TransKL

TransKL - Privacy Policy

Last Updated: May 22, 2025

This Privacy Policy describes the policies and procedures of MB "402 Solutions", registered at J. Janonio g. 1-26, Gargzdai, LT-96125 Klaipedos r., Lithuania ("402 Solutions", "We", "Us", or "Our") on the collection, use, and disclosure of information when You use the TransKL application (the "TransKL App" or "App"), and tells You about Your privacy rights and how the law protects You.

TransKL is a business application provided on a Software as a Service (SaaS) basis, designed to support decision-making and business processes. By using the TransKL App, You agree to the collection and use of information in accordance with this Privacy Policy.

1. Interpretation and Definitions

1.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1.2 Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access the TransKL App or parts of the TransKL App.
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Aggregated Data means anonymized and aggregated data obtained through the use of the TransKL App that does not allow for direct or indirect identification of the Client, its Users, or business transactions.
  • Client (also referred to as "You" or "Your") means a legal entity or natural person that has concluded the SaaS Agreement and uses the TransKL App.
  • Company (referred to as "402 Solutions", "We", "Us", or "Our") refers to MB "402 Solutions", J. Janonio g. 1-26, Gargzdai, LT-96125 Klaipedos r., Lithuania.
  • Cookies are small files placed on Your computer, mobile device or any other device by a website or application, containing details of Your browsing or usage history among other uses.
  • Country refers to: Lithuania.
  • Customer Data means any business data that the Client submits, uploads, or otherwise transmits using the TransKL App.
  • Device means any device that can access the TransKL App, such as a computer, mobile phone, or digital tablet.
  • Personal Data is any information that relates to an identified or identifiable natural person.
  • Service Provider means any natural or legal person who processes data on behalf of the Company, including third-party companies or individuals engaged to facilitate or support the TransKL App.
  • TransKL or the App means the business application provided by MB "402 Solutions" on a SaaS basis, including all its functionalities, updates, and versions.
  • Usage Data refers to data collected automatically, either generated by the use of the TransKL App or from the App's infrastructure itself (for example, session duration, access logs).
  • User means an employee or contractor of the Client who is authorized to use the TransKL App on behalf of the Client.

2. Scope of This Policy

The TransKL App is designed for business use by legal entities, natural persons, and their authorized employees or contractors. This Privacy Policy governs how We handle:

  • Customer Data: business data submitted, uploaded, or transmitted by Clients or Users through the TransKL App.
  • Personal Data: any personal data of natural persons that may be included in Customer Data.
  • Aggregated Data: anonymized and aggregated usage data that cannot be used to identify any Client, User, or business transaction.
  • Usage Data and technical logs: collected automatically for security, abuse prevention, and fee calculation purposes.

This Privacy Policy does not apply to third-party websites or services that may be linked from or integrated with the TransKL App.

3. Types of Data Collected

3.1 Customer Data

Clients may submit business data to the TransKL App in the course of their ordinary business operations. This may include data about business transactions, operations, and decision-making processes. The Client retains all rights to their Customer Data. We do not use Customer Data for any purpose other than providing and operating the TransKL App as agreed in the SaaS Agreement.

3.2 Personal Data

The TransKL App is intended for business data only. Clients undertake not to upload personal data of natural persons unless a separate legal basis exists and a separate data processing agreement has been concluded between the parties.

Where personal data is included in Customer Data, We may process the following categories:

  • Email address
  • First name and last name
  • Phone number
  • Address, postal code, city

If a Client transfers personal data, the Client is solely responsible for the lawfulness of such transfer. Where required by law, the parties will conclude a separate Data Processing Agreement.

3.3 Usage Data

Usage Data is collected automatically when using the TransKL App. It may include information such as Your Device's IP address, browser type and version, features and sections accessed within the App, the time and date of Your visit, time spent in different sections, unique device identifiers, and other diagnostic data.

When You access the TransKL App through a mobile device, We may also collect information such as the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, and the type of mobile browser You use.

3.4 Aggregated Data

We may derive and use Aggregated Data - anonymized and aggregated data that does not allow for the identification of any Client, User, or business transaction - exclusively for the analysis and improvement of the TransKL App's performance.

3.5 Tracking Technologies and Cookies

The TransKL App may use Cookies and similar tracking technologies to track activity and store certain information. Technologies used may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of the TransKL App.
  • Web Beacons. Certain sections of the TransKL App and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us to count users who have visited pages or opened emails, and gather other related statistics.

We use both Session and Persistent Cookies for the following purposes:

  • Necessary / Essential Cookies (Session): Essential to provide services available through the TransKL App and to authenticate Users.
  • Cookie Acceptance Cookies (Persistent): To identify if users have accepted the use of cookies.
  • Functionality Cookies (Persistent): To remember choices You make, such as login details or language preferences, providing a more personalized experience.

4. How We Use Your Information

We use the information We collect for the following purposes:

  • To provide and maintain the TransKL App, including monitoring usage and ensuring security.
  • To manage Your Account and registration as a User of the TransKL App.
  • For the performance of a contract: to fulfil obligations under the SaaS Agreement.
  • To contact You by email, telephone, SMS, or other electronic communication regarding TransKL App updates, security notices, or service-related communications.
  • To manage Your requests and provide technical support.
  • For fee calculation and verification of subscription payments.
  • For business transfers: to evaluate or conduct a merger, divestiture, restructuring, or similar transaction, where Customer Data may be among the assets involved.
  • For analysis and improvement: using only Aggregated Data, to analyze usage trends and improve the performance and features of the TransKL App.
  • To comply with applicable legal obligations.

We do not sell, rent, or share Customer Data with third parties for marketing or any other commercial purposes.

5. Legal Basis for Processing

Where personal data is processed, We rely on the following legal bases:

  • Contract performance: processing necessary for the performance of the SaaS Agreement with the Client.
  • Legitimate interests: processing for security monitoring, abuse prevention, and improvement of the TransKL App using only Aggregated Data.
  • Legal obligation: processing required by applicable Lithuanian and EU law.
  • Consent: where the Client or User has provided explicit consent, including consent to this Privacy Policy upon use of the TransKL App.
  • Separate agreement: where the Client submits personal data under a separate legal basis and data processing agreement.

6. Sharing Your Information

We may share Your information in the following situations:

  • With Service Providers: We may share information with Service Providers to monitor and analyze the use of the TransKL App and to support its operation.
  • For business transfers: We may share or transfer information in connection with, or during negotiations of, any merger, acquisition, or sale of Company assets. We will provide notice before Your data becomes subject to a different privacy policy.
  • With Affiliates: We may share information with Our affiliates, requiring them to honor this Privacy Policy.
  • As required by law: We may disclose information if required to do so by law, court order, or valid requests by public authorities (for example, a government agency or regulatory body).
  • To protect rights: We may disclose information where necessary to protect and defend the rights or property of 402 Solutions, prevent or investigate wrongdoing, or protect the safety of Users.
  • With Your consent: We may disclose Your information for any other purpose with Your explicit consent.

We do not sell Customer Data or share the Client's Confidential Information with third parties beyond the purposes described in this section.

7. Retention of Your Data

We retain Customer Data for the duration of the active Subscription Period. Upon termination or expiry of the SaaS Agreement, We will delete the Client's data within a reasonable period of time, unless retention is required by applicable law.

Usage Data is generally retained for a shorter period of time, except when used to strengthen the security or improve the functionality of the TransKL App, or where We are legally obligated to retain it for longer periods.

Aggregated Data, which does not identify any Client or User, may be retained indefinitely for analytical and service improvement purposes.

8. Transfer of Your Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in processing are located. MB "402 Solutions" is established in Lithuania and operates in accordance with EU law, including the General Data Protection Regulation (GDPR) where applicable. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or country unless adequate controls are in place.

9. Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You through the TransKL App.

You may update, amend, or delete Your information at any time by signing into Your Account within the TransKL App and visiting the account settings section. You may also contact Us to request access to, correction of, or deletion of any personal information You have provided to Us.

Please note that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

10. Security of Your Data

The security of Your Personal Data is important to Us. We implement appropriate technical and organizational measures to protect Customer Data within the TransKL App against unauthorized access, disclosure, alteration, or destruction.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your data, We cannot guarantee its absolute security.

11. Confidentiality

We treat all Customer Data as Confidential Information in accordance with the confidentiality provisions of the SaaS Agreement. We will not disclose or use any Confidential Information of the Client except as necessary to fulfil Our obligations under the Agreement.

The confidentiality obligations set out in the SaaS Agreement survive the termination or expiry of the Agreement for a period of five (5) years.

12. Children's Privacy

The TransKL App does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data through the TransKL App, please contact Us immediately. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

13. Client Responsibilities

As the TransKL App is intended for business use, the Client is responsible for:

  • ensuring that any personal data submitted to the TransKL App is processed on a lawful basis.
  • ensuring that Users are informed about the processing of their data where required by applicable law.
  • ensuring that Users comply with the terms of the SaaS Agreement.
  • the completeness and accuracy of all Customer Data submitted through the TransKL App.

14. Your Privacy Rights

Where personal data of natural persons is processed by 402 Solutions on behalf of the Client through the TransKL App, the relevant data subjects may exercise their rights under applicable data protection law (including the GDPR), which include:

  • The right to access, update, or delete the information We hold about You.
  • The right to rectification if Your information is inaccurate or incomplete.
  • The right to object to or restrict Our processing of Your personal data.
  • The right to data portability.
  • The right to withdraw consent at any time, where processing is based on consent.

Data subjects should direct such requests to the Client as the data controller. For privacy-related inquiries regarding Our own processing activities, please contact Us using the details provided in Section 17.

15. Links to Other Services

The TransKL App may contain links to other third-party services or websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's service. We strongly advise You to review the Privacy Policy of every service You use. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party services.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in Our practices, the TransKL App, or applicable law. We will notify You of any changes by posting the new Privacy Policy and updating the "Last Updated" date at the top of this document.

We will let You know via email and/or a prominent notice within the TransKL App prior to any material change becoming effective. You are advised to review this Privacy Policy periodically. Changes are effective when they are posted.

17. Contact Us

If you have any questions about this Privacy Policy or about how the TransKL App handles Your data, You can contact us:

MB "402 Solutions"
J. Janonio g. 1-26
Gargzdai, LT-96125 Klaipedos r.
Lithuania
Email: legal@transkl.eu
Website: www.transkl.eu

This Privacy Policy is governed by the laws of Lithuania. Any disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Lithuanian courts.

This Privacy Policy applies to the TransKL App and forms part of the 402 Solutions SaaS Agreement.