Google Tag Manager

We may use Google Tag Manager to manage measurement and advertising technologies on the website.

Google Tag Manager helps us technically manage tags and integrations installed on the website.

Where applicable, we transmit to Google services the visitor’s choices regarding the use of cookies and advertising data, including the relevant consent signals.

7. META (“FACEBOOK” AND “INSTAGRAM”) ADVERTISING

We use the Meta advertising platform, including, among other services, Facebook and Instagram, for advertising and measuring advertising performance.

Meta Pixel and/or other Meta measurement technologies may be used on the website.

With your consent, these technologies may help us to:

• determine whether you arrived at our website through a Facebook or Instagram advertisement;
• measure advertising campaign performance;
• record conversions completed on the website;
• create advertising audiences;
• carry out remarketing;
• deliver more relevant advertising messages;
• analyse user interaction with advertisements and the website.

For these purposes, Meta may receive information about your device, IP address, cookies or other identifiers, pages visited and actions performed on the website.

Meta may also process the data it receives in accordance with its own privacy policy.

8. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use cookies, pixels, tags and similar technologies on the website.

Cookies may be divided into the following categories:

Necessary Cookies

These cookies are required for the basic operation of the website, security, order processing, login functionality, saving cookie preferences and other essential functions.

We do not request separate consent for these cookies where they are necessary to provide a service requested by the visitor or to ensure the operation of the website.

Analytics Cookies

These cookies help us understand how visitors use the website and how we may improve it.

They are activated only after obtaining your consent.

Advertising and Marketing Cookies

These cookies are used to evaluate advertising effectiveness, create advertising audiences, carry out remarketing and, where applicable, personalise advertising.

This category may include technologies provided by Google Ads, Meta Pixel and other advertising platforms.

They are activated only after obtaining your consent.

Functional Cookies

These cookies allow the website to remember your preferences and provide additional functionality. Where such cookies are not necessary for the operation of the website or to provide a service requested by you, they are used only with your consent.

9. MANAGING COOKIE PREFERENCES

When you visit the website for the first time, a cookie preference window is displayed.

In this window, you may:

• accept all non-essential cookies;
• reject non-essential cookies;
• select individual cookie categories.

Your consent is voluntary.

Refusing to provide consent does not prevent you from using the website’s essential functions, except for functions for which the relevant technology is objectively necessary.

You may change your preferences or withdraw your consent at any time by using the “Cookie Settings” function available on the website.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

10. DIRECT MARKETING

If you have consented to receive our offers, news or other marketing communications, we may use the following personal data for this purpose:

• your name;
• email address;
• telephone number;
• information about the service you selected, to the extent necessary to tailor the offer.

You may withdraw your consent to direct marketing at any time by:

• clicking the unsubscribe link in an email;
• contacting us at info@saugyklos.lt.

In certain cases permitted by law, we may send existing customers offers concerning our similar services, provided that they are given a clear opportunity to opt out of such communications at any time.

11. WHO WE MAY DISCLOSE PERSONAL DATA TO

We may disclose your personal data only to the extent necessary and lawful.

Recipients or processors of personal data may include:

• IT system, server and hosting service providers;
• website administration and development service providers;
• CRM, customer service and communication system providers;
• payment service providers, banks and PayPal;
• accounting and audit service providers;
• advertising and marketing service providers;
• companies within the Google group;
• companies within the Meta group;
• insurance companies where related to the service provided;
• valuables transportation providers or other partners where you order their services;
• legal service providers;
• debt administration or collection service providers;
• public authorities, courts, law enforcement authorities and other entities where disclosure of information is required by law.

We provide service providers only with the information necessary for them to perform their functions and require them to ensure appropriate protection of the data transferred to them.

12. GOOGLE AND META AS DATA RECIPIENTS

When using Google and Meta technologies, certain data may be transferred to the relevant companies within these groups, including:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;

Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

Further processing of personal data by these service providers may also be subject to their respective privacy policies and terms of use.

13. TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Some of the service providers we use, or companies within their corporate groups, may be established outside the European Economic Area or may process information outside the European Economic Area.

In such cases, we ensure that personal data is transferred in accordance with GDPR requirements and subject to appropriate safeguards, such as:

• an adequacy decision adopted by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• other safeguards for data transfers permitted under the GDPR.

14. HOW LONG WE RETAIN PERSONAL DATA

We do not retain personal data for longer than necessary for the purpose for which it was collected.

As a general rule, we apply the following criteria:

• enquiry data – for as long as necessary to handle the enquiry and for a reasonable period after the communication has ended;
• customer contract and service data – for the duration of the contract and, where necessary to protect rights and interests or comply with legal requirements, for up to 10 years after the end of the contract;
• accounting documents – for the period required by applicable law;
• video surveillance recordings – generally for up to 30 days, unless a particular recording is required for the investigation of an incident or dispute;
• direct marketing data – until consent is withdrawn or for as long as another lawful basis for its use remains applicable;
• cookie and advertising technology data – in accordance with the retention period applicable to the particular cookie or service.

After the applicable retention period expires, personal data is deleted or anonymised, unless applicable law requires us to retain it for a longer period.

15. PERSONAL DATA SECURITY

We apply appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• unlawful use or disclosure;
• accidental loss;
• alteration;
• destruction.

Access to personal data is granted only to those employees and service providers who require it in order to perform their functions.

Despite the measures we take, no method of transmission over the Internet or electronic storage can guarantee absolute security.

16. YOUR RIGHTS

In the circumstances provided for under the GDPR, you have the right to:

  1. access the personal data we process about you;

  2. request correction of inaccurate or incomplete personal data;

  3. request deletion of your personal data;

  4. request restriction of the processing of your personal data;

  5. object to the processing of your personal data where such processing is based on our legitimate interests;

  6. object at any time to direct marketing, including profiling related to direct marketing;

  7. withdraw your consent where personal data is processed on the basis of consent;

  8. receive or transfer your personal data where the right to data portability applies;

  9. in the circumstances provided for under the GDPR, not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you.

Limited profiling may be carried out for advertising and analytics purposes on the website, for example by assigning a visitor to an advertising audience based on their interaction with the website. We do not make decisions based solely on such automated profiling that produce legal effects concerning you or similarly significantly affect you.

To exercise your rights, please contact us at:

info@saugyklos.lt

In order to protect your data, we may reasonably ask you to verify your identity before processing your request.

We will respond to your request within the time limits prescribed by the GDPR.

17. RIGHT TO LODGE A COMPLAINT

If you believe that we are processing your personal data improperly, we encourage you to contact us first at info@saugyklos.lt so that we can address the matter.

You also have the right to lodge a complaint with:

State Data Protection Inspectorate (VDAI)
L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania.

You may also contact the data protection supervisory authority of another European Union Member State in which you live or work.

18. DATA RELATING TO MINORS

Our individual safe deposit box rental services are not intended for minors who, under applicable law, are unable to independently enter into the relevant contract.

We do not knowingly collect children’s personal data for marketing purposes.

19. THIRD-PARTY WEBSITES

Our website may contain links to websites, social media accounts or services operated by other entities.

We do not control the processing of personal data carried out by such third parties, and therefore recommend reviewing their privacy policies before using their services.

20. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, for example if our services, technologies used or legal requirements change.

The current version of the Privacy Policy will always be published at www.saugyklos.lt.

The date of the most recent update is stated at the top of this Policy.

If the changes are material, we may provide additional notice through appropriate communication channels selected by us.

EUROCASH1, UAB / VAULTS1
Ukmergės g. 219-1, LT-07152 Vilnius, Lithuania
Email: info@saugyklos.lt
Tel.: +370 696 84 425
www.saugyklos.lt

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