This Recruitment Personal Data Processing Policy (hereinafter – the Policy) informs you how UAB “Venipak Lietuva”, legal entity code 300906055, registered office at Konstitucijos pr. 18, Vilnius (hereinafter – the Company), acting as the Data Controller, processes the personal data of individuals applying for vacant positions at the Company.

This Policy may be amended without prior notice. The latest version of the Policy is always available on the Company’s website: https://venipak.com/.

 

I. Data Controller Details

UAB „Venipak Lietuva“

Legal entity code: 300906055

Registered office: Konstitucijos. pr. 18, Vilnius

Phone: +370 700 55221

Email: [email protected]

 

II. Categories and Purposes of Candidate Personal Data

Recruitment

For the purpose of selecting a suitable candidate for a vacant position, the Company collects the following personal data:

  • name and surname;
  • email address and/or phone number;
  • information about the candidate’s work experience (names of employers, periods of employment, positions held, responsibilities and/or achievements);
  • information about education and qualifications;
  • information about language skills and other competencies required for the relevant position;
  • summary and results of interviews, feedback and assessments provided by the person conducting the recruitment;
  • other information voluntarily provided by the candidate in a CV, cover letter or other application documents (e.g., references, testimonials). Where such data is provided, it is processed in the same way as data requested by the Company.

Special categories of personal data (e.g., health-related information, criminal record certificates) may be collected only where this is necessary for recruitment to a specific position and only to the extent permitted and required by applicable law.

The Company may also collect personal data relating to a candidate’s qualifications, professional skills and business qualities from a former employer after informing the candidate in advance, and from a current employer only with the candidate’s consent.

 

AI career assistant

The Company uses an artificial intelligence (AI) career assistant on its website to answer questions about employment opportunities, provide information about vacancies and enable enquiries to be forwarded to the Company’s recruitment team. The assistant does not assess or rank candidates or make recruitment decisions.

Purpose Data processed
Answer questions about employment opportunities Chat messages, conversation history and session-related technical data
Forward an enquiry to the recruitment team when an individual chooses to leave contact details Name, phone number and email address, city, position of interest and enquiry

 

III. Legal Basis and Retention Period

Recruitment

For the purpose of selecting a suitable candidate for a vacant position, the Company processes personal data on the following legal grounds under the General Data Protection Regulation (hereinafter – GDPR):

  • the candidate’s consent, where the candidate submits application documents (GDPR Article 6(1)(a));
  • the Company’s legitimate interest in selecting a suitable candidate for a specific position (GDPR Article 6(1)(f)).

Personal data is stored for 30 days after the end of the recruitment process, unless otherwise required by law. The recruitment process is considered completed after the probation period of the selected candidate (3 months) has ended.

 

AI career assistant

Personal data submitted through the AI career assistant is processed on the basis of the Company’s legitimate interests (Article 6(1)(f) GDPR) in responding to enquiries about employment opportunities, forwarding enquiries to the recruitment team and ensuring the proper operation of the assistant.

The following retention periods apply:

  • Conversation history – 6 months after the conversation ends.
  • Contact details – 30 days after submission, after which they are automatically deleted from the assistant’s system. Where an individual participates in a recruitment process, further processing is subject to the retention periods set out in this Policy.

 

IV. Sources of Personal Data

Candidate personal data listed above is obtained:

  • directly from candidates, when they submit a CV, cover letter or other application documents through the Company’s communication channels or using the AI career assistant;
  • from the Lithuanian Employment Service, recruitment agencies, job portals, professional social networks (e.g., LinkedIn) or platforms (e.g., CV Bankas, CV Online). In such cases, the Company assumes that the candidate has been properly informed about the processing and transfer of their personal data and has given consent to the relevant service provider.

 

V. Disclosure of Personal Data

Candidate personal data may be disclosed to competent public authorities and law enforcement institutions only where required by applicable law or where necessary to protect the Company’s rights and legal claims.

Access to candidate personal data may also be granted to:

  • IT service providers maintaining and servicing the Company’s email systems and servers;
  • providers of AI career assistant development, maintenance, AI models, data storage, infrastructure and related IT services, to the extent necessary for the operation of the assistant;
  • electronic communications and/or communication service providers, providing services to the Company;
  • providers of internal work organisation and document management services, used by the Company;
  • recruitment service providers, engaged by the Company;
  • audit, legal or other professional service providers engaged by the Company, strictly to the extent necessary for their functions.

When using the AI career assistant, conversation data is transferred to Anthropic PBC, an AI model provider based in the United States. The transfer is based on the European Commission’s Standard Contractual Clauses. The data is not used to train AI models.

 

VI. Candidate Rights

In accordance with the GDPR, the Law on Legal Protection of Personal Data of the Republic of Lithuania, and other applicable data protection legislation, each job candidate whose personal data is processed by the Company has the following rights:

  • to receive confirmation as to whether the Company processes personal data relating to the candidate and, where this is the case, to request access to such personal data;
  • to request the correction of inaccurate personal data or, taking into account the purposes of processing, the completion of incomplete personal data;
  • to request the erasure of personal data held by the Company where such data is processed unlawfully or where other circumstances provided for in applicable law apply (for example, where the legal basis for processing no longer exists);
  • to request restriction of processing where the accuracy of the data is contested, where the candidate objects to the processing, where unlawful processing is identified but the candidate does not wish the data to be erased, or where the data is required for the establishment, exercise or defence of legal claims;
  • to object, on grounds relating to their particular situation, to processing based on the Company’s legitimate interests, and to withdraw consent where processing is based on consent;
  • to lodge a complaint with the State Data Protection Inspectorate (see https://vdai.lrv.lt);
  • to request the transfer of personal data to another data controller where the processing is based on the candidate’s consent.

 

VII. Procedure for Handling Requests

All requests relating to the exercise of data subject rights should be submitted by email to [email protected].

Upon receiving a request, the Company must verify the identity of the data subject and therefore has the right to request information and documents necessary to confirm the data subject’s identity.

Responses to data subject requests will be provided no later than 30 calendar days from the date on which the request and all documents required to prepare a response have been received.