Privacy policy

1. Who processes your data

The controller is the law firm Advokatų profesinė bendrija „Jurkonis ir partneriai LINDEN“ (“Linden”, “we”):

• company code 304034743;
• address Pylimo g. 19-16, LT-01141 Vilnius, Lithuania;
• e-mail info@linden.lt, phone +370 5 212 1506.

We comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other data protection law. For any question about how we handle data, contact us at info@linden.lt.

2. Website visitors

atlygis.linden.lt uses no cookies, no visitor analytics, no advertising and no social media plugins. All fonts, images and code load from our own server, so a visit sends none of your data to third parties.

Our server logs requests: IP address, time, page opened and browser type. These records keep the site running and secure and are kept for 14 days. Contact form submissions are not written to them. The legal basis is our legitimate interest (GDPR Article 6(1)(f)).

The “Pick a call time” button opens a Calendly page. If you book a call there, Calendly, LLC (USA) receives your name, e-mail address and chosen time on Linden's behalf. We use these only to hold the call; the legal basis is our legitimate interest in holding the call you asked for (GDPR Article 6(1)(f)). Calendly receives nothing until you press the button.

3. Questions sent through the contact form

What we receive

• your name and e-mail address;
• your company name, if you give it;
• the text of your question, the page you sent it from and the time.

We use the IP address only to limit repeated submissions and to block automated programs. We do not store it with your question.

Why we use it, and on what basis

We use the data to answer your question and, if you ask, to prepare an offer. The legal basis is our legitimate interest in answering questions we receive and preparing offers (GDPR Article 6(1)(f)).

You are not obliged to provide the data, but without a name and e-mail address we cannot answer your question.

Where the data goes

• Twenty, Linden's client management system. It is open-source software that Linden installed on its own equipment in Lithuania (EU). Your question is recorded there as a potential client.
• Brevo, an e-mail service that delivers the notice of your question to info@linden.lt.
• A copy of the question is kept on our server in Frankfurt for up to 30 days, so it is not lost if one of these systems is briefly down.

Please do not send special categories of data, such as health data, or the salaries of named employees through the form.

4. Users of the tool

Once the tool is live and your company's representatives create an account, we process:

• name, e-mail address, position and company;
• sign-in data and a record of actions in the tool (who approved a score or the pay system, and when);
• order and payment data. We do not receive card details: Paysera handles them.

The legal basis is our legitimate interest in performing the contract with the company you represent (GDPR Article 6(1)(f)), and for accounting records a legal obligation (GDPR Article 6(1)(c)). You are not obliged to provide the data, but without it we cannot give you access to the tool.

5. Client employees' data

The employer uploads its employees' data to the tool: name, job, pay, working time, sex, and contact details (e-mail or phone) used to share the pay system with them. The tool also records when an employee tapped “I have read it”.

Linden processes this data as a controller, in providing legal services to the employer: preparing and reviewing the pay system and informing employees about it. The legal basis is the legitimate interest of Linden and the employer in the employer meeting the requirements of Labour Code Article 140 (GDPR Article 6(1)(f)). The data is kept under the advocate's duty of professional secrecy.

• Employees' pay data is never combined with other clients' data.
• E-mails to employees contain no tracking pixels (invisible images). The only proof is the tapped “I have read it” button.
• Employees can exercise their rights by writing to Linden at info@linden.lt or to their employer.

6. Linden system suggestions

The Linden system guides the client step by step through preparing the pay system: it suggests job scores, groups and pay ranges, and explains pay gaps. Linden uses an AI service to prepare the suggestions. Linden is responsible for how it is used.

What data is used for suggestions

• job descriptions and the client's questions;
• employees' pay, working time, job group and sex.

Before suggestions are prepared, employees' names are replaced by codes (the tool does not collect personal ID codes). Under the GDPR such pseudonymised data is still personal data, so we protect it like any other personal data.

How we protect the data

• by contract, the AI service provider may not use your data to train its models;
• we have a data processing agreement with the provider under GDPR Article 28;
• the provider receives only the data needed to prepare a suggestion;
• data is sent over an encrypted connection.

Who decides

The Linden system's suggestions are only suggestions. The employer accepts or changes every score and decision, and a Linden lawyer reviews the pay system before the final document is issued. We make no automated decisions that produce legal effects for a person or similarly significantly affect them (GDPR Article 22).

The legal basis is our legitimate interest in providing the legal service to the Client (GDPR Article 6(1)(f)), as described in section 5.

7. Service providers

The following providers help us process data. They process data on Linden's behalf and under its instructions; each has a data processing agreement with us. Paysera processes payments as an independent controller.

8. Data outside the EEA

The tool's servers and database are in Frankfurt (Germany, EU). Some providers (Supabase, Calendly) are not EU companies, and the AI service provider may also process data in the USA, so we cannot promise that data will never be accessible outside the European Economic Area.

Where such a transfer happens, it relies on the safeguards in Chapter V of the GDPR:

• AI service provider (pseudonymised pay data): the European Commission's standard contractual clauses.
• Supabase: the European Commission's standard contractual clauses (Supabase's data processing addendum). The database is in Frankfurt, but the service is provided by a Singapore company.
• Calendly (call booking): the EU-U.S. Data Privacy Framework (Calendly, LLC is a participant) and the European Commission's standard contractual clauses in Calendly's data processing addendum.

9. How long we keep data

10. Your rights

You have the right to:

• know what data we hold about you and get a copy;
• have inaccurate data corrected;
• have data erased;
• restrict its processing;
• object to processing based on our legitimate interest;
• have your data transferred to another controller;
• lodge a complaint with the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).

These rights are subject to the conditions and exceptions set by law. Send your request to info@linden.lt. We answer without undue delay and within one month; in complex cases this may be extended as GDPR Article 12(3) allows.

11. Cookies

atlygis.linden.lt uses no cookies. The tool will use only strictly necessary cookies to keep you signed in. We will list them in this policy before the tool launches.

12. Changes

We may update this policy when the service or the law changes. The current version is always on this page, and we will tell users of the tool about material changes by e-mail.