May 25, 2018

This Privacy Policy is effective from the time of its acceptance.


1. Introduction

1. Introduction This Privacy Policy applies to all products, services, websites and applications offered by Kenlana Ltd (softgan), unless otherwise indicated. We call these services, websites and applications together as “services” in this policy.

References to “data” in this Privacy Policy will apply to any data that you submit to our company and data collected from our websites. A link to personal information or simply information means information about you personally, which we collect or for which we act as custodian.


SoftGan – Kenlana Ltd.

GDPR – General Data Protection Statement (EU) 2016/679.


2. Information we collect

2.1 Who are you?


The company uses the services of Kenlana Ltd on a contractual basis.

Website visitor

You are visiting one of our websites.


2.2 Information we collect about you.

Contact information (for example, email address).

You can provide us with your contact information, whether through the form on our website, interaction with our sales.


Usage information

We collect information about you when you interact with our websites and services. This includes what web pages you visit, what you click on when you perform these actions, what are your preferences regarding language and t

. D. The data provided within the scope of the task in accordance with the agreement in force between us and the Client are processed only to that extent. and in such a way as to achieve these objectives.


Device and browser data.

We collect information from devices and applications that you use to access our services. These devices basically mean your IP address, operating system version, device type, system and performance information, and browser type. If you are using a mobile device, we also collect the UUID for this device.


Information from the page tag.

We use third-party tracking services that use cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes user usage and statistics.


Log data.

Like most modern websites, our web servers store log files that record data each time a device accesses these servers. Log files contain information about the nature of each access, including source IP addresses, Internet service providers, files viewed on our site (for example, HTML pages, graphics, etc.), Operating system versions, device type, and timestamps. .

Referral information.

If you access SoftGan website from an external source (for example, via a link on another website or by e-mail), we record the information about the source that sent you to us.


3. How we use the information we collect

We process your personal data either with your consent or in order:


To implement Kenlana legitimate interests:

improved service experience; and

development of new products and services.

In each of the cases where we describe how we use your data in this privacy policy, we indicated which of these bases we rely on for processing.

You have given us your consent to use the collected data from our websites. In particular, we use:



We use contact information to respond to your requests, send you information as part of services and provide you with marketing information (since you do not refuse it).


Cookies – page tags and web beacons.

We collect information from page tags and web beacons so that we can determine how successful our advertising campaigns are.We also use page tags so that the sender of an email (for example, for a survey or a form) can measure the performance of their email message and learn how to improve email delivery and opening speed. For more information, please read our Cookie Policy.


How you use our services.

We use information about how you interacted with our websites in order to improve the maintenance of our websites for you and all users. Some examples that are relevant to you:




We collect information about the web pages you visit and your activities on our sites.

We process your personal information in the following categories of data for legitimate interests pursued by us, which are described in detail in this privacy policy. We have pledged to provide clear limits for each of these uses so that your privacy is respected and only the information necessary to achieve these legitimate purposes is used. Our main goal is to improve and ensure that our services and messaging are relevant to all of our users, as well as to ensure respect and protection of personal information of all users.


Device data.


We use these devices to troubleshoot and improve our service. We also determine your geographic location based on your IP address.


Log data.


We use log data for various business purposes, including:


Learn more: your browser type to determine how we can better represent our website in this browser environment.


To monitor abuse and troubleshooting.

Create new services, features, content or make recommendations.

Track aggregate / anonymous behavior to identify and understand trends in various interactions with our services.

Fix bugs and troubleshoot product functionality.

Referral information.

We use referral information to track the success of our integrations and referral processes.

More information: If you clicked on SoftGan advertising presented by one of our partners on the Internet that led you to one of our websites, we will record this information to help us track the success of advertising campaigns.

legal use.

To respond to legal requests or prevent fraud, we may need to use and disclose information or data about you that we hold. If we receive a subpoena or other legitimate request, we may need to check the data we have to determine how to respond to them.


4. Cookies

We and our partners use cookies and similar technologies on our websites. For more information, see Our Cookie Policy. We use certain cookies, as described in our Cookies Policy and our Privacy Policy, which you agree to when using our sites, and in the case of some cookies, for legitimate interests in providing and optimizing our services (when cookies are delivered ). required functionality). Cookies are small pieces of data that we store on the device you use to access our services so that we can recognize regular users. Each cookie expires after a certain period, depending on what we use it for. We use cookies and similar technologies for several reasons:


To collect indicators about your survey experience.

To make our site easier to use.

For security reasons.

To provide you with personalized content.

To improve our services.

Google Analytics and Yandex.Metrica.

You can delete or disable cookies through your browser settings.



We have a security statement related to our self-service businesses, which can be viewed here. For information about security related to our other business areas, you can contact your sales representative by filling out the form here.


6. Data Storage

The contact information provided in the feedback form on our website is stored for one (1) year. This period may be extended with your permission for the next year, but the total shelf life may not exceed 3 (three) years.


The retention period of the project data is determined by the agreement concluded between Kenlana and the Customer.


We also describe the expiration of cookies on our websites in our Cookie Policy.


7. Minors safety

Our services are not intended and cannot be used by minors. “Minors” are persons under the age of 18 (or younger, if allowed by the laws of their residence). SoftGan does not knowingly collect personal data of minors and does not allow them to register. If we become aware that we have collected the personal data of the minor, we may delete this information without prior notice. If you have reason to believe that this has happened, please contact our designated DPO.


8. Privacy Shield (relevant for our users from the EU)

Kenlana Ltd is located in the Republic of Lithuania and, accordingly, the data will be transmitted to the Republic of Lithuania.

Kenlana Ltd. participates and certifies its compliance with regulations on information protection in the Republic of Lithuania and, for EU users, the General Data Protection Regulations (GDPR), applied on May 25, 2018.

Please contact Kenlana Ltd as described in section 10 below. If you have any problems or complaints of any nature. If you have an unresolved privacy or data use problem that we have not resolved in a satisfactory manner, please contact our designated DPO.


9. Changes to our privacy policy

We may make changes to this Privacy Policy from time to time. We will identify the changes we have made on this page. In cases where a change significantly changes the way we collect or use your personal information or data, we will send a notice of this change to all owners of our accounts.


10. Your rights

Some of you (in particular, European users) have certain legal rights to receive information about whether we hold personal information about them, access to personal information about them that we hold, and also to correct, update, change or deletion under appropriate circumstances. Some of these rights may be subject to certain exceptions or limitations. We will respond to your request for the exercise of these rights within a reasonable time (and in all cases within 30 days of the receipt of the request).

Rights to which you are entitled:


Data Access Rights

The right to limit processing

Right to correct

Right to erase (right to be forgotten)

The right to object to the processing

The right to withdraw consent; and

Data Portability Rights

To get this list, you must first contact:



11. Exercise of your rights

Our contact information for privacy inquiries


Kenlana Ltd.

Republic of Lithuania,

Siauliu str. 10-56,

LT – 01134, Vilnius.

Tel.: +370 ???



Data Protection Officer (DPO):



e-mail: ???



If you are not satisfied with the way we considered the complaint you filed, you have the right to contact your local data protection oversight authority.


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