Data provided when you visit our website (the "Website") and use the services offered on the Website, and describes your rights as of a data subject and relevant obligations of UAB Horizontal media as of a data controller.

When you use the Website and the services offered on the Website, we receive and process your personal data. This means that we are a data controller and have a duty to ensure the proper protection of your data and to comply with other requirements imposed on us by the personal data protection legislation.

This Privacy Policy will explain to you what personal data, how and why we collect and process, inform you of your rights and how to enforce them, and provide other relevant information.

General provisions

1. is managed and administered by UAB Horizontal media, company‘s code 306083326, registered address Ozo st. 12A-1, Vilnius, VAT payer‘s code LT100014992210, registered in the Register of Legal Entities of the Republic of Lithuania.

2. We process the User Personal Data in accordance with Regulation of the European Parliament and of the Council (EU) 2016/679  of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (“the Regulation“), the Law of the Republic of Lithuania on the Legal Protection of Personal Data (“LLPPD“), the Law of the Republic of Lithuania on Electronic Communications  (“LEC”) and other directly applicable legal acts regulating personal data protection, as well as instructions of data protection supervisory authorities (in Lithuania - State Data Protection Inspectorate).

3. UAB Horizontal media respects the right of all its customers (purchasers of services), including Users of the Supplier's website (the "Website"), to privacy and undertakes to ensure the protection of their personal data and their rights as of data subjects.

4. This Privacy Policy governs the basic principles and procedures for the collection, processing and storage of Supplier's personal data.

5. By using the Supplier's Websites as well as by ordering / using the Supplier's services and providing the Supplier with your personal data, you agree to the terms of this Privacy Policy (except for data processing activities that will require your specific consent). Users are deemed to be aware of the Privacy Policy after they check or uncheck the box next to the text "I familiarized with and agree to" when registering or posting an ad on one of the Websites /customer system. The Privacy Policy may be re-accessed at any time through the Website.

6. Terms used:

6.1. "Personal data" shall mean any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name and surname, personal identification number, whereabouts and Internet identifier, or to one or more physical, signs of physiological, genetic, mental, economic, cultural or social identity.

6.2. “Data Subject“ shall mean a natural person - a customer of the Supplier (including visitors to the Website) whose personal data is collected by the Supplier.

6.3. “The data subject's consent“ shall mean any freely given specific and unambiguous expression of the will of the data subject by means of a statement or the unambiguous act, whereby he/she expresses his/her consent to the processing of personal data relating to him/her.

6.4. "Data processing" shall mean any operation or sequence of operations carried out by automated or non-automated means on personal data or sets of personal data, such as collection, recording, sorting, systematization, storage, adaptation or alteration, retrieval, familiarization, use, disclosure by way of transferring, disseminating or otherwise creating a possibility to use them, including collation or aggregation with other data, restriction, deletion or destruction of data.

6.5. "Data Processor" shall mean a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the Data Controller.

6.6. “Data Controller“ shall mean UAB Horizontal media, a company incorporated under the laws of the Republic of Lithuania, code 306083326, registered office at Ozo st. 12A-1, Vilnius city, Republic of Lithuania, data collected and stored in the Register of Legal Entities

6.7. “A cookie“ is a small piece of textual information that is automatically generated when you browse the Website and is stored on your computer or other terminal device. Cookies are standard web browsing practices that facilitate the User's browsing of a web page he/she has already visited, and simplify access to published information.

6.8. “Direct marketing“ shall mean the activity of offering goods and services to individuals by mail, telephone or other direct means and / or seeking their opinion on the goods or services being offered.

6.9. “System message“ shall refer to messages sent by e-mail and / or phone and / or through the browser that are related to the User-posted advertisement. Examples: Notification of successful ad payment, ad stats, ad and service expiration, password reminder, reminder of incomplete ad placement, etc.

For what purposes do we process your personal data?

7. The Supplier processes your personal data above for the following data-processing purposes: service order processing and administration, identification of Supplier's customers during the registration of the Supplier on one of our Websites and logging in to his account created, management of accounting documents related to service order, communication with you for the purposes of the performance of the service ordered, defect correction with a view to ensure the proper protection of our rights and the rights of our Customers should they be infringed and there be a need to identify the responsible person, direct marketing purposes (subject to prior consent of the data subjects).

8. The User understands and agrees that Third Parties may access, view and copy the Personal Data (for example, contact details in the Advertisements). Likewise, the User, who places the Advertisement, grants the persons concerned the right to contact him by telephone, e-mail, SMS, message in web browser, mobile app.

9. The Supplier has no purpose to store outdated, irrelevant Personal Data of the User. Such information is protected if it is required by law or for the purpose of carrying out the Supplier's activities (for example, historical data about the User's payments, etc.).

How do we process your data?

10. We ensure that your personal data will be: processed in a lawful, fair and transparent manner, collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes, adequate, relevant and only for the purposes they are processed (the principle of excessive data collection and collected data decreasing applies), accurate and, where necessary, kept up to date (the principle of accuracy applies), processed in such a way as to ensure appropriate security of personal data by appropriate technical and organizational measures, including protection against unauthorized or illegal data processing and against accidental loss, destruction or damage (the principles of integrity and confidentiality apply).

11. By submitting Personal Data, the User grants the Supplier the right to manage and process the Personal Data of the User as provided for in these Rules. The User has the right to revoke his / her permission for the Supplier to manage and process the User's Personal Data, delete the Personal Data and delete the Account.

12. The User agrees that upon registration and logging on to the Website, the IP address of the User's computer, the date and time of logging on to the system will be recorded.

13. The User understands and agrees to receive system messages. System messages are an integral part of ads and User registration. Without system messages, the Supplier would not be able to ensure the proper functioning of the Services ordered by the User.

14. The Supplier may combine available information about the User with information held by third parties in order to provide the User with relevant, interesting offers or services.

What personal data do we collect and how long do we store them?

15. The Supplier collects and further processes the following personal data you yourself provide to us when registering and / or ordering services on our Websites or otherwise ordering services: name, surname, address, date of birth, email, phone number, photo, logo, company details, skype name, data related to the services we provided / provide, such as ad upload details, subscription order information (search parameters), account numbers, billing, payment details, information about the consent and disagreement regarding the processing of personal data for direct marketing purposes, passwords, any other data you provide in addition on your own initiative when registering and / or ordering, managing the Services.

16. When you sign up and access the Website through your social network Facebook account, only your publicly accessible profile data is received and processed: your Facebook user ID, name, email address. You can unlink your Facebook account from the Website in the "Settings" section at any time. By accessing the Website through your social network Facebook account, you give Facebook permission to share your account information, in which case the source of the data received is Facebook.

17. When you order a paid service, we receive personal data (name, account number, transaction date and amount, purpose of payment) from your mobile operator, bank or electronic money institution at which you have an account, services, depending on the way of payment you choose. The legal basis for the processing of these personal data: transaction concluded.

18. Accounting documents and personal data indicated therein shall be retained for the period, which is obligatory according to the requirements of the applicable legal acts (currently documents confirming economical operations, in accordance with the General Document Retention Periods approved by order of the Chief Registrar of the Republic of Lithuania No V-100 of 9 March 2011 must be retained for 10 years. Upon the expiry of the retention period, the documents shall be destroyed); your other personal data specified in para 15-17 are saved for the period of cooperation between the Supplier and you (until the services ordered on the Website are being provided) and 5 (five) years thereafter.

19. The Supplier collects and further processes this Personal Data of you which you submit indirectly when registering, ordering services or receiving invoices for services rendered (ordered) on one of our Websites, i.e. this data is automatically collected from the computers and / or mobile devices you use when you access one of our Websites: the IP addresses and times of the logins, the browser used by the user and its version, the websites you visited before accessing our Website, service order history, ad archives, request histories, settings on receiving messages, such as data collected through cookies and similar technologies related to web browsing, etc.

20. Your personal data referred to in clause 19 is stored during the period of cooperation between the Supplier and you (at the time of ordering the service) and, depending on the data, for one year from the end of this period. This data may be stored for a longer period if there are other legal grounds for such a storage period.

Information security measures

21. To process the Personal Data, the Supplier shall implement the necessary organizational and technical security measures, which shall protect the Personal Data from accidental or unlawful destruction, alteration, disclosure, as well as from any other unlawful processing.

22. The Supplier uses software and other means to protect the login details of all Users. Payment details, payment card numbers used to pay for the paid services are purposefully coded.

23. The data we collect from you will be managed and processed within the territory of the European Union (EU), but may also be transferred or stored outside the EU (for example, by our supplier personnel outside the EU). In this case, we will take all necessary steps to ensure that your personal data is processed securely and in accordance with this Privacy Policy. As the User's information is sent over the Internet, the Supplier cannot guarantee the complete security of the information transmitted by the User. We also note that the Website contains ad content and other information (forum posts, etc.) which, in accordance with the Terms of Use of Website and this Privacy Policy, is intended for publication, is freely available on the Internet and may therefore be included in external searching systems results and be visible to individuals outside the EU as well.

What data subjects' rights do you have?

24. You have a right of access to your Personal Data held by us. To find out what Personal Data we have collected or received and from what sources, for what purposes we process them and whether all of your Personal Data is complete and correct, email us in advance to [email protected] from the email you specified during the registration on the Website or address us directly at Ozo st. 12 A-1, LT-08200 Vilnius. We do not provide such information over the phone.

25. You shall be also entitled:

25.1. having submitted, either in writing or by email, a request to us, to suspend the processing of Personal Data;

25.2. to find out what data about you we process;

25.3. to be forgotten, to request us to destroy the data processed about you;

25.4. request us to transfer the data about you to another personal data controller;

25.5. not agreeing to the Privacy Policy, to disagree to the processing of your Personal Data;

25.6. to immediately express your disagreement or submit a subsequent letter of objection to the processing of your Personal Data for Direct Marketing purposes.

26. Upon receipt of your request or instruction, we will respond and follow the steps outlined in the request. The answer will be given to you in writing.

27. By using our services, you agree to the use of your Personal Data to fulfil the service you have ordered on one of our Websites. You agree in advance that we have the right to store your Personal Data on servers, internal / external systems, clouds to the extent required by the laws of the Republic of Lithuania.

28. The Supplier shall reply to the User's inquiries about Personal Data no later than within 30 (days) from the date of receipt of the inquiry and all necessary documents from the User. The answer shall be presented in a form acceptable to the User. The answer shall be provided to the User shall be given free of charge 1 (once) every six months.

29. The Supplier shall not submit Personal Data if the User does not confirm his / her identity, requests data about another User as well as in other cases restricting the disclosure of data to the User, provided for in the laws.

30. Please be advised that you may submit a complaint to the National Data Protection Inspectorate if you believe that your rights as of a data subject have been violated. More information about the State Data Protection Inspectorate and complaints handling can be found here:

How do we process personal data for direct marketing purposes?

31. Only with your prior consent and subject to the provisions of the Law on Electronic Communications, the LLPPD and the Regulations, we reserve the right to send information related to the services you have ordered by e-mail and / or inquire about the current quality of the service you have ordered.

32. We process the following personal data of you for direct marketing purposes: name, surname, e-mail address, telephone number, IP address of the User's computer.

33. Your personal data is stored for direct marketing purposes until you submit a request to unsubscribe from direct marketing offers.

34. The User has the right to object to the processing of his / her Personal Data for direct marketing purposes. The User can opt out of direct marketing offers by either clicking on the relevant link in the newsletter or by email [email protected] or by calling the Supplier by the phone number specified in the contacts. The Supplier shall terminate the processing of the User Data for the purpose of direct marketing no later than within 5 (five) business days.

To whom do we provide your personal data?

35. Provider employees' access to your personal data is only necessary to fulfil their duties and only when the employee is bound by a confidentiality agreement that is signed with each employee in the company, depending on the data the employee processes.

36. Under no circumstances, the personal data you provide to us shall be disclosed to third parties, except:

36.1. if we have your consent to the disclosure of your Personal Data;

36.2. to law enforcement agencies, state institutions and agencies, in accordance with the procedure established by legal acts of the Republic of Lithuania, when there is a need to protect our, your or other persons' legitimate interests;

36.3. data processors who provide services to the Supplier and process your personal data on behalf of the Supplier and for the benefit of the Supplier or you (IT or cloud services company, telecommunications companies, banks, electronic money institutions, etc.). We only employ data processors that ensure that appropriate technical and organizational measures are implemented in a manner that ensures that the data processing complies with the requirements of the Regulation and that your rights as of a data subject are protected.

36.4. To the extent necessary to ensure the legitimate interest of “Vertikali Media“, we may share your personal information with legal, audit and other professional services providers and etc.

Use of cookies

37. We use cookies to ensure a convenient and efficient browsing of our Websites.

38. Most browsers automatically accept cookies. The user can view the saved cookies in his / her browser. The User may also revoke his / her consent to the use of cookies by changing the settings and deleting the saved cookies in the browser. In this case, some features of the Website may not work, such as sections of saved ads and saved searches.

39. Cookie information may consist of data about the User's use of the Website, login details, language settings. Cookies enable the Website to operate more efficiently and improve its services, in addition to providing information to the Website Administrators for statistical or marketing purposes.

40. Cookies for the User may also be recorded by a system displaying advertising information on the Website and used to display advertising banners, which should be of interest to the User and meet the interests of the User.

41. The Supplier uses the information obtained by cookies for the following purposes:

41.1. to identify returning, Registered Users for improving the convenience of the provision of such Users with the content or services they order.

41.2. to monitor User's consumption habits in order to provide the User with relevant content.

41.3. For service development and targeted marketing orientation.

42. The Website may use the following cookies:

42.1. Technical cookies are necessary for the User to browse the Website and to use various functions. Without these cookies, the User would not be able to use the Services of the Website;

42.2. Functional cookies allow the Website to memorize information entered by the User (such as login details), thereby facilitating the User's use of the Website and providing a better User Experience.

42.3. Analytical cookies are used to provide statistical analysis of User Behaviour on the Website. The results of these cookies are used anonymously by the supplier and exclusively for statistical purposes.

42.4. Advertising cookies are used to provide the User with services that may be of interest to the User or to offer a content similar to the one the User has already watched.

42.5. Third party cookies allow the User to see banners with current offers. The supplier does not have access to the information of third party cookies, which is under the full control of these third parties.

42.6. Social network cookies are necessary to use the Website information in a social profile account (e.g., to share an ad in your account or to express trust).

43. The user gives his / her consent to the use of cookies when he / she first visits the Website, becomes aware of the information about the use of cookies and by clicking on the "I agree" button. Similarly, consent for cookies is given when the User completes a registration on the Website. If the User's browser accepts cookies and the User does not delete and / or modify them, this also constitutes consent to the use of cookies.

44. The User's consent to the use of cookies is valid for 3 (three) years.

45. The User can choose whether or not to accept cookies and disable them by changing his/her browser settings.

46. ​​Without prejudice to legal acts, the Supplier may combine information obtained through the use of cookies with information obtained about a person by other means (e.g. statistical information on the services ordered).

47. Third parties may collect User Information for advertising purposes. Details of cookies collected by third parties the User may find out in the privacy policy of a specific third party. The Supplier shall not be liable for the accuracy, updating, completeness of the information of third parties or the compliance thereof with legal acts.

48. Cookies used on our websites:

Name of the cookie

Purpose of the processing



Possibility to find and use previous searches.

2 months


Possibility for the user to bookmark the list of ads.

1 year


Connect the user to the account without entering the login and password

30 days


Information notice on the use of cookies

3 years


Identify the user between page openings

Until closing the browser


49. The statistics tools we use are:

Cookie Provider Name

Cookie Provider Activities / Goals

Detailed information and cookie management

Statistics of Google analytics portal


Statistic of Gemius audience investigation


Marketing, statistics



50. Third parties authorized to use cookies in respect to the Website visitors for marketing and advertising purposes:

Cookie Provider Name

Cookie Provider Activities / Goals

Advertising banner broadcasting solutions


Using Website Indicators

51. The company sometimes uses not only cookies, but also website indicators. It is a tiny, one-pixel graphic image that enters the Data Subject's computer as part of a web page or as an HTML email. The Company uses these images, either directly or through other service providers, as Internet advertisements or on third party websites to determine whether the user to whom the advertisement is being showed makes an order, analyse the user traffic and optimize the services offered.

52. The company may include website indicators in promotional emails or newsletters to determine whether emails have been opened. Some Website indicators may be added by third party service providers to determine the effectiveness of Company's advertising campaigns or email communications. The Website Indicator can be used to place a persistent cookie on the Data subject's computer. You will then be able to recognize the Data Subject's computer each time you visit certain pages or send emails and collect anonymous information about the traffic to such pages. The Company prohibits the use of website indicators to collect or access personal information.

Profiling, making personal offers and making automated decisions

53. "Profiling" shall mean any form of automated processing of personal data where personal data are used to evaluate certain personal aspects relating to an individual, in particular for the purpose of analysing or predicting the performance, economic situation, health, personal status of that individual; hobbies, interests, trustworthiness, behaviour, location, or movement;

54. The profiling on our site involves the automatic processing of Personal Data in order to evaluate or predict certain personal characteristics of a user, such as their behaviour, personal preferences, interests, and residence. Profiling is used for the purpose of conducting analysis related to Guest Information for direct marketing purposes; such ongoing profiling shall be based on the legitimate interests of UAB Horizontal media and the user's express consent.

55. UAB Horizontal media may process Personal Data in order to improve the quality of the electronic services provided to the User, for example, to prepare personal offers to the User. If the User has given his consent for UAB Horizontal media to process the Personal Data for the purposes of direct marketing, UAB Horizontal media may process Personal Data in order to make general and personal offers of services provided by UAB Horizontal media. Such marketing activities may be based on the Services used by the User.

56. Profiling activities for the purpose of marketing and drawing up personal offers are based on the legitimate interest of UAB Horizontal media and the express consent of the user.

Other provisions

57. UAB Horizontal media may update or amend this Privacy Policy at any time. Such updated or amended Privacy Policy shall become effective upon posting on the Website. The Customer should check it from time to time to make sure that the Customer is satisfied with the current version of the Privacy Policy.

58. Any changes to our Privacy Policy will be posted on the Website. We will notify you, if necessary. The new terms of the Privacy Policy may also be posted on the Website and you may need to read and agree to them in order to continue using the Website and / or our Services.

Update Date: 2019-09-23